Policy DM1: General Development Criteria
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 33
Received: 11/08/2013
Respondent: Mrs Ann Cardus
What is the strategy to ensure that sufficient effort is spent on the assessment of planning applications such that refusals are watertight and cannot be overturned by the Planning Inspector? Will the planning department be adequately staffed in the future?
What is the strategy to ensure that sufficient effort is spent on the assessment of planning applications such that refusals are watertight and cannot be overturned by the Planning Inspector? Will the planning department be adequately staffed in the future?
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 101
Received: 01/10/2013
Respondent: Woodland Trust
The Woodland Trust would like to see absolute protection for ancient woodland, as it is an irreplaceable habitat.
We would like to highlight the multiple benefits of trees and woodland (eg improved air quality, reduced noise pollution, reducing the heat island effect, flood amelioration and for recreation). We would wish to see mention of the importance of tree planting and woodland creation in new developments.
The Woodland Trust would like to see no loss of ancient woodland as a result of development. We would also like to see ancient woodland buffered from new development.
Ancient woods are irreplaceable. They are our richest terrestrial wildlife habitats, with complex ecological communities that have developed over centuries, and contain a high proportion of rare and threatened species, many of which are dependent on the particular conditions that this habitat affords. For this reason, ancient woods are reservoirs of biodiversity, but because the resource is limited and highly fragmented, they and their associated wildlife are particularly vulnerable.
Their long continuity and lack of disturbance means ancient woods are often also living history books, preserving archaeological features and evidence of past land use, from earthworks to charcoal pits. They are also places of great aesthetic appeal, making them attractive for recreation and the many benefits this can bring in terms of health and well being.
With only 2.4% of the land area in Great Britain, it is essential that no more of this finite resource is lost. This means that ancient woodland must be protected absolutely from permanent clearance, but also that it must be protected from damaging effects of adjacent and nearby land-use that could threaten the integrity of the habitat and survival of its special characteristics.
It is not possible to replace ancient woodland by planting a new site, or attempting translocation. Every ancient wood is a unique habitat that has evolved over centuries, with a complex interdependency of geology, soils, hydrology, flora and fauna.
We are pleased to see that you expect biodiversity to be incorporated in and around developments. We would also like to note that trees are particularly important for new developments, as they deliver on so many levels:
These include for both landscape and biodiversity (helping habitats become more robust to adapt to climate change, buffering and extending fragmented ancient woodland), for quality of life and climate change (amenity & recreation, public health, flood amelioration, urban cooling) and for the local economy (timber and woodfuel markets).
Therefore we would like to see mention of the importance of tree planting for new developments.
The Independent Panel on Forestry says:
"Ensure woodland creation, tree planting and maintenance is part of the green space plan for new commercial and housing development'
It also recommends:
'Government to commit to an ambition to sustainably increase England's woodland cover from 10% to 15% by 2060, working with other landowners to create a more wooded landscape'.
The panel report emphasises the value of local authorities setting woodland creation targets:
"New Local Plans are the opportunity for communities to have more tree cover in their local area. More local authorities could follow the example of Sefton Borough who are increasing their tree cover, and the Greater London Authority who have a target to increase tree cover from 20% today, to 25% by 2025, and a further 5% by 2050.
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 271
Received: 01/10/2013
Respondent: Essex County Council
Essex County Council welcomes Criteria c. Essex County Council will seek to consider these impacts, in line with policies contained in the Development Management Policies, February 2011. Essex County Council would seek to ensure that the forthcoming highway modelling will assist in meeting this criteria and issues outlined in paragraph 4.5 concerning highway capacity and safety. Reference should also be made to construction traffic.
Essex County Council seek an additional criteria should be included whereby:
'All new development must mitigate its impact on local services and community infrastructure'.
See attached
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 330
Received: 02/10/2013
Respondent: Mr Richard Lunnon
Agent: JTS Partnership LLP
As currently worded this policy is unacceptable in that it states planning permission will be refused where a proposal has any adverse impact on visual amenity, the charcter and appearance of surrounding area, highway conditions and highways safety, health and environmental amenity. The policy needs to be amended to reflect this as per submission, as all development has some impact on all of the above.
See Atteched
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 393
Received: 02/10/2013
Respondent: JTS Partnership LLP
As currently worded, this policy is unacceptable in that it states that planning permission will be refused where a proposal has any adverse impact on matters such as visual amenity, the character or appearance of the surrounding area, highway conditions or highway safety, health, environment or amenity etc.
There are very few forms of development that do not have some adverse impact, whatever benefits they may bring, on some interest of acknowledged planning importance. The policy needs to be reworded to reflect this and the phrase „no significant unacceptable impact‟ needs to be added to each of the criteria.
see attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 437
Received: 02/10/2013
Respondent: Joy Fook Restaurant
Agent: JTS Partnership LLP
As currently worded, this policy is unacceptable in that it states that planning permission will be refused where a proposal has any adverse impact on matters such as visual amenity, the character or appearance of the surrounding area, highway conditions or highway safety, health, environment or amenity etc.
