The HBF has submitted written comments to South Northamptonshire Council in relation to its draft local development framework issues report.
In relation to the content of the Draft LDF itself, the HBF has the following brief comments to make:
Paragraph 3.1
Reference will need to be had to Milton Keynes and South Midlands sub-regional spatial strategy, which will provide the regional planning guidance context for the LDF.
Paragraph 3.2
It is stated that one of the factors is to seek to develop in areas where the existing infrastructure capacity is sufficient or can be made sufficient. The HBF would emphasise the importance of fully considering additional infrastructure capacity that is capable of being delivered on the back of housing development.
Paragraph 5.1
It is specified that an average of 40 percent of new housing across the district should be affordable, and that development should be at a minimum average density of 35 dwellings per hectare. No detailed explanations are given as to the full background for setting these requirements. It is stated later on that the council has recently adopted guidance seeking 40 percent affordable housing provision. However, its 1997 adopted local plan policy refers to the negotiation of provision. Therefore, the guidance does not appear to conform to that plan.
Q. 9
Whilst it is Government policy to promote the use of urban and brownfield sites generally, it must be recognised that these will not be capable of meeting all housing needs. It is always necessary to provide a proper mix of dwellings, in a number of different localities in order to address the wide range of different housing needs. Whilst large-scale development in villages may not be necessary, it would be a mistake to stop them from changing at all, regardless of their own specific local needs.
Q. 11
Any requirements will need to be based upon up to date housing needs surveys, and take full account of the economics of provision (including other planning gains being sought). The thresholds that the council can seek for affordable housing are set out in national planning guidance (i.e. circular 6/98).
Paragraph 7.4
Any assumptions the council makes concerning the upper floors of shops and commercial units for residential purposes must be realistic and based on past experience or specific policies to bring such change about. Many owners will often resist such changes, as they want to retain these areas for various uses such as storage. Often, they dont want to have to deal with tenants, and the legal rights that go with them.
Paragraph 9.1
The HBF would point out that the promotion of energy efficiency is basically a building regulations matter, not a planning one. PPG12 advises that planning should not seek to duplicate matters controlled by other legislative regimes.
Paragraph 10.1
It is assumed that the council will formally consult in relation to the particular components of its local development documents scheme and the dates for their individual preparation.
For further information please contact:
paul.cronk@hbf.co.uk(Paul Cronk)
Regional planner, HBF Eastern and East Midlands
0207 7960 1625 or 01206 303825