Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 529

Received: 21/12/2023

Respondent: Churchill Retirement Living

Agent: Churchill Retirement Living

There would appear to be a significant amount of overlap between the evidence required for the loss of community facilities / open space and the Health Screening Assessment and we would ask the Council to consider if sub-clause 2 e) is necessary on that basis.

Comment

Representation ID: 530

Received: 21/12/2023

Respondent: Churchill Retirement Living

Agent: Churchill Retirement Living

The consultation has not made a Local Plan Viability Assessment (LPVA) publicly available. There is therefore no evidence demonstrating that the affordable housing requirements proposed viable. By limiting the opportunities for comment of the Local Plan Viability Assessment we are of the view that the Council has deviated from national guidance and the Local Plan is not considered positively prepared, justified, effective and crucially is consistent with national policy.

Comment

Representation ID: 531

Received: 21/12/2023

Respondent: Churchill Retirement Living

Agent: Churchill Retirement Living

The delivery of a suitable level of specialist older persons' housing will be a substantial undertaking over the Local Plan period and unless action is urgently taken the Council will struggle to address this need. The inclusion of a dedicated policy which is supportive of the need to deliver specialist older persons' housing at suitable locations is commendable and supported accordingly.

Comment

Representation ID: 532

Received: 21/12/2023

Respondent: Churchill Retirement Living

Agent: Churchill Retirement Living

The aim of the replacement tree planting standards would appear to be a long-term increase in tree cover rather than like-for-like replacement, which will be an impediment to building at higher densities, particularly on previously developed sites Page 2in urban areas. This appears to run contrary to Policy DLP2 Growth Network: Regeneration Corridors and Centres which encourages the efficient use of land in sustainable, urban environments.
While we appreciate there are benefits to providing trees in urban areas, building at higher densities in these locations reduces greenfield land-take and is a highly sustainable outcome accordingly. A reduced tree standard for sites in urban areas would be more appropriate.
Given the significant requirement for tree planting an appropriate allowance should be made for tree planting within the Local Plan Viability Assessment.

Comment

Representation ID: 533

Received: 21/12/2023

Respondent: Churchill Retirement Living

Agent: Churchill Retirement Living

Policy DLP47 Renewable and Low Carbon Energy and BREEAM Standards - If the intended outcome of Policy DLP47 is the reduction of carbon emissions then we would query why the method for doing SO needs to be specified. We would also respectfully remind the Council that the costs of meeting enhanced sustainability standards must be accounted for the in the forthcoming Local Plan Viability Assessment.