B&MSDC Supplementary Planning Documents Consultation

Comment

Representation ID: 23603

Received: 20/06/2024

Respondent: Persimmon Homes ( Suffolk)

Persimmon Homes Suffolk welcomes the draft joint Supplementary Planning Documents (SPD) and the opportunity to partake in the consultation to provide feedback on further improving the documents. We have given great consideration to the Housing SPD (draft), considering the guidance alongside national guidance and policy and industry realities.

For ease of reference, specific comments are provided under subheadings relating to the SPD’s paragraph numbers in numerical order.

Para 2.1.13
Clarification is required to understand the Council’s point here; is the Council seeking that studies should meet the National Described Space Standards of a bedroom? What is the justification for the Council to require that studies should be of such a size?

We would ask the Council to reconsider the impact to schemes if “1 bed units should be in clusters of no more than 6” as this could cause difficulties in creating coherent and efficient schemes, especially for schemes that may make use of bungalows or apartment blocks.
Para 2.2.2 – 2.2.4
There is discrepancy between whether the percentage of affordable housing is set or is a minimum; the wording is confusing here. There needs to be clarity on how the Council will request housing above the 25% or 35% and what will be the justification for a request above the 25% and 35%. These uncertainties will cause viability issues for Applicants which will inevitably slow down the bringing development forward.

Para 2.2.9 – 2.2.10
Persimmon Homes Suffolk request that the Council seeks to be dynamic in their preferred Affordable Housing Mix to ensure that there is capability to adapt to the changing market. Flexibility in offering other types of Affordable Housing will help deliverability of schemes and therefore more Affordable Housing too.

Para 2.2.17
Persimmon Homes Suffolk queries what would happen if this format was not able to be adhered to, is there any flexibility in exceptional circumstances?

Para 2.2.18 and 2.2.21
A clear calculation needs to be provided to avoid any doubt or disagreements on what is classified as surplus. This will also allow Applicants to calculate viability of scheme.

Para 2.2.24
The Council state that “Affordable housing is not to be clustered in less desirable parts of Sites” but the SPD does not then give a definition of what would be considered as less desirable. Without a definition this is left open to interpretation, what one person might find less desirable another person might find desirable.

Para 4.3.2
“transferred” should not be included in this point as there are often occasions where a Registered Provider cannot be found or the contracts are taking longer than expected and so there could be an unnecessary delay to delivering open market houses.

Para 4.6.2 – 4.6.4
Are Housebuilders restricted to the Council’s list of Registered Provider? There should be flexibility for the Housebuilders to choose a Registered Provider and an understanding of the current market for Registered Providers.
Are the Council’s preferred Registered Providers currently seeking Affordable Housing provisions at this time?

Para 5.1.6
Housebuilder house types may not support this Principle and Persimmon Homes Suffolk ask for the justification behind a downstairs shower room.
Overall, Persimmon Homes Suffolk would seek more flexibility in this SPD and to reflect the changing trends in the affordable housing sector. This SPD does not include how the Council would adapt to the ever changing environment; this SPD needs to go further to demonstrate how issues can be resolved in order to maintain housing supply. There needs to be flexibility in tenure delivery and cascades where Registered Providers are unable to proceed to offer/contract on reasonable commercial terms.

Lastly, there is also little in here on First Homes. There needs to be clear guidance on this, the Council’s policy position, income caps, discount levels and OMV caps. These will effect viabilities for Housebuilders and therefore effect deliverability of sites.

We look forward to seeing the revised SPD and welcome any further discussion towards its creation.

Comment

Representation ID: 23604

Received: 20/06/2024

Respondent: Persimmon Homes ( Suffolk)

Persimmon Homes Suffolk welcomes the draft joint Supplementary Planning Documents (SPD) and the opportunity to partake in the consultation to provide feedback on further improving the documents. We have given great consideration to the Biodiversity and Trees SPD (draft), considering the guidance alongside national guidance and policy and industry realities.
For ease of reference, the comments are provided under subheadings relating to the SPD’s paragraph numbers in numerical order.

Para 3.2
Clear definitions are important to understand what the Council is seeking with the statement “ensuring measures are resilient to climate change”. By providing clear definitions, with examples, of the measures and what makes these resilient to climate change the council can ensure they have something to reference against when decision making and that they are consistent in their approach to Applications.

Para 4.14 – 4.19
To ensure the Council provides a consistent approach to decision making, it will be important to provide clarity in the SPD what situations / justifications the Council will ‘expect’ more, and how they justify that need.
The SPD should state the Council’s expectations clearly to enable Applicants that do not have pre-application advice to find what is expected from their application.

Para 4.20
Persimmon Homes Suffolk note that the Council “request that applicants deliver BNG on-site”, however this is often not possible, and the Council should ensure that the SPD is clear that the Council recognises this and provide further detail about how Applicants should demonstrate to the Council that they have followed the Mitigation Hierarchy and what evidence the Council would be seeking as part of an application. The Council should provide the justification for requiring the delivery of BNG on-site.

The SPD states “Off-site compensation is generally a last resort and will only be considered on a case-bycase
basis” but this is not quite in line with the Statutory Framework. Last resort applies to the purchase
of Statutory credits, not off-site units.

Para 4.25
There is some misalignment with the BNG Statutory Framework in the location hierarchy. Why has the
SPD not included all of the steps from the Statutory Framework, where does the Council see these points
fit in? The SPD misses out the following steps;
▪ within the LPA or NCA
▪ within the neighbouring LPA or NCA
▪ beyond the neighbouring Local Nature Recovery Strategy Area / LPA or NCA

Para 5.5
Further clarity is required in what to include in the calculations. Should the calculations exclude or
include continuation of standard habitat management regimes, specific to the site (i.e hedgerow
maintenance for visibility maintenance / highway safety reasons, routine grass cutting, but that which
maintains baseline BNG value, arable rotations which include fallow land as part of normal cropping
regime (fallow land has a higher baseline value than crop etc)?

Para 5.6
Persimmon Homes Suffolk is concerned that the Council, as the Competent Authority is stating that they
will be unable to make a Decision without a response from Natural England. The volume of work for
Natural England will be greatly increasing and so does the LPA have an agreement with Natural England
for this level of work, will Natural England be part of the Pre-Application process?

We would also welcome the option to pay for a priority service from Natural England or a payment to
ensure they respond within agreed timescales.
The SPD should state what happens if Natural England delays its consultation response? Will there be a
mechanism in place to hold Natural England accountable for any delay in response? What would happen
if Natural England never responded or kept delaying their response? There should be a publicly available
flow diagram of the process and timescales for the involvement of Natural England.

As the competent authority, does the LPA have a way in which it will measure the in-combination effect
if the Council is stating that this will be considered in the Decision, the SPD should be making it clear
how it is measurable. Currently this is an unknown for many LPAs and Priority Species.

Our last point is a general one; in relation to County level guidance, we would like the Council to ensure that any SPD expectations align with the County level guidance and adoption requirements, especially in relation to trees adjacent to highways.

We look forward to seeing the revised SPD and welcome any further discussion towards its creation.