Yes

ID sylw: 108289

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We support recognition that in the first instance area of public open space should be provided on site. However, the suggestion that that when this is not possible contributions will be required to enhance or provide new open spaces within 400m of development, is inappropriate.
There will be numerous apartment schemes and brownfield regeneration opportunities where public open space cannot be provided on site and there may be no areas of public open space with 400m that can be upgraded. The 400m distance threshold should be removed from the policy as there may be cases where this not practical. Where there is a need for open space to be provided off-site, the nature of that provision should be determined on the basis of the location of that site.

No

ID sylw: 108290

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

No. The Policy advises that where strategic residential development is proposed the need for sport and leisure facilities will be assessed on a case by case basis depending upon the type of development, location of the site and the capacity of existing facilities. Whilst we have no objection to open space provision being considered on a case by case basis, this policy approach provides no certainty to a developer how much open space or contributions to outdoor sports and leisure facilities will be expected on any site. The Policy should provide clear guidance on the potential amount of open space and outdoor sports and leisure provision that will be expected with new developments.

No

ID sylw: 108291

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

No. The areas of restraint are local landscape designations. There is no provision in the NPPF for the inclusion of local landscape designations in Local Plans. Paragraph 187a of the NPPF requires planning polices to protect and enhance “valued” landscapes only. The guidance in Section 15 of the NPPF is adequate to deal with local landscape matters.

No

ID sylw: 108292

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

No. The Policy is disproportionate and unclear. For example, it advises that the Council will “explore” the need for major development applications to require a full Landscape and Visual Impact Assessment. A planning application for 11 dwellings would constitute a major development. It would be entirely disproportionate for a LIVA to be submitted for the majority of cases for schemes of this size.
The Policy also suggests that where a proposal would result in landscape harm, the general principle is that it should be refused unless there will be an overriding benefit of development. The majority of the Plan’s housing requirement will be provided on greenfield sites due to a lack of brownfield land. Any development of a greenfield site is likely to have a degree of landscape harm as it will result in any development taking place in an area where there is currently no built development. This does not, however, mean that the starting point for determination of an application is a presumption it should be refused. Landscape impact is just one of many matters that needs to be considered as part of the determination process. The draft wording of the policy Direction 48 would appear to elevate the importance of landscape harm beyond other considerations.