The following aspects of the policy require modification to ensure consistency with the NPPF and statutory requirements as set out in the Planning (Listed Buildings and Conservation Areas) Act 1990:
Criterion A. "sympathetic to its character and setting" is not consistent with NPPF.
Criterion D. "only be permitted in exceptional circumstances;" is not consistent with the NPPF or 1990 Act.
It is recommended that the policy is re-visited generally to ensure consistency with the NPPF and the Planning (Listed Buildings and Conservation Areas) Act 1990.

Policy HP01, Housing Mix (page 124)

Self-build and/or custom build housing is supported by the National Planning Policy Framework (NPPF) and its contribution can help to diversify a housing offer, thus supporting housing delivery overall (Letwin, October 2018). CEG is committed to the delivery of self and custom build housing at Dunton Hills Garden Village (DHGV). Planning for a variety of housing types, including self and custom build assists in the delivery of housing on large sites. However, the minimum target of 5% set out in criterion A. c. (i) is not justified by an appropriate evidence base.

CEG is aware that the current level of interest on the Council's Self and Custom Build Register is relatively limited and the need for such housing does not, therefore, justify a minimum level of 5% being required. Indeed, if such a level isn't needed setting such a high minimum requirement could effectively prevent land being released for other types of housing which are needed.

In the 12 month period ending in October 2018 it is understood that 47 individuals and no associations were registered with the Council. Of the total number, 9 indicated a preference for village locations across the Borough, which in the future might include DHGV.

It is acknowledged that the Register is relatively new and the need for this type of housing might change over time. Considering this, a lower minimum requirement should be sought, probably at 1%, to support this type of housing at a level proportionate to the likely need. DHGV will provide for 2,700 new homes over the plan period, and 1% of this would amount to 27 self-build homes in total.

Overall CEG considers the 5% is too high and a lower figure should be adopted.

Policy HP03, Residential Density (page 128)

The policy is positively prepared. Taking a design led approach to density should enable development to achieve a net density of at least 35 dph or higher. This approach is consistent with Chapter 11 of the NPPF which seeks to make efficient use of land and optimise the density of development. A modification is proposed to reflect that density across a site should be an average.



Policy HP05, Affordable Housing (page 131 - 132)

CEG supports the approach set out at paragraph 6.35 which explains that the 'need' for 86% social rent and 14% other forms of affordable housing will be used to inform negotiations between the Council and developers to determine the appropriate tenure and mix of affordable housing.

This 'need' is then expressed as an 'indicative requirement' in Figure 6.2 and a 'requirement' in Policy HP05(B). The Policy currently requires a specific tenure split (86% social rent and 14% other forms of affordable housing) which may not be appropriate for the life of the Plan or for Strategic Allocations in the Plan. CEG supports the approach set out in paragraph 6.35 to ensure there is an appropriate amount of flexibility, for example, to accommodate changing circumstances over the lifetime of the Plan; and ensure the right mix and balance is created where Strategic Allocations are concerned.

Policy HP19: Conservation and Enhancement of the Historic Environment (page 160)
Paragraph 185 of the NPPF, requires that "Plans should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. This strategy should take into account: a) the desirability of sustaining and enhancing the significance of heritage assets, and putting them to viable uses consistent with their conservation;..."
In relation to designated heritage assets, paragraphs 195 and 196 provide for harm to heritage assets to be weighed against the public benefits of a proposal. As such, there are circumstances where not all heritage assets will be "sustained and enhanced". A modification is proposed in our response to question no. 6 to ensure consistency with the NPPF.

Policy HP20 Listed Buildings (page 161-162)
The Policy is not consistent with the NPPF or statutory requirements as set out in the Planning (Listed Buildings and Conservation Areas) Act 1990 about listed buildings and how proposals that affect them should be assessed. Some modifications are proposed in our response to question no. 6 to address this