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Development plan · Wicklow County Council

Wicklow County Development Plan 2022–2028 – Volume 1 Written Statement

The council's development plan written statement: its strategy, policies, objectives and development standards.

Wicklow County Council · 2022–2028 · 465 pages

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  1. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing Only in exceptional circumstances should the above principles be contravened, for example, where a barrier to development is involved. Any exceptions must be clearly justified by local circumstances and such justification must be set out in any planning application proposal. 6.3.5 Densities Higher densities are encouraged to achieve an efficient use of land and create compact, vibrant and attractive settlements. The capacity of a site to absorb higher densities is influenced by a range of factors including the local setting, development context, neighbouring uses, access, topography etc. The preparation of a design statement, including a detailed contextual and site analysis, will help determine a site’s capacity and the appropriate density. The potential of brownfield sites to consolidate the built form and deliver higher densities should be capitalised subject to protecting existing amenities and achieving high quality standards for future occupants. The design of any higher density development should be sensitive to, and respectful of, existing surrounding residential development. In existing residential areas, infill development shall generally be at a density that respects the established character of the area in which it is located and subject to the protection of the residential amenity of adjoining properties. New development should incorporate a mix of dwelling types and heights to achieve minimum densities and create interesting and attractive settlements. Large development should incorporate a mix of densities. This will result in interesting and distinctive built forms that enhance the character of an area while also providing an opportunity to provide for a mix of dwelling types. Mono-type building typologies (e.g. two storey or own-door houses only) will not be considered favourably, particularly developments of 100 units or more. High density does not necessarily mean high rise. Terraced housing offers an opportunity to achieve relatively high density. The design of the terrace can take a very modern interpretation or traditional guise. It is Council policy to encourage higher residential densities at suitable locations in accordance with the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009). Locations that are appropriate for higher densities include sites that are particularly close to existing or proposed major public transport corridors and nodes, sites that are within or proximate to major centres of activity such as town and neighbourhood centres. The density standards as per the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009) are set out in Table 6.1.
  2. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing Table 6.1 Density Standards Location Density Standards Large Towns5 (Bray, Greystones-Delgany, Arklow, Wicklow –Rathnew and Blessington)  Public Transport Corridors: Minimum density of 50 units per hectare within 500m walking distance of bus stop or 1km of light rail stop or rail station.  Outer Suburban / Greenfield Sites: Minimum density of 35 - 50 dwellings per hectare.  Development at net densities less than 30 dwellings per hectare should generally be discouraged particularly on sites in excess of 0.5 hectares. Small Towns and Villages6 (Kilcoole, Newtownmountkennedy, Baltinglass, Enniskerry, Rathdrum, Aughrim, Ashford, Carnew, Kilmacanogue, Roundwood, Tinahely, Newcastle, Dunlavin, Avoca, Shillelagh, Donard)  Centrally located sites: 30 – 40+ units per hectare for mainly residential schemes may be appropriate or for more mixed use schemes.  Edge of Centre Sites: 20-35 dwellings per hectare.  Edge of small town / village: Densities of less than 15 – 20 dwellings per hectare (as an alternative to one-off housing) as long as such development does not represent more than 20% of the total new planned housing stock of the small town or village. Villages under 400 Population Any individual scheme for new housing should not be larger than 10 units. In the application of density standards and the assessment of applications, cognisance shall also be taken on Circular letter NRUP 02/2021 that clarifies that in the application of the Sustainable Residential Development Guidelines, Planning Authorities should apply a graduated and responsive, tailored approach to the assessment of residential densities in Peripheral and/or Less Accessible Urban Locations, as defined in the Apartment Guidelines and as they apply to towns of all sizes, to ensure that such places are developed in a sustainable and proportionate manner. Apartments will be considered favourably in the Key Towns and the Self-Sustaining Growth Towns. High quality smaller scale apartment development will be considered in the Self-Sustaining Towns and rural towns provided that adequate services and amenities are in place to serve the development including high quality public open space. Where up to 9 residential units are proposed there shall be no restriction on dwelling mix provided that no more than 50% of the development comprises studio type units. 6.3.6 Universal Design & Lifetime Adaptable Housing Universal design is the design and composition of an environment so that it can be accessed, understood and used to the greatest extent possible by all people, regardless of their age, size, ability or disability. New developments, where possible, should include universally designed homes that can be easily adapted to meet people’s changing needs over time. The Universal Design Guidelines for Homes in Ireland (2015)7 are a first step in the process of raising awareness and inspiring people to think differently about the benefits of Universally Designed homes and the potential 5 These are defined in the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009) as those with a population of 5,000 or more. 6 These are defined in the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009) as those with a population ranging from 400 to 5,000 persons.
