Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

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Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

QUESTION 2: Do you agree that the optional water efficiency standard should be adopted and the proposed policy wording?

Representation ID: 23120

Received: 16/02/2017

Respondent: Town and Country Planning Solutions

Representation Summary:

The Plan is far too long and over-prescriptive and should not introduce any land use policy that duplicates the requirements or control achievable through the separate Building Regulations procedure. The requirement of a "letter of intent" is meaningless and will simply add unnecessarily to the planning application validation requirement. Draft Policy DRM1 (Water Efficiency) should be deleted as not reasonably necessary as it could not form the basis for refusing any planning application.

Full text:

The Plan is far too long and over-prescriptive and should not introduce any land use policy that duplicates the requirements or control achievable through the separate Building Regulations procedure. The requirement of a "letter of intent" is meaningless and will simply add unnecessarily to the planning application validation requirement. Draft Policy DRM1 (Water Efficiency) should be deleted as not reasonably necessary as it could not form the basis for refusing any planning application.

Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

QUESTION 8: Which option for the supply of affordable housing is most appropriate to ensure a sufficient supply of affordable homes without prejudicing the viability or deliverability of development?

Representation ID: 23121

Received: 16/02/2017

Respondent: Town and Country Planning Solutions

Representation Summary:

The Council should follow the National Planning Practice Guidance and adopt Option C. There is no special justification for Rother District to adopt more rigorous requirements as set out in Options A and B, which if introduced together with the additional financial development constraint imposed by CIL will stall much needed open market housing to add to the low level of existing supply in the District.

Full text:

The Council should follow the National Planning Practice Guidance and adopt Option C. There is no special justification for Rother District to adopt more rigorous requirements as set out in Options A and B, which if introduced together with the additional financial development constraint imposed by CIL will stall much needed open market housing to add to the low level of existing supply in the District.

Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

(b) Do you agree with the policy approaches to: adoption of the optional Building Regulations standards for accessible and adaptable housing? If not, what changes would you wish to see?

Representation ID: 23122

Received: 16/02/2017

Respondent: Town and Country Planning Solutions

Representation Summary:

The Building Act 1987 already provides "Access Standards" and so as not to unnecessarily constrict development no mandatory policy requirement should be imposed to require a higher standard.

Option D should be followed.

Full text:

The Government internal space standards already comprise a material planning consideration and so there is no need to also introduce a new Local Plan policy duplicating such standards so delete draft Policy DGH1 as not being reasonably necessary.

The Building Act 1987 already provides "Access Standards" and so as not to unnecessarily constrict development no mandatory policy requirement should be imposed to require a higher standard.

Option D should be followed.

Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

QUESTION 17: Do you agree with the policy approach to existing employment sites and the proposed policy wording?

Representation ID: 23123

Received: 16/02/2017

Respondent: Town and Country Planning Solutions

Representation Summary:

This part of the Policy should not be prescriptive. If a site is demonstrated as being non-viable, then it is important that effective use is made of such brownfield land. It should be open to the market to determine a viable alternative use, which can then be judged against other policies in terms of potential impact. The wording should therefore, be amended to provide greater flexibility for suitable and alternative uses.

Full text:

This part of the Policy should not be prescriptive. If a site is demonstrated as being non-viable, then it is important that effective use is made of such brownfield land. It should be open to the market to determine a viable alternative use, which can then be judged against other policies in terms of potential impact. The wording should therefore, be amended to provide greater flexibility for suitable and alternative uses.

Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

QUESTION 18: Do you agree with the policy approaches to maintaining landscape character and the High Weald AONB and to the respective proposed policy wordings?

Representation ID: 23124

Received: 16/02/2017

Respondent: Town and Country Planning Solutions

Representation Summary:

The term "major development" needs to be defined if the Policy is to be clearly understood.

Full text:

The term "major development" needs to be defined if the Policy is to be clearly understood.

Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

QUESTION 46: Do you agree with the recommendation regarding the Bexhill development boundary? If not, please explain how you wish the development boundary to be applied to this area?

Representation ID: 23125

Received: 16/02/2017

Respondent: Town and Country Planning Solutions

Representation Summary:

The development boundary should be amended to include assessed site BX50 (Appendix - page 370) as current planning application no. RR/2016/3206/P demonstrates that this land is suitable and achievable to accommodate approximately 30 additional dwellings. The site should theref0re, be the subject of a new site allocation policy.

Full text:

The development boundary should be amended to include assessed site BX50 (Appendix - page 370) as current planning application no. RR/2016/3206/P demonstrates that this land is suitable and achievable to accommodate approximately 30 additional dwellings. The site should theref0re, be the subject of a new site allocation policy.

Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

QUESTION 53: Do you agree with the requirements of Policy HAS5, including the boundary as defined in the Policies Map? If not, how would you wish to see it amended?

Representation ID: 23126

Received: 16/02/2017

Respondent: Town and Country Planning Solutions

Representation Summary:

The Combe Valley Countryside Park Policy allocation shown on Figure 65 (page 214) should be amended to exclude the former household waste site in Freshfields, as this land now has full planning permission (no. RR/784/CM - RR/2016/2901/CM) for a waste management use.

Full text:

The Combe Valley Countryside Park Policy allocation shown on Figure 65 (page 214) should be amended to exclude the former household waste site in Freshfields, as this land now has full planning permission (no. RR/784/CM - RR/2016/2901/CM) for a waste management use.

Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

QUESTION 12: Do you agree with the proposed policy approach to external residential areas and the proposed policy wording? If not, what changes would you wish to see?

Representation ID: 23127

Received: 16/02/2017

Respondent: Town and Country Planning Solutions

Representation Summary:

(i)
In some situations it might not be possible to provide a minimum 10m long rear garden length (although a suitable "side" garden area might be available). It would be better therefore, to express a minimum garden site in terms of its sq. m area.

(ii)
This part of the draft policy is unnecessary as it merely replicates Core Strategy Policy TR4.

Full text:

(i)
In some situations it might not be possible to provide a minimum 10m long rear garden length (although a suitable "side" garden area might be available). It would be better therefore, to express a minimum garden site in terms of its sq. m area.

(ii)
This part of the draft policy is unnecessary as it merely replicates Core Strategy Policy TR4.

Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

(a) Do you agree with the policy approaches to: adoption of the national internal space standard? If not, what changes would you wish to see?

Representation ID: 23867

Received: 16/02/2017

Respondent: Town and Country Planning Solutions

Representation Summary:

The Government internal space standards already comprise a material planning consideration and so there is no need to also introduce a new Local Plan policy duplicating such standards so delete draft Policy DGH1 as not being reasonably necessary.

Full text:

The Government internal space standards already comprise a material planning consideration and so there is no need to also introduce a new Local Plan policy duplicating such standards so delete draft Policy DGH1 as not being reasonably necessary.

The Building Act 1987 already provides "Access Standards" and so as not to unnecessarily constrict development no mandatory policy requirement should be imposed to require a higher standard.

Option D should be followed.

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