Other

ID sylw: 102018

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Savills (UK) Ltd

We have no objection in principle with the inclusion of a self/custom build policy requirement on large development sites. Whilst self/custom build is becoming more commonplace, we still have reservations over the appeal
of self/custom build plots that form part of large strategic-scale developments.
Most people looking to construct their own home are likely to want to do so on an individual plot or as part of a small collection of new homes. As such there is little evidence of self/custom build working successfully to boost housing delivery on large sites. We therefore recommend that a cascade mechanism is built into the policy which enables the developer to complete the development if the self/custom build plots do not come forward in a timely manner.

Other

ID sylw: 102022

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Savills (UK) Ltd

We have strong reservations regarding the proposed requirement for all residential development of 500+ dwellings to incorporate provision of gypsy, traveller and/or travelling show people pitches. Whilst this may appear to be a simple approach to addressing the identified need, it assumes that all such locations will be appropriate and desirable to the gypsy and traveller community. That is not necessarily the case as locational requirements and preferences may point to an alternative delivery strategy. It is in our view more appropriate to allocate specific sites within the SWLP which are known to meet the requirements of the community.

Other

ID sylw: 102036

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Savills (UK) Ltd

Our clients consider the emerging policy approach to be unsound - it is plainly not consistent with national policy as the requirements of the policy are not expressed as a percentage uplift from the TER as now required by the WMS.
The next logical question that follows is whether, in light of the WMS, there is merit in including a policy in the SWLP or instead relying upon Building Regulations. For the reasons set out above, our clients consider that there are good reasons to delete draft Policy DPD22 rather than modify it. The SWLP can then focus on ensuring development is directed towards sustainable locations (a matter covered in more detail elsewhere in our representations) and leave the Building Regulations regime to control the detailed standards for building fabric and energy generation. Such an approach would be entirely consistent with the Government’s expectation for the plan-making process.

No

ID sylw: 102039

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Savills (UK) Ltd

Our clients consider the emerging policy approach to be unsound - it is plainly not consistent with national policy as the requirements of the policy are not expressed as a percentage uplift from the TER as now required by the WMS.
The next logical question that follows is whether, in light of the WMS, there is merit in including a policy in the SWLP or instead relying upon Building Regulations. For the reasons set out above, our clients consider that there are good reasons to delete draft Policy DPD22 rather than modify it. The SWLP can then focus on ensuring development is directed towards sustainable locations (a matter covered in more detail elsewhere in our representations) and leave the Building Regulations regime to control the detailed standards for building fabric and energy generation. Such an approach would be entirely consistent with the Government’s expectation for the plan-making process.

No

ID sylw: 102043

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Savills (UK) Ltd

This draft policy sets out requirements for development proposals that affect heritage assets. We strongly object to the wording of this draft policy owing to its inconsistency with the Framework.
The draft policy relating to significance of heritage assets and justification of harm is inconsistent with paragraphs 205 – 214 of the Framework which contain a much more nuanced approach, reflecting the magnitude of harm and setting out appropriate justification in each case. The inconsistency with the Framework not only renders the draft policy unsound but would, if adopted in its current form, present challenges for accurate and consistent decision making.
The Framework states that ‘Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use’. In so doing it recognises that harm can be outweighed.
The first bullet point of DPD27 however states that ‘a strategic historic environment policy will … preserve and enhance the historic environment (including its setting) for its inherent value, and for the enjoyment of residents and visitors’.‘Preserve and enhance’ is a binary test where any harm would be render the application proposals in conflict with the policy. The Framework, however, seeks to balance harm against public benefits, even in circumstances where substantial harm will occur. For this reason, the current wording of draft DPD27 is unsound and must be revised in line with national policy.

No

ID sylw: 102051

Derbyniwyd: 07/03/2025

Ymatebydd: Barwood Land

Asiant : Savills (UK) Ltd

We recognise and support the need for development proposals to respect and respond to local landscape character, however, the draft policy approach in DPD48 sets an unachievable bar and would preclude most developments.
The second sentence of the policy states that “where a proposal would result in landscape harm, the general principle is that is should be refused unless there would be an over-riding benefit of the development for instance to meet an evidenced local housing need”