Consultation Draft (February 2017)

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Object

Consultation Draft (February 2017)

Policy SS1: Sustainable Development

Representation ID: 5407

Received: 07/04/2017

Respondent: PMW Property

Agent: Cerda Planning

Representation Summary:

Objections are lodged in respect of the principle and detail of Policy SS1. The approach taken is inconsistent with the NPPF and creates conflict as to whether the approach to sustainable development as set out within the NPPF should be applied to development proposals, or whether the approach to sustainable development as set out within the Emerging Plan should be applied to development proposals.
See attached.

Full text:

Objections are lodged in respect of the principle and detail of Policy SS1. The approach taken is inconsistent with the NPPF and creates conflict as to whether the approach to sustainable development as set out within the NPPF should be applied to development proposals, or whether the approach to sustainable development as set out within the Emerging Plan should be applied to development proposals.
The NPPF is clear that sustainable development is concerned with three dimensions; economic, social and environmental. The three roles to sustainable development should not be undertaken in isolation, because they are mutually dependent. Consequently, to achieve sustainable development, economic, social an environmental gains should be sought jointly and simultaneously through the planning system.
Policy SS1 seeks to capture all of the elements to sustainable development which flow through the NPPF between paragraphs 18 - 219 which the Framework makes clear constitutes the Government's view of what sustainable development in England means in practice. In seeking to incorporate all aspects of sustainable development in a single policy however, Policy SS1 is too brief to have any meaning.
It is to be noted that the NPPF does not contain any similar policy, but instead applies a presumption in favour of sustainable development which is set out at paragraph 14. It is considered that Policy SS1 should be amended to reflect the paragraph 14 provisions.
Notwithstanding this suggested revised approach to Policy SS1, as drafted there are a number of errors. For example, Criteria B seeks to promote previously developed land which reads as a sequential approach to development. This is in conflict with the Framework which sets out at Paragraph 17 that the approach should be to encourage reusing land that has been previously developed without favouring previously developed land over green field land. It is also noted at various points through Policy SS1 that there are requirements to protect environmental, built and heritage assets. The NPPF is not framed so as to protect acknowledged planning matters but instead is drafted in a more positive way so as to encourage, promote, manage, support and contribute to planning matters.
The re-drafting of Policy SS1 should reflect the approach set out within the NPPF.

Object

Consultation Draft (February 2017)

Policy SS2: Scale of Development

Representation ID: 5408

Received: 07/04/2017

Respondent: PMW Property

Agent: Cerda Planning

Representation Summary:

See attached

Full text:

Objections are lodged in respect of the quantum of new employment land being planned for, at 50 hectares.
Firstly, as the Emerging Plan makes clear at paragraph 2.16, the district has a low jobs density and there is a need to provide local employment opportunities close to where people live in order to reduce out commuting from the district.
To address this issue, the plan should do all it can to deliver economic growth, and as drafted Policy SS2 will likely be seen as a limit on the amount of employment land that can be brought forward. Instead, it should be seen as a minimum, and the target should be increased to provide maximum encouragement for all stakeholders to do all they can to deliver economic growth in the plan period.
Secondly, the district has traditionally relied on manufacturing and there is a need to diversify the local economy to create jobs in growth sectors such as advanced manufacturing, logistics and knowledge based sectors.
Maximising the provision of additional employment land will, in turn, maximise the potential for diversification and as such will deal with underlying economic issues prevalent across the district.
Thirdly, the 2013 Employment Land Update recommended that employment land provision for the district should be between 35 and 75 hectares. The NPPF is clear that development plans should meet full, objectively assessed needs including that for economic growth. With the evidence base underpinning the plan indicating that the plan should deliver 75 hectares of employment land, and an Emerging Plan intending to deliver only two thirds of this, it cannot be said that the Emerging Plan is meeting full objectively assessed needs.
Fourthly, and notwithstanding the above, the evidence base is in the process of being updated to take account of more recent data and is highly likely that the quantum of employment land to be planned for will increase once up to date evidence is prepared. For the plan to be found sound, it is important that the most up to date evidence base is relied upon for the purposes of plan policy preparation

