Development Management - Proposed Submission
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Development Management - Proposed Submission
Respondent: The Society for the Protection of Undercliff Gardens
Legally compliant? Not specified
Duty to co-operate? Not specified
Representation Summary:
The Council's present proposals appear to be the greatest threat experienced since this Society was formed more than 60 years ago to protect the character of Undercliff Gardens. The proposed DPD reduces planning policy to principles rather than specifics, a broad brush approach providing maximum flexibility rather than specific detailed requirements. To implement this policy document will require a high level of assessment and consultation, but it is our experience that these essential qualities are rarely available. We have no confidence that this document will improve matters, and it may well prove to be a developers charter. We therefore suggest that more work is required to "tighten" up a well meaning document.
Full text:
This is our response to your letter dated 18 March 2011 regarding the proposed submission version of the above. We have already provided our observations on the previous draft - which have largely been ignored.
The Council's present proposals appear to be the greatest threat experienced since this Society was formed more than 60 years ago to protect the character of Undercliff Gardens. For this reason, our representations are considered to be of the highest importance.
To quote the introduction - this DPD will be used for positively managing development and will be used to assess and determine planning applications. It is a framework in which to manage the built environment and ensure successful place making. Its importance cannot therefore be overestimated.
SUMMARY OF REPRESENTATION BY SPUG
The proposed DPD reduces planning policy to principles rather than specifics, a broad brush approach providing maximum flexibility rather than specific detailed requirements. To implement this policy document will require a high level of assessment and consultation, but it is our experience that these essential qualities are rarely available. We have no confidence that this document will improve matters, and it may well prove to be a developers charter. We therefore suggest that more work is required to "tighten" up a well meaning document.
SAVED POLICIES.
Saved policies emphasise the unique character of certain areas in the Borough, but they are to be superseded by this document. However, current reports to the Development Control Committees make full and frequent reference to saved policies - in other words they are not redundant or superfluous but are fully used on a day to day basis to support assessments of planning applications. They are also widely used by the Council when submitting evidence to Appeals Inspectors. By deleting these essential statements of policy we would expect them to be replaced by a stronger, direct, incontrovertible, policy document - which the proposed DPD is not. We suggest that more work is required to protect the areas previously covered by saved policies.
SECTION 3 SEAFRONT CHARACTER ZONE.
This section acknowledges and "identifies several distinctive character zones and each has a different form and function" to quote the proposed DPD. So far so good.
On page 39, Policy Table 1 para 3 refers to one such zone. But the new principles which are to replace saved policy C12 for this zone are reduced to "development will only be acceptable where it will improve the design quality of Undercliff Gardens...and where it retains the characteristics and form of the area. Development that materially changes the existing character, appearance, and form of the area will be resisted".
Based on past experience, at best such intentions will either be unenforceable or are subjective. Who is to judge? Who is qualified to judge? Who will have the time, qualifications, or motivation to carefully consider the details of any application? This well intentioned broad brush approach is a dangerous concept in our view. We envisage endless arguments about whether an application is retaining the characteristics and form of an area, and whether the existing character, appearance, and form of the area will be changed. Who will argue on behalf of the public, the residents, and future generations? Developers are well able to argue for themselves that an application should be approved of course.
This DPD seems like a developers charter because it is possible to show that a single development does not materially change the character of an area [not a difficult argument to make] but if such a building is approved it will then become a precedent for other similar developments, often won on appeal, and the character of an area will then have been changed for ever. QED.
SUSTRANS.
Item 3iii still refers to this organisation which is no longer active. Obviously the name should be removed, and the sentence might be changed to "improve the public realm linked to improvement of the cinder path".
DETAILED CONSIDERATIONS.
Letters received by SPUG from our residents regarding this DPD may be summarised by quoting just 3 typical examples:
1. In reality, it will be its application and stewarding that we need to be concerned about.
Who will safeguard it, and will there be a body that ensures that proper monitoring
and reporting is provided? Hopefully there will be a local and national provision for this.
2. "Development that materially changes the existing character, appearance and form of the area or materially affects the benefits and amenity of neighbouring properties will be resisted."
3. "I fail to understand how planning permission was granted [for 82] allowing the property to be built further forward than the previous property. This restricts neighbours' views. The point is so blindingly obvious that I have no confidence in the planning officials responsible to put it at its mildest. Are they mad or what? It's a very large, single dwelling, isn't it?"
