Development Management Policies DPD

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.

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.