  3. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing opportunity to address some of the challenges society faces by future-proofing our homes through embracing Universal Design thinking. Building for Everyone: A Universal Design Approach provides comprehensive best practice guidance on how to design, build and manage buildings and spaces so that they can be readily accessed and used by everyone, regardless of age, size, ability or disability8. 6.3.7 Quality of Design in New Housing Developments The Planning Authority has to strike a careful balance between on the one hand enabling new housing development that meets housing demand while ensuring that highest standards of urban design, architectural quality and residential amenity. The quality and character of our towns and villages lies in the consistency of the language and the way the buildings relate in form, scale, treatment, materials and details. It is important that new development is designed to respect and complement the historic urban grain and incorporate a layout and design that strengthens the identity and character of the settlement. An understanding of context and appreciation of character is at the core of good urban design. It lays the foundations for a unique design response. The design and layout of new development should be based on an informed and considered response to a site’s setting and context. All applications for multiunit residential development should be accompanied by a design statement which clearly demonstrates how the design responds to the local context. Further detail on this is provided in Appendix 1. New housing development should be designed to respect its setting and provide for a strong connection with the character of the existing settlement. Particular attention should be paid to boundaries, public space and planting in order to achieve good quality. Permeability should inform the layout and design. New residential and mixed-use schemes should deliver attractive street-based traditional town environments that incorporate a good sense of enclosure, legible streets, squares and parks and a strong sense of place. Developments should include an effective mix of heights that integrates well with the existing urban structure and historical streetscapes. The NPF requires a flexible approach to planning policy to enable infill and brownfield development with a focus on design-led performance-based outcomes rather than specifying absolute requirements in all cases. Therefore planning standards will be flexibly applied to well-designed development proposals that can achieve urban infill and brownfield development objectives. Such flexibility must still ensure that public safety is not compromised and the environment is suitably protected9. The Development and Design Standards (Appendix 1) sets out Wicklow County Council’s requirements with respect to the design standards for new housing developments. All new housing developments will be assessed in accordance with the development and design standards set out in this appendix. Guidelines for Sustainable Residential Development in Urban Areas (2009) The Urban Design Manual, which accompanies the ‘Guidelines for Sustainable Residential Development in Urban Areas’ (DoEHLG 2009), provides comprehensive guidance on design issues. The Manual sets out a series of 12 design criteria for development sub-divided into three groups: (i) Neighbourhood (ii) Site (iii) Home. These groups reflect the spatial scales and order of priorities that should help inform and guide the design of any new residential and mixed-use development. The 12 criteria, as set out in Table 6.2, are sequenced in logical order to reflect the need to prioritise the fundamental strategic issues including density, layout and connections. The Manual should be used as a key reference tool at pre-planning consultations and in the assessment of planning applications for any new residential 7 National Disability Authority Centre for Excellence in Universal Design 8 http://universaldesign.ie/Built-Environment/ 9 Refer to NPO 13 Project Ireland 2040: National Planning Framework
  4. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing and mixed-use development proposals. The design and layout of new housing development in rural towns and villages should reflect their rural setting and pay homage to the principles of vernacular architecture. Table 6.2 Design Considerations – 12 Criteria Neighbourhood Context Connections Inclusivity Variety How does the development respond to its surroundings? How well connected is the new neighbourhood? How easily can people use and access the development? How does the development promote a good mix of activities? Site Efficiency Distinctiveness Layout Public Realm How does the development make appropriate use of resources, including land? How do the proposals create a sense of place? How does the proposal create people friendly streets and spaces? How safe, secure and enjoyable are the public areas? Home Adaptability Privacy & Amenity Parking Detailed Design How will the buildings cope with change? How does the scheme provide a decent standard of amenity? How will the parking be secure and attractive? How well thought through is the building and landscape design? Source: Guidelines for Sustainable Residential Development in Urban Areas (DoEHLG 2009) Urban