Draft Planning Obligations SPD
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Draft Planning Obligations SPD
5.6.10
Representation ID: 28559
Received: 14/07/2014
Respondent: Carter Jonas
Agent: Carter Jonas
If this means, as per section 5.7 of the strategy, that the expectation is that full open space provision (informal space) is made available on all sites, and no element of the required provision can be commuted through planning obligation then I object to this most vigorously. The current system of negotiating an appropriate level of on-site provision having regard to a range of factors is sensible and should be continued.
If this means, as per section 5.7 of the strategy, that the expectation is that full open space provision (informal space) is made available on all sites, and no element of the required provision can be commuted through planning obligation then I object to this most vigorously. The current system of negotiating an appropriate level of on-site provision having regard to a range of factors is sensible and should be continued.
Object
Draft Planning Obligations SPD
5.6.15
Representation ID: 28560
Received: 14/07/2014
Respondent: Carter Jonas
Agent: Carter Jonas
The threshold of 10 dwellings or over whereby a LAP should be provided is too low. This paragraph also suggests a LAP may be sought on sites of less than 10 dwellings which I object to. A threshold of 25 dwellings should apply here, and no LAP should be required on smaller sites.
The threshold of 10 dwellings or over whereby a LAP should be provided is too low. This paragraph also suggests a LAP may be sought on sites of less than 10 dwellings which I object to. A threshold of 25 dwellings should apply here, and no LAP should be required on smaller sites.
Object
Draft Planning Obligations SPD
5.6.16
Representation ID: 28561
Received: 14/07/2014
Respondent: Carter Jonas
Agent: Carter Jonas
This is too general and should be caveated. If there is a nearby and easily accessible LEAP, there seems little point in replicating it on a site.
This is too general and should be caveated. If there is a nearby and easily accessible LEAP, there seems little point in replicating it on a site.
Object
Draft Planning Obligations SPD
5.7.1
Representation ID: 28562
Received: 14/07/2014
Respondent: Carter Jonas
Agent: Carter Jonas
I object to the "exceptional cases" test that is applied here. There are often very good reasons to have an element of usable and good quality open space on a site but to then provide a commuted sum via a planning obligation for a specific off-site project. To expect all open space in accordance with the informal open space standards to be met on site will have an adverse effect in reducing dwelling yield at a time when housing need in the City remains extremely high. This needs to be re-thought.
I object to the "exceptional cases" test that is applied here. There are often very good reasons to have an element of usable and good quality open space on a site but to then provide a commuted sum via a planning obligation for a specific off-site project. To expect all open space in accordance with the informal open space standards to be met on site will have an adverse effect in reducing dwelling yield at a time when housing need in the City remains extremely high. This needs to be re-thought.
Object
Draft Planning Obligations SPD
7.1.1
Representation ID: 28563
Received: 14/07/2014
Respondent: Carter Jonas
Agent: Carter Jonas
There is no case for public art being covered in this document. It is not a funding infrastructure project per S216 of the Planning Act 2008 and it is not something that can be secured by planning obligation as confirmed in the NPPG. It is something to be secured via condition as part of the objective of securing high quality development however it must be done by negotiation and not by tariff.
There is no case for public art being covered in this document. It is not a funding infrastructure project per S216 of the Planning Act 2008 and it is not something that can be secured by planning obligation as confirmed in the NPPG. It is something to be secured via condition as part of the objective of securing high quality development however it must be done by negotiation and not by tariff.
Object
Draft Planning Obligations SPD
7.3.1
Representation ID: 28564
Received: 14/07/2014
Respondent: Carter Jonas
Agent: Carter Jonas
Public art cannot be funded by CIL. This is made clear in the list of funding infrastructure projects in S216 of the Planning Act 2008. This whole section (public art) should be omitted from this strategy document.
Public art cannot be funded by CIL. This is made clear in the list of funding infrastructure projects in S216 of the Planning Act 2008. This whole section (public art) should be omitted from this strategy document.
Object
Draft Planning Obligations SPD
11.1.1
Representation ID: 28565
Received: 14/07/2014
Respondent: Carter Jonas
Agent: Carter Jonas
My only objection here is that the section in the strategy document on viability fails to mention that existing use value is a valid consideration when considering viability. We have had experience of projects that are not viable on the basis of a "full" planning obligation package (including affordable housing) on the basis that the existing use value of the site was too great. This is an important point which the strategy document should recognise.
My only objection here is that the section in the strategy document on viability fails to mention that existing use value is a valid consideration when considering viability. We have had experience of projects that are not viable on the basis of a "full" planning obligation package (including affordable housing) on the basis that the existing use value of the site was too great. This is an important point which the strategy document should recognise.
Object
Draft Planning Obligations SPD
11.2.7
Representation ID: 28566
Received: 14/07/2014
Respondent: Carter Jonas
Agent: Carter Jonas
Decreased in the BCIS index should also be reflected in the wording of agreements. It is unreasonable to ignore decreases.
Decreased in the BCIS index should also be reflected in the wording of agreements. It is unreasonable to ignore decreases.