There are very few forms of development that do not have some form of adverse impact, whatever benefits they may bring, on some interest of acknowledged planning importance. This needs to be reworded as per attachment.
See Attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 464
Received: 02/10/2013
Respondent: Sans Souci Enterprises Limited
Agent: JTS Partnership LLP
As currently worded, this policy is unacceptable. It states that planning permission will be refused where a proposal has any adverse impact on matters such as visual amenity, the character or appearance of the surrounding area, highway conditions or highway safety, health, environment or amenity etc.
By definition, very few forms of development do not have an adverse impact. The policy needs to be reworded to reflect this and the phrase "no significant unacceptable impact‟ (or similar words to that effect) needs to be added to each of the criteria.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 530
Received: 02/10/2013
Respondent: Ursuline Sisters
Agent: JTS Partnership LLP
The Sisters object to the wording of DM1(a) which will likely have the effect of precluding almost all forms of new development. Very few forms of development will have "no adverse effect on visual amenity, the character or appearance of the surrounding locality" and it is incumbent on the Council, in seeking to achieve good planning, that all impacts of new development, whether positive or negative, are weighed against each other to reach a balanced decision.
Please amend as per attached.
See Attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 566
Received: 02/10/2013
Respondent: Hansteen Holdings Plc
Agent: McGough Planning Consultants
Hansteen support this policy.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 714
Received: 02/10/2013
Respondent: CLM Ltd
Agent: JTS Partnership LLP
As currently worded, this policy is unacceptable in that, on a literal interpretation, any development proposal that has an adverse impact on matters such as visual amenity, the character or appearance of the surrounding area, highway conditions or highway safety, health, environment or amenity etc. would have to be refused planning permission. There are very few forms of development that do not have some form of adverse impact. The policy needs to be reworded to reflect this and the words 'no significant unacceptable impact' (or similar words to that effect) need to be added to each of the criteria.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 821
Received: 02/10/2013
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
Criteria (f) refers to biodiversity. In our view, the wording of criteria (f) is too general and the reference to "around developments" is too vague. Whilst measures to incorporate biodiversity within development sites should be encouraged, the ability to deliver biodiversity opportunities on land outside of the application site boundary or allocated site boundary may prove difficult and ultimately affect the delivery of the site. Therefore the wording of criteria (f) of Policy DM1 should be changed and the reference to "around developments" deleted.
See attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 864
Received: 26/09/2013
Respondent: Environment Agency
We consider this policy would benefit from the addition of the text set out in italics below:
i. Result in no increase in flood risk on site or off site.
This policy seeks to cover general development criteria. We consider it important that flood risk is included to ensure that this policy is consistent with paragraphs 99 and 100 of the National Planning Policy Framework and that it can be considered 'sound'.
See attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 919
Received: 01/10/2013
Respondent: Crest Nicholson
Agent: Savills UK
This policy is generally considered appropriate. It should be noted that housing need should be considered as an exceptional circumstance where the need for development outweighs harm caused by other factors. This approach accords with the NPPF (paragraph 187) in looking for solutions, rather than problems regarding development options.
See attached
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 980
Received: 16/09/2013
Respondent: Campaign for the Protection of Rural England (CPRE) Brentwood Branch
Page 75 after paragraph H states: "In exceptional circumstances, where the Council considers the need for development outweighs any harm caused, the Council will require suitable compensation measures, either on-site or off-site"
We believe this policy should be modified to show that in addition, actual compensation should be paid to immediate neighbours who experience a loss of amenity or actual home value reduction, in the event the Council grant planning permission in these circumstances
See attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1111
Received: 02/10/2013
Respondent: Childerditch Properties
Agent: Strutt & Parker LLP
An extension of 1.96 hectares to Childerditch Industrial Park will satisfy the criteria of policy DM1
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1548
Received: 01/10/2013
Respondent: D. Lessons
The village is characterised by larger plots, the majority backing onto open fields, creating natural habitats for birds and wildlife. We object as
a. Such a large development on the edge of the village, and on Metropolitan Green Belt, will result in the loss of open countryside, and the villages rural character
b. The beautiful aspect to the Thames, from the hill in the "area of natural beauty" (Thorndon Park), will be lost forever due to an increase in the number of visitors to the park, creating damage through overuse, and ultimately destroying the "natural beauty" of the park.
See attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1892
Received: 02/10/2013
Respondent: Crest Nicholson
Agent: Savills UK
This policy is generally considered appropriate. It should be noted that housing need should be considered as an exceptional circumstance where the need for development outweighs harm caused by other factors. This approach accords with the NPPF (paragraph 187) in looking for solutions, rather than problems regarding development options.
See Attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1900
Received: 24/10/2013
Respondent: Historic England
While we welcome part g), it should read 'great weight will be given' to reflect para 132 of the NPPF appropriately. We suggest that this sentence should be extended at the end to include 'or enhancement'.
See attached