Planning – Application Comments

Consultation Date: Thu 09 Jan 2025

Comment Date: Thu 20 Feb 2025

The development needs to accord with Joint Local Plan policy DEV 32, the adopted SPD and the Climate Emergency Planning Statement.

This requires a statement of resource minimisation (DEV32.1) and climate resilience (DEV32.2) but the applicants also needs to submit an energy statement which shows how the development will deliver DEV32.3 (Energy Hierarchy), DEV32.5 (20% carbon savings) and DEV32.6 (future-proofed for connection to district energy network), along with the requirements set out in the Climate Emergency Planning Statement. A Climate Emergency Compliance Form also needs to be completed.

Just to be clear, as this site is within the district energy opportunity area, identified in our SPD, DEV32.6 would apply. As a minimum, the development should be designed to be able to easily connect to a future network, if the timing doesn't allow this to happen from completion. A communal system would be ideal in this respect, to minimise any future disruption and costs.

The energy related elements of DEV32 needs to be set out in an Energy Statement. Further details can also be found in the Supplementary Planning Document.

Comment Date: Thu 30 Jan 2025

181 Rendle Street EDG24.001.FRSR-084.pdf

Comment Date: Fri 24 Jan 2025

This pre-application enquiry seeks advice on the proposed demolition of the existing warehouse and construction of 24x affordable, 1&2 bed apartments at the above-mentioned site. The Local Highway Authority (LHA) would not wish to raise any in-principle objections to the proposed development.

The application site is located in an area that is readily accessible by sustainable modes of transport as it is within walking distance of the city centre, bus stops on Union Street and a wide range of services and amenities ranging from schools to food outlets and health facilities.

In terms of trip generation, the existing use of the site as a scrap and waste management facility would have given rise to a level of vehicular trips on the local road network. It is not considered that the new proposed residential use would increase the number of vehicular trips previously established and therefore the LHA would not have any concerns in this regard.

It is noted that there is no off-street parking proposed and therefore the development is proposed as car-free. As stated above, the site is in an accessible location and it is also situated within a Controlled Parking Zone (CPZ) which operates Monday-Sunday between 11am-3pm (from which the development would be excluded if planning permission were to be granted). In addition, there are further parking controls in the form of double yellow lines enforced within the surrounding streets which would also contribute to the control of overspill parking.

Furthermore, consultation with the Parking team has confirmed that there is currently sufficient capacity to easily park in the nearby Western Approach car park to accommodate vehicles associated with the 24 properties. Whilst permits cannot be secured for use within this car park, long-term parking from a month to a year can be purchased. Therefore, there is the option for future residents to access suitable parking within close proximity to the development should they need to.

For these reasons, car-free development is considered acceptable in this instance.

The proposed plans detail a cycle store to the rear of the property which can be accessed from Manor Gardens. As detailed within paragraph 8.31 of the SPD, secure communal stores should be provided for developments of flats. The stores should be well lit, fully covered and conveniently located. The level of cycle parking should meet the minimum requirements of 1x space per bedroom and the LHA would expect to see full details relating to the size and specification of the cycle store as part of any formal planning application.

As vehicular access to the site would no longer be required, the redundant vehicle crossing should be removed and the footway and kerb face reinstated using materials that are in keeping with the local area. The applicant would be required to contact Plymouth Highways for the necessary approvals and permits to undertake the works prior to the occupation of the units.

A Travel Plan which covers the measures to be implemented on site to encourage sustainable travel among all site users will need to be submitted and approved for the development.

Further guidance on the requirement for travel plans and what these should include can be found here: https://www.plymouth.gov.uk/travel-plans

While the site may naturally encourage the use of sustainable and active modes of transport with its proximity to the city centre, an incentive such as a sustainable travel voucher can help encourage someone to make a change in their existing travel behaviour, especially if it means they do not need to initially pay to use the bus, to buy or hire a bicycle.

In conclusion, the LHA would not wish to raise any in-principle objections to the proposed development. A Transport Statement, Travel Plan and full details relating to the proposed cycle storage will be required as part of any formal planning application.

In addition, the LHA will also require a Demolition/Construction Traffic Management Plan and Highway Dilapidation survey to be submitted and approved prior to the commencement of works on-site, however such information could be secured via planning condition if permission were to be granted.


The proposed development has been considered in accordance with the Councils current Development Plan Policies and having regard for the National Planning Policy Framework.



Abbie Perry

Transport Planning Officer
Officer authorised to sign on behalf of the
Director for Strategic Planning & Infrastructure

24/01/2025

Comment Date: Fri 24 Jan 2025

25/00027
Pre application advice sought for proposal to construct 24 Affordable Housing units ' one and 2 bed.
Site 181 Rendle St

Housing Delivery Comments Jan 2025

The site is centrally located, however it adjoins several commercial uses, which may raise concerns about compromised amenity levels for the proposed residential properties. If the residential use proposals are deemed acceptable alongside broader planning considerations, the Housing Delivery Team would in principle support this proposal to provide Affordable Housing units in a high demand area of the city. The number of units appropriate for the site would need to be considered carefully. This potential 'in principle' support would be contingent upon the applicant providing sufficient evidence that policies DEV9 (accessible housing), DEV10 (housing quality) and DEV7 (affordable housing) will be complied with.

Affordable Housing

The proposed residential units are described as Affordable ' however it is not clear from the submitted details what mechanism would be used to secure the properties as Affordable Housing. If a residential scheme is considered to be acceptable, a s106 legal agreement would be used to secure the Affordable Housing and template legal terms can be provided.