Many questions spring to mind regarding what is not included in a document that will be used to consider the detail of any planning application. Some may be answered by reference to the Design and Townscape Guide, but this document can, we presume, be comfortably ignored.
The same questions continually arise whenever SPUG is asked to comment on an application.
For example:
* Why is a proposed building allowed to project in front of the line of building?
* Why are balconies allowed to project in front of adjoining buildings?
* Why is development on Grand Parade frontage being allowed?
* Why is overlooking not dealt with?
* Why are the benefits and amenities of neighbouring properties not protected?
* Why are there no levels on the drawings?
* Why are the materials proposed not in accordance with the Design and Townscape Guide?
* Why is landscaping not shown?
Until such questions are answered, we remain highly concerned that this DPD is not fit for purpose
Development Management - Proposed Submission
Respondent: The Society for the Protection of Undercliff Gardens
Legally compliant? Not specified
Duty to co-operate? Not specified
Representation Summary:
Saved policies emphasise the unique character of certain areas in the Borough, but they are to be superseded by this document. However, current reports to the Development Control Committees make full and frequent reference to saved policies - in other words they are not redundant or superfluous but are fully used on a day to day basis to support assessments of planning applications. They are also widely used by the Council when submitting evidence to Appeals Inspectors. By deleting these essential statements of policy we would expect them to be replaced by a stronger, direct, incontrovertible, policy document - which the proposed DPD is not. We suggest that more work is required to protect the areas previously covered by saved policies.
Full text:
This is our response to your letter dated 18 March 2011 regarding the proposed submission version of the above. We have already provided our observations on the previous draft - which have largely been ignored.
The Council's present proposals appear to be the greatest threat experienced since this Society was formed more than 60 years ago to protect the character of Undercliff Gardens. For this reason, our representations are considered to be of the highest importance.
To quote the introduction - this DPD will be used for positively managing development and will be used to assess and determine planning applications. It is a framework in which to manage the built environment and ensure successful place making. Its importance cannot therefore be overestimated.
SUMMARY OF REPRESENTATION BY SPUG
The proposed DPD reduces planning policy to principles rather than specifics, a broad brush approach providing maximum flexibility rather than specific detailed requirements. To implement this policy document will require a high level of assessment and consultation, but it is our experience that these essential qualities are rarely available. We have no confidence that this document will improve matters, and it may well prove to be a developers charter. We therefore suggest that more work is required to "tighten" up a well meaning document.
SAVED POLICIES.
Saved policies emphasise the unique character of certain areas in the Borough, but they are to be superseded by this document. However, current reports to the Development Control Committees make full and frequent reference to saved policies - in other words they are not redundant or superfluous but are fully used on a day to day basis to support assessments of planning applications. They are also widely used by the Council when submitting evidence to Appeals Inspectors. By deleting these essential statements of policy we would expect them to be replaced by a stronger, direct, incontrovertible, policy document - which the proposed DPD is not. We suggest that more work is required to protect the areas previously covered by saved policies.
SECTION 3 SEAFRONT CHARACTER ZONE.
This section acknowledges and "identifies several distinctive character zones and each has a different form and function" to quote the proposed DPD. So far so good.
On page 39, Policy Table 1 para 3 refers to one such zone. But the new principles which are to replace saved policy C12 for this zone are reduced to "development will only be acceptable where it will improve the design quality of Undercliff Gardens...and where it retains the characteristics and form of the area. Development that materially changes the existing character, appearance, and form of the area will be resisted".
Based on past experience, at best such intentions will either be unenforceable or are subjective. Who is to judge? Who is qualified to judge? Who will have the time, qualifications, or motivation to carefully consider the details of any application? This well intentioned broad brush approach is a dangerous concept in our view. We envisage endless arguments about whether an application is retaining the characteristics and form of an area, and whether the existing character, appearance, and form of the area will be changed. Who will argue on behalf of the public, the residents, and future generations? Developers are well able to argue for themselves that an application should be approved of course.
This DPD seems like a developers charter because it is possible to show that a single development does not materially change the character of an area [not a difficult argument to make] but if such a building is approved it will then become a precedent for other similar developments, often won on appeal, and the character of an area will then have been changed for ever. QED.
SUSTRANS.
