Regulation 19 - Proposed Draft Local Plan Submission

Object

Representation ID: 13956

Received: 02/05/2025

Respondent: Urban&Civic and Homes England

Agent: Quod

Legally compliant? Not specified

Sound? No

Duty to co-operate? Yes

Soundness - Not justified, not effective:
Requirement for 10% self or custom build homes on a site of the scale of SA02 is not evidenced and may not be deliverable.
A consolidated response has been prepared and attached as part of this pack. This response provides details of why we consider named policies to be unsound. (see attachment)

Object

Representation ID: 13957

Received: 02/05/2025

Respondent: Urban&Civic and Homes England

Agent: Quod

Legally compliant? Not specified

Sound? No

Duty to co-operate? Yes

Soundness -Not justified. See our response to policy SA02.
The Gypsy & Traveller and Travelling Showpeople site assessment (Final Report November 2024) recommends a policy approach which suggests requirements of ‘up to’ 5 hectares on strategic sites, with an option for off site provision in defined circumstances. The policy should reflect the advice of the consultants, either as part of the site specific policy or Policy HN06.
A consolidated response has been prepared (see attachment). This response provides details of why we consider named policies to be unsound.

Object

Representation ID: 13958

Received: 02/05/2025

Respondent: Urban&Civic and Homes England

Agent: Quod

Legally compliant? Not specified

Sound? No

Duty to co-operate? Yes

Soundness - Not effective.
Part (d) includes reference to restoring or 'equivalent mitigation' for damaged features.
The policy and supporting text do not set out how ‘equivalence’ should be assessed, and this would make the policy subjective and difficult to implement.
A consolidated response has been prepared and attached as part of this pack. This response provides details of why we consider named policies to be unsound. (see attachment)

Object

Representation ID: 13959

Received: 02/05/2025

Respondent: Urban&Civic and Homes England

Agent: Quod

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Soundness:
Priority should follow the travel hierarchy, as set out in wider transport and planning policy, where pedestrians and cyclists are prioritised. Therefore, active travel should be mentioned first before public transport. The priority is written correctly in the supporting text but this is not reflected in the policy text.
A consolidated response has been prepared and attached as part of this pack. This response provides details of why we consider named policies to be unsound. (see attachment)

Object

Representation ID: 13960

Received: 02/05/2025

Respondent: Urban&Civic and Homes England

Agent: Quod

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Soundness - Effective:
A 3 star rating under BRE Home Quality Mark scheme is one of several sustainable constriction standards. We therefore suggest an adjustment in wording to be inclusive of alternative sustainability accreditations/routes to provide a more flexible approach as HQM is not widely adopted and may not be preferred for all development. In addition, HQM is transitioning into BREEAM UK New Construction: Residential (from April 2025).

A consolidated response has been prepared and attached as part of this pack. This response provides details of why we consider named policies to be unsound. (see attachment)