Object
Proposed Submission Development and Site Allocations (DaSA) Local Plan
Representation ID: 24318
Received: 06/12/2018
Respondent: Town and Country Planning Solutions
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Paragraph 6.11 states that "Valued landscapes... clearly include AONBs and their settings". Case law confirms however, that such designated landscapes do not necessarily amount to "valued landscapes" having regard to Paragraph 170 of the NPPF (2018) and its previous incarnation in Paragraph 109 of the 2012 version. The HWAONB washes over 82% of the District and some parts will have more important or special characteristics that make them 'valued landscapes' compared to other parts of the AONB. Paragraph 6.11 should therefore, be amended to delete this reference to valued landscapes.
Paragraph 6.11 also refers to the scale of development with the AONB, and draft Policy DEN2 states that development should be "small-scale", but provides no further definition as to what might be regarded as small-scale or considered large scale. This is important given that the AONB designation washes over major settlements such as Battle, which might well be capable of accommodating large scale development without harming the AONB. The Policy should therefore, either be amended to delete the words "small-scale" or alternatively, this should be clearly defined.
Paragraph 6.11 states that "Valued landscapes... clearly include AONBs and their settings". Case law confirms however, that such designated landscapes do not necessarily amount to "valued landscapes" having regard to Paragraph 170 of the NPPF (2018) and its previous incarnation in Paragraph 109 of the 2012 version. The HWAONB washes over 82% of the District and some parts will have more important or special characteristics that make them 'valued landscapes' compared to other parts of the AONB. Paragraph 6.11 should therefore, be amended to delete this reference to valued landscapes.
Paragraph 6.11 also refers to the scale of development with the AONB, and draft Policy DEN2 states that development should be "small-scale", but provides no further definition as to what might be regarded as small-scale or considered large scale. This is important given that the AONB designation washes over major settlements such as Battle, which might well be capable of accommodating large scale development without harming the AONB. The Policy should therefore, either be amended to delete the words "small-scale" or alternatively, this should be clearly defined.