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Changes to the Current Planning System Consultation Suggested answers to 35 questions within consultation
document For example, Cheshire East has recently seen high levels of
housebuilding to catch up after years of low numbers, this high level would lead
us to having a high requirement for the future. Q2: In the stock element of the baseline, do you
agree that 0.5% of existing stock for the standard method is appropriate? If
not, please explain why. Q3: Do you agree that
using the workplace-based median house price to median earnings ratio from the
most recent year for which data is available to adjust the standard method’s
baseline is appropriate? If not, please explain why. Q5: Do you agree that
affordability is given an appropriate weighting within the standard method? If
not, please explain why. Q6: Authorities which are
already at the second stage of the strategic plan consultation process
(Regulation 19), which should be given 6 months to submit their plan to the
Planning Inspectorate for examination? Q7: Authorities close to
publishing their second stage consultation (Regulation 19), which should be
given 3 months from the publication date of the revised guidance to publish
their Regulation 19 plan, and a further 6 months to submit their plan to the
Planning Inspectorate? Q8: The Government is
proposing policy compliant planning applications will deliver a minimum of 25%
of onsite affordable housing as First Homes, and a minimum of 25% of offsite
contributions towards First Homes where appropriate. Which do you think is the
most appropriate option for the remaining 75% of affordable housing secured
through developer contributions? Please provide reasons and / or evidence for
your views (if possible): ii) Negotiation between a
local authority and developer. iii) Other (please
specify)
Q9: Should the existing
exemptions from the requirement for affordable home ownership products (e.g. for
build to rent) also apply to apply to this First Homes requirement? Yes Q10: Are any existing
exemptions not required? If not, please set out which exemptions and why. No , see answer to Q9 Q11: Are any other
exemptions needed? If so, please provide reasons and /or evidence for your
views. No additional exemptions are
required but the wording “unless this would …. significantly prejudice the
ability to meet the identified housing needs of specific groups “should be
retained. Q12: Do you agree with the
proposed approach to transitional arrangements set out above? Yes, but local authorities
should have the options of reviewing tenure mix when advice on the mix has
already been given Q13: Do you agree with the
proposed approach to different levels of discount? Yes Q14: Do you agree with the
approach of allowing a small proportion of market housing on First Homes
exception sites, in order to ensure site viability? Q15: Do you agree with the
removal of the site size threshold set out in the National Planning Policy
Framework? Q16: Do you agree that the
First Homes exception sites policy should not apply in designated rural areas? For each of these
questions, please provide reasons and / or evidence for your views (if
possible): Q17: Do you agree with the
proposed approach to raise the small sites threshold for a time-limited period? (see question 18 for
comments on level of threshold) No. There remains a huge and
overwhelming need for affordable homes which are already difficult to secure so
any reduction is unacceptable. Q18: What is the
appropriate level of small sites threshold? i) Up to 40 homes ii) Up to 50 homes iii) Other (please
specify) iii) There should be no small
site threshold. Q19: Do you agree with the
proposed approach to the site size threshold? Q20: Do you agree with
linking the time-limited period to economic recovery and raising the threshold
for an initial period of 18 months? Q21: Do you agree with the
proposed approach to minimising threshold effects? Q22: Do you agree with the
Government’s proposed approach to setting thresholds in rural areas? Q23: Are there any other
ways in which the Government can support SME builders to deliver new homes
during the economic recovery period? Q24: Do you agree that the
new Permission in Principle should remove the restriction on major development? Q25: Should the new
Permission in Principle for major development set any limit on the amount of
commercial development (providing housing still occupies the majority of the
floorspace of the overall scheme)? Please provide any comments in support of
your views. Q27: Should there be an
additional height parameter for Permission in Principle? Please provide comments
in support of your views. Q28: Do you agree that
publicity arrangements for Permission in Principle by application should be
extended for large developments? If so, should local planning authorities be: ii) subject to a general
requirement to publicise the application or iii) both? iv) disagree Option ii) Q30: What level of flat
fee do you consider appropriate, and why? The fee should avoid creating
an incentive for using PiP approach rather than outline when outline is the most
appropriate approach Q31: Do you agree that any
brownfield site that is granted Permission in Principle through the application
process should be included in Part 2 of the Brownfield Land Register? If you
disagree, please state why. Yes Q32: What guidance would
help support applicants and local planning authorities to make decisions about
Permission in Principle? Where possible, please set out any areas of guidance
you consider are currently lacking and would assist stakeholders. Guidance isn’t the issue, the issue is that with PiP is
that there isn’t enough information at the application phase to justify the
location, land use, amount of development or transport access. Q33: What costs and
benefits do you envisage the proposed scheme would cause? Where you have
identified drawbacks, how might these be overcome? 5 week timescale isn’t enough to access information
requirements for major schemes and without greater information it will often not
be possible to agree to the principle of development. Q34: To what extent do you
consider landowners and developers are likely to use the proposed measure?
Please provide evidence where possible. There is no evidence that PiP
has any benefits over the traditional system and introducing it would increase
uncertainty for all due to lack of information. Q35: In light of the
proposals set out in this consultation, are there any direct or indirect impacts
in terms of eliminating unlawful discrimination, advancing equality of
opportunity and fostering good relations on people who share characteristics
protected under the Public Sector Equality Duty? If so, please specify the
proposal and explain the impact. If there is an impact – are there any actions
which the department could take to mitigate that impact? |