Item 3iii still refers to this organisation which is no longer active. Obviously the name should be removed, and the sentence might be changed to "improve the public realm linked to improvement of the cinder path".
DETAILED CONSIDERATIONS.
Letters received by SPUG from our residents regarding this DPD may be summarised by quoting just 3 typical examples:
1. In reality, it will be its application and stewarding that we need to be concerned about.
Who will safeguard it, and will there be a body that ensures that proper monitoring
and reporting is provided? Hopefully there will be a local and national provision for this.
2. "Development that materially changes the existing character, appearance and form of the area or materially affects the benefits and amenity of neighbouring properties will be resisted."
3. "I fail to understand how planning permission was granted [for 82] allowing the property to be built further forward than the previous property. This restricts neighbours' views. The point is so blindingly obvious that I have no confidence in the planning officials responsible to put it at its mildest. Are they mad or what? It's a very large, single dwelling, isn't it?"
Many questions spring to mind regarding what is not included in a document that will be used to consider the detail of any planning application. Some may be answered by reference to the Design and Townscape Guide, but this document can, we presume, be comfortably ignored.
The same questions continually arise whenever SPUG is asked to comment on an application.
For example:
* Why is a proposed building allowed to project in front of the line of building?
* Why are balconies allowed to project in front of adjoining buildings?
* Why is development on Grand Parade frontage being allowed?
* Why is overlooking not dealt with?
* Why are the benefits and amenities of neighbouring properties not protected?
* Why are there no levels on the drawings?
* Why are the materials proposed not in accordance with the Design and Townscape Guide?
* Why is landscaping not shown?
Until such questions are answered, we remain highly concerned that this DPD is not fit for purpose
Development Management - Proposed Submission
Policy DM6 - The Seafront
Respondent: The Society for the Protection of Undercliff Gardens
Legally compliant? Not specified
Duty to co-operate? Not specified
Representation Summary:
The principles outlined in Policy Table 1 para 3 are to replace saved policy C12. Based on past experience, at best such intentions will either be unenforceable or are subjective. This well intentioned broad brush approach is a dangerous concept in our view. We envisage endless arguments about whether an application is retaining the characteristics and form of an area, and whether the existing character, appearance, and form of the area will be changed.
This DPD seems like a developers charter because it is possible to show that a single development does not materially change the character of an area [not a difficult argument to make] but if such a building is approved it will then become a precedent for other similar developments, often won on appeal, and the character of an area will then have been changed for ever.
Full text:
This is our response to your letter dated 18 March 2011 regarding the proposed submission version of the above. We have already provided our observations on the previous draft - which have largely been ignored.
The Council's present proposals appear to be the greatest threat experienced since this Society was formed more than 60 years ago to protect the character of Undercliff Gardens. For this reason, our representations are considered to be of the highest importance.
To quote the introduction - this DPD will be used for positively managing development and will be used to assess and determine planning applications. It is a framework in which to manage the built environment and ensure successful place making. Its importance cannot therefore be overestimated.
SUMMARY OF REPRESENTATION BY SPUG
The proposed DPD reduces planning policy to principles rather than specifics, a broad brush approach providing maximum flexibility rather than specific detailed requirements. To implement this policy document will require a high level of assessment and consultation, but it is our experience that these essential qualities are rarely available. We have no confidence that this document will improve matters, and it may well prove to be a developers charter. We therefore suggest that more work is required to "tighten" up a well meaning document.
SAVED POLICIES.
Saved policies emphasise the unique character of certain areas in the Borough, but they are to be superseded by this document. However, current reports to the Development Control Committees make full and frequent reference to saved policies - in other words they are not redundant or superfluous but are fully used on a day to day basis to support assessments of planning applications. They are also widely used by the Council when submitting evidence to Appeals Inspectors. By deleting these essential statements of policy we would expect them to be replaced by a stronger, direct, incontrovertible, policy document - which the proposed DPD is not. We suggest that more work is required to protect the areas previously covered by saved policies.
SECTION 3 SEAFRONT CHARACTER ZONE.
This section acknowledges and "identifies several distinctive character zones and each has a different form and function" to quote the proposed DPD. So far so good.
On page 39, Policy Table 1 para 3 refers to one such zone. But the new principles which are to replace saved policy C12 for this zone are reduced to "development will only be acceptable where it will improve the design quality of Undercliff Gardens...and where it retains the characteristics and form of the area. Development that materially changes the existing character, appearance, and form of the area will be resisted".
