Local Plan to 2030 Regulation 19 - Publication June 2016

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18 comments.

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Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft STRATEGIC POLICIES Strategic Development Requirements Housing delivery

  • Comment ID: ALP/1907
  • Status: Accepted
The policy is unsound because it is unjustified. According to paragraph 3.44 of the Local Plan an average of 144 windfall dwellings have been completed each year over the last 10 years (2006?). The windfall rate has been reduced by 25% to take account of non-delivery. This discount is a wise precaution. However, we have been unable to locate an assessment of how many windfalls have materialised through the development of residential gardens. Paragraph 48 of the NPPF requires the Council to take
Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION B - EMPLOYMENT AND THE LOCAL ECONOMY Loss or redevelopment of Employment Sites and Premises Content

  • Comment ID: ALP/1918
  • Status: Accepted
The policy is unsound because it is unjustified, ineffective and potentially inconsistent with emerging government planning policy. The policy places many conditions on the re-development of employment sites for housing. It requires applicants to satisfy various criteria. Some of these criteria are vague. For example, for urban sites, part B requires the applicant to demonstrate that a unit has been unlet or for sale "for a substantial period of time". It is unclear what the Council might deem
Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION D - THE NATURAL AND BUILT ENVIRONMENT Water and Climate Change Water Quality, Supply and Treatment Content

  • Comment ID: ALP/1922
  • Status: Accepted
The policy is unsound because it conflicts with national policy. The Council requires that major proposals for new development – presumably schemes of ten or more dwellings – must demonstrate that there will be adequate water supply and wastewater treatment facilities in place to support the development etc. The second paragraph requires that all development proposals must provide a connection to the sewerage system…as advised by Southern Water. There are a number of difficulties with these f
Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft Introduction Content

  • Comment ID: ALP/1859
  • Status: Accepted
Duty to cooperate (paragraph 2.5) The Local Plan is unsound with regard to the duty to cooperate. The Local Plan has not demonstrated that the duty to cooperate has been discharged since it is unsupported by adequate evidence to describe what the cross-boundary strategic issues are that affect Ashford. The Local Plan refers to a detailed 'Duty to Cooperate' Statement forming part of the evidence base but this document is not yet available to support the Regulation 19 Consultation. It is diffic
Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION A - HOUSING Accessible and Adaptable Content

  • Comment ID: ALP/1913
  • Status: Accepted
Parts of the policy are unsound because they are a) unjustified; and b) ineffective. The NPPG states that local planning authorities will need to gather evidence to determine whether there is a need for additional standards in their area. In relation to the accessibility and wheelchair housing standards the local authority is required to assess: * the likely future need for housing for older and disabled people; * Size, location, type and quality of dwellings needed to meet specifically evide
Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION F - IMPLEMENTATION Deferred Financial Contributions Deferred financial contributions

  • Comment ID: ALP/1924
  • Status: Accepted
The policy is unsound because it is unjustified. We accept that in those cases where an applicant is unable to meet all the requirements of local planning policy set out in the Local Plan, then the applicant should submit viability evidence. We do not accept, however, the 'claw-back' provision. If a scheme has to make adjustments to policy in order to become viable, then those adjustments will need to be determined at the time of the application. The possibility that the Council will insist on
Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION A - HOUSING Residential Windfall Development Content

  • Comment ID: ALP/1873
  • Status: Accepted
Policy HOU3 – Residential development in Ashford urban area The policy is unsound because it is ineffective. Firstly, it is unclear whether this policy applies to Ashford town or all built-up areas of Ashford Borough. This should be clarified. Secondly, the policy applies to windfall residential development. We appreciate that because windfalls cannot be identified in advance, it is necessary to have a policy providing guidance of what types of schemes may be acceptable. However, we consider
Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION A - HOUSING Residential Space Standards Content

  • Comment ID: ALP/1908
  • Status: Accepted
The policy is unsound because it is unjustified. National planning policy set out in the Written Statement to Parliament of 25 March 2015 states that the: "optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need". The NPPG provides further guidance on the relevant evidence that needs to be assembled to justify the adoption of the Nationally Described Space Standard. The NPPG advises that the Council should t
Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION A - HOUSING Accessible and Adaptable Content

  • Comment ID: ALP/1911
  • Status: Accepted
This policy is unsound because it is contrary to national planning policy. It should be deleted from the Local Plan. This is a local policy that attempts to dictate the internal layout of new dwellings. National planning policy as set out in the Written Statement to Parliament of 25 March 2015 states clearly that, other than the Building Regulations and the three optional technical standards, no other local policies are allowed "relating to the construction, internal layout and performance of n
Home Builders Federation Ltd (… 10 Aug 2016

Local Plan to 2030 - Publication Draft Introduction Content

  • Comment ID: ALP/1855
  • Status: Accepted
Thank you for consulting with the Home Builders Federation (HBF) on Ashford Borough Council's Local Plan. The HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership which includes multi-national PLC's, regional developers and small, local builders. In any one year, our members account for over 80% of all new "for sale" market housing built in England and Wales as well as a large proportion of newly bu
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