Development & Building Height Guidelines for Planning Authorities (2018) The ‘Urban Development and Building Heights Guidelines for Planning Authorities’ acknowledge that increasing prevailing building heights has a critical role to play in addressing the delivery of more compact growth in our urban areas particularly the large towns through enhancing the scale and density of development. The Guidelines require that building heights must be generally increased in appropriate urban locations. Specifically the Guidelines require that the scope to consider general building heights of at least three to four storeys, coupled with appropriate density, in locations outside what would be defined as city and town centre areas, and which would include suburban areas must be supported in principle in development plans. Proposals including buildings that are of a height and scale significantly greater than the prevailing height and scale shall be assessed in accordance with the development management criteria set out in Section 3.0 of the Urban Development and Building Heights Guidelines (DHPLG 2018). In accordance with Specific Planning Policy Requirement (SPPR) 1 of the Urban Development and Building Height Guidelines for Planning Authorities (2018), Local Area Plans (LAPs) shall identify locations where increased height and density will be supported where it forms part of strategic redevelopment, regeneration and infill development proposals. Design Standards for New Apartments Guidelines for Planning Authorities (2020) The shift in Government policy towards securing more compact and sustainable urban development will result in a significant increase in apartment type development. The Guidelines recognise that it is therefore critical to ensure that apartment living is an increasingly attractive and desirable housing option for a range of household types and tenures. With regard to location, the Guidelines indicate that apartments are most appropriately located within urban areas. The scale and extent of apartment development should increase in relation to proximity to core urban centres, locations that are well served by public transport, are close to employment and a range of urban amenities including parks / waterfronts, shopping and other services.
  5. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing The Guidelines set out detailed design parameters including mix, internal space standards, dual aspect ratios, floor to ceiling height, storage space, amenity space and car parking. All new housing developments that include apartments are required to demonstrate compliance with the Guidelines in accordance with the specific planning policy requirements. 6.3.8 Rural Housing Wicklow’s countryside hosts a variety of uses including rural communities, attractive towns and villages, agriculture, forestry, tourism, renewable energy, rural enterprise and scenic landscapes. The Planning Authority will continue to carefully manage demand for housing in the countryside in order to protect natural resources, continue to cater for a variety of land uses, protect the environment and rural landscape, to avoid urban generated rural housing and ensure the needs of those with a bona fide necessity to live in the rural area are facilitated. It is also important that the scale of rural housing permitted does not undermine the role of small towns and villages and threaten their viability. The NPF identifies the following national policy objective which the Development Plan must be consistent with: National Policy Objective 19 Ensure in providing for the development of rural housing, that a distinction is made between areas under urban influence, i.e. within the commuter catchment of cities and large towns and centres of employment, and elsewhere:  In rural areas under urban influence, facilitate the provision of single housing in the countryside based on the core consideration of demonstrable economic or social need to live in a rural area and siting and design criteria for rural housing in statutory guidelines and plans, having regard to the viability of smaller towns and rural settlements;  In rural areas elsewhere, facilitate the provision of single housing in the countryside based on siting and design criteria for rural housing in statutory guidelines and plans, having regard to the viability of smaller towns and rural settlements. The NPF states that it is important ‘to differentiate, on the one hand, between rural areas located within the commuter catchment of the five cities and our largest towns and centres of employment and, on the other hand, rural areas located outside these catchments’. Wicklow’s rural areas are considered to be ‘areas under urban influence’ due to their location within the catchment of Dublin, Bray, Greystones, Wicklow-Rathnew and Arklow in addition to Gorey (Co. Wexford) and Naas (Co. Kildare). In rural areas under urban influence it is necessary to demonstrate a functional economic or social requirement for housing need. This is also subject to siting and design considerations. Rural areas are more sensitive to development and therefore require a quality design response to help assimilate development into the landscape. All new rural housing is required to apply the design principles set out in the Wicklow Rural Housing Design Guide which is included in the appendices.
