2 responses from Mr Keith Reed (Individual)
1. Mr Keith Reed (Individual) : 13 Nov 2017 11:25:00
Before completing this online representation please tick the box to show that you have read the guidance notes accompanying this consultation.
I have read the guidance notes
Appendices, maps or other
General comment / comment on procedure
1.1 Do you consider the AONB DPD to be legally compliant?
Yes
1.3 Do you consider the AONB DPD to be sound?
Yes
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible.
If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
I support the soundness of the AONB DPD because it reflects well the statutory purpose of the AONB in giving great weight to conserving landscape and natural beauty. in particular I support:
- the reasons for preparing the DPD set out in paragraph 1.25
- the interpretation of the NPPF in paragraph 1.3.6
- the objectives in paragraph 2.2.1
- Policy AS01 Development Strategy, especially that all development should be consistent with the primary purpose of the AONB and support the Special Qualities of the AONB as set out in the Management Plan
- Paragraphs 3.1.3 and 3.1.4 in stating that it is not necessary for the AONB DPD to identify a specific housing requirement
- Policy AS02 on Landscape, especially the references to rural nature, local distinctiveness, visual amenity, tranquillity, dark skies and the sense of space and place
- Policy AS06 on Key Settlement Landscapes relating to 'bringing the country into the settlements and reinforcing their rural character' (but consider that further locations around Silverdale could meet that definition)
- Policy AS08 on Design, in particular the references in paragraphs 4.5.3 to visual permeability and 4.5.23 to open areas forming an important part of Silverdale's character
- Policy AS12 on Water Quality, Sewerage and Sustainable Drainage, especially in relation to the need for evidence in areas not connected to mains drainage (but consider that this could contain a stronger presumption against development in such areas and not merely a statement of process as drafted)
- Policy AS16 in excluding any sites from Silverdale, not because of any objection in principle but because no sites were found to be appropriate in the light of the statutory purposes, especially supporting the exclusion of land at Whinney Fold on the basis that a combination of factors related to landscape impact, drainage, biodiversity (including impact on the Morecambe Bay designated site), and highways safety rule this site out.
2.1 If your representation is seeking a modification, do you wish to participate at the oral part of the Examination?
Yes, I wish to participate at the oral examination
2.2 If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
In order to express the views of residents concerned about the potential allocation of land at Whinney Fold, Silverdale from the point of view of both a resident and a qualified town planner with over 40 years' experience in local and strategic planning.
Please tick the box if you wish to be notified when the document is submitted, recommendations published and adopted.
Please notify me
2. Mr Keith Reed (Individual) : 13 Nov 2017 11:38:00
Before completing this online representation please tick the box to show that you have read the guidance notes accompanying this consultation.
I have read the guidance notes
Policy Reference
AS12 - Water quality, sewerage and sustainable drainage
If you have selected policy / site omission, please enter the site reference or location, or specify the policy area as appropriate.
The second paragraph of Policy AS12
1.3 Do you consider the AONB DPD to be sound?
Yes
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible.
If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
While supporting the plan as generally sound, I consider that Policy AS12, second paragraph, is a statement of process rather than policy and that it should be strengthened.
1.6 Please set out what modification(s) you consider necessary to resolve your objection and make the DPD legally compliant or sound, having regard to the matter(s) you have identified above. (Please note that any non-compliance with the Duty to Cooperate is incapable of modification at examination). You will need to say why this modification will make the DPD legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.
Policy AS12, second paragraph, should be amended to read as follows:
'In areas not connected to mains drainage, development proposals that will increase drainage discharges will only be approved if the condition and capacity of the existing infrastructure is adequate or if proposed sewerage treatment plant would not have an adverse impact on the environment or landscape.'
2.1 If your representation is seeking a modification, do you wish to participate at the oral part of the Examination?
Yes, I wish to participate at the oral examination
2.2 If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
As a local resident and town planner with over 40 years' experience I consider that this matter should be considered in relation to its impact on a potential site at Whinney Fold which may be subject to an omission objection from developers.
