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Publication Draft
DS4 Spatial Strategy
Representation ID: 66134
Received: 27/06/2014
Respondent: La Salle Investments
Agent: Harris Lamb
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy not sound due to criterion A, C and G of the policy. Parts A & C advise that new employment development will, in the first instance, be directed to previously developed land in the urban area and where greenfield sites are required for employment they should be allocated in accessible locations in close proximity to existing or proposed housing. This does not address the unique circumstances in the District where a number of significant previously developed sites are located in the green belt including Stoneleigh Park. In para 3.157 onwards the Council supports the unique role of the Park and its economic benefits and notes that a review of the master plan may be needed during the plan period. However A to C as drafted would direct development away from the park. Additional text should be included within the explanation to advise that this doesnt apply to previously developed land in the green belt. Criteria G advises that development in the green belt will be limited to locations where exceptional circumstances can be justified. This test only applies in the plan making process when local authorities are in the process of altering green belt boundaries. It is therefore inappropriate for criteria g to refer to exceptional circumstances. Instead it should advise that the construction of new buildings in the green belt will be considered as inappropriate with the following exceptions:
* Buildings for Agricultural and Forestry
* Provision of appropriate facilities for outdoor sport, outdoor recreation and cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes including land within it;
* The extension or alteration of a building providing that it does not result in disproportionate additions over and above the size of the original building
* Replacement of a building provided the new building is in the same use and not materially larger than the one it replaces.
* Limited infilling in villages, and limited affordable housing for local community needs in accordance with wider policies in the Local Plan; or
* Limited infilling or the partial or complete redevelopment of previously developed sites (Brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have greater impact on the openness of the Green Belt and the purposes of including the land within it than the existing development. The previously developed sites in the Green Belt include those identified by Local Plan Policy LS2 - Major Site in the Green Belt.
* In all other circumstances it will be necessary for an applicant to demonstrate "very special circumstances" for development in the Green Belt to be considered acceptable.
see attached
Object
Publication Draft
EC1 Directing New Employment Development
Representation ID: 66229
Received: 27/06/2014
Respondent: La Salle Investments
Agent: Harris Lamb
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
In the event that a specific policy for Stoneleigh Park is included in the plan as requested a cross reference to this should be included in Policy E1.
see attached
Object
Publication Draft
CT1 Directing New Tourism, Leisure and Cultural Development
Representation ID: 66230
Received: 27/06/2014
Respondent: La Salle Investments
Agent: Harris Lamb
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The approach of CT1 does not reflect the NPPF specifically paragraph 28 that advises to support a strong rural economy local plans should support sustainable rural tourism and leisure developments. This should support the provision and expansion of tourist and visitor facilities at appropriate locations where identified needs are not met by existing facilities in rural service centres. Stoneleigh Park is a major tourist attraction as paragraph 3.114 confirms. As drafted CT1 would direct new improved tourism and leisure developments away from Stoneleigh Park.
see attached
Object
Publication Draft
CT2 Directing New or Extended Visitor Accommodation
Representation ID: 66233
Received: 27/06/2014
Respondent: La Salle Investments
Agent: Harris Lamb
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
No specific concerns regarding the approach of Policy CT2, however, it fails to take account of the unique circumstances affecting Stoneleigh Park. Stoneleigh Park holds numerous shows and conferences taking place in the site throughout the year where it is necessary for people to stay on the site overnight. The existing hotel has limited capacity and outline planning permission has been granted for a larger hotel on site. Outline planning permission is in place for the development of new and extended camping facilities. However any further applications would be determined in the context of CT2 therefore to add additional clarity additional text should be included to cross reference to the proposed new policy and its guidance on visitor accomodation on the site.
see attached
Object
Publication Draft
CT4 Extensions to Tourism, Cultural or Leisure Facilities in Rural Areas
Representation ID: 66234
Received: 27/06/2014
Respondent: La Salle Investments
Agent: Harris Lamb
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The general approach of the policy is supported however part B needs to be amended. In line with the NPPF Part B of policy should not seek to prevent rural tourism, cultural or leisure developments, simply because they generate significant volumes of additional traffic if that traffic can be mitigated against and does not result in "severe" residual cumulative impacts.
see attached
Object
Publication Draft
MS2 Major Sites in the Green Belt
Representation ID: 66238
Received: 27/06/2014
Respondent: La Salle Investments
Agent: Harris Lamb
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Generally supportive of Policy MS2 and recognition that limited infilling and the redevelopment of previously developed sites in the Green Belt is appropriate as set out in the NPPF. However it provides limited guidance on the form and nature of development the local authority will consider appropriate at Stoneleigh Park. THe current adopted plan includes a specific policy which the previous local plan inspector confirmed was required due to the significant scale of Stoneleigh Park, the fact it has a Royal Charter and its unique development position. Policy MS2 should be amended to cross refer to a new policy guiding the development of Stoneleigh Park. Support reference that there may be very special circumstances to support further development at Stoneleigh Park given its unique nature. Whilst having a masterplan or development brief to deal with this is desirable it is not essential and could be dealt with through a planning application if necessary.
see attached
Object
Publication Draft
Major Sites in the Economy
Representation ID: 66248
Received: 27/06/2014
Respondent: La Salle Investments
Agent: Harris Lamb
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
There is no policy to guide future development at Stoneleigh Park. This is inappropriate as:
There may be a need to revisit the masterplan application during the plan period. However, there is no specific guidance in the emerging Plan to confirm the scale, type and nature of uses which are appropriate at Stoneleigh Park. It is likely that a review of the masterplan will be necessary if HS2 comes forward as a significant proportion of the north east section of Stoneleigh Park is within the safeguarding area. The previous Local Plan had a policy which the inspector deemed necessary due to the sites size, and the unique circumstances of the Royal Charter under which it operates. The policy should reflect the range of uses that the outline Masterplan planning permision puts in place.
see attached
Support
Publication Draft
CC2 Planning for Renewable Energy and Low Carbon Generation
Representation ID: 66249
Received: 27/06/2014
Respondent: La Salle Investments
Agent: Harris Lamb
We welcome the inclusion of a policy that provides guidance on the delivery of renewable energy development. Specifically, we support the reference in the policy to the Local Authority supporting the principle of renewable energy generation technologies.
see attached