Development Management DPD Preferred Policy Options Document

Comment

Representation ID: 28318

Received: 27/02/2012

Respondent: Campaign to Protect Rural Essex

Dear Mr Scratton

Development Management DPD Preferred Policy Options Document Consultation

In my capacity as Chair of Southend District for Campaign for Protection of Rural Essex of which I am also a Trustee, I would take this opportunity to comment on the above document together with its Sustainability Appraisal :-

SUSTAINABILITY APPRAISAL
DM1 Design of New Developments
All proposed amendments are fully supported.
DM 2 Density of New developments
We have concerns that the flexible approach which is the preferred option on a site by site basis could result in increase in number of appeals, overdevelopment and/or setting of unacceptable precedent. In our view there should be either an upper limit or some more definitive guidance given on acceptable maximum levels of density.


DM 5 Light Pollution
This policy is welcomed and the proposed 1 no amendment is supported.

DM 9 Development on Edge of Conservation Areas
We have concerns that the term a 'balanced approach' lacks any proper definition. Risk here of adjacent developments creeping up too close to conservation areas and that the quality of those areas could be adversely affected.
DM 10 Existing Businesses in the Green Belt
We have concerns that the omission of a cap of 25% with decisions to be made on a case by case basis could be open to argument and a resultant increase in planning appeals. We would prefer to see some definitive guidance given. The other 2 no proposed amendments are supported.
DM 12 Conversion of Existing Agricultural Buildings in the Green Belt
We have concerns that decisions made solely on a case by case basis could lead to an increase in planning appeals. All 4 no proposed amendments are supported and in particular amendment no 1.
DM 16 Extensions to Dwellings in the Green Belt
The principle of a cap of 25% on increase in floor space is supported but always on condition that all 3 no proposed amendments are incorporated. Presumably the statistic relates to internal floor space?
DM 19 Basements in the Green Belt
The principle of a cap of 25% on increase in floor space is supported but always on condition that all 3 no proposed amendments are incorporated and in particular amendment no 3. Presumably the statistic should relate to internal floor space?
DM 20 The Replacement or Rebuild of Existing Dwellings in the Green Belt
It has been noted that policy on new build development is covered within Core Strategy where an indicative figure of 1% of the District Green Belt is cited which we would support.
Preferred option is supported as also is the proposed single amendment.
DM 21 Extension of Domestic Gardens in The Green Belt
Preferred option is supported as also is the proposed single amendment.

DM 24 Other Important Landscape Features
Preferred option is supported as also is the proposed single amendment.
DM 26 Traffic Management
Preferred option is supported as also is the proposed single amendment.
DEVELOPMENT MANAGEMENT PREFERRED POLICY OPTIONS DOCUMENT
Vision & Objectives
The vision and objectives are supported and in particular to 'prioritise re-development of brownfield sites for housing to minimise the release of Green Belt' and also to 'ensure the minimum amount of Green Belt is allocated to meet the districts housing and employment needs'
Generally
We do recognise that a minimum amount of green belt will need to be reallocated for appropriate alternative uses to meet the district's housing and employment needs.
However we would question whether the maximum target of 1% of District total as stated within the Core Strategy should be repeated here for the avoidance of any doubt in interpretation of the statement.
Our comments listed above under the DM sections of the Sustainability Appraisal will apply equally to the corresponding Draft Policy Statements provided within the DMD.

Yours sincerely,





RICHARD THOMSON (FRICS)
Chair of CPRE (Southend Branch)
CPRE (Essex County Branch)