Local Plan Issues and Options (Regulation 18)

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Comment

Local Plan Issues and Options (Regulation 18)

Question EG 1

Representation ID: 5444

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy EG1
I&O_5816
Yes.

Comment

Local Plan Issues and Options (Regulation 18)

Question EG 2

Representation ID: 5445

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy EG1
I&O_5817
Yes, those are the key strategic employment locations.

Comment

Local Plan Issues and Options (Regulation 18)

Question EG 4

Representation ID: 5446

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy EG 1
I&O_5818
Yes, the policy approach should be to safeguard out of town office locations for office use, to ensure space is retained for employment growth over the Plan period.

Comment

Local Plan Issues and Options (Regulation 18)

Question EG 5

Representation ID: 5447

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy EG 1
I&O_5819
Yes, to ensure good space is retained for employment growth over the Plan period.

Comment

Local Plan Issues and Options (Regulation 18)

Question HO 4

Representation ID: 5449

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy HO2
I&O_5821
No, because the policy approach does not clearly follow national policy in the Framework. Paragraph 67 of the Framework says the ‘affordable housing requirement for sites to be released from the green belt should require at least 50% of the housing to be affordable’, which the proposed policy approach repeats. However, the policy approach does not go on to include the rest of the policy at paragraph 67b, which goes on to say, ‘unless this would make the development unviable (when tested in accordance with national planning practice guidance on viability)’. The policy approach should also explicitly reference this second part to Framework paragraph 67b.   Also no because, to require affordable homes to be indistinguishable from market housing may give rise to unforeseen tensions in the design of proposals. Housing associations can have specific requirements that may clash with the approach the developer is seeking to take to the open market homes, for example, the association may not want render to be used owing to their view that it comes with higher long term maintenance obligations, while the developer may wish to use it on their open market properties. Accommodating the wishes of the housing association would result in the affordable homes being distinguishable from the open market homes, but it would not result in a design which was of poorer quality. There may be other architectural features where this could arise, for example, door and window furniture, landscape and boundary treatment, car parking layout and architectural detailing. It would therefore be more appropriate for the policy approach to require the design quality of affordable homes to be comparable to market housing, achieving high quality design and dispersed throughout the site.

Comment

Local Plan Issues and Options (Regulation 18)

Question GT 1

Representation ID: 5451

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy GT1
I&O_5823
No, because there is no evidence that there is a demand from within the Gypsy and Traveller community for provision of plots as part of larger residential sites. Also, the different plot sizes and site layout would not integrate with the street scenes created by housing plot sizes and layout. Therefore, the policy approach should not include this proposal.

Comment

Local Plan Issues and Options (Regulation 18)

Question GT 2

Representation ID: 5463

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy GT1
I&O_5835
The same search sequence should be followed as for housing sites, to include use of previously developed land.

Comment

Local Plan Issues and Options (Regulation 18)

Question GT 4

Representation ID: 5465

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy GT1
I&O_5837
No, because there is no evidence that there is a demand from within the Gypsy and Traveller community for provision of plots as part of larger residential sites. Also, the different plot sizes and site layout would not integrate with the street scenes created by housing plot sizes and layout.

Comment

Local Plan Issues and Options (Regulation 18)

Question GT 5

Representation ID: 5467

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy GT1
I&O_5839
It is not clear what the proposed approach is based on. Notwithstanding that, smaller sites will be (comparatively) easier to integrate into layouts (notwithstanding the responses to Questions GT1 and GT4) and therefore two pitches for every 500 dwellings would be more appropriate.

Comment

Local Plan Issues and Options (Regulation 18)

Question HW 1

Representation ID: 5469

Received: 28/08/2025

Respondent: Penmar Farming Limited

Representation Summary:

Suggested policy HW1
I&O_5841
The requirement to produce a health impact assessment should be removed. It adds no value because it repeats information provided elsewhere in an application.

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