Support

Representation ID: 399

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS generally supports this policy, which is consistent with some of the categories of development identified in paragraph 89 of the NPPF as potentially being appropriate in the Green Belt. We consider that the policy introduces, in accordance with NPPF guidance, a degree of flexibility and will allow genuine in-fill plots, which, although currently located in the Green Belt, in practice, serve no Green Belt function, to be brought forward for development. However, we are of the view that there are many more 'relevant frontages', than are currently listed in the policy, to which it should apply.

Object

Representation ID: 402

Received: 02/10/2013

Respondent: JTS Partnership LLP

This policy needs to be substantially reviewed so that it accords with NPPF guidance and is therefore unsound. Paragraph 89 of the NPPF makes it clear that the following classes of development may be appropriate in the Green Belt:- the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building.

The way that the policy is currently worded, suggests the Council will only grant permission for residential extensions in the Green Belt in 'very special circumstances'.

Object

Representation ID: 403

Received: 02/10/2013

Respondent: JTS Partnership LLP

This policy needs to be substantially reviewed as it is inconsistent with NPPF guidance and, accordingly, is unsound.

Object

Representation ID: 405

Received: 02/10/2013

Respondent: JTS Partnership LLP

This policy must be reviewed in order to ensure that it is consistent with NPPF guidance (paragraph 90). The only tests set out in the NPPF, in relation to the reuse of existing buildings in the Green Belt, are that:- the proposal should preserve openness; and that, the building should be of permanent and substantial construction. All other criteria should be omitted from the policy for the matters covered are either out with NPPF guidance or are dealt with by other policies in the plan (i.e. Policy DM1).

Object

Representation ID: 406

Received: 02/10/2013

Respondent: JTS Partnership LLP

This policy should be reworded so that it more closely coincides with Policy DM17 in that the opening paragraph should read as follows:
Development will not be permitted where it would have a detrimental effect on, or result in the loss of, significant landscape heritage or a feature of ecological importance, including trees, woodlands or hedgerows, unless it can be demonstrated that the justification for the development outweighs the harm caused.

Object

Representation ID: 407

Received: 02/10/2013

Respondent: JTS Partnership LLP

This policy needs to be reviewed in light of the guidance set out in the NPPF (paragraphs 126 to 141). In particular, the final paragraph of the policy needs to be reworded for, as it is currently set out, it implies that change of use of listed buildings will only be permitted in certain circumstances. This does not accord with
NPPF policy, which indicates that changes of use should only be refused if harm is caused to the heritage value of the asset.

Object

Representation ID: 408

Received: 02/10/2013

Respondent: JTS Partnership LLP

This policy needs to be amended in order to clarify what the Council requires when it refers to, in paragraph 2, a 'full archaeological assessment'. Consistent with NPPF guidance, it is normally only necessary to provide a Phase 1 Archaeological Assessment, in respect of most sites that are considered to be of
archaeological interest. It is only in respect of the most important sites (i.e. scheduled ancient monuments) that a more detailed study, including intrusive investigations, should be required prior to an application being submitted.

Support

Representation ID: 409

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS takes no issue with the sites identified for residential development in this policy but considers that the Council needs to identify additional land.

Support

Representation ID: 412

Received: 02/10/2013

Respondent: JTS Partnership LLP

Whilst we recognise the need to provide affordable housing within the Borough, we welcome the Council's understanding that such provision can potentially impact upon the viability of a scheme. Accordingly, JTS welcomes, and supports, the final paragraph of the policy.
We also consider that the policy should not seek any affordable housing provision on sites of less than 15 units. On smaller sites (14 units and below) it is often physically, or logistically, difficult, or financial disadvantageous, to include affordable housing on site. These problems become more acute, the smaller the site gets.

Support

Representation ID: 413

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS generally supports this policy and welcomes the flexibility set out in the second paragraph.