Local Plan Review: Preferred Approach 2016-2035
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Local Plan Review: Preferred Approach 2016-2035
Policy S4: Meeting Housing Needs
Representation ID: 2755
Received: 06/02/2019
Respondent: Home Builders Federation
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.
See attachment
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
Understand that requirement for this policy is no longer - as such it repeats national policy and should be deleted.
See attachment
Comment
Local Plan Review: Preferred Approach 2016-2035
Policy S6: Affordable Housing
Representation ID: 2758
Received: 06/02/2019
Respondent: Home Builders Federation
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.
See attachment
Comment
Local Plan Review: Preferred Approach 2016-2035
Policy S27: Flood Risk Management
Representation ID: 2759
Received: 06/02/2019
Respondent: Home Builders Federation
Suggest policy rewording
See attachment
Support
Local Plan Review: Preferred Approach 2016-2035
Policy DM1: Specialist Housing
Representation ID: 2761
Received: 06/02/2019
Respondent: Home Builders Federation
Welcome support for specialist accom, but suggest that Council seeks to identify number of specialist homes for older people and identify sites.
See attachment
Comment
Local Plan Review: Preferred Approach 2016-2035
Policy DM2: Housing Mix
Representation ID: 2763
Received: 06/02/2019
Respondent: Home Builders Federation
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.
See attachment
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
No ref to parking provision required - unsound as does not comply with legislation that prevents CDC from setting policy in SPDs.
See attachment
Support
Local Plan Review: Preferred Approach 2016-2035
Policy DM9: Existing Employment Sites
Representation ID: 2766
Received: 06/02/2019
Respondent: Home Builders Federation
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
See attachment
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
Part 4 of policy not consistent with NPPF, suggest policy rewording
See attachment
Comment
Local Plan Review: Preferred Approach 2016-2035
Policy DM28: Natural Environment
Representation ID: 2769
Received: 06/02/2019
Respondent: Home Builders Federation
Part 5 of policy inconsistent with NPPF para 16.
See attachment