Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
SP2: Settlement HierarchyIn
Representation ID: 2334
Received: 23/04/2024
Respondent: Claypole Parish Council
The Parish Council considers that Policy SP2 of the Local Plan Review is unsound, and it fails to meet the test of soundness relating to the tests of ‘positively prepared’, ‘justified’ and ‘effective’ as set out in paragraph 35 of the National Planning Policy Framework (NPPF) December 2023.
The Parish Council considers that the proposed amendment to escalate Claypole from a ‘small village’ to a ‘larger village’ in the settlement hierarchy is not based on cogent or substantive evidence.
In support of its position the Parish Council has had regard to the following matters:
• Findings of the Inspector on the current Local Plan settlement hierarchy and the original methodology;
• Lack of any evidence base changes
• Community engagement and relationship to the Neighbourhood Plan
• The relevance of the cross-boundary relationship to Newark
• Incorrect scoring for Claypole
• The methodology for determining the settlement hierarchy is fundamentally flawed and incomplete
• The geographic isolation of Claypole from the remainder of South Kesteven and the role and function of Claypole as a settlement
Our full rationale underpinning our position is set out in the attached technical paper produced by the planning consultant who has supported the Parish Council on the Neighbourhood Plan and other planning matters over many years.
Object
Regulation 18 Draft Local Plan
EN5: Water Environment and Flood Risk Management
Representation ID: 2335
Received: 23/04/2024
Respondent: Claypole Parish Council
The Parish Council considers that Policy EN5 of the Local Plan Review is unsound, and it fails to meet the test of soundness relating to the tests of ‘justified’, ‘effective’ and ‘consistent with national policy’.
This policy as currently written is inconsistent with national policy set out in the NPPF and Planning Practice Guidance in relation to when a Flood Risk Assessment is required and in relation to when the Sequential and Exception Tests apply.
As a Parish, Claypole has flood risk present from fluvial (river) and surface water sources. The River Witham presents fluvial flood risk to the western side of the Parish including the Claypole Bridge area. The wider Parish and the main village have significant areas at risk of surface water flooding, including much of the eastern end of the village. This risk of surface water flooding is particularly important given the nature of the underlying clay, as such it is imperative that the Local Plan approach towards flood risk reflects national policy fully. Our full concerns are explained in the attached technical paper.
Object
Regulation 18 Draft Local Plan
EN6: The Historic Environment
Representation ID: 2336
Received: 23/04/2024
Respondent: Claypole Parish Council
The Parish Council considers that Policy EN6 of the Local Plan Review is unsound, and it fails to meet the test of soundness relating to the tests of ‘justified’, ‘effective’ and ‘consistent with national policy’ as set out in paragraph 35 of the NPPF.
This policy as currently written is inconsistent with national policy set out in the NPPF and Planning Practice Guidance in relation to non-designated heritage assets. The Claypole Neighbourhood Plan identifies non-designated heritage assets which are an important part of the village built form. Our full explanation is set out in the attached technical paper.
Object
Regulation 18 Draft Local Plan
DE1: Promoting Good Quality Design
Representation ID: 2337
Received: 23/04/2024
Respondent: Claypole Parish Council
The Parish Council considers that Policy DE1 of the Local Plan Review is unsound, and it fails to meet the test of soundness relating to the tests of ‘positively prepared’, ‘justified’, ‘effective’ and ‘consistent with national policy’ in the NPPF.
As explained in the attached technical paper the policy as currently written can be misinterpreted and implies that Neighbourhood Plans are only relevant considerations for major development proposals.
Support
Regulation 18 Draft Local Plan
H1: Housing AllocationsThe
Representation ID: 2338
Received: 23/04/2024
Respondent: Claypole Parish Council
Claypole Parish Council supports Policy H1 in so far as Claypole is concerned, because it does not propose to allocate any sites for housing in Claypole. The Claypole Neighbourhood Plan already includes two housing allocations.
As explained in the attached technical paper the Parish Council would resist any proposals to allocate land for additional housing in Claypole in the Local Plan if promoted by other parties or suggested by South Kesteven.
Object
Regulation 18 Draft Local Plan
Neighbourhood Plans
Representation ID: 2339
Received: 23/04/2024
Respondent: Claypole Parish Council
The Parish Council highlights that Figure 4: Neighbourhood Plan Designation Map in the Local Plan Review is factually incorrect in respect of Claypole. The Claypole Neighbourhood Plan was passed at Referendum on the 5th October 2023 at which point it became part of the development plan, it was subsequently ‘made’ (which is now purely an administrative act) by SKDC on the 23rd November 2023.