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Publication Draft
EC1 Directing New Employment Development
Representation ID: 66034
Received: 26/06/2014
Respondent: NFU
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy EC1 requires applicant to demonstrate that a proposal "would not generate significant traffic movements which would compromise the delivery of wider sustainable transport objectives, including safety, in accordance with TR2". We would be concerned if a proposal for a rural business were rejected because of the perception that the business is unsustainable because potential clients would access the service via car transport.
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Object
Publication Draft
DS19 Green Belt
Representation ID: 66216
Received: 26/06/2014
Respondent: NFU
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Does not refer to agricultural and rural businesses located in the Green Belt. Green Belt policy should be more flexible to allow rural businesses to develp and evolve, which will help safeguard their long term viability.
Agricultural business located within greenbelt have to respond to the same pressures to comply with higher welfare and environmental management standards in the same way as those businesses located in other areas of the county.
It should also recognise that farming businesses have an essential role in maintain the local landscape.
see attached
Object
Publication Draft
H12 Housing for Rural Workers
Representation ID: 66218
Received: 26/06/2014
Respondent: NFU
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Unreasonable to include the size restriction outlined in section 4.83.
The 140sq.m includes garaging which in reality makes the residential floor space even smaller.
This size limit is at odds with the new permitted development rights, whereby farmers can convert redundant agricultural buildings to up to three C3 residential units with a total floor space of 450m2. Therefore we think that it is out of step to attempt to restrict rural workers dwellings to 140sq.m
When new dwellings are constructed for farm businesses it is important that they are large enough to cope with the many demands of the farm business, together with the needs of a farming family.
It is also important to recognise that an agricultural dwelling must be flexible enough to accommodate families at a range of life stages.
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Object
Publication Draft
HS3 Local Green Space
Representation ID: 66219
Received: 26/06/2014
Respondent: NFU
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Concerned that as it currently worded there appears to be a risk that agricultural land could be designated as Local Green Space.
We are concerned about the impacts of this policy farm businesses, particularly those that operate in the urban fringe or for those who already have issues with trespass.
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Support
Publication Draft
Flooding and Water
Representation ID: 66220
Received: 26/06/2014
Respondent: NFU
With the exception of FW1 (f) we are broadly supportive of the Councils approach to flooding and water. The paper highlights the importance of resilience and this is a key issue for farmers and growers in the district. Large new developments in urban areas do have the potential to cause downstream impacts, even when new SUDs techniques are employed. It is important to recognise that farmers have to deal with these impacts as they are responsible for maintaining many of the area's watercourses and drainage infrastructure. Waterlogging and flooding has the potential to directly impact upon the productivity of agricultural land so it is important to value and maintain our existing drainage infrastructure.
see attached
Object
Publication Draft
FW1 Development in Areas at Risk of Flooding
Representation ID: 66221
Received: 26/06/2014
Respondent: NFU
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We are very concerned about Point f "the site is not required for washland creation as part of overall flood defence strategy for river catchments" and the section that says "land that is required for current and future flood management will be safeguarded from development". We can find no justification or explanation for this policy within the plan.
We would like more information on the definition of 'washland' as a concept.
We would like more information on the definition of 'washland' as a concept. In flood risk management 'washland' is defined both as:
* an area of the floodplain that is allowed to flood or
* where it is deliberately flooded by a river or stream for flood management purposes.
Washland usually refers to an area which is deliberately flooded to protect people property elsewhere and that this requires a project to control the storage of water and its inflow and outflow into that storage area. This would usually be via an agreement with the landowner or if the land was owned by the local authority. We would assume that this policy would require land to be clearly earmarked for a deliberately engineered flood storage scheme rather than more general designation of the floodplain.
see attached
Support
Publication Draft
FW2 Sustainable Urban Drainage
Representation ID: 66222
Received: 26/06/2014
Respondent: NFU
We agree that new development sites should have land earmarked for SUDs so that surface water runoff can be captured and managed. It is important that the downstream impacts of schemes are thoroughly investigated. This is particularly important as some local watercourses are suffering from a lack of maintenance which impedes their ability to cope with additional surface water flows. High peak flows and flash floods must also be considered as often the existing infrastructure cannot cope and an increase in impermeable surfaces may make this worse. It is vital that that adequate water resources and drainage capacity is available to cope with any new demands placed on the county's natural infrastructure.
see attached
Object
Publication Draft
NE1 Green Infrastructure
Representation ID: 66223
Received: 26/06/2014
Respondent: NFU
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Farmers and landowners must be fully engaged with discussions on Green Infrastructure as they own and manage many of the districts key Green Infrastructure assets.
Previous studies have shown that agricultural businesses routinely invest in landscape management and enhancement works for example hedging, tree planting, cutting and grazing. For many farmers the landscape management and biodiversity enhancements on their farms are a source of great pride and it does them a disservice to not have this aspect of land management recognised by this document. Farmers who do not (for a variety of reasons) participate in agri-environment schemes also make valid contributions. The work of the Campaign for the Farmed Environment (www.cfeonline.org.uk) has shown that these farms use a range of voluntary techniques to enhance the options and that this management is funded by farm businesses.
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