Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 16028

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16609
In response to question LS2 above, the key settlement gaps should be reviewed in light of the current local housing need, which is a minimum of 1,928 new homes per year. As discussed above, for the Council to make sufficient land available to deliver the required homes, some land will need to be released from the Green Belt. This may also include land that is currently defined in Local Plan (Part Two) Policy GBC 3 as a key settlement gap. On the basis that the Council is required to make enough land available to meet its local housing need in full within the Plan period, the key settlement gaps should be reviewed to ensure the policy does not restrict sustainable residential development from coming forward. This approach would be consistent with the NPPF where it requires local authorities to meet local housing needs in full and to review Green Belt boundaries where necessary.


Email from Jonathan Ainley

Comment

Representation ID: 16029

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16610
At GI 1, the Issues and Options consultation document sets out the policy approach towards Green Infrastructure, Biodiversity and Geodiversity. In response to the tree planting ratio specifically, the 2:1 proposed ratio is appropriate and would significantly increase the overall number of trees in the District. An increased requirement for tree replacement would place a substantial cost on developers which can reduce developer confidence and in turn the rate of development. There should be flexibility built into this policy to ensure that if there are site specific reasons why a large number of trees need to be removed, this can be accommodated without an unrealistic replacement programme. 


Email from Jonathan Ainley

Comment

Representation ID: 16030

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16611
The mandatory requirement for certain developments to deliver a minimum 10% net gain in biodiversity is provided by the Environment Act 2021. Savills consider that the New Local Plan should reflect the 10% requirement and not increase the requirement beyond this. It should be noted that the statutory requirement is for a minimum of 10% net gain to be provided as such, depending on the site specific constrains, viability and other factors, the legislation is designed to set the 10% as a minimum. If the Local Plan adopted a policy requirement above the 10% mandatory requirement, this could risk reducing the number of homes that can be delivered, since an additional cost would be placed on developers, which could impact the viability of potential housing developments. The viability assessment supporting the New Local Plan would have to consider the financial implications of this. The New Local Plan should reflect the national mandatory requirement of a minimum of 10% net gain.


Email from Jonathan Ainley

Comment

Representation ID: 16031

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16612
At DS 1, the Issues and Options Consultation document sets out that the New Local Plan will promote sustainable, high quality design and construction. Savills broadly supports the approach to design policy, particularly in relation to making the best use of high quality materials and reducing the opportunity for crime and disorder, and the fear of crime. While the broad policy approach is supported, the New Local Plan should ensure that policies relating to design are flexible and take into account site characteristics. With regards to Nationally Described Space Standards (NDSS) it should be noted that these can only be introduced where there is a clear need and the introduction of the Standards would not impact development viability. The Council will need to demonstrate robust justifiable evidence to introduce the NDSS. It should also be noted that well-designed homes that are below NDSS provide high quality, functional homes, which are appropriate for various budgets. Smaller dwellings play a valuable role in meeting specific needs for both open market and affordable home ownership housing.


Email from Jonathan Ainley

Comment

Representation ID: 16032

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16613
In response to question DS2, if the Council produces a borough-wide Design Code, this should inform the New Local Plan so that design policies are consistent and evidence-based. Design policy that is clear and consistent and informed by a borough-wide Design Code will help inform development proposals for major development and will add clarity to what is expected of developments in terms of design. This will in turn increase developer confidence, which will have a positive influence on development.


Email from Jonathan Ainley

Comment

Representation ID: 16033

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16614
Northern Trust acknowledges the importance of advancing energy efficiency through a nationally consistent set of standards and a timetable that is universally understood and technically feasible. This aligns with the Written Ministerial Statement of December 2023 (WMS), which states that the Government does not expect plan-makers to set local energy efficiency standards for buildings that exceed current or planned building regulations. The WMS clearly indicates that any planning policies proposing local energy efficiency standards for buildings that go beyond current or planned building regulations should be rejected at examination if they lack a well-reasoned and robustly costed rationale. This rationale must ensure that development remains viable and considers the impact on housing supply and affordability in accordance with the NPPF. Additionally, any extra requirements should be expressed as a percentage uplift of a dwelling's Target Emissions Rate (TER), calculated using a specified version of the Standard Assessment Procedure (SAP). Therefore, if the Council wishes to pursue this policy, it should use the TER and ensure that they have a well-reasoned and robustly costed rationale that fully considers viability and the potential impact of the policy on housing supply and affordability.


Email from Jonathan Ainley