SD009 Summary of Reps to the Publication
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Summary of Representations to the Local Plan Part 2 Publication Regulation 22 (1) (c) (v) Statement June 2021 Page 1 of 28 Contents 1 Consultation Procedure for the Local Plan Part 2 Publication (Regulation 19) ................................................. 3 2 Overview of the Consultation Responses ........................................................................................................... 4 3 Summary of Issues Raised ................................................................................................................................... 5 Appendix A: Evidence of Regulation 19 Consultation ................................................................................................ 9 Appendix B: Schedule of Representations (presented in plan order) together with the Council’s response Bound Separately Appendix C: Schedule of Representations (presented in respondent order) together with the Council’s response ........................................................................................................................................................... Bound Separately Page 2 of 28 1 Consultation Procedure for the Local Plan Part 2 Publication (Regulation 19) 1.1 The purpose of this document is to fulfil Regulation 22 (1) (c) (v) of the Town and Country Planning (Local Development) (England) Regulations 2012, by providing a summary of the representations made pursuant to Regulation 20 (i.e. those made at the Publication stage). 1.2 This document does not detail those representations made at earlier Local Plan Part 2 consultation stages, which are set out in a separate Consultation Statement (December 2020). This was made available on the Council’s website at the Publication consultation stage. 1.3 Consultation on the Publication (Regulation 19) Local Plan ran for eight weeks from Friday 19th February to Friday 2nd April 2021. 1.4 The consultation documents (i.e. the Publication Local Plan Part 2, Sustainability Appraisal, Publication Policies Maps, Consultation Statement and Statement of Representations Procedure) and other supporting documents were made available in accordance with the Regulations and the Council’s adopted Statement of Community Involvement. Anyone wishing to respond was asked to state whether they considered the Plan to be legally compliant and sound. 1.5 Blackpool Council provided the opportunity for any organisations/individuals (including statutory bodies, key stakeholders and members of the public) to submit representations on the Publication and supporting documents by: Publishing the consultation documents, representation form, guidance notes on making representations and all supporting documents on the Council’s website (www.blackpool.gov.uk/localplanpart2) Notifying around 1200 bodies, groups and individuals on the Local Plan consultation database by letter or email (this includes specific and general consultation bodies as set out in the Regulations and individuals/organisations who had previously responded to earlier Local Plan Part 2 consultation stages); Displaying a public notice in the Blackpool Gazette. Publishing social media posts on Facebook and Twitter 1.6 Appendix A provides evidence of the Publication consultation including a list of statutory and general consultees notified, copies of the letter/email sent, public notice and the Local Plan Part 2 web page. Page 3 of 28 2 Overview of the Consultation Responses 2.1 The Council received 25 responses to the Local Plan Part 2 Publication from statutory (specific) consultees, general consultees, developers, agents and other individuals including residents and local businesses. These responses generated 85 issues in total on different aspects of the Local Plan Part 2 and supporting documents. 2.2 Section 3 of this document sets out summary tables which list those individuals/organisations that submitted responses to the (Regulation 20) consultation and summarise the representations made (presented in the same order as the Plan) together with the Council’s response. Some representations have resulted in the need to suggest minor modifications, which are set out in the separate Schedule of Proposed Minor Modifications document. Table 1: List of Respondents 1 Highways England 2 British Sign and Graphics Association 3 Lancashire Wildlife Trust 4 Blackpool and Fylde Rail Users Association 5 Marine Management Organisation 6 I Bagot 7 Theatres Trust 8 Historic England 9 United Utilities 10 Blackpool Civic Trust 11 Homes England 12 D Wane 13 Natural England 14 Lancashire County Council 15 Homebuilders Federation 16 Pavilion Trustees 17 Sport England 18 McDonalds Restaurants 19 Environment Agency 20 Fylde Council 21 Bourne Leisure 