Local Plan Review: Preferred Approach 2016-2035

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S4: Meeting Housing Needs

Representation ID: 2755

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

Do not disagree with use of standard method, but consider delivery of housing in neighbouring authorities and HMA to ensure needs are met in full.

Suggest trajectory is provided in line with para 73.

Suggest including buffer of 20%

Aim should not be to prepare a plan with a stepped trajectory - the plan should allocate a range of sites to ensure provision is even across the plan period.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S1: Presumption in Favour of Sustainable Development

Representation ID: 2757

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

Understand that requirement for this policy is no longer - as such it repeats national policy and should be deleted.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S6: Affordable Housing

Representation ID: 2758

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

Concerned that CDC not published viability evidence.

Approach of ensuring AH is indistinguishable not effective to delivery - AH is a different product and may be designed differently and use different materials. Provided the proposed devt is in keeping with design policies than differential appearance should not be an issue for consideration.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S27: Flood Risk Management

Representation ID: 2759

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

Suggest policy rewording

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Support

Local Plan Review: Preferred Approach 2016-2035

Policy DM1: Specialist Housing

Representation ID: 2761

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

Welcome support for specialist accom, but suggest that Council seeks to identify number of specialist homes for older people and identify sites.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy DM2: Housing Mix

Representation ID: 2763

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

Policy which specifies housing mix is overly restrictive and does not offer flexibility - mix should not be in policy.

CDC must identify need for accessible homes to ensure it does not compromise viability. If seeking to require proportion of homes built to part M4(2) of Regs, must be justified. Where CDC seeks to apply optional technical standards must be considered in viability assessment.

Should justify inclusion of Nationally Described Space Standard.

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Object

Local Plan Review: Preferred Approach 2016-2035

Policy DM8: Transport, Accessibility and Parking

Representation ID: 2764

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

No ref to parking provision required - unsound as does not comply with legislation that prevents CDC from setting policy in SPDs.

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Support

Local Plan Review: Preferred Approach 2016-2035

Policy DM9: Existing Employment Sites

Representation ID: 2766

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

Welcome general approach but not clear how sequential test will be demonstrated:
1. which sequential test is it?
2. sequential test refers to new town centre uses not loss of older uses - not consistent with national policy

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy DM16: Sustainable Design and Construction

Representation ID: 2768

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

Part 4 of policy not consistent with NPPF, suggest policy rewording

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy DM28: Natural Environment

Representation ID: 2769

Received: 06/02/2019

Respondent: Home Builders Federation

Representation Summary:

Part 5 of policy inconsistent with NPPF para 16.

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