DM12 Conversion of Existing Agricultural Buildings in the Green Belt - Preferred Option

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Comment

Development Management Policies DPD

Representation ID: 17920

Received: 13/04/2010

Respondent: Natural England

Representation Summary:

Natural England is generally supportive of Policy DM12. However, in addition to considering effects of additional generated traffic on the highway network, the council may wish to consider the possible effects on the capacity of other infrastructure, especially sewerage and power supply. Increased numbers of persons living or working at rural locations may exceed the capacity of existing sewage treatment systems, thus resulting in pollution or a need for upgrading. Increased power demands may require upgrading of local transformers and supply cables. Such upgrades may themselves have significant landscape or ecological impacts.

Full text:

Natural England is generally supportive of Policy DM12. However, in addition to considering effects of additional generated traffic on the highway network, the council may wish to consider the possible effects on the capacity of other infrastructure, especially sewerage and power supply. Increased numbers of persons living or working at rural locations may exceed the capacity of existing sewage treatment systems, thus resulting in pollution or a need for upgrading. Increased power demands may require upgrading of local transformers and supply cables. Such upgrades may themselves have significant landscape or ecological impacts.

Comment

Development Management Policies DPD

Representation ID: 17999

Received: 14/04/2010

Respondent: Mr Paul Sealey

Representation Summary:

Whilst I recognise that changes in height may be necessary, there needs to be some way of controlling such changes. Indeed I would suggest adding a general proviso to the list that "the proposed change will not be to the detriment of the wider local landscape". In this way a change which would affect peoples enjoyment of a particular vista could be controlled whereas a change without such a backdrop would be allowed. The key aspect is the impact on the wider landscape rather than the building itself.

Full text:

Whilst I recognise that changes in height may be necessary, there needs to be some way of controlling such changes. Indeed I would suggest adding a general proviso to the list that "the proposed change will not be to the detriment of the wider local landscape". In this way a change which would affect peoples enjoyment of a particular vista could be controlled whereas a change without such a backdrop would be allowed. The key aspect is the impact on the wider landscape rather than the building itself.

Comment

Development Management Policies DPD

Representation ID: 25536

Received: 04/05/2010

Respondent: Go-East

Representation Summary:

Reference - Page 35
Policy DM12. You might consider whether there is a relationship with Policy DM7 Local List.

Full text:

Thank you for sending the Discussion and Consultation Documents to Government Office.

In summary, we think the draft documents are thorough and detailed. My comments relate mainly to the Development Management Document, as I anticipate that local stakeholders and those with thematic expertise and site-specific knowledge, are better positioned to comment on the Allocations Document.

In terms of the Development Management Document, it is well-written, accessible and easy to understand. It relates well to the emerging Core Strategy. Preferred options are identified, and alternatives are demonstrated to have been considered. You have asserted the emerging DPD has been subject to sustainability appraisal. As you amend the draft and develop a clear way forward, you might use the text to confirm that it has also been tested against the Habitats Regulations Assessment. The January 2010 HRA Report is available on your website.

Detailed comments on paragraphs and proposed policies are appended to this letter. I have observed that you are developing a 'house style' for making vision statements. Each thematic section is supported by a detailed Vision Statement, drawn from the Core Strategy that describes policy objectives up to 2025. The 'Vision' subsection on page 3 is, perhaps, a recital of a corporate mission statement.

Please contact me if you would like to discuss anything contained in this letter or on any aspect of your work with the Local Development Framework.

Reference - Page 3
You have confirmed sustainability appraisal and listed the assessments in your evidence base (pages 6 - 8). You might confirm the DPD has been tested against Habitats Regulations.

Reference - Page 22
Character of Place - Local List. You might consider that an economic use of an historic building might best secure its long-term care and maintenance.

Reference - Page 32
Policy DM10 (i). You might reconsider replacing the term "valuable" agricultural land with 'best and most versatile' and include a clear link to Para.28 of PPS7 Sustainable Development in Rural Areas.

Reference - Page 35
Policy DM12. You might consider whether there is a relationship with Poilcy DM7 Local List.

Reference - Page 43
You might include a reference to Annex A of PPS7 Sustainable Development in Rural Areas when describing the functional and viability tests for determining applications for agricultural dwellings.

Reference - Page 44
You have recognised the national policy requirement for dwellings to be commensurate with functional requirements. You might explain how you derived the figure of 175 square meters.

Reference - Page 53
Your commitment to direct development away from areas of flood risk is welcome. National policy directs development to sites of lowest probability of flooding. You might take advice from the Environment Agency whether your proposed construction of policy (especially inclusion of "as far as practicable") is in conformity with PPS25.

Comment

Development Management Policies DPD

Representation ID: 26033

Received: 06/05/2010

Respondent: Rochford Chamber of Trade

Representation Summary:

DM12 Conversion of Existing Agricultural Buildings in the Green Belt
Whilst you refer to PPS4 and PPG2, current policy seems to ignore PPG7. Policy PPG7 does not rule out the conversion of agricultural premises for business or residential use. Therefore, to encourage skills and growth in the rural economy, we support a less restrictive approach as above. We see this as being potentially good for the local economy both in terms of new business and providing local work for construction and building supplies.

With regard to listed buildings, each case should be judged on its merits.

