Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Support

Representation ID: 7234

Received: 17/09/2021

Respondent: L&Q Estates Limited

Agent: Barton Willmore

The Promoters do not object to the proposed new policy and support the flexibility shown to larger sites which
allows for negotiation on the number of self-build and custom build dwellings. However, whilst we support clarity on timing, it is not clear how these may be delivered from a design perspective, particularly with larger sites currently requiring a design code to be
submitted with an application (adopted Policy 29). It would be useful to understand the Council’s expectation on larger sites, how these may be design ‘coded in’ i.e. smaller clusters around a site, with a design passport to be provided to potential purchasers of plots.
It is also unclear how specific percentages required by different scales of development have been arrived at. For example, a requirement of 2no. self and custom build plots on a 10 dwelling site equates to 20% provision, and a requirement of 7no. self and custom build plots on a 90 dwelling site equates approximately to 8% provision. Typically many local plans require roughly 5% provision or are negotiated on a case by case basis according to evidence of need. This also represents an unbalance in how much provision is sought based on the scale of a site, when there is no evidence to support such an
approach.

Support

Representation ID: 7235

Received: 17/09/2021

Respondent: L&Q Estates Limited

Agent: Barton Willmore

It is unclear what ’environmental net gain’ means in the context of this policy and if this requires more than ecological net gain measures. Paragraph 8 of the NPPF already defines the environmental objectives of sustainable development as protecting and enhancing our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.
Environmental net gain could therefore encompass several features leading to confusion in the interpretation and application of this policy and ultimately its soundness. This will inevitably lead to issues for decision makers when trying to apply the policy to developments.
The main focus of the policy appears to be on biodiversity and therefore we think the policy wording should be more closely aligned with this aspiration and replace ‘environmental net gain’ with ‘biodiversity net gain’ which is fully supported by the Promoters.
If the Council’s ambition is to secure greater levels of green infrastructure or green corridors to boost natural capital in the Borough, we would suggest this is best set out in a separate strategic policy, which is informed by a Green Infrastructure Study to identify areas of deficiency and opportunity. As this is a Borough-wide issue it requires a more planned, joined-up approach underpinned by evidence to maximise opportunities to
improve the natural capital of the area, rather than relying on individual site appraisals that risk a more piecemeal, uncoordinated approach.

Support

Representation ID: 7236

Received: 17/09/2021

Respondent: L&Q Estates Limited

Agent: Barton Willmore

The provision of First Homes came into effect from 28 June 2021. The consultation does not include any information on what will be required in the Local Plan moving forward. It is critical that site promoters and developers are able to understand what the Council will
seek on sites as part of the Local Plan updates. We note that within the evidence bases the Council has produced they have been part of the consideration to date, and therefore a policy update to clarify would be prudent.