Based on past experience, at best such intentions will either be unenforceable or are subjective. Who is to judge? Who is qualified to judge? Who will have the time, qualifications, or motivation to carefully consider the details of any application? This well intentioned broad brush approach is a dangerous concept in our view. We envisage endless arguments about whether an application is retaining the characteristics and form of an area, and whether the existing character, appearance, and form of the area will be changed. Who will argue on behalf of the public, the residents, and future generations? Developers are well able to argue for themselves that an application should be approved of course.
This DPD seems like a developers charter because it is possible to show that a single development does not materially change the character of an area [not a difficult argument to make] but if such a building is approved it will then become a precedent for other similar developments, often won on appeal, and the character of an area will then have been changed for ever. QED.
SUSTRANS.
Item 3iii still refers to this organisation which is no longer active. Obviously the name should be removed, and the sentence might be changed to "improve the public realm linked to improvement of the cinder path".
DETAILED CONSIDERATIONS.
Letters received by SPUG from our residents regarding this DPD may be summarised by quoting just 3 typical examples:
1. In reality, it will be its application and stewarding that we need to be concerned about.
Who will safeguard it, and will there be a body that ensures that proper monitoring
and reporting is provided? Hopefully there will be a local and national provision for this.
2. "Development that materially changes the existing character, appearance and form of the area or materially affects the benefits and amenity of neighbouring properties will be resisted."
3. "I fail to understand how planning permission was granted [for 82] allowing the property to be built further forward than the previous property. This restricts neighbours' views. The point is so blindingly obvious that I have no confidence in the planning officials responsible to put it at its mildest. Are they mad or what? It's a very large, single dwelling, isn't it?"
Many questions spring to mind regarding what is not included in a document that will be used to consider the detail of any planning application. Some may be answered by reference to the Design and Townscape Guide, but this document can, we presume, be comfortably ignored.
The same questions continually arise whenever SPUG is asked to comment on an application.
For example:
* Why is a proposed building allowed to project in front of the line of building?
* Why are balconies allowed to project in front of adjoining buildings?
* Why is development on Grand Parade frontage being allowed?
* Why is overlooking not dealt with?
* Why are the benefits and amenities of neighbouring properties not protected?
* Why are there no levels on the drawings?
* Why are the materials proposed not in accordance with the Design and Townscape Guide?
* Why is landscaping not shown?
Until such questions are answered, we remain highly concerned that this DPD is not fit for purpose
Development Management - Proposed Submission
Policy DM6 - The Seafront
Respondent: The Society for the Protection of Undercliff Gardens
Representation Summary:
Table 1 Seafront Character Zones Item 3iii still refers to this organisation which is no longer active. Obviously the name should be removed.
Full text:
This is our response to your letter dated 18 March 2011 regarding the proposed submission version of the above. We have already provided our observations on the previous draft - which have largely been ignored.
The Council's present proposals appear to be the greatest threat experienced since this Society was formed more than 60 years ago to protect the character of Undercliff Gardens. For this reason, our representations are considered to be of the highest importance.
To quote the introduction - this DPD will be used for positively managing development and will be used to assess and determine planning applications. It is a framework in which to manage the built environment and ensure successful place making. Its importance cannot therefore be overestimated.
SUMMARY OF REPRESENTATION BY SPUG
The proposed DPD reduces planning policy to principles rather than specifics, a broad brush approach providing maximum flexibility rather than specific detailed requirements. To implement this policy document will require a high level of assessment and consultation, but it is our experience that these essential qualities are rarely available. We have no confidence that this document will improve matters, and it may well prove to be a developers charter. We therefore suggest that more work is required to "tighten" up a well meaning document.
SAVED POLICIES.
Saved policies emphasise the unique character of certain areas in the Borough, but they are to be superseded by this document. However, current reports to the Development Control Committees make full and frequent reference to saved policies - in other words they are not redundant or superfluous but are fully used on a day to day basis to support assessments of planning applications. They are also widely used by the Council when submitting evidence to Appeals Inspectors. By deleting these essential statements of policy we would expect them to be replaced by a stronger, direct, incontrovertible, policy document - which the proposed DPD is not. We suggest that more work is required to protect the areas previously covered by saved policies.
SECTION 3 SEAFRONT CHARACTER ZONE.
