Development Management Policies DPD

We agree that the character of a locality is a relevant consideration in the formulation of development proposals. We disagree that it is always necessary to "reflect" the character or identity of an existing area in new development schemes. This is particularly the case for major development proposals, where it is possible to create new character areas and distinctive architectural styles, but even smaller scale development or infill proposals can successfully adopt new approaches. In some cases of course, the identity of the existing built environment may not necessarily warrant repetition.

We agree therefore with the comment in the third paragraph that developments should "consider" the identity of the surrounding area, but not that they should necessarily "reflect" it. Incidentally, there is a degree of repetition between the 1st and 3rd paragraphs in relation to this matter, and the word "reflect" should be deleted from both in our submission, or perhaps for the sake of conciseness the first paragraph should be deleted.

In terms of the list of items in the second paragraph, we do not disagree that these are relevant issues. Obviously different types of application will require different considerations, and not all of the factors will apply in every case.

On a matter of detail, we note the reference in the third paragraph to the effective running of the Council's recycling scheme. We agree that recycling is an important design consideration, and clearly the Council has a major role to play in the overall cycle by collection. There are of course many alternative approaches to recycling, and practices will change over the lifetime of the Plan. It is important that the application of the Policy does not lead to overly prescriptive solutions.

We support the efficient use of land, and the principle that the Council is seeking to achieve in this policy. There is a degree of repetition in the policy between the first and second paragraphs, with the second paragraph citing "immediate context" as an important factors, and the first paragraph listing a range of items that in effect make up the "immediate context". The policy could perhaps be simplified as follows:

"Proposals for residential development must optimise the capacity of the site in a manner that is compatible with the immediate site context (including use, intensity, scale and character), on-site constraints, the type of development proposed and any particular design objectives, and the need to provide an appropriate mix of dwellings to meet the community's needs"

We do not disagree with the need for new housing to provide accommodation that is well planned and suitable for modern living. We do disagree however that it is the purpose of the planning system to dictate what that is. Accommodation needs have changed markedly over time, and will continue to change in the future.

A more appropriate approach would be to retain the first part of Policy DM4, but to produce Supplementary Guidance (which can be amended and updated more quickly) if the Council wish to include specific floor sizes.

It is important to ensure that the information required with any particular planning application is proportionate and relevant to the application being submitted. It is impractical as part of a major development scheme, and particularly one made in outline, to submit detailed lighting information. Unless there are significant lighting issues that need to be determined as part of the application itself, it should normally be sufficient to deal with lighting details by condition, and for major schemes to be accompanied by a lighting strategy rather than detailed lighting schemes.

Countryside Properties have addressed the matter of the Green Belt boundary in separate representations to the Core Strategy and Site Allocations DPD. Paragraph 2.8 of PPG 2 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

The reference to ensuring that the "minimum amount of Green Belt is allocated" completely ignores the requirement in PPG2 to set a long-term, permanent Green Belt boundary that will not need to be altered at the end of the Plan period.

Countryside Properties have addressed the matter of realistic and achievable BREEAM/CSH objectives in their representations to the Core Strategy. Any amendments to the Core Strategy arising from the Inspector's findings on these matters should be reflected in a revised Vision.

The second sentence of this policy seems to imply that all of the features that follow are necessarily of importance for fauna or flora, which of course will not always be the case e.g. not all hedgerows or ponds are necessarily always of material nature conservation interest. If the intention of the policy is to protect these features where they are of nature conservation importance, then to avoid ambiguity the sentence should state ... "The Council will protect the following landscape features from loss or damage where they are of importance for fauna and flora, when considering proposals:"

There is potentially a contradiction between the first and the second paragraphs, with the first paragraph appearing to state a categorical position on protection from loss or damage, and the second paragraph (correctly in our view) noting that an exception will exist where there is appropriate mitigation. To aid clarity, it may in fact be easiest to delete the second sentence in the first paragraph entirely, and place the list of features after the second paragraph.

We support the provision of appropriate car parking in new development. There may however be other instances where flexibility on the minimum standard is appropriate (for example as part of a major development scheme where there is a comprehensive package of non-car travel proposals alongside complimentary parking restraint measures). This would ensure consistency with DM26 which includes demand management measures as part of traffic management in new development.

We suggest that the wording in brackets be amended as follows:

"... although this may be relaxed in residential areas near town centres and train stations, or as part of a package of travel plan measures on major development sites ..."

Whilst it may be likely that there will be a predominance of B1 and B2 uses on new employment sites, it is important that in a changing economic climate, this policy should not be used to frustrate or limit job creation via an overly restrictive approach. Indeed, a restrictive approach is very much contrary to the stated employment Vision, which include for example that:

"a new employment park in the west of the District ... has been developed which caters for a range of employment types in a flexible manner that adapts to changes in the economy."

It is also unclear what the policy means when it refers to a "predominance" of B1 and B2 uses, and we are concerned that this phrasing opens up a wide range of interpretation.

In addition, to make new commercial sites attractive to occupiers, experience shows that flexibility of business use is required, and that at least an element of B8 space is necessary for many occupiers. If there are specific sites where B8 (or indeed potentially B2) uses are not suitable, this can be specified in the Site Allocations DPD.

We suggest that the policy should be more positively worded to promote employment uses, whilst still maintaining a focus on the 'B' uses, as follows:

"Within new and existing employment land, development in Classes B1, B2 and B8 will be supported. Alternative uses will be considered having regard to ...."

This alternative wording still makes clear that B1 and B2 uses are favoured uses, but avoids problems of interpretation, and still makes it possible for other employment generating uses to come forward that comply with the criteria listed.