  6. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing 6.4 Housing Objectives General CPO 6.1 New housing development shall be required to locate on suitably zoned or designated land in settlements and will only be considered in the open countryside when it is for the provision of a rural dwelling for those with a demonstrable housing social or economic need to live in the open countryside. CPO 6.2 The sale of all developments of residential units, whether houses, duplexes or apartments, to commercial institutional investment bodies shall be prohibited. Design CPO 6.3 New housing development shall enhance and improve the residential amenity of any location, shall provide for the highest possible standard of living of occupants and in particular, shall not reduce to an unacceptable degree the level of amenity enjoyed by existing residents in the area. CPO 6.4 All new housing developments (including single and rural houses) shall achieve the highest quality of layout and design, in accordance with the standards set out in the Development and Design Standards (Appendix 1) and the Wicklow Single Rural House Design Guide (Appendix 2). CPO 6.5 To require that new development be of the highest quality design and layout and contributes to the development of a coherent urban form and attractive built environment in accordance with the following key principles of urban design:  Strengthening the character and urban fabric of the area;  Reinforcing local identity and sense of place;  Optimise the opportunities afforded by the historical and natural assets of a site / area;  Providing a coherent, legible and permeable urban structure;  Promoting an efficient use of land;  Improving and enhancing the public realm;  Conserving and respecting local heritage;  Providing ease of movement and resolving conflict between pedestrians/cyclists and traffic;  Promoting accessibility for all; and  Cognisance of the impact on climate change and the reduction targets for carbon emissions set out by the Government. CPO 6.6 To require that all planning applications for multi-unit residential development are accompanied by a Design Statement10. Design Statements shall include a detailed assessment of existing environment and historic character and demonstrate how the design has evolved in response to these underlying characteristics and fabric of the town / village. The Design Statement should address each of the 12 criteria set out in the Urban Design Manual (DECLG May 2009). The layout, access, road widths and open space should be cognisant of town and village character. CPO 6.7 The design and layout of new residential and mixed-use development shall deliver highly permeable, well connected streets which facilitate active street frontage in accordance with best practice set out in the Sustainable Residential Development in Urban Areas Guidelines for Planning Authorities (DEHLG May 2009) and the Design Manual Urban Roads and Streets (DTTS & DECLG 2013). 10 Design Statements may be required for additional formats of development the discretion of the Planning Authority
  7. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing CPO 6.8 Support the provision of lifetime adaptable homes that can accommodate the changing needs of a household over time and in particular to require that all new residential developments in excess of 20 residential units to provide a minimum 5% universally designed homes in accordance with the requirements of ‘Building for Everyone: A Universal Design Approach and the Universal Design Guidelines for Homes in Ireland (2015)11. Social and Affordable Housing CPO 6.9 To implement the provisions of the Wicklow Housing Strategy and in particular, to apply a 10% (or a greater percentage if provided for in future legislation) social housing requirement pursuant to Part V of the Planning and Development Act 2000 (as amended) to land zoned for residential use, or for a mixture of residential or other uses, except where the development would be exempted from this requirement. In certain circumstances, as set out in the Affordable Housing Act 2021, this requirement will be 20% devoted to social and affordable housing. CPO 6.10 To ensure the selection of lands or housing units to purchase or lease by the Council, including Part V, counteracts undue segregation by persons of different social backgrounds. CPO 6.11 To actively promote and support the development of affordable housing across all areas and settlement categories in the County, and in particular, to avail of and maximise take up of all and any future national affordable housing programmes and funds, including serviced site initiatives in smaller towns and villages. CPO 6.12 To provide and facilitate social housing in rural areas. Density CPO 6.13 To require that new residential development represents an efficient use of land and achieves