HBF has submitted brief written comments to Lincolnshire County Council in response to its Choices and Issues Paper published in order to commence its Structure Plan Review.
Mr I Annibal
Head of Operations
Lincolnshire Development
Lincolnshire County Council
Beech House
Witham Park
Lincoln LN5 7JH
13th June 2003
Dear Mr Annibal
LINCOLNSHIRE STRUCTURE PLAN REVIEW CHOICES AND ISSUES PAPER
Thank you for giving the HBF opportunity to comment on the above mentioned document.
The HBF wishes to make only brief comments at this stage in the planning process, these are set out below.
What will influence the Structure Plan?
The Government Office for the East Midlands will no doubt be advising the County Council on whether or not it should now be progressing work on a new Structure Plan or redirecting its attention to progressing work on the new Regional Spatial Strategy.
Where will new development be located?
Although flood risk is an important concern, PPG 25 sets out the circumstances where it should be a real issue. The guidance makes it quite clear that in many instances development will be able to proceed as long as measures are implemented to address specific matters of concern to the Environment Agency.
Where will new development be located?
The County Council states that it is keen to maximise the benefits from S.106 agreements for Lincolnshire residents. It must be remembered that any requirements should be directly related to the scale and nature of the development in question. It is not the role or purpose of such agreements to serve the interests of the wider general public. Any requirements should take full account of Circulars 1/97 and 6/98 and also site specific matters (in some instances, economics might dictate that no contributions to such requirements would be feasible).
The location of new development should take full account of market demand. If it were to be purely based upon social need then it is unlikely that the required level of housing supply would be delivered.
What type of housing should be provided?
It is stated that where private housing is built on sites of a certain size, developers must make sure that a proportion of the houses are affordable in some way. It must be remembered that developer contributions cannot be demanded, they can only be sought. It is also the case that they must be considered on a site by site basis and take full account of all other costs including other suggested developer requirements. Consequently, in some instances no affordable housing provision will be appropriate due to remediation costs or other types of requirements having priority (transportation measures, community facilities, educational provision e.t.c.).
It is acknowledged that local authorities are required to ensure the provision of an appropriate range of dwellings to meet different needs. However, these needs have to be viewed on a settlement or district-wide basis. It is often not appropriate for individual sites to be expected to deliver all such needs as there are often design, locality, marketing and economic reasons why such provision would be inappropriate.
I look forward to the acknowledgment of these comments.
Yours sincerely
Paul Cronk
Regional Planner
For further information please contact HBF East Midlands Regional Planner: Paul Cronk on 0207 608 5114 or at paul.cronk@hbf.co.uk