Other

ID sylw: 108410

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We support the SWLP approach to prioritising access to public transport, walking and cycling routes.

The provisions of Policy Direction 31 illustrate the objections we have made in respect of applying a sequential approach to delivering brownfield land before considering green field release – our underlying objection is that broader sustainability considerations must outweigh any notion of sequential site release. An inherently sustainable approach is to minimise reliance on the private car, rather than determining development strategy by reference to a policy designation.

Applying the provisions of Policy Direction 31 it is clear that focussing development on the main towns and settlements, which have good connections, is a sound and justifiable approach.

Other

ID sylw: 108411

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We support the provisions of Policy Direction 38. 10% BNG is a requirement which properly should be set out in policy.

Policy should go further, and make clear that any voluntary commitment to delivering BNG beyond 10% is a significant benefit which should be put in to a planning balance assessment at development management stage.

Other

ID sylw: 108412

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We support the provisions of Policy Direction 43c, specifically in relation to the need for new development to deliver new open spaces. However, the guidance for new open spaces should be provided now, to enable GI strategies to be applied to Design Codes and a broader site by site assessment as to infrastructure delivery, site yield and overall site viability and thus deliverability.

We support a broad range approach to open space typologies, including in relation to food production via community orchards and allotments.

Other

ID sylw: 108413

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We support the requirement that all new development should comply with the NDSS.

However, we make detailed objections to the provisions of Policy A.

It should not be a requirement that all 1 and 2 bedroom affordable homes be built with bedrooms capable of accommodating 2 occupiers in each bedroom. The NDSS expressly provides for a 2 bedroom 3 person home.
Furthermore, we object to 100% of all new open market housing achieving M4(2) standards. This is a disproportionate requirement, it is not evidenced as being a requirement of the SWLP, and as a result we would suggest a maximum of 50% of all new affordable housing achieving this standard.

No

ID sylw: 108414

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We object in principle to this policy.

Self build plots meets a specific need within the SWLP area, and it is appropriate to plan for the delivery of self build properties, however the provision of 5% of all sites of 100 houses or more is a wholly unacceptable approach to delivering on need.

Self build plots set within spatial growth sites will result in sites becoming piecemeal, it will be more challenging to first development and then implement Design Coding. The alternative approach is for the SWLP to expressly allocate sites specifically for the delivery of self build plots and no other purposes.

Other

ID sylw: 108415

Derbyniwyd: 06/03/2025

Ymatebydd: The Kler Group

Asiant : Cerda Planning Ltd

We broadly support the provisions of Policy J and the objective of reducing flood risk.

However, we consider that the provisions of the policy are not consistent with the NPPF, specifically regarding the sequential approach to locating development.

The policy should be amended to make clear that all development sites should apply the sequential test at site selection stage rather than layout design stage. This approach should be applied to both plan making and development management.