8. Natural Environment

Support

Representation ID: 8364

Received: 20/03/2020

Respondent: Sport England - East Region

Sport England supports the content of section 8.4 of the SPD in relation to requiring provision to made for outdoor sport in new development through developer contributions or on-site provision. The reference to only seeking on-site provision where this would generate a usable quantity of open space for a form of provision for which there is an identified requirement is welcomed as this should help prevent unsuitable on-site proposals being progressed.

Object

Representation ID: 8365

Received: 20/03/2020

Respondent: Sport England - East Region

Paragraphs 8.4.14-8.4.18 only provide limited guidance to provide clarity and transparency on the Council’s approach to securing developer contributions for outdoor sports facilities.

It is therefore requested that this section is amended to provide more detailed advice covering the matters identified in these comments. This will help ensure that the approach set out in the SPD is consistent with the tests in Regulation 122 of the CIL Regulations and would reduce the risk of challenge in practice. It would also provide greater clarity and transparency for all parties involved in the process.

Object

Representation ID: 8366

Received: 20/03/2020

Respondent: Sport England - East Region

Objection is made to the proposal in paragraph 8.4.4 to all schemes having regard to a standard of 1.6 hectares per 1000 population for outdoor sport which would be used for quantifying provision in new development. However, the use of this standard is not consistent with the Council’s Playing Pitch Strategy which also forms part of the Council’s local plan evidence base, and which did not advocate the use of a generic outdoor sports standard for applying to new development. It is therefore requested that the standard is removed from the SPD and replaced with amended guidance.

Object

Representation ID: 8423

Received: 16/03/2020

Respondent: Anglian Water Services Ltd

8.8 Water supply and waste-water infrastructure

Anglian Water as a sewerage company seeks fair contributions through charges directly from developers under the provisions of the Water Industry Act 1991 to drain a site effectively. As such we would not, in most cases, make use of planning obligations or standard charges under Planning Legislation for this purpose.

In general, water recycling centre (previously referred to as sewage or wastewater treatment works) upgrades where required to provide for additional growth are wholly funded by Anglian Water through our Business Plan from our customer bills.

We welcome the reference made to the use of planning conditions for foul drainage as this will help to ensure that the risk of sewer flooding (where relevant) to our customers is addressed as part of the planning process. However we would not expect to make use of legal agreements or conditions relating to foul treatment capacity as suggested.

It is therefore proposed that para 8.8.4 is amended as follows:

‘8.8.4 Mechanisms for delivering any necessary new or improved water and/ or wastewater infrastructure, including foul water treatment and drainageisposal, may be required via planning conditions and/or legal agreement in accordance with Local Plan Policy NE10 Water Conservation and wastewater infrastructure.’

Object

Representation ID: 8443

Received: 24/03/2020

Respondent: Barkway Parish Council

8.4.7 - No standards are being set for the protection of green corridors which are to be considered on a case by case basis. This is unacceptably vague and leaves this important aspect of protecting the countryside and its biodiversity too vulnerable.

Object

Representation ID: 8456

Received: 24/03/2020

Respondent: Letchworth Garden City Heritage Foundation

Agent: Planning Matters

8.2.1 & 2 - Clarity should be provided as to which requirements can be dealt with by way of condition and by legal obligation.

8.4.2 - A clearer commitment is needed with regards the standards review.

8.4.12 - The provision of strategic open space should attract contributions from projects across the area as it will be accessible to all.

8.4.18 & 19 - Examples of exemption cases should be provided.

8.4.20 - 24 - Clarification should be provided as to the role Section 106 agreements can play in securing aspirations.

8.10.1 - Any LPA requirements must reasonably relate to a proposal to secure legal compliance.

Object

Representation ID: 8465

Received: 25/03/2020

Respondent: Bloor Homes South Midlands

Agent: White Peak Planning

8.4 - Table to be amended to show the units of measurement and annotate or remove the footnote.

Object

Representation ID: 8469

Received: 01/04/2020

Respondent: Hertfordshire County Council - Environment & Infrastructure Department

8.3 - . It should also be noted that Therfield Heath is a significant archaeological site which the historic environment record notes includes prehistoric burial mounds, many of which are Scheduled Monuments. This is the most significant prehistoric landscape in the county. The SPD document should include measures to conserve and enhance the historic as well as the natural environment of this site.

The relevant Natural Environment sections that relate to the Landscape service area include 8.1 Policy Context, 8.4 Open Spaces and 8.7 Other forms of Green Infrastructure (GI).

Overall the document appears to include the aspects that should typically be covered by this type of document, which is welcomed.

In addition we support the reference to GI networks and connections for people and wildlife, beyond that identified as formal open space under 8.4, and the reference to the Districts GI Plan as the evidence base underpinning this.

Object

Representation ID: 8476

Received: 25/03/2020

Respondent: Bellcross Homes and Gallagher Developments Ltd

Agent: Rapleys LLP

8.4.23 - 'For larger or strategic sites, the ten-year timeframe will also apply', provides certainty by deleting may be extended.