28 - DM29 Provision of New Open Spaces, Sport and Recreation Facilities
Object
Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications
Representation ID: 24269
Received: 20/11/2015
Respondent: Home Builders Federation Ltd (HBF)
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The part of the policy in relation to residential development is unjustified. The policy requires that developments of 15 dwellings or more provide at least 10% of the area, or 15% in higher density schemes, as public green space. In view of the Council's inability to meet its OAN in full, and because there is no plan to provide for these unmet needs elsewhere, we consider that this policy requirement is unjustified.
See attached.
Support
Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications
Representation ID: 24275
Received: 19/11/2015
Respondent: Sport England
Sport England supports the modifications made to this policy which now include the need to provide for indoor as well as outdoor sports facilities where justified. The policy supporting text also makes reference to the emerging Playing Pitch Strategy and Sports Facilities Strategy as key documents that will help to inform policy/decision making as well as identify priorities for enhancing off-site facilities if on-site provision is not a reasonable option. Sport England welcomes the reference to these up to date and robust evidence bases.
See attached.
Object
Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications
Representation ID: 24316
Received: 21/12/2015
Respondent: Mr Matt Clarke
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The modified policy appears to require contributions towards both on-site and off-site open space and facilities regardless of local circumstances. This could result in an over provision at a local level, which may unnecessarily reduce land available for other uses - particularly at a time when there is a need to significantly boost the housing land supply. It is also unclear how viability will be factored into the process. The NPPF paragraph 174 requires that the cumulative impact of standards and policies should not put implementation of the plan at serious risk, and should facilitate development throughout the economic cycle.
See attachment
Object
Core Strategy and Policies DPD Review - Pre-Submission of Main Modifications
Representation ID: 24327
Received: 21/12/2015
Respondent: Mr Arwel Owen
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The provisions of DM29 are not supported by a clear evidence base which should be made available in its entirety to allow the basis for the standards to be understood.
See attachments