Typically, a proposal such as this would be designed alongside a Registered Provider, who would either purchase units once developed or manage the units as Affordable Housing under a long lease agreement. There are a number of Registered Providers (RPs) of Affordable Housing working in Plymouth who the applicant is recommended to contact and work alongside in the design stages, to ensure specifications will meet RP requirements. Registered Providers can only access government funding to purchase affordable units which meet strict design standards/specifications ' hence early engagement is essential. Contact details of Plymouth Housing Development Partnership RP members can be supplied if required.

Clarification on the nature of the Affordable Housing proposals in this case would be most useful to enable the Housing Delivery Team to assist in the progression of a scheme ' if a residential use is considered acceptable in all other planning respects.

There is significant demand for affordable housing in Plymouth. There are currently nearly 9,000 households in Plymouth on waiting lists for affordable housing.

Paragraph 4.74 of Policy DEV7.2 within the JLP Supplementary Planning Document (SPD) outlines that the affordable housing contribution for developments of above ten homes should be:

'At least 30 per cent of the total number of dwellings should be affordable without public subsidy, subject to viability. For schemes of more than 15 units, the presumption is for on-site delivery unless there are exceptional circumstances agreed by the Council.

Paragraph 4.79 of the SPD sets out the Council's preferred tenure mix for affordable housing units, which is 65% social rent and 35% affordable home ownership tenures. Policy compliant Affordable Housing provision for a residential development of 24 units would require provision of 7.2 affordable housing units ' rounded up to 8 affordable housing units. This information is provided for information only as the proposal is for all units to be Affordable.

In terms of Affordable Housing tenure, the policy requirement would be equivalent to 5 social rented dwellings (65% of 8) and 3 affordable home ownership dwellings (35% of 8). Any proposals for a below policy level of Affordable Housing delivery will need to be supported by an open book full viability report provided by the applicant and verified by a Plymouth City Council Viability Officer (or other viability expert) for robust assessment.

Other detailed aspects of Affordable Housing delivery such as agreed mix and locations are outlined in the SPD document and would be captured in standard s106 clauses.

Accessible Housing

There is a chronic shortage of accessible housing and many households who are in need of this type of accommodation wait far too long for suitable housing to become available.

Policy DEV9.4 of the JLP requires at least 20% of dwellings to meet national standards for accessibility and adaptability (Category M4(2) of Building Regulations) on developments of five or more homes. HDT would welcome a proposal to deliver a higher % of M4(2) dwellings where possible.

However, detailed plans to comply with these requirements should be provided by the applicant. An accessible housing compliance template is supplied alongside these comments to assist the applicant in providing sufficient verification for this aspect of the proposals.

Assuming sufficient evidence is supplied, a planning condition would be recommended in order to ensure that the full accessible/adaptable specification is delivered and retained for future residents. The accessibility of the site surroundings will also need to be carefully considered.

Housing for Older Persons

Policy DEV7 of the JLP outlines a key need for 'smaller dwellings most suited to younger and older people' in the Plymouth Policy Area. The Older Persons Housing Task force has recently issued a series of reports outlining the need for more Older persons housing provision ' which in this case could be accessible housing which is particularly attractive to those wishing to downsize.

The 2021 census confirms that there are more than 85,000 households in Plymouth under-occupying their properties ' many with 2 or 3 spare bedrooms. This is similar to the national profile of underoccupied residential properties. Research shows that many of those households would be prepared to move ' given the availability of improved choice of downsize housing options. Research identifies a key incentive to downsize is the ability to future proof by choosing accessible housing which enables people to live independently at home for as long as possible.

Housing Quality

Policy DEV10.5 of the JLP states that all dwellings, irrespective of tender, should meet the size standards set out in the Nationally Described Space Standards (NDSS). It would be helpful if the proposals were accompanied by a schedule of proposed units sizes and associated storage space.

Policy DEV10.5 also states that sufficient external amenity space or private gardens should be provided for with new dwellings. The proposed floor plans do not appear to show any proposed private amenity space ' a matter which would need to be addressed in order to comply with this policy requirement.

Summary

If a residential use proposal is deemed acceptable against other planning considerations, and the relevant assurances are provided to HDT with regards to compliance against JLP policies DEV7, DEV9, and DEV10, the Housing Delivery Team would support this proposal. Provided the concerns raised above can be overcome, a residential proposal would be well-placed to make an important contribution towards broadening housing choice and meeting accessible and affordable housing need in the city.

Comment Date: Wed 22 Jan 2025

Regarding the proposal 25/00027/MJR to create 24 affordable one and two bed apartments at 181 Rendle Street the Economic Development team would like to raise the following concerns:

Within the Plymouth and South West Devon Joint Local Plan, policy Dev 14 sets out that proposals which result in the loss of employment space are required to provide a robust justification to either demonstrate the wider economic benefits that the new proposed use will bring or that the site has no reasonable prospect of being used for employment uses moving into the future.

For Economic Development to fully consider the proposed change of use we would therefore like to see evidence that there is no demand for the site as employment space, this should include marketing materials used to demonstrate what activity has been done to market the site for a reasonable period of time, a minimum of 12 months. Alternatively, we would consider an economic analysis of the development which clearly outlines how the change of use would create a greater or broader economic impact in the area than retaining the space for employment uses.

Finally, point 3 of Policy Dev 14 advises that 'Employment sites will be protected from inappropriate neighbouring development that will adversely affect the employment operations taking place on the site.' Plot 181 of Rendle Street is currently surrounded by employment sites, we would welcome details as to how the applicant proposes to safeguard the existing employment units from new proposed residential units to allow us to fully consider the impact this change of use could have on the area.