This section acknowledges and "identifies several distinctive character zones and each has a different form and function" to quote the proposed DPD. So far so good.
On page 39, Policy Table 1 para 3 refers to one such zone. But the new principles which are to replace saved policy C12 for this zone are reduced to "development will only be acceptable where it will improve the design quality of Undercliff Gardens...and where it retains the characteristics and form of the area. Development that materially changes the existing character, appearance, and form of the area will be resisted".
Based on past experience, at best such intentions will either be unenforceable or are subjective. Who is to judge? Who is qualified to judge? Who will have the time, qualifications, or motivation to carefully consider the details of any application? This well intentioned broad brush approach is a dangerous concept in our view. We envisage endless arguments about whether an application is retaining the characteristics and form of an area, and whether the existing character, appearance, and form of the area will be changed. Who will argue on behalf of the public, the residents, and future generations? Developers are well able to argue for themselves that an application should be approved of course.
This DPD seems like a developers charter because it is possible to show that a single development does not materially change the character of an area [not a difficult argument to make] but if such a building is approved it will then become a precedent for other similar developments, often won on appeal, and the character of an area will then have been changed for ever. QED.
SUSTRANS.
Item 3iii still refers to this organisation which is no longer active. Obviously the name should be removed, and the sentence might be changed to "improve the public realm linked to improvement of the cinder path".
DETAILED CONSIDERATIONS.
Letters received by SPUG from our residents regarding this DPD may be summarised by quoting just 3 typical examples:
1. In reality, it will be its application and stewarding that we need to be concerned about.
Who will safeguard it, and will there be a body that ensures that proper monitoring
and reporting is provided? Hopefully there will be a local and national provision for this.
2. "Development that materially changes the existing character, appearance and form of the area or materially affects the benefits and amenity of neighbouring properties will be resisted."
3. "I fail to understand how planning permission was granted [for 82] allowing the property to be built further forward than the previous property. This restricts neighbours' views. The point is so blindingly obvious that I have no confidence in the planning officials responsible to put it at its mildest. Are they mad or what? It's a very large, single dwelling, isn't it?"
Many questions spring to mind regarding what is not included in a document that will be used to consider the detail of any planning application. Some may be answered by reference to the Design and Townscape Guide, but this document can, we presume, be comfortably ignored.
The same questions continually arise whenever SPUG is asked to comment on an application.
For example:
* Why is a proposed building allowed to project in front of the line of building?
* Why are balconies allowed to project in front of adjoining buildings?
* Why is development on Grand Parade frontage being allowed?
* Why is overlooking not dealt with?
* Why are the benefits and amenities of neighbouring properties not protected?
* Why are there no levels on the drawings?
* Why are the materials proposed not in accordance with the Design and Townscape Guide?
* Why is landscaping not shown?
Until such questions are answered, we remain highly concerned that this DPD is not fit for purpose
Development Management - Proposed Submission
Policy DM6 - The Seafront
Respondent: The Society for the Protection of Undercliff Gardens
Legally compliant? Not specified
Duty to co-operate? Not specified
Representation Summary:
Additional wording that seeks to protect the amenity of neighbouring properties is suggested to strengthen the statement in Policy Table 1 3(ii).
Full text:
This is our response to your letter dated 18 March 2011 regarding the proposed submission version of the above. We have already provided our observations on the previous draft - which have largely been ignored.
The Council's present proposals appear to be the greatest threat experienced since this Society was formed more than 60 years ago to protect the character of Undercliff Gardens. For this reason, our representations are considered to be of the highest importance.
To quote the introduction - this DPD will be used for positively managing development and will be used to assess and determine planning applications. It is a framework in which to manage the built environment and ensure successful place making. Its importance cannot therefore be overestimated.
SUMMARY OF REPRESENTATION BY SPUG
The proposed DPD reduces planning policy to principles rather than specifics, a broad brush approach providing maximum flexibility rather than specific detailed requirements. To implement this policy document will require a high level of assessment and consultation, but it is our experience that these essential qualities are rarely available. We have no confidence that this document will improve matters, and it may well prove to be a developers charter. We therefore suggest that more work is required to "tighten" up a well meaning document.
SAVED POLICIES.