Object

Consultation Draft (February 2017)

Policy SS3 : Spatial Strategy and the Distribution of Development

Representation ID: 5409

Received: 07/04/2017

Respondent: PMW Property

Agent: Cerda Planning

Representation Summary:

Object to approach.
The Emerging Plan seeks to deliver economic growth in only four location across what is an extensive rural district.
This has a number of flaws:
1. limited locations causes the plan to be inherently inflexible and sensitive to market change, viability issues.
2.the rate of delivery is limited. Spreading economic growth across a wider portfolio of sites, enables a larger economic market to be captured by the plan, with less infrastructure requirements and reduced lead-in times. 3.Focusing on four sites will increase commuting distances as not directed to locations where houses are proposed.

Full text:

Objections are lodged in respect the approach set out in Policy SS3.
For economic growth, this will be focused on primary employment areas identified within Policy WC2 and on four strategic sites.
It is important to note that Policy WC2 does not allocate new employment land; instead, Policy WC2 is concerned with protecting existing employment land.
Thus, it can be seen that despite the significant need for additional employment land, and despite the Emerging Plan recognising the need for more jobs and to deal with out migration, the Emerging Plan seeks to deliver economic growth in only four location across what is an extensive rural district.
The approach taken has a number of fundamental flaws.
Firstly, the delivery of employment land on such a limited number of locations causes the plan to be inherently inflexible. If it transpires through the plan period that one of the four locations is sensitive to market change, viability issues, or land owner issues, the result is a significant proportion of the economic growth required in the plan period will not be delivered. In such circumstances the plan does not have any alternative other than to cause economic growth to be reduced.
Secondly, the rate of delivery of economic growth will be limited by focusing employment on four strategic level sites. It will be far harder to bring employment land forward on sites which need significant infrastructure delivery before employment land can be brought forward. Furthermore, the market will determine the rate of delivery on any given site. Spreading economic growth across a wider portfolio of sites, of differing sizes and in differing locations, enables a larger economic market to be captured by the plan, less infrastructure requirements which reduces the lead-in time for delivering economic growth, and with a wider economic market being catered for the delivery of economic growth once infrastructure matters are addressed will be far quicker.
Thirdly, commuting as well as out commuting are key issues for the district. Focusing all of the economic growth on four sites will inevitably cause commuting distances to increase since economic growth is not being directed to locations where it is required, nor is economic growth being focused on areas where houses are located. If the Emerging Plan were to distribute economic growth across a wider range of sites, geographically split across the district, commuting distances would reduce since jobs and houses would be more closely related which is an inherently sustainable form of development and is an approach endorsed by the NPPF.
Consequently, the entire strategy for distributing economic growth should be re-visited since there are more appropriate alternatives available to the Council when compared with the chosen strategy.

Object

Consultation Draft (February 2017)

Policy SS9: North East Derbyshire Green Belt

Representation ID: 5410

Received: 07/04/2017

Respondent: PMW Property

Agent: Cerda Planning

Representation Summary:

See attached

Full text:

See attached

Object

Consultation Draft (February 2017)

Policy SS14: Development in the Countryside

Representation ID: 5411

Received: 07/04/2017

Respondent: PMW Property

Agent: Cerda Planning

Representation Summary:

See attached.

Full text:

See attached.

Comment

Consultation Draft (February 2017)

Provision & Protection of Employment Land to Accommodate Growth

Representation ID: 5566

Received: 07/04/2017

Respondent: PMW Property

Agent: Cerda Planning

Representation Summary:

See attached

Full text:

See attached

Object

Consultation Draft (February 2017)

Table 6.1 - Employment Land Availability

Representation ID: 5569

Received: 07/04/2017

Respondent: PMW Property

Agent: Cerda Planning

Representation Summary:

See attached

Full text:

See attached

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