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Comment

Draft Local Plan

Policy 9.10: Established Areas of Development in the Green Belt

Representation ID: 15442

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

Paragraph 89 is very clear in regard to the development of infill plots and considers that limited infilling in villages is appropriate development. The relevant frontages set out above are not defined areas of a village. The Council do not have a justified case to "continue to resist strong(ly) pressure to allow new development".

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Object

Draft Local Plan

Policy 9.11: Previously Developed Land in Green Belt

Representation ID: 15443

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

NPPF provides that "the limited infilling or the partial or complete redevelopment of previously developed sites, whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development" can be appropriate development in the Green Belt. Where the draft policy is generally consistent with this guidance it needs to introduce warranted and justified additional criteria (particularly relating to 'sustainability').

Policy is contradictory to the Brownfield Register, which is currently progressing through the House of Lords, and the intentions of the Government to ensure that 90% of brownfield land is redeveloped for housing by 2020.

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Object

Draft Local Plan

Policy 9.12: Site Allocations in Green Belt

Representation ID: 15445

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

The Green Belt boundary should be established on a strong defensible line. Drawing the boundary across the middle of fields or gardens is totally unsatisfactory and even field boundaries may not be sufficiently permanent to form a reliable long-term boundary. Green Belt boundary should exclude existing residential development (except, where acknowledged, the Green Belt 'washes over' an entire village) and this exclusion must extend to the whole of the residential curtilage. The Council should be de-allocating smaller sites.

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Draft Local Plan

Policy 9.14: Re-use and Residential Conversion of Rural Buildings

Representation ID: 15447

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

The principle of this policy is supported. However, in regard to the conversion to residential, the criteria requiring evidence to business or alternative uses is not supported.
- Reference is made to Paragraph 90 of the NPPF, which states that "the re-use of building provided that the buildings are of permanent and substantial construction" is appropriate development. It does not set out the criteria as stated within Policy 9.14 and as such, is considered inconsistent with the NPPF and unsound.
- Recent changes to PD for the change of use from agricultural to residential sets out the Government's intentions in regard to the re-use of such buildings. In addition, the Government has introduced temporary PD rights for the conversion of light industrial to residential. Given the need for housing within the Borough, this policy appears heavily restrictive and not in the best interests or Government intentions.

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