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Draft Local Plan
Policy 10.1: Sustainable Transport
Representation ID: 15682
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
Policy 10.1 seeks developer contributions for improvements to links from new development to key destinations and the wider network.
Reference should be made to the NPPF (para 204) and the tests of planning obligation to ensure that the Policy is 'Consistent with national policy'.
See attached.
Object
Draft Local Plan
Water Conservation
Representation ID: 15683
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
It is noted within this paragraph that the Code for Sustainable Housing has been withdrawn, however water conservation measures are sought. As per the Written Ministerial Statement in Section 6.0, Local Plans should not set any additional local technical standards or requirements relating to the performance of new dwellings. This requirement should therefore be removed to be 'Consistent with national policy'.
See attached.
Comment
Draft Local Plan
Policy 10.6: High Quality Design Principles
Representation ID: 15684
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
It is considered that requirements contained within Policy 10.6 are sought to be addressed elsewhere in the DLP, and therefore can be removed for this Policy wording. Notably:
- Part (g) - Policy 9.5 addresses designated heritage assets
- Part (n) - Policy 10.4 considers the quality and design of new developments; and
- Part (p) - Policy 10.3 concerns sustainable construction and energy requirements.
See attached.
Object
Draft Local Plan
Policy 10.8: Open Space in New Development
Representation ID: 15685
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
The supporting paragraph (para 10.45) to the DLP states that BBC will seek at least 15% of a development site to be set aside for public open space. However, no justification or relationship to evidence work is provided in relation to this and therefore is required before the Policy can be deemed to be 'Justified'
See attached.
Object
Draft Local Plan
Policy 10.11: Air Quality
Representation ID: 15686
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
Policy 10.11 states that BBC will expect development proposals to "reduce" sources of air pollution.
NPPF (para 204) requires planning obligations to be necessary to make the development acceptable, directly related to the development, and fair and reasonable in scale and kind. It is therefore considered beyond the remit of a planning application, for air pollution to sought to be reduced. Development proposals should mitigate against its own adverse development impact only. The Policy as currently worded is therefore not considered 'Justified'.
See attached.
Object
Draft Local Plan
Policy 10.15: Contaminated Land and Hazardous Substances
Representation ID: 15687
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
A number of DLP policies set out specific requirements for planning applications, for example Policy 7.2, Policy 10.1, Policy 10.3, Policy 10.13 and Policy 10.15.
LPAs are required to publish a list of information requirements for planning application, proportionate to the nature and scale of the development proposals and reviewed on a frequent basis. National policy notes that local information requirements have no bearing on whether a planning application is valid unless they are set out on such a list. Such requirements should not therefore be included within policies.
See attached.
Object
Draft Local Plan
Policy 10.13: Flood Risk
Representation ID: 15688
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
A number of DLP policies set out specific requirements for planning applications, for example Policy 7.2, Policy 10.1, Policy 10.3, Policy 10.13 and Policy 10.15.
LPAs are required to publish a list of information requirements for planning application, proportionate to the nature and scale of the development proposals and reviewed on a frequent basis. National policy notes that local information requirements have no bearing on whether a planning application is valid unless they are set out on such a list. Such requirements should not therefore be included within policies.
See attached.
Object
Draft Local Plan
Policy 10.3: Sustainable Construction and Energy
Representation ID: 15689
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
A number of DLP policies set out specific requirements for planning applications, for example Policy 7.2, Policy 10.1, Policy 10.3, Policy 10.13 and Policy 10.15.
LPAs are required to publish a list of information requirements for planning application, proportionate to the nature and scale of the development proposals and reviewed on a frequent basis. National policy notes that local information requirements have no bearing on whether a planning application is valid unless they are set out on such a list. Such requirements should not therefore be included within policies.
See attached.
Object
Draft Local Plan
Policy 10.1: Sustainable Transport
Representation ID: 15690
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
A number of DLP policies set out specific requirements for planning applications, for example Policy 7.2, Policy 10.1, Policy 10.3, Policy 10.13 and Policy 10.15.
LPAs are required to publish a list of information requirements for planning application, proportionate to the nature and scale of the development proposals and reviewed on a frequent basis. National policy notes that local information requirements have no bearing on whether a planning application is valid unless they are set out on such a list. Such requirements should not therefore be included within policies.
See attached.
Object
Draft Local Plan
Policy 7.2: Housing Type, Mix, Size and Tenures
Representation ID: 15691
Received: 05/05/2016
Respondent: Croudace Strategic Ltd
Agent: Barton Willmore
A number of DLP policies set out specific requirements for planning applications, for example Policy 7.2, Policy 10.1, Policy 10.3, Policy 10.13 and Policy 10.15.
LPAs are required to publish a list of information requirements for planning application, proportionate to the nature and scale of the development proposals and reviewed on a frequent basis. National policy notes that local information requirements have no bearing on whether a planning application is valid unless they are set out on such a list. Such requirements should not therefore be included within policies.
See attached.