Comment

Representation ID: 22423

Received: 11/10/2021

Respondent: Mr Maurice Sanders

Agent: Avison Young

Policy DEL1 – Infrastructure Provision
This policy requires that all new developments should be supported by the necessary on and off-
site infrastructure to serve its needs, mitigate its impact on the environment and the local
community and ensure that it is sustainable and contributes to the proper planning of the wider
area, unless material circumstances or considerations indicate otherwise.

Notwithstanding this position, the provision of developer contributions should only be sought
where these are proportionate to the level and impact arising from new development. As outlined
in paragraph 57 of the NPPF:
“Planning obligations must only be sought where they meet all of the following tests:
a) Necessary to make the development acceptable in planning terms;
b) Directly related to the development; and
c) Fairly and reasonably related in scale and kind to the development.”
We therefore recommend that the policy is reworded to make clear that all new developments
should be supported by the necessary on and off-site infrastructure, where it is viable to do so.
Policy HOU2 – Housing Density, Type and Accessibility
Policy HOU2 recognises that the density and type of housing to be provided on any housing site
will be informed by (i) sub-regional and local needs, (ii) access to sustainable transport methods
and (iii) the need to achieve high quality design. Insofar as (i) is concerned, our Client considers it
will be important to maintain flexibility to allow for changing local market circumstances. In this
regard, it will also be important to ensure that housing mix prescriptions are determined in line
with up-to-date evidence.
Paragraph 125 of the National Planning Policy Framework states:
“Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is
especially important that planning policies and decisions avoid homes being built at low densities and
ensure that developments make optimal use of the potential of each site.”
This policy also states that plans should contain minimum density standards for city and town
centres and other locations that are well served by public transport, and that the use of minimum
density standards should also be considered for other parts of the plan area and that it may be
appropriate to identify a ‘range’ of densities that reflects the accessibility and potential of different
areas.
Barnardo’s, therefore, as a matter of principle, support the range of minimum net densities set
out in Policy HOU2 of between 40 dph and 100 dph.