Object
Publication Plan November 2022
Representation ID: 5343
Received: 19/12/2022
Respondent: St Philips
Agent: Pegasus Group
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Whilst there is no in principle objection to the requirements of the policy or the provision of open space within developments, some clarifications are required in order to ensure that the Policy is sound.
The policy requirement for on-site equipped play provision as default is not supported as it will not be appropriate for every site, for example where there is already high-quality equipped play provision in the locality it would not make sense to duplicate this provision.
In addition, it is not appropriate to require open space to be centrally located on all sites as this does not take into consideration differences in development sites opportunities and constraints. It is requested that the Council amend the policy to allow a more flexible
approach to achieve the right design solution for each site.
The focus of Green Infrastructure provision should be based on quality rather than quantity or ‘useability’ and the exclusion of small incidental green infrastructure (GI) without a clear recreational purpose from on-site open space provision is not supported. The policy text
cites landscape buffers as an example of incidental GI which may be excluded. This is not appropriate as landscape buffers can be of a significant size and clearly make a contribution towards open space provision on a site. They should therefore be included in these calculations. Planning Practice Guidance acknowledges that 'Green infrastructure can embrace a range of spaces and assets that provide environmental and wider benefits.
The policy should therefore be revisited and clarified, with clear reference to national guidance ensure that open space and green infrastructure is properly and clearly defined and to recognise the contribution that a range of spaces and uses will bring to a development.
The policy as drafted is unsound as it is inconsistent with national policy and is unjustified for the reasons set out above.