Support

Representation ID: 15571

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We support the proposed housing trajectory in Appendix 3, and the identification of the Site's short term delivery (0-5 years) in Appendix 2.

Comment

Representation ID: 15583

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 6.2 states, in respect of previously developed land (brownfield sites), that this supply of land should be prioritised.

Although the sequential approach is appropriate for site identification, such an approach should not be stringently applied in relation to deliverability. It would be deemed inappropriate for BBC to delay the delivery of an allocated development site if, for example, other brownfield sites were yet to come forward.

Comment

Representation ID: 15590

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 7.4 refers to Figure 7.2, which provides a list of housing land allocations but does not provide detail on form, scale and access as required under paragraph 157 of the NPPF. Whilst it is not considered appropriate that a Local Plan is overly prescriptive in terms of development requirements, it is deemed necessary that policies and criteria for each allocation site are provided to assist decision makers in considering development proposals (NPPF, para 154). Equally, an Applicant should be provided with guidance to ensure an appropriate planning application for those sites allocated can be submitted.

It is therefore considered appropriate that the DLP is revised to include individual policies on allocated development sites containing criteria against which subsequent proposals can be assessed. This will ensure that the Plan is 'Consistent with national policy', 'effective' and therefore "sound" in this regard.

Object

Representation ID: 15594

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 6.3 wording is not considered to be 'Consistent with national policy' as per the following:

Part (a): This requirement is not contained within the NPPF. Instead, paragraph 58 directs that policies should ensure development responds to local character, reflect the local surroundings and is visually attractive, whilst not preventing or discouraging appropriate innovation.

Part (c): wording is inconsistent with the NPPF (para 32), which states that development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are "severe".

Object

Representation ID: 15595

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 6.3 wording is not considered to be 'Consistent with national policy' as per the following:

Part (d): wording fails to take account of the balance within the NPPF (para 109) in that both new and existing development should be prevented from contributing to or being put at unacceptable risk from, or being adversely affect by unacceptable levels of soil, air, water or noise pollution or land instability.

Part (f): The NPPF (para 118) directs the planning applications should be encouraged to seek opportunities to incorporate biodiversity in and around developments, and therefore it is considered inappropriate to state that proposals "should take full account" of biodiversity opportunities.

Object

Representation ID: 15596

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 6.3 wording is not considered to be 'Consistent with national policy' as per the following:

Part (g): This is considered to be largely in compliance with the NPPF (para 132), excluding the additional requirement to consider the assets enhancement. In addition, "greater" should be reworded to state "great" in accordance with paragraph 132. The test to be considered in the NPPF, when considering the impact of a development on the significance of a designated heritage asset, is whether such development would lead to substantial harm to/total loss of a heritage asset's significance (Para 133), or less than substantial harm (Para 134).

Part (i): This fails to take acknowledge the NPPF (para 204), in that planning obligations should only be sought where necessary to make the development acceptable in planning terms, directly related to the development, and fairly and reasonably related in scale and kind to the development.

Comment

Representation ID: 15598

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Considered appropriate that the DLP is revised to include individual policies on allocated development sites containing criteria against which subsequent proposals can be assessed. This will ensure that the Local Plan is 'Consistent with national policy', 'effective' and therefore "sound" in this regard.

Comment

Representation ID: 15599

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 7.2 requires that developments of 6 or more dwellings, or greater than 0.2 hectares, provide an appropriate mix of dwelling types, sizes and tenures. This element of the Policy is supported where it is consistent with the NPP

Comment

Representation ID: 15600

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We question the appropriateness of the Policy's requirement for 5% of dwellings to be suitable and easily adaptable for occupation by the elderly or disabled, and in addition, a minimum of 5% self-build properties. The NPPF is clear that LPAs must assess the cumulative impact of Local Plan policies on the viability of development. It is unclear from the DLP whether BBC has undertaken viability testing on such requirements.

Comment

Representation ID: 15601

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We do not consider it appropriate to make reference to Building Regulations within Local Plan policies. BBC cannot require Applicants to comply with any standards other than the Building Regulations and the optional technical standards if these are adopted by the Council. As Written Ministerial Statement 25 March 2015 states:

From the date the Deregulation Bill 2015 is given Royal Assent, local planning authorities...should not set in their emerging Local Plans, neighbourhood plans, or supplementary planning documents, any additional local technical standards or requirements relating to the construction, internal layout or performance of new dwellings. This includes any policy requiring any level of the Code for Sustainable Homes to be achieved by development.