BASE HEADER

Our Ref.: C/5887

Local Plan Pre Submission

Thank you for your email of 16 May consulting The Theatres Trust on the pre submission draft of the New Local Plan. Please find the Response Form attached - unfortunately when expanding item 7, I was then unable to access item 8, so include my full response below in the hope that someone can rescue my representation.

The Theatres Trust is The National Advisory Public Body for Theatres, and was established by The Theatres Trust Act 1976 to 'promote the better protection of theatres'. The Trust delivers statutory planning advice on theatre buildings and theatre use in England through The Town and Country Planning (Development Management Procedure) (England) Order 2010 (DMPO) requires the Trust to be consulted on planning applications which include 'development involving any land on which there is a theatre.'

7.
The document is unsound because it does not reflect item 70 of the National Planning Policy Framework (NPPF) which states that to deliver the social, recreational and cultural facilities and services that the community needs, planning policies and decisions should plan for the use of shared space and guard against unnecessary loss of valued facilities.

There are no policies to protect your social and cultural facilities to reflect the NPPF. Policy CT3 protects existing visitor accommodation, and Policy CT4 will extend cultural and leisure facilities in rural areas. However, the aspirations in the text of the section on Culture, Leisure and Tourism do not complement the policies that are supposed to support this text.

* para.3.112 states that as cultural assets such as theatres, cinemas, libraries etc enrich people's quality of life, it is appropriate to consider how planning can assist (presumably in their protection and enhancement).
* para.3.116 states that culture, leisure and tourism are important for centres to be vibrant and prosperous (i.e. 'valued facilities').
* para.3.128 says that 'meeting places, cultural facilities and public art are important features in sustainable communities (i.e. 'valued facilities').'
* para.3.129 says that 'new development will inevitably place demands on existing public meeting places such as community halls and public cultural facilities such as theatres, concert halls and libraries (i.e. 'valued facilities').'
* para.3.9 repeats para.3.112 regarding the importance of cultural assets with reference to policy PC0 which supports 'the important role of culture and leisure assets'.

Policy HS8 does protect community facilities, but is wholly inadequate in providing a comprehensive description for the term 'community facilities'. Paragraph 5.90 gives some D1 examples and says that other facilities (presumably cultural, leisure and tourism) may be protected, but only in exceptional circumstances. Theatres are sui generis, and all other entertainment facilities are D2 so are not included in this policy.

There is no policy in this document to protect your cultural, leisure and tourism facilities.

8.
There needs to be a clear definition for the term 'community facilities'. It is not adequate for Policy HS8 to only protect some community facilities, it should protect all to reflect item 70 of the NPPF. A comprehensive description for all community facilities should be included in the Glossary which would obviate the need to provide examples: community facilities provide for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of the community.

If the council wishes to support its cultural, leisure and tourism offer, there must be clearer and more practical guidance in Policies PC0 and CT1.

For PC0 we suggest h) is amended to read to support existing culture and leisure assets for the important role they play in our communities and economy, .....

CT1 only deals with new developments and there is no mention of assessing existing venues and whether there is any requirement for new. We suggest there is an additional policy to protect and enhance existing cultural infrastructure if there is no amendment to Policy HS8 because, as stated previously, the document contains no policy to protect its existing successful and important cultural and leisure infrastructure.


Rose Freeman
Planning Policy Officer