the minimum densities as set out in Table 6.1 subject to the reasonable protection of existing residential amenities and the established character of existing settlements. In promoting higher densities and more compact development, new development should demonstrate compliance with:  the Sustainable Urban Housing Guidelines for Planning Authorities (DEHLG 2009) and accompanying Urban Design Manual – A Best Practice Guide;  Quality Housing for Sustainable Communities (DoEHLG 2007);  Design Standards for New Apartments Guidelines for Planning Authorities (2018)  Design manual for Urban Roads and Streets; and  any subsequent Ministerial guidelines. CPO 6.14 To densify existing built-up areas subject to the adequate protection of existing residential amenities. CPO 6.15 Higher density proposals should be designed to a high standard, incorporate a mix of housing types and sizes and deliver compact urban forms that enhance the local built environment and contribute towards a sustainable mix of housing options. Proposals should provide an appropriate design response to the site, be designed to a high quality and afford adequate protection for residential amenity of neighbouring properties. CPO 6.16 To encourage and facilitate high quality well-designed infill and brownfield development that is sensitive to context, enables consolidation of the built environment and enhances the streetscape. 11 National Disability Authority Centre for Excellence in Universal Design
  8. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing Where necessary, performance criteria should be prioritised provided that the layout achieves welldesigned high quality outcomes and public safety is not compromised and the environment is suitably protected. Height and Scale CPO 6.17 To facilitate development incorporating higher buildings (i.e. buildings that exceed the contextual prevailing height) where it has been adequately demonstrated that the development complies with the assessment criteria set out in Section 3.2 of the Urban Development and Building Heights Guidelines for Planning Authorities (DHPLG 2018) or any subsequent height guidelines. In accordance with the SPPR 3 of Urban Development and Building Heights Guidelines, where:  an applicant for planning permission sets out how a development proposal complies with the Urban Development and Building Heights Guidelines, particularly SSPR1 and SPPR2 thereof; and  the assessment of the planning authority concurs, taking account of the wider strategic and national policy parameters set out in the NPF and Guidelines; then the planning authority may approve such development, even where specific objectives of the relevant development plan or local area plan may indicate otherwise. In accordance with the SPPR 1 of Urban Development and Building Heights Guidelines, Planning Authorities are required explicitly identify areas where increased building height will be actively pursued for redevelopment, regeneration and infill development to secure the objectives of the NPF and RSES. In this regard, the identification of locations for increased building height shall be carried out in the preparation of Local Area Plans for settlements in Tiers 1-3 of the County Settlement Hierarchy as these are deemed the only settlements of sufficient scale and diversity in urban grain to accommodate such increases in height. CPO 6.18 To ensure that building height within future development makes a positive contribution to the built form of the area, is not obtrusive and does not adversely impact on the streetscape, local amenity or views. Require all development proposals, including infill development, to include an analysis of the impact of building height and positioning of buildings on:  The immediate & surrounding environment - streetscape, historic character;  Adjoining structures;  Open spaces and public realm;  Views and Vistas. Sequence / Phasing of Housing CPO 6.19 The development of zoned land should generally be phased in accordance with the sequential approach as set out in this chapter. The Council reserves the right to refuse permission for any development that is not consistent with these principles. CPO 6.20 Housing development shall be managed and phased to ensure that infrastructure is adequate or is being provided to match the needs of new residents. New significant residential or mixed use development proposals (of which residential development forms a component)12, shall be required to be accompanied by a Social Infrastructure Audit, to 12 Being defined as developments in excess of 50 units of housing in any settlements in Levels 1-4 in the hierarchy, 25 housing units in Levels 5-10, and all developments over 25 units in excess of 500m distance to a public transport service, as well as other format / sizes / locations are may be deemed necessary by the Local Authority.
