Regulation 19 - Proposed Draft Local Plan Submission

Object

Representation ID: 13887

Received: 04/05/2025

Respondent: Davidsons Developments Limited

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Prudent for the HLP to build in contingency to address unmet housing needs beyond 2036, rather than deferring this to a subsequent plan period.
An uplift in delivery is enouraged to; address the widening differential between the HLP's annual average requirement and the newer LHN calculated using the new Standard Method, support the acute need for affordable housing, and provide a higher buffer closer to 20% given the inherent risks within the spatial strategy associated with the delivery of a very large-scale development (OA1).
A balanced distribution of sites between the most sustainable parts of the district is a sound strategy. However, Broughton Astley has been allocated a smiliar level of growth to less sustainable settlements and that does not appear to be justified by evidence. In the SA it is not clear how the apportionment of growth has been tested between the Large, Medium and Small villages and what alternatives were considered. Directing more growth to large villages, as these are amongst the most sustainable, particularly Broughton Astley, and allocating a balanced mix of smaller sites would provide flexibility and contingency.
Omission site Land at Dunton Road, BA (21/8252) proposed as appropriate for allocation. Vision and access documents appended.

Object

Representation ID: 13896

Received: 04/05/2025

Respondent: Davidsons Developments Limited

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Observations are made about the following assumptions made in the Viability Report; allowance for on-site infrastructure is too high, allowance for professional fees for strategic sites is not clear, the use of lower quartile BCIS costs and that economies of scale cannot be universally assumed across an entire site.
It is also not clear how the cumulative policy burdens of the HLP have been factored into the viability appraisal.

Object

Representation ID: 13897

Received: 04/05/2025

Respondent: Davidsons Developments Limited

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The evidence on need is based principally on the District's ageing population, a national trend. The Written Ministerial Statement and PGG allows adoption of enhanced technical standards on an authority by authority basis based on clearly evidenced need including; size / location / type / quality to meet need, the accessibility and adaptability of the existing housing stock and viability impact.
The proportion of accessible units that can be addressed through policy HN04 10% requirement for older persons accommodation needs consideration.
This policy is not currently justified by evidence and needs to be revisited prior to submission of the Local Plan.

Object

Representation ID: 13899

Received: 04/05/2025

Respondent: Davidsons Developments Limited

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

A number of observations are made about; the appropriateness of a blanket percentage across all schemes of a certain size, its failure to contemplate a scenario of lack of demand, and its lack of provision for accommodation to be delivered as market units if an evidenced lack of demand.
The viability impact of the policy does not appear to have been assessed cumulatively with other policy burdens.
Policy lacks justification and should be revisited.

Object

Representation ID: 13907

Received: 04/05/2025

Respondent: Davidsons Developments Limited

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Self build should be encouraged using council-owned land or designating specific sites via negotiations with landowners or through a criteria-based policy.
Integrating self and custom-build plots within large-scale housing developments is challenging because it; is difficult to co-ordinate construction, poses health and safety risks, comes forward over much longer timeframes, is often not liable to Section 106 contributions towards infrastructure and affects viability.
Supportive of a mechanism to allow unsold plots to be built out as market housing, however 18 months is overly restrictive. Six months is adequate, with no requirement for plots to be available immediately to validly commence the marketing period.

Object

Representation ID: 13908

Received: 04/05/2025

Respondent: Davidsons Developments Limited

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Generally supportive of a policy requirement to safeguard residential amenity. Development should be opposed on amenity grounds only where it causes material or significant harm to users of nearby land and buildings—not based on subjective thresholds of “acceptability.”

Object

Representation ID: 13909

Received: 04/05/2025

Respondent: Davidsons Developments Limited

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Whilst we are generally supportive of a policy requirement to address landscape character and sensitivity, Part 1 d) of the policy refers to restoring and providing equivalent mitigation for damaged features and/or landscapes that would be damaged or degraded as a result ofdevelopment. It is not clear what this element of the policy requires. It is clearly not practical, viable or developable to expect new development to restore or compensate for the loss of landscapes themselves as all new development will, by its nature, have a landscape impact.
Landscape features lost can be provided for where practicable.