Object

Representation ID: 71676

Received: 17/02/2020

Respondent: Spitfire Bespoke Homes Ltd

Agent: Pegasus Group

Spitfire’s representations to the Informal Consultation Draft consultation raised concerns about Policy RLS2, its relationship and necessity in the context of Local Plan Policy BE1, its lack of clarity regarding sustainable development standards. These concerns remain.
In the Regulation 16 draft NDP, Policy RLS2 has been amended to introduce more clarity on the expectations for housing development in some respects. The first three paragraphs of the policy now include: a requirement for all homes to be Lifetime Homes; an expectation that proposals should aim ‘where possible’ to achieve Level 4 of the Code for Sustainable Homes; and encouragement for the incorporation of higher environmental standards such as Passivhaus.
The fourth paragraph of Policy RLS2 also requires housing development to include design features that increase resilience to extreme weather events (including increased risk of river and surface water flooding) and for applicants to demonstrate the water efficiency of their proposals including ‘where practicable’ the incorporation of water efficiency and re-use measures in the design).
Whilst the requirements in the first three paragraphs of Policy RLS2 are less vague than in the previous draft of the policy, the requirements in the fourth paragraph remain imprecise in terms of the prevailing standards required for compliance. With respect to the requirements in all four of these paragraphs, Spitfire remain concerned that the NDP has not assessed the viability implications of encouraging compliance with a more rigorous set of standards and requirements than those required by the existing district wide criteria in Local Plan Policy BE1. Spitfire would also reiterate that there is no support for this approach within Local Plan Climate Change policies CC1 or CC3.
The policy is deemed not to meet the basic conditions, in that its requirements and expectations do not flow from national guidance, nor are they in general conformity with the Local Plan strategic policies. They therefore fail basic conditions a) and e).
With regard to the final paragraph of Policy RSL2, it is not considered appropriate for a NDP policy to state certain descriptions of development ‘will be refused’. The final paragraph also lacks clarity in its references to ‘poor design’ and ‘the relevant criteria’. Spitfire’s recommendation would be that the final paragraph ought to be omitted.