  9. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing determine if social and community facilities in the area are sufficient to provide for the needs of the future residents. Where deficiencies are identified, proposals will be required to either rectify the deficiency, or suitably restrict or phase the development in accordance with the capacity of existing or planned services. New significant residential or mixed use development proposals shall be required to be accompanied by a ‘Accessibility Report’ that demonstrates that new residents / occupants / employees (including children and those with special mobility needs) will be able to safely access through means other than the private car: (a) local services including shops, schools, health care and recreational facilities, and (b) public transport services. Where deficiencies are identified, proposals will be required to either rectify the deficiency, or suitably restrict or phase the development in accordance with the capacity/quality of existing or planned linkages. Existing Residential Areas CPO 6.21 In areas zoned ‘Existing Residential’ house improvements, alterations and extensions and appropriate infill residential development in accordance with principles of good design and protection of existing residential amenity will normally be permitted (other than on lands permitted or designated as open space, see CPO 6.25 below). While new developments shall have regard to the protection of the residential and architectural amenities of houses in the immediate environs, alternative and contemporary designs shall be encouraged (including alternative materials, heights and building forms), to provide for visual diversity. CPO 6.22 In existing residential areas, small scale infill development shall generally be at a density that respects the established character of the area in which it is located, subject to the protection of the residential amenity of adjoining properties. However, on large sites or in areas where previously unserviced, low density housing becomes served by mains water services, consideration will be given to densities above the prevailing density, subject to adherence to normal siting and design criteria. CPO 6.23 To facilitate mews lane housing in suitable locations, subject to high quality design that respects the existing character and heritage of the area and provides for a high standard of residential amenity for existing and future occupants. CPO 6.24 To facilitate family / granny flat extensions for use by a member of the immediate family subject to protection of existing residential amenity and compliance with the criteria set out in the Development and Design Standards (Appendix 1). CPO 6.25 In existing residential areas, the areas of open space permitted, designated or dedicated solely to the use of the residents will normally be zoned ‘RE’ as they form an intrinsic part of the overall residential development. Such lands will be retained as open space for the use of residents and new housing or other non-community related uses will not normally be permitted. Protection of Residential Amenity in Transitional Areas CPO 6.26 While the zoning objectives indicate the different uses permitted in principle in each zone it is important to avoid abrupt transitions in scale and use at the boundary of adjoining land use zones. In these areas it is necessary to avoid developments that would be detrimental to amenity. In zones
  10. Wicklow County Development Plan 2022-2028 Chapter 6 | Housing abutting residential areas, particular attention will be paid to the use, scale, density and appearance of development proposals and to landscaping and screening proposals in order to protect the amenities of residential properties. Dwelling Mix / Sizes / Locations / Formats CPO 6.27 To require new multi-unit residential development to provide an appropriate mix of unit types and sizes to ensure that there is a range of unit types available to suit the needs of the various households in the county, in accordance with the Design Standards for new Apartments, Guidelines for Planning Authorities (2020). CPO 6.28 Apartments generally will only be permitted in settlements Levels 1 to 6 and in accordance with the location requirements set out in Section 2.4 of the Design Standards for New Apartments, Guidelines for Planning Authorities (2020). All apartment development should be served by high quality usable open space. CPO 6.29 Temporary residential structures (e.g. mobile homes, caravans, cabins, portacabins etc) form a haphazard and substandard form of residential accommodation and generally have poor aesthetic value and can detract from the overall appearance of an area. Therefore permission will generally not be granted for such structures. CPO 6.30 The maximum size of any single ‘housing estate’ shall be 200 units and developments that include more than 200 units should be broken into a number of smaller ‘estates’, which shall be differentiated from each other by the use of materially different design themes. CPO 6.31 To support the development of a programme for ‘new homes in small towns and villages’ to provide serviced sites with appropriate infrastructure to attract people to build their own homes and live in small towns and villages. The development of ‘serviced sites’, where site purchasers have the option of designing their own home, shall be particularly encouraged on zoned / designated housing land. CPO 6.32 To support independent living and facilitate the provision of supported housing (specific purpose built accommodation) for older people and people with disabilities towns and villages. To facilitate the provision of nursing homes, retirement villages, residential care facilities at appropriate locations in towns and villages in the County. These facilities must be well served by infrastructure and amenities including accessible footpaths, local shops and public transport in order to allow the residents to be socially included and to allow better care in the community, independence and access. CPO 6.33 To protect the existing housing stock to meet housing demand and require that any proposals for short-term letting13 provide a detailed justification for the proposed use and demonstrate to the satisfaction of the Planning Authority that any proposals don’t undermine the provision of housing and that there is a sufficient supply of rental properties available for longer-term rental in the area. The cumulative impact of applications will also be considered in the assessment of any application. Proposals that would increase pressures on the housing market including the rental market will not be considered favourably. CPO 6.34 Support the change of use of vacant commercial premises in town / village centres to residential purposes outside of the retail core areas as identified in Chapter 10, subject to CPO 10.9. 13 Short term letting is defined as the letting of a house or apartment, or part of a house or apartment, for any period not exceeding 14 days.

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