Comment

Representation ID: 358

Received: 12/12/2023

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

Policy DLP40 – Landscape Design
6.2.
Policy DLP40 places significant emphasis upon the delivery of soft landscaping through new development, seeking to minimise the use of hard surfacing. Although this is supported in principle, the wording of this Policy as currently drafted is overly restrictive, requiring that hard surfacing should not be used unless there is an ‘overriding need’ in order to strengthen wildlife habitat, and achieve climate change benefits. It is contended that this Policy fails to appreciate that the sensitive use of hard surfacing can also achieve environmental benefits. For example, the use of permeable paving can assist in the sustainable drainage of sites and can provide filtration to improve water quality.
6.3.
Policy DLP40 also stipulates that development proposals are required to include a mix of native and non-native tree and plant species, however this fails to appreciate that the suitability of sites to accommodate specific plant species will vary on a site by site basis. Policy DLP40 as currently drafted fails to account for this, and should therefore be amended to identify an aspiration for the use of native plant species to be prioritised where feasible and viable. Finally, Policy DLP40 requires that, in accordance with new legislation, developments should ensure that they do not lead to the spread of non-native invasive species and should be managed to prevent any future re-establishment of such species. It is not considered necessary for Policy DLP40 to reassert the provisions of national legislation in this respect and the policy text should be amended to remove this unnecessary duplication and ensure that this Policy serves a clear purpose, in accordance with Paragraph 16 of the Framework.
6.4.
Furthermore, whilst generally the use of hard surfaces should be minimised, typically there will be an expectation for the provision of some areas of hard surfacing such as patios in gardens and paving around doorways, beyond the minimal footpath areas that are an essential requirement. The end-users requirements for developments should be a consideration that is balanced with environmental objectives in order to ensure that sustainable development will be achieved.

Object

Representation ID: 563

Received: 15/12/2023

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

6.3. This draft Policy seeks to ensure high quality and attractive on-site green space is delivered, recognising the role that this can play in terms of sustainable development. Whilst overall, the aims and objectives of this policy are supported, part 1 seeks to avoid the use of hard surfaces and is not considered to be wholly justified. Whilst generally the use of hard surfaces should be minimised, typically there will be an expectation for the provision of some areas of hard surfacing such as patios in gardens and paving around doorways, beyond the minimal footpath areas that are an essential requirement. The end-users requirements for developments should be a consideration that is balanced with environmental objectives in order to ensure that sustainable development will be achieved.

6.4. It is also considered that the policy as currently drafted overlaps with other policy in the emerging Plan, notably DLP33 relating to trees. As such, the policies should be reviewed to ensure that there is no duplication, and policy requirements relating to arboriculture are contained within a single policy, rather than included in various policies of the emerging Plan.

Object

Representation ID: 579

Received: 21/12/2023

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

6.3.
This draft Policy seeks to ensure high quality and attractive on-site green space is delivered, recognising the role that this can play in terms of sustainable development. Whilst overall, the aims and objectives of this policy are supported, part 1 seeks to avoid the use of hard surfaces and is not considered to be wholly justified. Whilst generally the use of hard surfaces should be minimised, typically there will be an expectation for the provision of some areas of hard surfacing such as patios in gardens and paving around doorways, beyond the minimal footpath areas that are an essential requirement. The end-users requirements for developments should be a consideration that is balanced with environmental objectives in order to ensure that sustainable development will be achieved.
6.4.
It is also considered that the policy as currently drafted overlaps with other policy in the emerging Plan, notably DLP33 relating to trees. As such, the policies should be reviewed to ensure that there is no duplication, and policy requirements relating to arboriculture are contained within a single policy, rather than included in various policies of the emerging Plan.

Support

Representation ID: 660

Received: 22/12/2023

Respondent: Natural England

We welcome the inclusion of this policy. A requirement for sustainable drainage that is nature-based and contributes to the site design for biodiversity could be made

Support

Representation ID: 661

Received: 22/12/2023

Respondent: Natural England

We welcome the inclusion of this policy. A requirement for sustainable drainage that is nature-based and contributes to the site design for biodiversity could be made

Comment

Representation ID: 714

Received: 22/12/2023

Respondent: Canal and River Trust

Should reference DLP36.

Comment

Representation ID: 805

Received: 30/01/2024

Respondent: Historic England

DLP40. The policy would benefit from reference to historic landscapes.