Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review

Object

Representation ID: 25719

Received: 12/03/2019

Respondent: AquiGen

Based on the over-allocation of land identified by the Evidence Base, we consider that the proposed allocations under the Local Plan require further review. This is to ensure the Local Plan is justified and consistent with the Evidence Base. If not, the Local Plan cannot be found sound. In order to achieve soundness, we recommend the proposed allocations are reviewed to reduce the amount of land that is allocated. We recommend that the amount of land identified for allocation in the Plan is reduced under Policy CS13 and the supporting paragraphs.

Object

Representation ID: 25720

Received: 12/03/2019

Respondent: AquiGen

As NPPF paragraph 120 relates to allocated land and recommends the use of the no reasonable prospect test, to ensure consistency with the NPPF, we recommend Policy DM32 is amended to allow the test to be applied to defined Employment Area land. This will ensure the Plan is consistent with national guidance and adequately flexible to deal with changing market signals and needs. This is particularly important given the surplus allocation position compared with need as identified in our assessment.

There is ambiguity regarding paragraphs 9.32.2 and 9.32.4 in relation to the "no reasonable prospect test" and employment area land.

Object

Representation ID: 25723

Received: 12/03/2019

Respondent: AquiGen

Welcome the introduction of marketing requirements generally but suggest amendments:
- Paragraph 2.1; agreement with the Council before marketing is carried out is unnecessary.
- Paragraph 2.5; providing names and contact details raises potential confidentiality issues. A simple schedule noting the origin of an enquiry and reason is sufficient.
- Paragraph 2.6; A commercial site is not generally marketed at a set value and to agree this with the Council is unprecedented and unreasonable.

Object

Representation ID: 25724

Received: 12/03/2019

Respondent: AquiGen

Note that the Council is preparing an update to the Retail and Commercial Leisure Study to inform the Regulation 19 plan consultation by Summer 2019. We intend to comment as necessary on this policy and the updated Retail Study at that time (if required).

Object

Representation ID: 25725

Received: 12/03/2019

Respondent: AquiGen

Recommend that Ravenswood District Centre is extended to include the Site 1 (Ip141a) frontage plot. The rationale includes:
- Geographical proximity to existing centre;
- Lidl require a new and larger store due to inadequate parking, limited store sales area and no opportunities to extend. The Site 1 plot can accommodate this.
- Lidl will seek to ensure the building avoids long term vacancy and is re-occupied as soon as possible.

We would welcome discussions with officers if the principle of this extension to the District Centre is acceptable.

Object

Representation ID: 25726

Received: 12/03/2019

Respondent: AquiGen

Object to criterion (a) which requires consideration of the appropriateness of scale when assessing out-of-centre retail proposals. The use of 'scale' is no longer recommended by national guidance and is therefore inconsistent with NPPF paragraphs 86 and 89 which only require an applicant to demonstrate compliance with the Sequential Approach and Impact. As identified at paragraph 89 b), scale forms part of the consideration of Impact. There is no requirement to demonstrate appropriateness of scale, separate from impact. A requirement to demonstrate scale has not been identified by the Evidence Base as a retail policy requirement. Remove criterion a.