CLA response to the South Downs National Park Authority - Local Plan Preferred Options

The CLA has responded to the Preferred Options Consultation on the South Downs National Park Authority Local Plan.

Strategic Policies SD20:  Sustainable Tourism and the Visitor Economy

•             CLA is concerned that the SDNPA maintain the requirement for development to be reliant on public transport and other sustainable means of transport. 

The National Policy Statement for National Networks published in January 2015 for the Department for Transport produced guidance stating that “...it is not realistic for public transport, walking or cycling to represent a viable alternative to the private car for all journeys, particularly in rural areas....”. In addition the NPPF sets out at Section 4 Promoting sustainable transport, paragraph 29, that the “Government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas”.

This distinction is also picked up NPPF paragraph 34.

The NPPF also reflects that there are different policies and measures required in different communities and that “...opportunities to maximise sustainable transports solutions will vary from urban to rural areas.” See paragraph 29 and further reinforced at paragraph 34.

•             Given that the SDNP is predominately a rural area, this Policy should recognise that the use of private vehicles is inevitably the primary practical mode of transport.  Particularly where public transport is not available or limited.

•             CLA is pleased that the reuse of existing buildings is encouraged and redundant/semi redundant agricultural buildings are a plentiful and underutilised resource in the National Park, this therefore should be recognised through the planning process when applications are made.

•             Point 5 is non-specific and we have great concerns that this would be used to refuse permission on the basis of some adverse impact even where the net impact would be positive overall for the National Park and its economy as a whole.  Any development could be seen to have some adverse impact, but the overall net impact should be the overall consideration.  Clarification is needed.

 Strategic Policy SD21:  Recreation

•             CLA is concerned that the SDNPA maintain the requirement for  development to be reliant on public transport and other sustainable means of transport. 

The National Policy Statement for National Networks published in January 2015 for the Department for Transport produced guidance stating that “...it is not realistic for public transport, walking or cycling to represent a viable alternative to the private car for all journeys, particularly in rural areas....”. In addition the NPPF sets out at Section 4 Promoting sustainable transport, paragraph 29, that the “Government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas”.

This distinction is also picked up NPPF paragraph 34.

The NPPF also reflects that there are different policies and measures required in different communities and that “...opportunities to maximise sustainable transports solutions will vary from urban to rural areas.” See paragraph 29 and further reinforced at paragraph 34.

•             Given that the SDNP is predominately a rural area, this Policy should recognise that the use of private vehicles is inevitably the primary practical mode of transport.  Particularly where public transport is not available or limited.

•             CLA is pleased that the reuse of existing buildings is encouraged and redundant/semi redundant agricultural buildings are a plentiful and underutilised resource in the National Park, this therefore should be recognised through the planning process when applications are made.

 Strategic Policy SD22:  Development Strategy

•             CLA is pleased that the reuse of existing buildings is encouraged and redundant/semi redundant agricultural buildings are a plentiful and underutilised resource in the National Park, this therefore should be recognised through the planning process when applications are made.

•             The CLA is encouraged by the recognition of the need for development within country estates and the contribution that these numerous and significant businesses across the National Park make.

 

Strategic Policy SD27: Sustaining the Rural Economy

•             CLA encourage the support for small and local businesses and would wish to see Agriculture included in the key sectors for priority support – as stated on page 269 of this document that Agriculture is a “crucial part of the National Park’s economy”

•             CLA would encourage the siting of employment development on brown field sites such as former agricultural units where the agricultural business has developed to leave building underutilised.

•             The vital economic importance of high quality broadband and mobile connectivity needs to be recognised. The SDNPA must acknowledge that in order to maintain a diverse and economically sustainable rural economy it will mean that infrastructure is required to service this area which could be in the form of broadband, Wifi repeaters (masts & dishes), mobile phone masts (4g & 5g) and other hard infrastructure.  Rather than potentially restricting residence and businesses from communication infrastructure because of the perceived harm to the landscape we believe the SDNPA should encourage better design of such infrastructure to reduce its impact.

 Development Management policy SD44:  Replacement dwellings, extension and annexes

•             CLA is supportive of the recognition of the need for replacement dwellings in the right circumstances as well as the extension and annexing of existing dwellings.

 

Development Management policy SD45: Agriculture and forestry

•             CLA encourages the SDNPA to take a sensible and flexible approach to the application of Permitted Development Rights (PDR) where they apply. 

•             Point 8 relating to the dismantling of structures is impractical and unworkable and should be removed.  Determining the end of a use is would be virtually impossible.  We cannot see that this policy holds any grounds within National guidance.  The usual rules of abandonment should apply.

 Development Management policy SD46:  Farm Diversification

•             CLA reminds the SDNPA that point 10.99 of the supporting text on page 276 states that “Farming is the principal land use in the South Downs National Park and helps sustain its special qualities”, without the flexibility and support to diversify it could stifle the viability of an important business sector.

•             CLA questions the need for a farm plan to be submitted with an application of diversification, due to the sensitive nature of business information and the significant level of work required to produce such documentation with no tangible benefit. 

•             The Policy should recognise the entrepreneurial skill of rural business owners and the wide variety of diversified business streams entered into by farm business in particular.  CLA are concerned to see a prescriptive list permissible diversification project which the SDNPA have deemed appropriate.

 

Development Management policy SD47:  Rural Workers’ Dwellings

•             CLA wants to see in practice a sensible approach to the requirement for the proof of need for agricultural workers dwellings as experience has proven that this process has been cumbersome, over examined and rejected often without reasoned judgement.

•             The availability of alternative accommodation should be considered on the basis of appropriateness and affordability neither of which have been taken into consideration within this Policy drafting.

•             CLA would draw the SDNPA attention to the special position of rural worker housing, which is always restricted in its occupation and exclude this type of dwelling from your CIL charging schedule. Our view is that the CIL should not apply to these dwellings, which will have been justified as a requirement for the specific business such as agricultural, forestry and other essential rural enterprises. Such properties are not sold for development gain and are usually restricted by some form of occupancy condition which has already had a negative impact on the value of the development.

 Development Management policy SD48:  Conversion of Agricultural Buildings

•             CLA wishes to have clarification of point b...“is not in a wholly isolated location from infrastructure, amenities and services”.  Agricultural farmsteads are typically isolated and away from many community services but are well established and form a part of the landscape.

•             Whilst the CLA recognise the desire not to substantially reconstruct existing agricultural buildings, this Policy should not restrict the need to make best use of modern energy efficiencies and design.

•             The retention of existing building elements should not prejudice the scope for building improvement particularly, the higher level of the building craftsmanship available.

 Development Management policy SD49:  Equestrian Buildings

•             CLA acknowledges that the draft plan on sustainable transport recognised the importance of equestrian use as sustainable in Policies SD18 and SD19.   We therefore would expect a positive approach to planning in respect of equestrian uses.