Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14765

Received: 29/08/2025

Respondent: The Smith Family

Agent: NJL Consulting

I&O_15315
The policy as written suggests the intention to reflect the government’s requirement for housing sites in the Green Belt to provide at least 50% affordable housing. The amount of affordable housing a scheme can provide depends on the overall viability of a project and a flexible approach is needed to take account the circumstances of individual schemes. The approach should be justified by up-to-date evidence of need and viability tested, as deliverability should not be compromised by over ambitious requirements. Therefore, the most effective approach would be to identify areas with the greatest need for affordable housing and apply lower thresholds in those locations, allowing for a more flexible and responsive delivery strategy.

Comment

Representation ID: 14766

Received: 29/08/2025

Respondent: The Smith Family

Agent: NJL Consulting

I&O_15316
The Smith Family agree that housing developments should take every reasonable opportunity to promote and positively contribute to the health outcomes for the borough. The supporting PPG, healthy and safe communities, suggests the use of a health impact assessment (HIA) can be beneficial “where there are expected to be significant impacts”. Planning policies SPDs can include specific triggers requiring a HIA to be submitted with a planning application, particularly where evidence shows that the development could significantly affect sensitive receptors. However, for this approach to be effective, CWAC must first establish clear health priorities and needs across the borough and throughout the plan period. This would then allow the Council to define appropriate local triggers, e.g., the size or type of development, or its location that would determine when an HIA is required.

Comment

Representation ID: 14767

Received: 29/08/2025

Respondent: The Smith Family

Agent: NJL Consulting

I&O_15317
The Smith Family do not consider a need to include a specific policy in relation to separation distances. This can be included within a supporting SPD which can go into further details regarding contextual changes around the borough that may result in instances where distances may require shortening or lengthening.

Comment

Representation ID: 14768

Received: 29/08/2025

Respondent: The Smith Family

Agent: NJL Consulting

I&O_15318
The Smith Family agree that private outdoor amenity space is essential in new developments and should be provided. As with Policy HW 3, this could be further detailed in a dedicated SPD on outdoor amenity and open space. This SPD could establish clear thresholds, requirements, and exceptions, covering aspects like garden sizes, public open space standards, and play provision.

Comment

Representation ID: 14769

Received: 29/08/2025

Respondent: The Smith Family

Agent: NJL Consulting

I&O_15319
Our client supports the overall intent of this policy to promote healthy and sustainable communities. However, this must be balanced against the need to meet housing requirements. The release of carefully selected Green Belt land at sites such as Hollow Lane, Kingsley which are well-placed within the heart of the existing communities and settlements, presents an opportunity to deliver a comprehensive development that includes new and enhanced open space and recreational facilities as well as opportunities to improve existing provision located immediately adjacent (i.e. Kingsley Cricket Club). Policy DM35 sets out a clear framework for delivering open space provision and allows for off-site contributions where on-site delivery is not practical. Carrying this approach forward into the emerging Local Plan would support a comprehensive strategy. However, it must be underpinned by up-to-date evidence to provide developers with a clear and consistent baseline. Policy DM35 should be reviewed, as it sets open space provision standards based on an open space study that now requires updating. Revised evidence may lead to changes in the required provision for each typology, reflecting evolving local needs and priorities.

Comment

Representation ID: 14770

Received: 29/08/2025

Respondent: The Smith Family

Agent: NJL Consulting

I&O_15320
Our client consider that the thresholds set out in adopted Policy DM35 could be considered suitable, however, these need to be tested through a strategic viability assessment.

Comment

Representation ID: 14771

Received: 29/08/2025

Respondent: The Smith Family

Agent: NJL Consulting

I&O_15321
Our client recommends that CWAC update the Open Space Study, as the current assessment covers the period 2016–2030 and does not align with the extended timeframe of the emerging Local Plan. Open space provision and quality can change significantly over time, so an updated study is essential to ensure that both on-site and off-site contributions are proportionate and targeted to areas where need is greatest. This approach aligns with Paragraph 103 of the NPPF, which states that planning policies should be based on robust and up-to-date assessments of the need for open space, sport, and recreation facilities (including any quantitative or qualitative deficits or surpluses) and opportunities for new provision, The findings from these assessments should then inform what provision is required, which the Local Plan should seek to accommodate. The Playing Pitch Strategy was updated in February 2025 and as such is considered appropriate to inform the emerging Local Plan.