Policy SP06, Effective Delivery of Development (page 60)
A footnote might usefully clarify what constitutes large complex allocation sites, as referenced in criterion A, as far as the Council is concerned.

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

In relation to Policy BE02 criterion (f):
"f. where feasible and viable, include commercial and domestic scale renewable energy and decentralised energy as part of new development."

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

For consistency with paragraph 153 of the NPPF and with Policy BE03 of the Local Plan the following modification are proposed.
In relation to Policy BE04 criterion (B):
"B. New development of over 500 dwelling units, or brownfield and urban extensions at 500 units or more, or where the clustering of neighbouring sites totals over 500 units, will be expected, where feasible and viable, to incorporate decentralised energy infrastructure in line with the following hierarchy..."
and
"ii. Where there is no existing heat network, new development will be expected to deliver an onsite heat network, unless demonstrated that this would be unfeasible or would render the development unviable;"

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

BE11 Strategic Transport Infrastructure (page 92 - 94)

For consistency with Policy R01, the following modification is proposed:
"B. ii) improving the public realm, circulation arrangement and capacity of West Horndon station as well as creating associated multimodal interchange through phases to support new residents and employees at West Horndon and Dunton Hills Garden Village"

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

Policy BE22, Open Space in New Development (page 119)

Policy BE22 is not positively prepared or consistent with paragraph 56 of the NPPF because it is not reasonable to request financial contributions in circumstances where a developer is providing functional open space on-site. To ensure the policy is positively prepared consistent with the NPPF modifications are proposed as follows:

"A. New development proposals are expected to provide functional on-site open space and/or recreational amenities or, where it is demonstrated that this is not possible, and may, where appropriate be required to also provide a financial contribution in lieu towards new or improved facilities within the borough."

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

To ensure the policy is positively prepared and justified the following modification is proposed:

"c. i. a minimum of 5 1% self-build homes which can include some custom housebuilding;..."

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

Policy HP03, Residential Density (page 128)

A modification is proposed to reflect that the density should be an average across a site, recognising that on large strategic sites a range of densities might be appropriate. This would ensure the policy is positively prepared.

"B. Residential development proposals will generally be expected to achieve an average net density of at least 35 dwellings per hectare or higher..."

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

Modifications are proposed to ensure that the tenure split is guided, rather than dictated, by the SHMA. Modifications are proposed below to ensure the policy is positively prepared and consistent with the intention of the Plan as set out at paragraph 6.35.

"B. In considering the suitability of affordable housing, the Council will require that:
a. the tenure split be made up of 86% Affordable/Social Rent and 14% as other forms of affordable housing (this includes starter homes, intermediate homes and shared ownership and other forms of affordable housing as described by national guidance or legislation) or having regard to the most up to date SHMA;"

"B. c. the type, mix, size and cost of affordable homes must meet should have regard to the identified housing need as reported by the Council's most up-to-date Strategic Housing Market Assessment and Housing Strategy"

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

The following modification is proposed to ensure consistency with the NPPF:
Criterion A (a) "take account of the desirability to conserve, sustain and enhance..."

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