I write on behalf of my client Fairview New Homes Ltd.

Fairview New Homes Limited (FNH) is a leading house builder that specialises in the provision of new housing on previously developed land to provide accommodation at the more affordable end of the market. They are therefore very familiar with the issues arising out of the redevelopment of previously developed land and the costs that can often be involved. They are also a major provider of affordable housing and therefore it is hoped that their views will be appropriately taken on board during the progression of the LDF.

In relation to the Core Strategy Preferred Options consultation document, please find below on behalf of FNH the following comments:

Housing Numbers & Phasing

FNH considers that the most suitable and sustainable approach for the Council should be both the re-use of previously developed land and at the same time some greenfield land in sustainable locations. Further housing development is necessary, and Green Belt areas on the periphery of an urban area should be considered for housing. FNH would therefore support the option in paragraph 4.5.10 that would allow the release of land on the edge of settlements.

This approach is in accordance with PPG2 on Green Belts that states in paragraph 2.8 "...encroachment of the Green Belt may have to be allowed in order to accommodate future development. If boundaries are drawn too excessively tightly around existing built up areas it may not be possible to maintain the degree of permanence that Green Belts should have." PPG2 therefore suggests taking land out of the Green Belt that borders existing settlements.

FNH would request that the Council establishes a policy framework that would support the release of land Green Belt land on the edge of existing settlements for housing development.

FHN also request that the Council considers non-housing sites for residential development if they come forward for redevelopment.

Some non-housing sites in the Borough may be better used for housing or mixed-use development and so employment and commercial land should be released for housing where it no longer fulfils its commercial use. Paragraphs 38 and 44 of PPS3 require local planning authorities to consider whether sites that are currently allocated for commercial use be more appropriately re-allocated for housing development. Such an approach would support the deliverability of housing in the Borough. Through the re-use of non-housing sites for residential development, the Council would accord with paragraph 40 of PPS3, which states that a key objective for Local Planning Authorities is to continue to make effective use of land that has been previously developed.

FNH consider that the Council should allow for the release of such land only for housing if it is surplus to requirements.

Affordable Housing

Fairview object to the 'possible' option whereby 30% of all new homes in the district be affordable on all sites unless such a site is considered to be a rural exception site.

FNH consider it necessary to state that any affordable housing targets should be indicative and set at a maximum negotiation level at which point the characteristics and constraints of a site can be discussed with the local authority to determine an appropriate level of affordable housing for the development. This will accord with PPS3, which states that housing targets should reflect the economic viability of land for housing within the area taking into account risks to delivery.

FNH request that it is stated within the document and through policy that the level of affordable housing in development schemes is determined with regard to individual site characteristics such as site costs and constraints as well as financial viability.

FNH therefore consider that the affordable housing mix on new development sites should therefore be negotiated on a site by site basis.

Detailed Design Brief

FNH would object to the requirement that a detailed design brief on all major planning applications be submitted in advance of a planning application. This is an unreasonable request, particularly as Design and Access Statements are a compulsory requirement. The submission of a planning brief would constitute additional information that would add extra cost to the development.

Whilst it is right and proper that the level of design quality is considered within policy terms, it should not however stifle housing delivery. Design initiatives sometimes create an additional cost to the developer and together with Section 106 requirements, this could make some schemes unviable and as a consequence important housing sites would not come forward. FNH consider that the design of a particular scheme should be discussed and negotiated with the local planning authority at an early stage on a site-by-site basis.

Code for Sustainable Homes

FNH object to the inclusion of the Central Government's "Code for Sustainable Homes" initiative into the Core Strategy.

Fairview considers that the "Code for Sustainable Homes" (2006) initiative should remain voluntary as stated in the document and that Councils cannot require developers to comply with it. Such initiatives are a cost to the developer and the viability of delivering housing schemes must be a priority.



Lifetime Homes Standard

FNH consider that requirements relating to lifetime homes standards in new developments should be negotiated on a site by site. Such initiatives should not be enforced through policy as they constitute an additional cost to the developer. The viability of delivering housing schemes must be a priority.

Health Impact Assessment

FNH consider that requirements relating to the submission of a Health Impact Assessments with planning applications for new developments should be negotiated on a site by site. Such initiatives should not be enforced through policy as they constitute an additional cost to the developer. The viability of delivering housing schemes must be a priority.

Carbon Neutral Developments

FNH would object if a particular provision is stipulated in the Core Strategy for residential developments to be carbon neutral.

Whilst recognising that the construction industry need to become more proactive in promoting and incorporating the use of environmentally friendly technology in the built environment, whereby FNH has gone as far as to introduce a wide range of renewable energy measures in its recent developments. The use of a "blanket" policy to provide renewable technology should not stifle regeneration and development. Such rigid requirements may make some schemes unviable and as a consequence important housing sites may not come forward to be developed. Moreover, where difficult sites are being regenerated and the costs are significant, other issues may be more important to reduce, for example contamination and affordable housing. The viability of delivering schemes must be a priority.

FNH therefore require renewable energy generation to be negotiated on a site by site basis, taking into consideration the characteristics and viability of the site.

Fairview object to the 'probable' option whereby all new housing development to include renewable energy provision (page 38). Whilst it is right and proper that energy and sustainable issues are considered, they should not stifle regeneration and development. Such initiatives are a cost to the developer and the viability of delivering housing schemes must be a priority. FNH are of the view that this should be assessed on a site-by-site basis and should not be applied to all residential developments. FNH therefore object to such requirements unless the policy makes it clear that viability will be an issue to be considered.

Water and Energy Conservation

FNH consider that initiatives relating to water and energy conservation in new developments should be negotiated on a site by site. Such initiatives should not be enforced through policy as they constitute an additional cost to the developer. The viability of delivering housing schemes must be a priority.

I trust that Fairview's comments on the Core Strategy Preferred Options shall be considered, however should you require clarification on any matters raised above, please do not hesitate to contact me.