Saved policies emphasise the unique character of certain areas in the Borough, but they are to be superseded by this document. However, current reports to the Development Control Committees make full and frequent reference to saved policies - in other words they are not redundant or superfluous but are fully used on a day to day basis to support assessments of planning applications. They are also widely used by the Council when submitting evidence to Appeals Inspectors. By deleting these essential statements of policy we would expect them to be replaced by a stronger, direct, incontrovertible, policy document - which the proposed DPD is not. We suggest that more work is required to protect the areas previously covered by saved policies.
SECTION 3 SEAFRONT CHARACTER ZONE.
This section acknowledges and "identifies several distinctive character zones and each has a different form and function" to quote the proposed DPD. So far so good.
On page 39, Policy Table 1 para 3 refers to one such zone. But the new principles which are to replace saved policy C12 for this zone are reduced to "development will only be acceptable where it will improve the design quality of Undercliff Gardens...and where it retains the characteristics and form of the area. Development that materially changes the existing character, appearance, and form of the area will be resisted".
Based on past experience, at best such intentions will either be unenforceable or are subjective. Who is to judge? Who is qualified to judge? Who will have the time, qualifications, or motivation to carefully consider the details of any application? This well intentioned broad brush approach is a dangerous concept in our view. We envisage endless arguments about whether an application is retaining the characteristics and form of an area, and whether the existing character, appearance, and form of the area will be changed. Who will argue on behalf of the public, the residents, and future generations? Developers are well able to argue for themselves that an application should be approved of course.
This DPD seems like a developers charter because it is possible to show that a single development does not materially change the character of an area [not a difficult argument to make] but if such a building is approved it will then become a precedent for other similar developments, often won on appeal, and the character of an area will then have been changed for ever. QED.
SUSTRANS.
Item 3iii still refers to this organisation which is no longer active. Obviously the name should be removed, and the sentence might be changed to "improve the public realm linked to improvement of the cinder path".
DETAILED CONSIDERATIONS.
Letters received by SPUG from our residents regarding this DPD may be summarised by quoting just 3 typical examples:
1. In reality, it will be its application and stewarding that we need to be concerned about.
Who will safeguard it, and will there be a body that ensures that proper monitoring
and reporting is provided? Hopefully there will be a local and national provision for this.
2. "Development that materially changes the existing character, appearance and form of the area or materially affects the benefits and amenity of neighbouring properties will be resisted."
3. "I fail to understand how planning permission was granted [for 82] allowing the property to be built further forward than the previous property. This restricts neighbours' views. The point is so blindingly obvious that I have no confidence in the planning officials responsible to put it at its mildest. Are they mad or what? It's a very large, single dwelling, isn't it?"
Many questions spring to mind regarding what is not included in a document that will be used to consider the detail of any planning application. Some may be answered by reference to the Design and Townscape Guide, but this document can, we presume, be comfortably ignored.
The same questions continually arise whenever SPUG is asked to comment on an application.
For example:
* Why is a proposed building allowed to project in front of the line of building?
* Why are balconies allowed to project in front of adjoining buildings?
* Why is development on Grand Parade frontage being allowed?
* Why is overlooking not dealt with?
* Why are the benefits and amenities of neighbouring properties not protected?
* Why are there no levels on the drawings?
* Why are the materials proposed not in accordance with the Design and Townscape Guide?
* Why is landscaping not shown?
Until such questions are answered, we remain highly concerned that this DPD is not fit for purpose
Development Management - Proposed Submission
Policy DM6 - The Seafront
Respondent: The Society for the Protection of Undercliff Gardens
Legally compliant? Not specified
Duty to co-operate? Not specified
Representation Summary:
Many questions spring to mind regarding what is not included in a document that will be used to consider the detail of any planning application. Some may be answered by reference to the Design and Townscape Guide, but this document can, we presume, be comfortably ignored.
For example:
* Why is a proposed building allowed to project in front of the line of building?
* Why are balconies allowed to project in front of adjoining buildings?
* Why is development on Grand Parade frontage being allowed?
* Why is overlooking not dealt with?
* Why are the benefits and amenities of neighbouring properties not protected?
* Why are there no levels on the drawings?
* Why are the materials proposed not in accordance with the Design and Townscape Guide?
* Why is landscaping not shown?
Until such questions are answered, we remain highly concerned that this DPD is not fit for purpose.
Full text:
This is our response to your letter dated 18 March 2011 regarding the proposed submission version of the above. We have already provided our observations on the previous draft - which have largely been ignored.
