Comment

Representation ID: 387

Received: 02/10/2013

Respondent: JTS Partnership LLP

Whilst the objectives underlying this draft policy are to be welcomed, greater recognition needs to be given to the fact that the incorporation of sustainable construction and renewable energy technologies, within a scheme, can significantly increase the cost of new development and can, therefore, in certain instances, threaten viability. Greater flexibility needs to be built into the policy, with the third paragraph being reworded as follows:-
Where development viability is compromised by these standards, the developer/applicant will need to provide evidence as to why the targets cannot be met (either in their entirety or in part).

Support

Representation ID: 388

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS generally supports this policy, but considers that a number of amendments need to be made in order to ensure that it is NPPF compliant. See attachment.

Support

Representation ID: 389

Received: 02/10/2013

Respondent: JTS Partnership LLP

We consider that this policy should be reworded. Whilst no objection is raised, in principle, to any of the matters to which it relates, only larger development schemes will need to, and will be capable of, addressing all the matters set out therein. As currently drafted, the policy applies to "all new development‟, whether it is a strategic site or a small scale extension to an existing property.

Comment

Representation ID: 390

Received: 02/10/2013

Respondent: JTS Partnership LLP

We consider that further guidance should be set out in the supporting text, to the policy, describing how the Council will assess the provision of, or contributions required to, that necessary off-site infrastructure, which it will seek from new development, in advance of it adopting a CIL Charging Schedule. Currently, the
Council has no mechanism for doing this -or for assessing the impact of new development.

Comment

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.

Support

Representation ID: 394

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS generally supports this policy, although it notes that a number of the strategic employment sites do not necessarily meet all of the criteria set out therein.

Support

Representation ID: 395

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS generally supports this policy. however we consider that the Council has omitted a number of sites which are currently being used for employment purposes and that, accordingly, this part of the policy needs to be reviewed.
We fully support the Borough Council's decision to reallocate a number of existing employment sites for alternative development (such as the Wates Way Industrial Estate), where the proposed alternative use(s) make more efficient use of the land and helps satisfy the shortfall in housing land.

Support

Representation ID: 396

Received: 02/10/2013

Respondent: JTS Partnership LLP

We welcome the support for development related to small scale rural enterprises and which diversifies the range of economic activity both on farms and in the rural area generally.
There is, however, a concern that whilst the policy refers both to agricultural and other rural enterprises, the supporting text almost exclusively concerns the diversification of existing farms. The Council should explicitly recognise that there are many other types of enterprise (other than farms and agriculture) that benefit the rural economy (such as riding schools, livery stables, small scale visitor accommodation etc).

Object

Representation ID: 397

Received: 02/10/2013

Respondent: JTS Partnership LLP

The policy does not reflect the fundamental changes that are happening in this sector and the move towards online retailing and the reduction in demand for traditional retail units (which is being experienced nationwide). The proposal to allow no further loss of Class A1 retail units, within primary shopping frontages, and to also retain 60% of units in secondary frontages and shopping parades in Class A1 retail use, does not reflect the market, not justified in the supporting text (or evidence base). JTS objects to the policy and the lack of a Proposals Map identifying 'primary' and 'secondary' frontages.

Support

Representation ID: 398

Received: 02/10/2013

Respondent: JTS Partnership LLP

We generally support the objectives underlying this policy, but consider that it needs substantial amendment in order to bring it into line with relevant NPPF guidance.