Regulation 19 - Proposed Draft Local Plan Submission

The policy should be amended to remove options 2f and 2g as these are not sustainable drainage options.

In Paragraph 2b "promote" should be replaced with "use".

Use of impermeable surfaces for paths, driveways and gardens should also be specified more directly.

This policy needs to be much stronger, given the flooding issues caused by unsustainable surface water drainage systems.
Paragraph 2f and 2g especially are NOT sustainable drainage systems for surface water and should not be options in this list. No new development should discharge surface water into a combined sewer, even as a last resort.

In Paragraph 2b "promote" should be replaced with "use", otherwise this is largely optional.

Use of impermeable surfaces for paths, driveways and gardens should also be specified more directly.

The policy should be amended to include requirements for on-site renewable energy generation (e.g. solar panels) and also optimum orientation (slope & aspect) and design of roof areas to increase solar energy generation potential.

This policy does not mention on-site renewable energy generation (e.g. solar panels) and also optimum orientation (slope & aspect) and design of roof areas to increase solar energy generation potential.

This should be installed at the time of build as this is most cost effective.

Remove the statement "If full mitigation cannot be provided, compensation will be required as a last resort to ensure there is no net-loss or a net gain of priority habitat and priority species" from the policy as this is not compatible with sustainable development.

This policy does not go far enough to ensure protection of biodiversity/geodiversity.

Paragraph 3 states "If full mitigation cannot be provided, compensation will be required as a last resort to ensure there is no net-loss or a net gain of priority habitat and priority species". However, priority habitats (e.g. mature woodland, hedging etc) by their definition cannot be readily replaced like-for-like elsewhere through compensation. This statement effectively provides a get-out for developers to pay a fee rather than properly mitigate these impacts. This is not compatible with sustainable development.

The policy needs to be amended to include requirements for new community facilities in larger developments.

The policy should also be amended to include leisure facilities specifically and that any proposals relating to those take into account the current builtd sports facility strategy.

Paragraph 2 should be reworded to state that diversification should not result in loss of a facility as per paragraph 3.

This policy does not cover any requirement for provision of new community facilities in large developments, including indoor leisure facilities. The policy should also mention leisure facilities specifically and state that any development proposals relating to leisure facilities must take into account the current built sports facilities strategy.

Paragraph 2 allows for diversification, but this should only be allowed where it has been demonstrated this does not cause the loss of a valued facility. For example, conversion of a sports hall to other use should not be permitted if it results in the loss of a facility that is still needed (as per the provisions in paragraph 3). This should be made clearer.

The policy should be amended to include a requirement for screening of equipment that is in or close to public spaces, include green space and grass verges.

The words "historic environment" should be replaced with "environment".

The policy should include a requirement for screening of equipment, especially in or close to public spaces.
Paragraph f should not be restricted to just the historic environment.

This "support" should also be backed up by including NHP groups (including Neighbourhood Forums) in future planning decisions following formulation of NHPs. This could be through a "community council" or other group that could help ensure that the policies and recommendations in NHPs are actually delivered upon, providing greater confidence in the process to those involved.

The council should also consider how it can better support NHP groups through expertise, resources, access to council facilities (e.g. meeting rooms) etc, as grant funding is limited and largely spent on consultants.

The proposed sites should be reconsidered or better provision for supporting infrastructure should be included. Proposed density levels should be reviewed to ensure that these are viable given the requirement for sustainable development.

Delivering the scale of development that is required within the timescale is likely not to be viable, given the resources available to HDC to effectively deal with development proposals and monitor compliance with the plan policies. HDC has struggled to do this up to now with the previous rate of development.

We also believe that the Local Plan as it stands is not viable due to the need to ensure sustainable development. There are currently many contradictions in the strategic policies (e.g. SA01 & SA03) that mean that development will not be sustainable or viable at the proposed density levels.