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Joint Local Plan MM9 JOINT LOCAL PLAN SCHEDULE OF AND SUMMARY RESPONSE TO REPRESENTATIONS ON MAIN MODIFICATIONS December 2018 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) As set out in our letter of 5th January 2017, the essential transport infrastructure elements of the plan had been established in advance of the transport hearing sessions. Two matters were then discussed at the hearings which related to whether the plan, which was submitted in advance of the essential transport infrastructure elements being identified, makes effective provision for the timely delivery of the infrastructure as identified. Two questions were going to be considered further by the inspector: Firstly, whether a minor modification was necessary in order to provide suitable sign posting to the essential transport infrastructure elements of the plan and, Secondly, whether it was necessary or helpful to reinforce the Lisa Highways 42 1002528 General guidance contained within NPPF by including a minor modification to Policy Dev 31 to include "Planning permission will be granted only where the impact of development is not McCaffrey England considered to be severe’. Following the hearing HE subsequently wrote to the Programme officer at Plymouth, for the attention of the Inspector setting out the proposed wording, to ensure that the impact of growth set out in the Plan could be safely accommodated and without a severe operational impact on the SRN. It is noted that the minor modification proposed by HE has not been incorporated in to the Main Mods, are you able to confirm that the inspector has considered this point and has concluded that the modification is not necessary, hence why the proposed modification isn’t included? During the hearings I made representations on behalf of Stoke Gabriel Neighbourhood Plan in regard to housing policy for housing needs including enabling the use of exception sites for self-build, so I welcome the incorporation of TTV new on this issue. However, I have been unable to find any policy recognition of the ongoing water drainage and sewer overload General - issues in Stoke Gabriel, and note several other comments in regard to insufficiency of the sewer and storm drain network in several parts of South Hams. 243 1002903 Leaf Lovejoy Stoke Gabriel Please ensure that policy that prevents additional housing being constructed without addressing the capacity of local sewer networks to effectively both drain and treat combined sewer outflows, and to imporve local drainage structures. Greenspace Allocation - Miss Bethan Request to amend the Riverford boundary area from Strategic Greenspace, to Neighbourhood Greenspace, due to inaccurate and flawed information within Plymouth City Councils 162 1190532 Plym Valley Roberts own site assessments, submitted to the Planning Inspector in April 2018. Please see attached report. (Riverford) Jillings Heynes Diocese of MM1 – the change is noted but it still does not remove our objection made previously regarding this part of the Plan in respect of addressing the point whereby greenfield sites that 194 964187 MM01 Ed Heynes Planning Ltd Plymouth perform well in terms of meeting established sustainability criteria should not be discounted in terms of delivering development; Once this consultation has closed, can the following concerns be clearly addressed going forward.... When will the 'Final' JLP be published? As time goes by how will any new Mr Graham changes/attempts to change be managed and will they go through consultation? How will they be communicated? As time goes by, will all proposed developments that could have 239 1191222 MM01 Palmer impacts on the final, agreed JLP be subjected to the rigorous checks adopted by the JLP process? Such that the JLP does not become a theoretical exercise, where the idealogy applied is simply overtaken by uncontrolled, unchecked developments. MM1 Policy SPT1 (3i) MM1 in relation to Policy SPT1 (3i) proposes to re-cast the wording set out in the submission draft plan so as to provide that: “The effective use of land is made for development through optimising the reuse of previously developed sites, therefore reducing the need for green field development ...” (modifications underlined) Whilst this objective is laudable and is supported by Sutton Harbour Holdings, it risks being an empty expression of aspiration unless it is underpinned by concrete, practical provision to ensure its delivery. The nature of the problem is exemplified by the scale of under-utilised previously developed land within Plymouth City which is not promoted for re-development in this Plan, whilst extensive tracts of peripheral greenfield land, in the setting of a Grade 1 listed building and the Dartmoor National Park, with highly challenging topography, a poor relationship to existing services and facilities and inadequate (and potentially unfunded) road access at Woolwell are allocated for development. Mr Will Montagu Sutton Harbour 307 1095702 MM01 Edmonds Evans Holdings plc Accordingly, it is considered that the City Council’s