Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
H1: Housing AllocationsThe
Representation ID: 2555
Received: 24/04/2024
Respondent: Mr M J Dickinson
Agent: Robert Doughty Consultancy
Objects to the process of allocating sites for residential development and the failure to allocate site SKPR-59 Land at Park Farm, Bourne in favour of two less favourable sites in Bourne.
Object
Regulation 18 Draft Local Plan
NEW POLICY 4: Biodiversity Opportunity and Delivering Measurable Net Gains
Representation ID: 2556
Received: 24/04/2024
Respondent: Mr M J Dickinson
Agent: Robert Doughty Consultancy
Will potentially restrict the operation of farming land based on a map, the derivation of which is unknown.
Instead of providing evidence on BOM, Appendix 1 sets out how to use the map – it provides no information on how the maps were prepared, or how they can be justified.
We OBJECT to the inclusion of Policy 4 unless the mapping exercise that underpins the operation of the policy can be robustly justified through a rigorous public consultation exercise. Clarity should also be provided on the focus for delivery of offsite BNG – will landowners whose land is arbitrarily designated under the BOM exercise be pressured to give up their land for the provision of BNG? Or will development proposals be considered unfavourably if any offsite BNG provision does not include land identified in the BOM exercise?
Object
Regulation 18 Draft Local Plan
EN3: Green Infrastructure
Representation ID: 2557
Received: 24/04/2024
Respondent: Mr M J Dickinson
Agent: Robert Doughty Consultancy
Restrict the operation of farming land based on a map. No indication of how maintenance or enhancement will be delivered; nor how the policy will operate against the continued use of land for agricultural purposes with little or no public access.
Problematic as development will be dependent on third party landowners providing land for Green Infrastructure use when they will have other aspirations for the land which may not fit in with those to deliver Green Infrastructure. Developers also appear to be denied the opportunity to consider promoting Biodiversity Net Gain or Green Infrastructure on land that is not designated in the Biodiversity Opportunity Mapping for South Kesteven exercise.
Object
Regulation 18 Draft Local Plan
NEW POLICY 2: Best and Most Versatile Agricultural Land
Representation ID: 2558
Received: 24/04/2024
Respondent: Mr M J Dickinson
Agent: Robert Doughty Consultancy
Goes beyond the national requirements for applications for development on Best and Most Versatile Agricultural Land, together with a requirement in principle for land to be returned to agricultural use, without justifying the additional requirement.
OBJECT to the inclusion of New Policy 2 unless:
• The introduction of a lower trigger point for the production of Agricultural Land Classification reports can be justified.
• The policy is reworded to remove the requirement for sites allocated through the Local Plan process.
• The requirement to return land to agricultural use upon the cessation of development is removed.
Object
Regulation 18 Draft Local Plan
Appendix 1: Principles for Development within Biodiversity Opportunity Areas.
Representation ID: 2559
Received: 24/04/2024
Respondent: Mr M J Dickinson
Agent: Robert Doughty Consultancy
Objects to the designation of Land as Green Infrastructure or Biodiversity Opportunity areas without any justification or consultation.
Objects to the use of the Biodiversity Opportunity and Green Infrastructure Maps as the basis for operating policies until:
• The assessment used to justify designation of specific land as BOM is published and is subject to consultation with the public, the development industry, and, significantly, the current owners and users of the land.
• Appendix 1 should be reworded to provide an explanation, rather than act as an additional policy.
The Regulation 18 draft plan also includes policies that impact on the future of the site, whether as a future allocation or for promotion via a planning application. The various mapping exercises which are unjustified and/or inaccurate, and as such should not form the basis of a planning policy.
Object
Regulation 18 Draft Local Plan
Appendix 2: Principles for Development within Green Infrastructure Areas.
Representation ID: 2560
Received: 24/04/2024
Respondent: Mr M J Dickinson
Agent: Robert Doughty Consultancy
Objects to the designation of Land as Green Infrastructure or Biodiversity Opportunity areas without any justification or consultation.
Objects to the use of the Biodiversity Opportunity and Green Infrastructure Maps as the basis for operating policies until:
• The assessment used to justify designation of specific land as BOM is published and is subject to consultation with the public, the development industry, and, significantly, the current owners and users of the land.
• Appendix 1 should be reworded to provide an explanation, rather than act as an additional policy.
The Regulation 18 draft plan also includes policies that impact on the future of the site, whether as a future allocation or for promotion via a planning application. The various mapping exercises which are unjustified and/or inaccurate, and as such should not form the basis of a planning policy.