1.1 Purpose of the document
Support
Draft Planning Obligations SPD
Representation ID: 28477
Received: 06/06/2014
Respondent: Natural England
Strategic Environmental Assessment/Habitats Regulations Assessment
In principle SPDs should not be subject to the Strategic Environmental Assessment Directive or the Habitats Directive because they do not normally introduce new policies or proposals or modify planning documents which have already been subject to a Sustainability Appraisal or Habitats Regulations Assessment. However a SPD may occasionally be found likely to give rise to significant effects which have not been formally assessed in the context of a higher level planning document. This may happen, for example, where the relevant high level planning document contains saved policies within a saved local plan which predates the need to carry out a SA or HRA and therefore no higher tier assessment has taken place. If there is any doubt on the need to carry out a SA or HRA a screening assessment should be carried out.
Thank you for your consultation on the above dated 30 May 2014, which was received by Natural England on 30 May 2014.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support the principle of meaningful and early engagement of the general community, community organisations and statutory bodies in local planning matters, both in terms of shaping policy and participating in the process of determining planning applications.
Whilst we welcome this opportunity to give our views, the topic of the Supplementary Planning Document does not relate to our remit to any significant extent. We do not therefore wish to comment.
Strategic Environmental Assessment/Habitats Regulations Assessment
In principle SPDs should not be subject to the Strategic Environmental Assessment Directive or the Habitats Directive because they do not normally introduce new policies or proposals or modify planning documents which have already been subject to a Sustainability Appraisal or Habitats Regulations Assessment. However a SPD may occasionally be found likely to give rise to significant effects which have not been formally assessed in the context of a higher level planning document. This may happen, for example, where the relevant high level planning document contains saved policies within a saved local plan which predates the need to carry out a SA or HRA and therefore no higher tier assessment has taken place. If there is any doubt on the need to carry out a SA or HRA a screening assessment should be carried out.
We now ask that all planning consultations are sent electronically to the central hub for our planning and development advisory service at the following address: consultations@naturalengland.org.uk. This system enables us to deliver the most efficient and effective service to our customers.
We really value your feedback to help us improve the service we offer. We have attached a feedback form to this letter and welcome any comments you might have about our service
Object
Draft Planning Obligations SPD
Representation ID: 28505
Received: 11/07/2014
Respondent: Savills
Agent: Savills
Significant number of jobs through in commuting as a planned strategy whilst developers have a responsibility to contribute, they do not have a responsibility to compensate for the authorities strategy shortcomings.
Suggest new text to the end of the paragraph to read "...provided they meet the tests set out in the Regulations.
The tests are:
* necessary to make the development acceptable in planning terms
* directly related to the development; and
* fairly and reasonably related in scale and kind to the development.
Significant number of jobs through in commuting as a planned strategy whilst developers have a responsibility to contribute, they do not have a responsibility to compensate for the authorities strategy shortcomings.
Suggest new text to the end of the paragraph to read "...provided they meet the tests set out in the Regulations.
The tests are:
* necessary to make the development acceptable in planning terms
* directly related to the development; and
* fairly and reasonably related in scale and kind to the development.
Object
Draft Planning Obligations SPD
Representation ID: 28506
Received: 11/07/2014
Respondent: Savills
Agent: Savills
1.1.1
Significant number of jobs through in commuting as a planned strategy whilst developers have a responsibility to contribute, they do not have a responsibility to compensate for the authorities strategy shortcomings
1.1.5
The SPD generally is lengthy in nature and uses a significant amount of jargon and complex terms without definitions or a glossary. If the authority are aiming the document at local residents, developers and landowners it should be less technical
1.3.1
CCC need to ensure that reps made against the CIL charging Schedule are adequately considered in relation to this document
See details for further comment
1.1.1
Significant number of jobs through in commuting as a planned strategy whilst developers have a responsibility to contribute, they do not have a responsibility to compensate for the authorities strategy shortcomings.
Suggest new text to the end of the paragraph to read "...provided they meet the tests set out in the Regulations.
The tests are:
* necessary to make the development acceptable in planning terms
* directly related to the development; and
* fairly and reasonably related in scale and kind to the development.
1.1.5
As a general point the SPD is lengthy in nature and uses a significant amount of jargon and complex terms without definitions or a glossary. If the authority are aiming the document at local residents, developers and landowners as stated in paragraph 1.1.5 then it should be less technical and more user friendly in nature. It is suggested that the document should be a technical tool and should be aimed at developers and consultants as those likely to submit planning applications and a less technical summary document be produced for the public and interested parties.
1.3.1
Savills welcome the production of the SPD alongside the CIL charging schedule in general. CCC need to ensure that reps made against the CIL charging Schedule are adequately considered in relation to this document and that amendments are made accordingly as part of a holistic process.
Support
Draft Planning Obligations SPD
Representation ID: 28545
Received: 14/07/2014
Respondent: Mrs Jane Jackson
Support
Suport whole document
Object
Draft Planning Obligations SPD
Representation ID: 28549
Received: 14/07/2014
Respondent: Carter Jonas
Agent: Carter Jonas
A narrow point perhaps, but it seems to me that the language used in paragraph 1.1.1 is unfortunate, describing as it does the "harm" caused by new development. I consider that new development should be considered in a more positive light. Yes, its effects on the likes of transport infrastructure will often require mitigation but it is in my opinion too general to describe development as causing harm. What does this mean in any event?
A narrow point perhaps, but it seems to me that the language used in paragraph 1.1.1 is unfortunate, describing as it does the "harm" caused by new development. I consider that new development should be considered in a more positive light. Yes, its effects on the likes of transport infrastructure will often require mitigation but it is in my opinion too general to describe development as causing harm. What does this mean in any event?