proposed Main Modification 1 should be accompanied by the following companion/explanatory text: “Where previously developed land of significant scale (> 5 ha) is known to be available (or is likely to become available) for redevelopment and remains under-utilised in relation to its potential to deliver housing and other appropriate uses, the City Council will engage with the owners of such land and produce a Development Brief to ensure that redevelopment proposals come forward in accordance with the principles of sustainable development at the earliest possible opportunity during the Plan period.” Reason: To ensure that previously developed land is brought forward to meet the ongoing development needs of the City in a timely fashion; and to avoid the unnecessary release of increasingly remote and environmentally sensitive greenfield sites. Rockspring Mr Alistair Boyer 327 1191547 MM01 Barwood Please see attached letter. MacDonald Planning (Plymouth) Ltd 1 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) SUPPORT with strong reservations. No changes have been made to acknowledge that natural assets should be protected, conserved and enhanced for future generations in line with the concept of intern-generational equity as enunciated in UNGA's principles of sustainable development. Other suggested changes have not been resolved through the proposed modifications: To bring the policy in line with biodiversity policy through the use of the established term "net gains" in biodiversity not the ambiguous "overall gains". And to bring in Ms Victoria line with law and policy on the biodiversity through the use of "conservation" in addition to protection and enhancement To properly reflect the mitigation hierarchy of first to avoid, 364 1095125 MM01 Tanner- then mitigate, and as a last resort, compensate. "iii. Pollution and adverse environmental impacts of development are avoided, minimised and effectively mitigated where Tremaine unavoidable, and as a last resort compensated for;" To include landscape character as part of a sustainable environment. This is different from local distinctiveness "v . Local distinctiveness , landscape character and sense of place is respected, maintained and strengthened through high standards of design." These have not been addressed by the MM or the AM. Reference paragraph 3.17 Figure 3.2 and the new paragraph to follow 3.17. This whole paragraph brings in a new variation to the meaning of sustainability, without any definition and thus in effect negates any conclusion made from the assessment of the criteria in Figure 3.2. This seems to change a measurable policy to one that can never be used to assess any level Mr Mike of sustainability. Adding this new paragraph would mean planners and developers could virtually ignore sustainability as an issue. 22 1010886 MM02 Wynne- Powell I believe the new paragraph should be removed completely, as bringing in new sentences that have no legal meaning is pointless and counterproductive to achieving the purpose of the JLP and effectively makes table 3.2 irrelevant. Thurlestone Parish Council Policy SPT 2 Sustainable linked neighbourhoods and sustainable rural communities NEW PARA TO FOLLOW 3.17. We support the clarification that the LPAs will rely on neighbourhood 86 1002318 MM02 Sue Crowther and plans to support the delivery of sustainable development in the Sustainable Villages of the TTV Policy Area. One of the main legal requirements (Basic Conditions) of a neighbourhood Neighbourhood plan is to demonstrate that it contributes to the achievement of sustainable development. Plan Emery Wainhomes Mr John 208 893384 MM02 Planning (South West) M M 2 : Policy SPT2 narrative The proposed modifications reflect those agreed with the Council at the hearings, and are supported. Coxon Partnership Holdings Ltd. Ms Victoria 365 1095125 MM02 Tanner- SUPPORT. Tremaine MM3 – It would seem counter intuitive for a Local Plan to have a lower expectation of housing supply from ‘sustainable’ villages, where development is expected and planned than for windfall sites, where development is unplanned. We cannot understand why the assumed rate of windfall development over the time period 2017-2034 is significantly greater than the previous assumption over a slightly longer period of 2016-2034; the only conclusion can be that it is increased to allow the maths to add up and justify reductions elsewhere within the figures. The way in which the figures are framed provides an artificial suppression of delivery from a sustainable source of housing, i.e. the NPPF (para.7) sates that “the purpose of the planning system is to contribute to the achievement of sustainable development”, the JLP has identified certain settlements as ‘sustainable villages’, ergo development in these 6 1074071 MM03 Neal Jillings Place Land LLP locations is ‘sustainable development’ subject to detailed technical consideration. Clearly, the scale of development that is deemed sustainable will relate, to a degree, to the scale of the sustainable village to which it is attached.
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