Core Strategy Submission Document
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Core Strategy Submission Document
Vision
Representation ID: 16379
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Vision
By 2017 - the fourth bullet point states that strategically located and planned developments are predominately situated within areas least at risk from flooding
PPS25 advises that the key aim of managing risk would seek to only permit development in areas of flood risk when there are no reasonable available sites in areas of lower flood risk.
The sequential test should be used to demonstrate that the land developed is the lowest possible risk and the exception test should only be used when it has been demonstrated that there are no available sites available on sites in lower risk areas.
The Core Strategy advises that there are available sites in lower risk areas, therefore, this proposal would be contrary to PPS25.
Vision
By 2017 - the fourth bullet point states that strategically located and planned developments are predominately situated within areas least at risk from flooding
PPS25 advises that the key aim of managing risk would seek to only permit development in areas of flood risk when there are no reasonable available sites in areas of lower flood risk.
The sequential test should be used to demonstrate that the land developed is the lowest possible risk and the exception test should only be used when it has been demonstrated that there are no available sites available on sites in lower risk areas.
The Core Strategy advises that there are available sites in lower risk areas, therefore, this proposal would be contrary to PPS25.
Amend text of the second sentence of fourth bullet:
• '... These strategically located and planned developments are situated within areas least at risk from flooding.'
Support
Core Strategy Submission Document
Policy ENV1 - Protection and Enhancement of the Natural Landscape and Habitats and the Protection of Historical and Archaeological Sites
Representation ID: 16380
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
It is important that development is directed away from the sites of international, national and local nature conservations importance and support the implementation of the Crouch and Roach Management Plans.
It is important that development is directed away from the sites of international, national and local nature conservations importance and support the implementation of the Crouch and Roach Management Plans.
Object
Core Strategy Submission Document
8.22
Representation ID: 16381
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Support the application of the sequential test, which seeks to direct development to areas at least risk of flooding. The application of PPS25 exceptions test will only be applied when the sequential test has shown that there are no available locations for necessary development other than within areas of at risk of flooding.
However, do not support the statement that the majority of development necessary within the District can be accommodated within Flood Zone 1 (areas least at risk of flooding), although there may be exceptions involving previously developed land.
PPS25 does not caveat that the exceptions test can be overridden by previously developed land; flood risk needs to be considered along with other planning issues. Taking into consideration the aim to manage risk, the use of a previous developed site in an area subject to flood risk would put property and people at greater risk; particularly, when it would replace a less vulnerable use (employment), with a more vulnerable use (residential).
Support the application of the sequential test, which seeks to direct development to areas at least risk of flooding. The application of PPS25 exceptions test will only be applied when the sequential test has shown that there are no available locations for necessary development other than within areas of at risk of flooding.
However, do not support the statement that the majority of development necessary within the District can be accommodated within Flood Zone 1 (areas least at risk of flooding), although there may be exceptions involving previously developed land.
PPS25 does not caveat that the exceptions test can be overridden by previously developed land; flood risk needs to be considered along with other planning issues. Taking into consideration the aim to manage risk, the use of a previous developed site in an area subject to flood risk would put property and people at greater risk; particularly, when it would replace a less vulnerable use (employment), with a more vulnerable use (residential).
Amend text of third sentence of fourth paragraph of 'Appraising Risk':
'... As such, it is envisaged that the majority of new development necessary within the District can be accommodated within Flood Zone 1 (areas of least risk of flooding).'
Object
Core Strategy Submission Document
Policy ENV3 - Flood Risk
Representation ID: 16382
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Support the principal of directing development to areas least at risk of flooding. The application of PPS25 exceptions test should only be applied when the sequential test has shown that there are no available locations for necessary development other than within areas at risk of flooding.
Do not support the statement that previously developed land within Flood Zone 3 should be considered ahead of greenfield land that has a lower flood risk. PPS25 does not caveat that the exceptions test can be overridden by previously developed land; flood risk needs to be considered along with other planning issues. Taking into consideration the aim to manage risk, the use of a previous developed site in an area subject to flood risk would put property and people at greater risk; particularly, when it would replace a less vulnerable use (employment), with a more vulnerable use (residential).
Support the principal of directing development to areas least at risk of flooding. The application of PPS25 exceptions test should only be applied when the sequential test has shown that there are no available locations for necessary development other than within areas at risk of flooding.
Do not support the statement that previously developed land within Flood Zone 3 should be considered ahead of greenfield land that has a lower flood risk. PPS25 does not caveat that the exceptions test can be overridden by previously developed land; flood risk needs to be considered along with other planning issues. Taking into consideration the aim to manage risk, the use of a previous developed site in an area subject to flood risk would put property and people at greater risk; particularly, when it would replace a less vulnerable use (employment), with a more vulnerable use (residential).
Amend text of first paragraph of policy to:
'We seek to direct development away from areas at risk of flooding by applying the sequential test and, where appropriate, the exceptions test, as per PPS25. It is envisaged that the majority of development can be accommodated in areas at least risk of flooding (Zone 1).'
Support
Core Strategy Submission Document
Policy ENV7 - Small Scale Renewable Engergy Projects
Representation ID: 16383
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
Future developments should be designed to include (where appropriate) small scale renewable energy projects, as this will contribute to a more sustainable form of development.
Future developments should be designed to include (where appropriate) small scale renewable energy projects, as this will contribute to a more sustainable form of development.
Support
Core Strategy Submission Document
Policy ENV8 - On-Site Renewable and Low Carbon Energy Generation
Representation ID: 16384
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
Combined with the use of large and/or small scale renewable energy projects, this will assist in reducing carbon dioxide emissions from new residential developments.
Combined with the use of large and/or small scale renewable energy projects, this will assist in reducing carbon dioxide emissions from new residential developments.
Support
Core Strategy Submission Document
Policy CLT1 - Planning Obligations and Standard Charges
Representation ID: 16385
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
The use of planning obligations and standard charges for financial contributions towards the required off-site and strategic infrastructure is supported. The prompt and efficient use of financial contributions should be required.
The use of planning obligations and standard charges for financial contributions towards the required off-site and strategic infrastructure is supported. The prompt and efficient use of financial contributions should be required.
Support
Core Strategy Submission Document
Policy CLT3 - Secondary Education
Representation ID: 16386
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
In order to facilitate the addition residential units proposed for Ashingdon, it is important that King Edmund School can be expanded in order to accommodate the additional children generated by the new housing.
In order to facilitate the addition residential units proposed for Ashingdon, it is important that King Edmund School can be expanded in order to accommodate the additional children generated by the new housing.
Support
Core Strategy Submission Document
Policy T1 - Highways
Representation ID: 16387
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
Developments located in sustainable locations will assist in reducing the need to travel by private vehicles.
Developments located in sustainable locations will assist in reducing the need to travel by private vehicles.
Support
Core Strategy Submission Document
Policy T3 - Public Transport
Representation ID: 16388
Received: 22/10/2009
Respondent: Aber Ltd
Agent: Colliers International
Developments should be well related to public transport, and/or accessible by means other that the private car, in order to encourage the use of public transport, together with cycling and walking.
Developments should be well related to public transport, and/or accessible by means other that the private car, in order to encourage the use of public transport, together with cycling and walking.
