 |
 |
YOU ARE HERE |
 Article |
|
CURRENT USERS |
|
|
|
 |
|
Observations on Consultation Drafts, PPS 12 And Guide to LDF Preparation
|
- 2.2.10 - There are two important, separate points here, whose impact is reduced by combining them. The first is about the evidential foundation for proposals, and the second is to do with the use of criteria. We suggest that they are separated and each made clear, with a link to Section $.2 on the evidence base.
- 2.2.13 - We do not understand this. It is a requirement that the LDS should set out all documents to be produced as part of the LDF, so how can the core strategy set out criteria for something which has already been established? We advise that this is omitted.
- 2.2.15 - The reference to saved policies here appears incorrect. The proposals map is an LDD in its own right, and can surely only contain policies and proposals set out in DPDs. Saved policies will not be part of DPDs, but hangovers from the existing system, so how can they lawfully appear on the proposals map?
- As a separate issue, it is not clear where in the new system the general extent of key regional policies such as the Green Belt will be set in future. This is an important matter for practice. If this will be an LDF function, we suggest that it is covered here. If it is a matter for RSSs, it should be covered in the new PPS 11.
- 2.4.2 - While we accept that supplementary planning documents should not include new land allocations, we suggest that it is made clear that, where a DPD proposes an area of mixed uses, it would be appropriate for a SPD to set out how the different uses would be deployed on the ground.
- 2.5.3 - We suggest that a reference to the Society's imminent guidance on policy framing is included here.
- 3.1.5 - It should be made clear that the SCI will apply not only to plan preparation but to development control also.
- 3.1.7 to 3.1.10 - This section of text seems rather repetitive and lacks the conciseness of the rest of the document.
- 3.2.3 - This connects back to our earlier point about selective reviews of plans, and being able to avoid putting all aspects of current policy up for challenge, and we would ask that the point is addressed here.
- 4.2.1 - There should be a reference here to the importance of a sound evidence base in demonstrating the soundness of the plan at examination.
- Section 4.3 - We have made the point earlier, in relation to the process diagram, that it needs to be made clear that SA and SEA apply throughout the process. We are aware of the separate guidance being developed on SA/SEA, which will need to be reflected here.
- 4.3.4 - DPDs are required to conform generally with the RSS, not merely have regard to it.
- 4.3.5 - The concept of front-loading needs to be got across much earlier in the PPS.
|
|
|
|
|
Save
Print
Email
Discuss