Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 7942

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8431
Yes


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.

Comment

Representation ID: 7943

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8432
Yes and Yes


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.

Comment

Representation ID: 7944

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8433
Safeguard subject to criteria


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.

Comment

Representation ID: 7945

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8434
Yes


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.

Comment

Representation ID: 7946

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8435
No Specialist Extra Care almost always needs to be freestanding as it is supported by care support services that a standard housing estate cannot possibly viably entertain / deliver. To also suggest that out of settlement proposals will be resisted suggests that settlement boundaries will be introduced (this would be welcomed) however, given that none of the settlements have internal capacity (brownfield of infill sites) large enough to accommodate an extra care housing scheme on this suggest that the default decision would be to refuse permission – this cannot be accepted since there is an overriding need for this type of accommodation and that the Authority must recognise that provision may indeed need to be located in rural areas.


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.

Comment

Representation ID: 7947

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8436
No – being too prescriptive with respect type, tenure and percentage split is not providing market flexibility and the policy needs to be more collegiate. For example, a site may seek to solely deliver First Homes or Custom/self-build homes and these should not be subjected to an autocratic policy that seeks to impose measures that would simply undermine delivery of these tenures.


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.

Comment

Representation ID: 7948

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8437
No – the 50% target must be subject to an overarching viability testing which takes into account other policy areas such as CIL, commuted sum contributions and infrastructure requirements – which cumulatively may over-burden schemes and could make them unviable – thereby risking housing delivery. In addition, the policy should also introduce a “subject to viability” wording. Furthermore, applying affordable housing to Older Persons housing and Student accommodation is counter-intuitive – these products are already delivering a specialist need and to burden them with a prescriptive tenure is likely to introduce feasibility and viability challenges.


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.

Comment

Representation ID: 7950

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8439
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.

Comment

Representation ID: 7951

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8440
DM19 : needs amending as few sites in the rural area meet the Brownfield Register threshold; many sites may not have access to public transport (see NPPF 110) and the bar is set too high by Criterion 7 and allows far too much subjectivity to creep into decision making. DM21 : there is no rational reason why extension/alterations and replacement dwellings cannot and should not be allowed to be any less than 40% GEA/volume be they in the urban area, open countryside or the Green Belt – allowing homeowners to extend and stay in their homes with growing households should be supported not penalised due to postcode. DM22 : should be amended as the “criterion bar” is set far higher for conversions that are located in the open countryside that it is for Green Belt conversions that are subject to NPPF criterion.


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.

Comment

Representation ID: 7953

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

I&O_8442
No - NPPF covers this adequately and the same approach should apply to all dwellings in the open countryside and Green Belt.


Extension was agreed. Original email was received in time but had errors in question numbers so updated information was requested.