HOU 5 - Affordable Housing Change required: HOU 5 is unsound as the policy fails the tests of CE 1, 2 and 3‐ Coherence and Effectiveness The policy is not founded on a robust
evidence basis which explains the rationale behind the policy triggers and provides a clear understanding on the implications arising from the policy.
Lacuna Developments request that Council reconsiders its evidence basis to support the Affordable Housing policy.
HOU6 - Housing Mix Change required: HOU 6 is unsound as the policy fails the tests of CE 1 and 2 ‐ Coherence and Effectiveness The policy should be deleted as it duplicates
provisions already set out in HOU 5 and places unnecessary restrictions on private housing developers.
DES3 & HOU4 - Tall Buildings and Density of Residential Development Change required: (a) We are not supportive of setting guideline heights. Based on the analysis undertaken
we recommend that the threshold of 35m AOD is revisited and the text ‘those which are significantly higher than their surroundings’ is removed as there is no guidance to
determine what is significantly higher. (c) Criteria is unsound as it doesn’t read across other policies in the plan specifically those set out in the Built Heritage section. (d) Replace
‘Contribute to a cluster or an interesting skyline when grouped together’ with ‘Contribute to a cluster or create a focal point or beacon (a Point Block) which acts as a form of marker
contributing to a positive skyline.’ As drafted there is a conflict in respect of the clustering and grouping and assessing each application on its own merits. Individually, or in groups,
tall buildings can affect the image and identity of the city. Para 3.4 of the Technical Supplement 06 states that ‘Tall buildings are generally easily recognisable and act as key
landmarks within a city’s skyline either individually or as a cluster.’ (our emphasis) (e) Replace ‘Support locations of civic or visual importance including major transport nodes, civic
spaces and areas of high employment’ with ‘Support locations of civic or visual importance including major transport nodes, civic spaces, areas of high employment, at arrival
points into the city, waterfront and areas of regeneration including those identified as Development Opportunity Sites and masterplans’ Consideration should be given to including
criteria in DES3 that 'regard should be had to extant masterplans/frameworks or extant planning permissions whereby locations for taller buildings are identified or approved…'. (f)
Add ‘will bring significant regeneration benefits and contribute positively to place‐making’ similar to other UK cities it should be acknowledged that taller buildings can act as
catalysts for wider regeneration. Skylines of cities such as Manchester, Leeds, Liverpool and Birmingham act as markers and signposts of regeneration. (g) Remove ‘Existing tall
buildings within Belfast will not set a policy precedent for similar development on adjacent sites.’ This is unsound because it is an invitation to set aside an assessment of context
and character, factors which are genuine and important material considerations in making a planning decision within the new policy framework. The PAC decision (ref: 2013/A0124)
is of particular relevance.
Density of Residential Development Change required: 'An increase in the density of housing and mixed use developments will be promoted in town and city centres and other
locations which benefit from high accessibility to public transport facilities and major regeneration/masterplan sites including those with a waterfront location.
CGR 1 - Community Cohesion and Good Relations Change required: That the policy be amended. Criterion (a) and (b) should be deleted. Criterion (c) reworded to state that where
the opportunity exists to improve future connectivity across peace infrastructure and create permeable neighbourhoods that this should be incorporated into design proposals. No
change to criterion (d) and (e). These changes would assist in making the policy sound as the revised criteria is found on good planning principles and paragraph 4.17 of the SPPS.
BH2 Conservation Areas Change required: The policy is unsound as it fails the tests of CE 2 Coherence and Effectiveness The policy is not founded on a robust evidence basis
which explains the rationale behind the policy triggers and provides a clear understanding on the implications arising from the policy. Lacuna Developments requests that Council
reconsiders its evidence basis. The policy should reference the balance that needs to be achieved with replacement development and recognising there is a legislative test.
TRAN 8 Parking and Servicing Arrangements Change required: Policy TRAN 8 is unsound as the policy fails the tests of CE 2 and C4. The policy should introduce flexibility and we
would suggest deletion of ‘DfI standards’ and replacement with ‘published standards.’
TRAN 9 Parking Standards within areas of Parking Restraint Change required: The policy fails to satisfy the test of CE2 in that the evidence base prepared to support the policy is
not provided within the technical supplements and the recommendations following from Council’s Car Parking Strategy (published in May 2018) have not been provided. We
respectfully suggest that Council prepares an up to date evidence basis to support this policy and on the basis of the evidence collated reassesses whether the evidence supports
this policy position.
OS 3 Ancillary Open Space Change required: There is insufficient evidence within the technical supplement to support the policy proposed A robust, up to date evidence basis
should be prepared to support this policy.