22 Ministry of Defence 23 Stay Blackpool 24 KFC 25 E & H Parkinson Page 4 of 28 3 Summary of Issues Raised 3.1 The following section sets out a summary table of the responses received by each individual/organisation (Table 2). Tables of the full representations grouped in Respondent Order along with the Council’s response are available at Appendix C. Tables of the representations grouped by Plan order along with the Council’s response are also available at Appendix B. Table 2: List of Individuals/Organisations who responded with an overview of their Representation(s) Respondent Overview of Representation(s) Considers transport evidence base need updating 001 Highways England Typographical error in IDP Update Policy DM22: Shopfronts - Raises concerns with policy and 002 British Sign and supporting text Graphics Assoc Policy DM24: Advertisements - Raises concerns with policy and supporting text 003 Lancashire Wildlife Amendments suggested to the Green Infrastructure Topic Paper Trust 004 Blackpool and Raises concerns regarding the wording in paragraph 3.1.21 of the Fylde Rail Users IDP Update Association 005 Marine Policy DM33: Coast and Foreshore - Suggests amendment to Management supporting text Organisation 006 I Bagot Supportive of the plan 007 Theatres Trust Policy DM37: Community Facilities - in support Sustainability Appraisal – disagrees with SA scoring in relation to Objective 14 cultural heritage for DM10, DM17, DM19, DM22, DM30 and HSA1.7 Site Allocation HSA1.7 – reference to Heritage Impact Assessment required in Schedule 1 Policy DM1: Design requirements for new build housing development – sound, subject to a minor amendment 008 Historic England Policy DM9: Blackpool Zoo - sound, subject to a minor amendment Policy DM10: Promenade and Seafront - not sound, amendments required Policy DM17: Design Principles - not sound, amendments required Policy DM19: Strategic Views - not sound Policy DM22: Shopfronts – not sound Policy DM26: Listed Buildings – sound Page 5 of 28 Policy DM27: Conservation Areas - sound, subject to a minor amendment Policy DM30: Archaeology – not sound General comments made Policy DM31: Surface Water Management – general support Policy DM21: Landscaping – general support 009 United Utilities Supports the addition of a separate policy that requires the use of design techniques like rainwater recycling, green roofs, water butts and permeable surfaces. Recognise the need to finalise a Marton Moss Neighbourhood Plan 010 Blackpool Civic General support of a number of policies Trust Raises concern over the proposed golf course leisure development and the impact on Victoria Hospital and Stanley Park designations. 011 Homes England No comments to make. Requests land at Avondale, Rough Heys Land to be included as a housing 012 D Wane allocation. Policy DM35: Biodiversity – suggests policy could be strengthened by including reference to providing measurable net biodiversity gains in perpetuity. No reference to Ancient Woodland and Veteran Trees. The policy needs to consider impacts on soils. Policy DM36: Controlling Pollution and Contamination – suggests 013 Natural England the policy could be strengthened by including reference to the protection of designated sites from air pollution impacts. Habitats Regulations Assessment – Issues raised regarding recreational disturbance, notably in relation to Site HSA1.11 Land off Kipling Drive 014 Lancashire County Policy HSA1: Housing Site Allocations – Notes sites HSA1.13 and HSA1.14 are Council close to known surface water flooding areas within LCC. Policy HSA1: Housing Site Allocations - The HBF does not consider that the Council has given sufficient consideration to the possibility that some sites may not come forward due to unforeseen circumstances and that this may apply to all types of sites. 015 Homebuilders Recommends that the plan allocates more sites than required to Federation meet the housing requirement Policy DM1: Design requirements for new build housing development - not considered to be sound as it is not justified or consistent with national policy particularly with respect to the requirement for minimum 20% of all new build dwellings to meet Page 6 of 28 the nationally described space standard (NDSS) and the M4(2) or M4(3) standards. Policy DM35: Biodiversity - not considered to be sound as it is not justified or consistent with national policy with respect to biodiversity net gain. Policy DM41: Transport Requirements for New Development – not sound with respect to requirement for EV charging points. Provided justification for Clifton Retail Park to be included as an allocation 016 Pavilion Trustees as a commercial centre. Playing Pitch Strategy - notes that whilst the evidence suggests that there is sufficient capacity to meet supply and demand, there is clearly