Regulation 18 draft Local Plan
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Regulation 18 draft Local Plan
Policy CC8 - Renewable Energy
Representation ID: 6999
Received: 04/01/2024
Respondent: Stoke Dry Estate
Agent: Phillips Planning Services
The policies map proposes the inclusion of a new designation (yellow) which is said to define
“Areas potentially suitable for the development of wind turbines” which is then linked to Policy CC8.
We specifically highlight two sites that are larger areas which would be very visible from the reservoir and
also from Stoke Dry and the village of Caldecott located just to the east.
Whilst it is recognised that it may be helpful to include these designations to provide guidance to landowners and that the designation does not absolutely guarantee a future planning permission, once included on a policies map in this way it will be difficult to resist.
We therefore ask that the yellow areas highlighted in accompanying info are removed. This would not of course
preclude applications coming forward in these locations but would lessen what will otherwise be seen as a presumption in favour.
Comments noted. To be considered at the next more detailed stage of the Renewable Energy Study.
Object
Regulation 18 draft Local Plan
Policy SS4 – Infill and rounding off development in smaller villages and hamlets
Representation ID: 7004
Received: 04/01/2024
Respondent: Stoke Dry Estate
Agent: Phillips Planning Services
Stoke Dry is identified as being a location for ‘small scale redevelopment and infill opportunities only’.
Concern is raised regarding the inclusion of the ‘up to 5 dwellings’ restriction. The Policy includes a criteria which states that any proposal must reflect the existing scale
and density of the settlement which can be readily used to assist in the consideration of whether a proposal is too large or out of character.
Placing a 5 dwelling limit pre-judges site size, potential and relationship with the existing settlement. It may also hinder the redevelopment of previously developed sites which could accommodate a greater number and would not be viable at that level.
We suggest that this limit is removed so that site numbers are considered on their merits of the particular site and so ‘design led’. An alternative to the removal of the wording would be to include an additional sentence to note that this is a guide or stating point but higher numbers may be supported subject to appropriate justification to demonstrate why a particular site may accommodate more than 5.
A site size limit of maximum 5 dwellings is considered appropriate in these locations.
Object
Regulation 18 draft Local Plan
Policy SS9 – Non-residential development in the countryside
Representation ID: 7005
Received: 04/01/2024
Respondent: Stoke Dry Estate
Agent: Phillips Planning Services
Policy SS9 suggests that permission will only be granted where it is for one of ten purposes as listed.
The Policy wording should be amended to remove “only” from the first sentence. At present by including “only” the policy appears to be seeking to exclude consideration of any other development not specifically listed. By removing “only” the Policy would read more positively
Criterion (e) is supported in principle.
However, the criterion includes a requirement that it is demonstrated that there are no acceptable alternative sites within existing permitted or allocated sites or as part of the redevelopment of a commercial site. It is suggested that criterion (e) is amended as follows:
“(e) new employment growth comprising sustainable rural tourism, leisure, or rural enterprise that creates local employment opportunities and supports the local economy and communities and where no acceptable alternative can be identified within existing permitted or allocated sites, or within or through redevelopment of
existing commercial premises. Where a proposal is of a scale or nature that clearly requires a countryside location or is associated with or is required to service an
existing rural attraction it will not be necessary to undertake an alternative site assessment.
This change would also better align with criterion ii of Policy E4 ‘Rural Employment’
Criterion (h) - This wording is too restrictive and that the policy should lend support for other forms of farm diversification projects in addition to waste management. It
may also be considered contradictory when read in conjunction with Policy E5
We ask that the wording is changed as follows:
“h) farm diversification generally and also that which supports waste management development.”
Objection noted.
Policy SS1 established the housing and employment needs for the plan period. It states that the majority of this need will be met within the Planned Limits of Development (PLDs) and through site allocations within the plan. Policy SS9 (now SS8) only comes into effect where there is an essential need, which is in line with the NPPF (para 88 and 89) which outlines that in some cases there will need to be development in rural areas to account for community and employment need. SS9 (now SS8) ensures that the development proposed is based on and can demonstrate an essential need where the development is not attainable in an other suitable location within the PLD.
Support
Regulation 18 draft Local Plan
Policy E4 - Rural Economy
Representation ID: 7008
Received: 04/01/2024
Respondent: Stoke Dry Estate
Agent: Phillips Planning Services
The Estate supports the content of the Policy as setting out a reasonable approach to protecting rural areas whilst acknowledging that rural areas can accommodate some farm diversification and employment provision.
Support noted.
Support
Regulation 18 draft Local Plan
Policy E5 - Sustainable farm diversification
Representation ID: 7009
Received: 04/01/2024
Respondent: Stoke Dry Estate
Agent: Phillips Planning Services
The Estate supports the content of the Policy as setting out a reasonable approach to protecting rural areas whilst acknowledging that rural areas can accommodate some farm diversification and employment provision.
Support noted.
Object
Regulation 18 draft Local Plan
Policy E8 - Local Visitor Economy
Representation ID: 7010
Received: 04/01/2024
Respondent: Stoke Dry Estate
Agent: Phillips Planning Services
General support for Policy E8. However, concern is raised that it may be interpreted by Development Control Officers as precluding development away from towns and villages when as set out above many elements of the rural area are popular and draw tourism due to their scenic locations or include activities which require a rural location.
We suggest that the final paragraph of E8 is amended as follows:
“Sustainable rural tourism development of an appropriate scale and use which utilises the conversion of existing buildings and well-designed new buildings in the
countryside will also be supported where they are located adjacent to or closely related to the towns and villages which respect the setting and character of the location. Development that is further removed from existing towns and villages will be supported where the development is of a nature which requires a more rural location."
Noted. All development beyond the PLD is considered rural and therefore where developments are located adjacent to or closely related to towns and villages. These are considered the most sustainable locations, hence the need to focus developments to these locations, as set out in the policy.
Object
Regulation 18 draft Local Plan
Policy EN11 - Eyebrook Reservoir Area
Representation ID: 7011
Received: 04/01/2024
Respondent: Stoke Dry Estate
Agent: Phillips Planning Services
Whilst Policy E9 makes clear that it will be applied to “Caravans, Camping, Lodges, Log Cabins,
Chalets and other similar forms of self-serviced holiday accommodation” outside of the Eyebrook reservoir area,
Policy E11 ‘Eyebrook Reservoir’ clearly relates to the reservoir area but in terms of similar tourist accommodation it only states that “caravan and camping sites will not be permitted”.
It does not make reference to lodges, log cabins, chalets or other forms of self serviced holiday accommodation.
If the Policy is purposely drafted so as not to prevent other forms of accommodation the Estate fully agrees with this approach. The Estate considers that certain low key forms of accommodation, for example ‘tree houses’ and / or walkers bothy style accommodation, if well located and not visible from the shoreline should be supported within the Eyebrook area to service existing visitors and uses.
If the Council’s intent when referring to camping and caravan sites is that this should be applied to other forms of accommodation, for example tree houses, then the estate would object to this element of the policy and seek more flexibility to allow proposals to be considered on their own merits as part of well prepared planning applications.
Noted.