Full text:

The Green Belt and Countryside

DM10 Existing Businesses in the Green Belt
We support the preferred option

DM11 Rural Diversification
We support the preferred option

DM12 Conversion of Existing Agricultural Buildings in the Green Belt
Whilst you refer to PPS4 and PPG2, current policy seems to ignore PPG7. Policy PPG7 does not rule out the conversion of agricultural premises for business or residential use. Therefore, to encourage skills and growth in the rural economy, we support a less restrictive approach as above. We see this as being potentially good for the local economy both in terms of new business and providing local work for construction and building supplies.

With regard to listed buildings, each case should be judged on its merits.

Tourism Opportunities in the Green Belt

DM13 Green Tourism

Your paragraph which states "appropriate locations should not result in agglomeration of similar facilities" could result in uneconomically viable and restricted businesses. If the authority is serious about encouraging Green Tourism, it must let the market decide. As an example, Southend Sea Front is known for Hotels and B&B accommodation. This grouping ensures its economic viability. Restrictive policy constrains it.

This policy should be less restrictive

Transport

DM25 Parking Standards
In order to attract and keep business in the district, we should relax the maximum car parking standards for key trip destinations. By enforcing this restriction we are directing shoppers out of the district. Example: Fossetts Way, TESCOS, Rayleigh Weir and Lakeside. The public will go where there is car parking. This policy is driving out business development to neighborouring districts, increases car use and congestion.

On page 57 there is mention of the RDC Transport Strategy Supplementary Planning Document. This document has not been issued as a consultation or in draft form. What is the timetable for this?

Economic Development

DM26 Traffic Management
There is no policy to support the increase in traffic generated by the proposed, planned developments. Example: Coombes Farm, Airport Expansion, West Rochford, Ashingdon Road, Christmas Tree Farm and Stambridge Mills. We should at least have a contingency plan in the event of gridlock.

DM27 Employment Land
This appears to be yet another restriction, driving people out of the area for retail activity. (See DM25 above.)

Cases should be judged according to their merits.

Retail & Town Centres

DM29 Town Centre Shopping Frontages
The 75% rule (Guidance) for retail outlets in town centres should be enforced.

The authority should not be in the business of micro managing the market. Shoppers like choice, any vibrant, retail centre will provide choice which is often clustered.

DM30 Upper Floor Locations in Town Centres
Agree preferred option

DM31 Village & Neighbourhood Shops
We agree that "retail use is important to ensure the vitality and vibrancy of any shopping frontage and to meet the needs of local communities".

DM32 Advertisements and
DM33 Advertisements affecting Conservation Areas and Listed Buildings
The authority need to have effective guidelines rather than the subjective judgements which are not user friendly and singularly unhelpful.

Comment

Development Management Policies DPD

Representation ID: 26047

Received: 28/04/2010

Respondent: Go-East

Representation Summary:

Page 35 - Policy DM12. You might consider whether there is a relationship with Policy DM7 Local List.

Full text:

Thank you for sending the Discussion and Consultation Documents to Government Office.

In summary, we think the draft documents are thorough and detailed. My comments relate mainly to the Development Management Document, as I anticipate that local stakeholders and those with thematic expertise and site-specific knowledge, are better positioned to comment on the Allocations Document.

In terms of the Development Management Document, it is well-written, accessible and easy to understand. It relates well to the emerging Core Strategy. Preferred options are identified, and alternatives are demonstrated to have been considered. You have asserted the emerging DPD has been subject to sustainability appraisal. As you amend the draft and develop a clear way forward, you might use the text to confirm that it has also been tested against the Habitats Regulations Assessment. The January 2010 HRA Report is available on your website.

Detailed comments on paragraphs and proposed policies are appended to this letter. I have observed that you are developing a 'house style' for making vision statements. Each thematic section is supported by a detailed Vision Statement, drawn from the Core Strategy that describes policy objectives up to 2025. The 'Vision' subsection on page 3 is, perhaps, a recital of a corporate mission statement.

Please contact me if you would like to discuss anything contained in this letter or on any aspect of your work with the Local Development Framework.

Page 3 - You have confirmed sustainability appraisal and listed the assessments in your evidence base (pages 6-8). You might confirm the DPD has been tested against Habitats Regulations.

Page 22 - Character of Place - Local List. You might consider that an economic use of an historic building might best secure its long-term care and maintenance.

Page 32 - Policy DM10 (i). You might reconsider replacing the term 'valuable' agricultural land with 'best and most versatile' and include a clear link to Para.28 of PPS7 Sustainable Development in Rural Areas.

Page 35 - Policy DM12. You might consider whether there is a relationship with Policy DM7 Local List.

Page 43 - You might include a reference to Annex A of PPS7 Sustainable Development in Rural Areas when describing the functional and viability tests for determining applications for agricultural dwellings.

Page 44 - You have recognised the national policy requirement for dwellings to be commensurate with functional requirements. You might explain how you derived the figure of 175square meters.

Page 53 - Your commitment to direct development away from areas of flood risk is welcome. National policy directs development to sites of lowest probability of flooding. You might take advice from the Environment Agency whether your proposed construction of policy (especially inclusion of 'as far as practicable') is in conformity with PPS25.