The Council's present proposals appear to be the greatest threat experienced since this Society was formed more than 60 years ago to protect the character of Undercliff Gardens. For this reason, our representations are considered to be of the highest importance.
To quote the introduction - this DPD will be used for positively managing development and will be used to assess and determine planning applications. It is a framework in which to manage the built environment and ensure successful place making. Its importance cannot therefore be overestimated.
SUMMARY OF REPRESENTATION BY SPUG
The proposed DPD reduces planning policy to principles rather than specifics, a broad brush approach providing maximum flexibility rather than specific detailed requirements. To implement this policy document will require a high level of assessment and consultation, but it is our experience that these essential qualities are rarely available. We have no confidence that this document will improve matters, and it may well prove to be a developers charter. We therefore suggest that more work is required to "tighten" up a well meaning document.
SAVED POLICIES.
Saved policies emphasise the unique character of certain areas in the Borough, but they are to be superseded by this document. However, current reports to the Development Control Committees make full and frequent reference to saved policies - in other words they are not redundant or superfluous but are fully used on a day to day basis to support assessments of planning applications. They are also widely used by the Council when submitting evidence to Appeals Inspectors. By deleting these essential statements of policy we would expect them to be replaced by a stronger, direct, incontrovertible, policy document - which the proposed DPD is not. We suggest that more work is required to protect the areas previously covered by saved policies.
SECTION 3 SEAFRONT CHARACTER ZONE.
This section acknowledges and "identifies several distinctive character zones and each has a different form and function" to quote the proposed DPD. So far so good.
On page 39, Policy Table 1 para 3 refers to one such zone. But the new principles which are to replace saved policy C12 for this zone are reduced to "development will only be acceptable where it will improve the design quality of Undercliff Gardens...and where it retains the characteristics and form of the area. Development that materially changes the existing character, appearance, and form of the area will be resisted".
Based on past experience, at best such intentions will either be unenforceable or are subjective. Who is to judge? Who is qualified to judge? Who will have the time, qualifications, or motivation to carefully consider the details of any application? This well intentioned broad brush approach is a dangerous concept in our view. We envisage endless arguments about whether an application is retaining the characteristics and form of an area, and whether the existing character, appearance, and form of the area will be changed. Who will argue on behalf of the public, the residents, and future generations? Developers are well able to argue for themselves that an application should be approved of course.
This DPD seems like a developers charter because it is possible to show that a single development does not materially change the character of an area [not a difficult argument to make] but if such a building is approved it will then become a precedent for other similar developments, often won on appeal, and the character of an area will then have been changed for ever. QED.
SUSTRANS.
Item 3iii still refers to this organisation which is no longer active. Obviously the name should be removed, and the sentence might be changed to "improve the public realm linked to improvement of the cinder path".
DETAILED CONSIDERATIONS.
Letters received by SPUG from our residents regarding this DPD may be summarised by quoting just 3 typical examples:
1. In reality, it will be its application and stewarding that we need to be concerned about.
Who will safeguard it, and will there be a body that ensures that proper monitoring
and reporting is provided? Hopefully there will be a local and national provision for this.
2. "Development that materially changes the existing character, appearance and form of the area or materially affects the benefits and amenity of neighbouring properties will be resisted."
3. "I fail to understand how planning permission was granted [for 82] allowing the property to be built further forward than the previous property. This restricts neighbours' views. The point is so blindingly obvious that I have no confidence in the planning officials responsible to put it at its mildest. Are they mad or what? It's a very large, single dwelling, isn't it?"
Many questions spring to mind regarding what is not included in a document that will be used to consider the detail of any planning application. Some may be answered by reference to the Design and Townscape Guide, but this document can, we presume, be comfortably ignored.
The same questions continually arise whenever SPUG is asked to comment on an application.
For example:
* Why is a proposed building allowed to project in front of the line of building?
* Why are balconies allowed to project in front of adjoining buildings?
* Why is development on Grand Parade frontage being allowed?
* Why is overlooking not dealt with?
* Why are the benefits and amenities of neighbouring properties not protected?
* Why are there no levels on the drawings?
* Why are the materials proposed not in accordance with the Design and Townscape Guide?
* Why is landscaping not shown?
Until such questions are answered, we remain highly concerned that this DPD is not fit for purpose
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