Section 3
Replies and Comments to the Regulation 14 Pre–submission Consultation Exercise
North Kesteven District Council – Regulation 14 Comments
- Introduction
North Kesteven District Council (NKDC) was consulted on the pre-submission draft of the Bracebridge Heath Neighbourhood Plan (BHNP).
Firstly, NKDC would like to congratulate the BHNP Steering Group on the work they have undertaken to date. A lot of time and effort has clearly gone into the production of the plan and into the evidence and consultation that has underpinned it.
It is also clear that comments provided on previous drafts by officers at NKDC have been taken into account in finalising this plan for consultation and this is welcomed.
- Conclusion
Overall, it is considered that the Bracebridge Heath Neighbourhood Plan, subject to the below comments and recommendations, meets the basic conditions as required by regulations. It is considered that the recommended changes below can be made without the need for re-consulting in advance of the plan being submitted to NKDC.
Review of the draft Neighbourhood Plan
This section provides a detailed review of the document being consulted on at the pre-submission stage. Where relevant it includes comments about the basic conditions and suggestions for proposed wording changes.
- Plan period
NKDC comments
What is the rationale behind the 21 year plan period of 2020-2041? It’s not necessarily a problem, but it doesn’t correspond to the Local Plan timeframe, nor the proposed new plan period which is proposed to run until 2040 and this is unusual. It is noted that this had changed from a 2040 end date since the last draft NKDC commented on.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Altered to 2040 to give a 20 year life span.
- Introduction Para 3
NKDC Comments
This paragraph is internally conflicting in that it says that the plan sets out planning polices for a 17 year period, yet the plan period is stated as 2020-2041.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Error rectified.
- Introduction Para 4
NKDC Comments
This paragraph refers to the map of the parish in Figure 1, but it is labelled as Map 1
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Changed to read map 1.
- Paras 1.7 & 1.8
NKDC Comments
The local proportion of the CIL receipts should still be available to the parish despite commitments for the wider CIL funds to the bypass and secondary education. As such, it is recommended that these two paragraphs are reworded to reflect this. Please contact the NKDC planning department if you have any questions about any CIL receipts in your parish.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Reworded
- Para 2.1
NKDC Comments
It is recommended that you add “(as amended)” to the end of the paragraph to reflect the fact that the regulations have been updated.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
‘as amended’ added to script.
- Para 2.2
NKDC Comments
The statement in the last sentence of this paragraph, which says that the plan will become a material consultation after it goes through the second round of consultation is inaccurate. It is for the decision maker to determine the weight that can be attributed to emerging plans and this can be informed by a number of factors including the stage of preparation of the plan and the extent to which there are unresolved objections to relevant policies.
The earlier parts of the paragraph also stand out against the wider text. Whilst it is recognised that this is intended to be written in the past tense referring to current future stages, it does stand out against neighbouring paragraphs in the plan. It is recommended that this paragraph is revised to something along the lines of the following:
“Following the statutory six week pre-submission consultation running from January 20th 2020 to March 2nd 2020, the Bracebridge Heath Neighbourhood Plan will be submitted to North Kesteven District Council and the plan will then be subject to a second six week consultation.”
The earlier parts of the paragraph also stand out against the wider text. Whilst it is recognised that this is intended to be written in the past tense referring to current future stages, it does stand out against neighbouring paragraphs in the plan. It is recommended that this paragraph is revised to something along the lines of the following:
“Following the statutory six week pre-submission consultation running from January 20th 2020 to March 2nd 2020, the Bracebridge Heath Neighbourhood Plan will be submitted to North Kesteven District Council and the plan will then be subject to a second six week consultation.”
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Changed wording to improve accuracy.
- Para 2.3
NKDC Comments
Similarly to the comments against paragraph 2.3 above there are some slight factual inaccuracies that should be addressed. It is recommended that it be reworded along the following lines:
“The Neighbourhood Plan will be subjected to an independent examination and it will then go to a local referendum. If it is successful at referendum decisions on planning applications will be decided against the Bracebridge Heath Neighbourhood Plan as part of the wider Development Plan alongside the Central Lincolnshire Local Plan.”
“The Neighbourhood Plan will be subjected to an independent examination and it will then go to a local referendum. If it is successful at referendum decisions on planning applications will be decided against the Bracebridge Heath Neighbourhood Plan as part of the wider Development Plan alongside the Central Lincolnshire Local Plan.”
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Changed wording to improve accuracy.
- Policy 1
NKDC Comments
This policy is considered to meet the basic conditions. To be more aligned to the national definition of ‘major’ development, the threshold in this policy could refer to schemes that are “for 10 or more dwellings or with a site area of 0.5 hectares or more”.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Added the hectare size to the statement.
- Policy 2
NKDC Comments
Whilst this policy is generally considered to meet the basic conditions, there are some minor adjustments needed to improve its clarity and to align it to Local Plan policy.
Some of the wording in the bulleted lists under part 2 of the policy do not flow with the preceding text, i.e. it currently says “To achieve this the new development should:…b. ensuring…c. respecting… d. providing…e. ensuring…f. bin, recycling…” This should be “b. ensure…”, “c. respect…”, “d. provide…”, “e. ensure…”, and “include adequate bin, recycling…”
Some of the wording in the bulleted lists under part 2 of the policy do not flow with the preceding text, i.e. it currently says “To achieve this the new development should:…b. ensuring…c. respecting… d. providing…e. ensuring…f. bin, recycling…” This should be “b. ensure…”, “c. respect…”, “d. provide…”, “e. ensure…”, and “include adequate bin, recycling…”
Part 2e of the policy is at odds with Policy LP24 of the adopted Local Plan. If this policy were to be included in the final plan it would introduce conflict between the two policies. It is recommended that this part of the policy is deleted and the Local Plan policy is relied upon.
In part 2f of the policy, screening is not always the best or only way of accommodating waste storage sensitively. This would be better if worded as
“f. include adequate bin, recycling and green waste storage in the design of the scheme with screening provided where necessary.”
“f. include adequate bin, recycling and green waste storage in the design of the scheme with screening provided where necessary.”
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Changed wording as suggested.
Removed part 2e to avoid conflict with CCLP and will rely on policy LP24.
Amended part 2f wording to that suggested.
Policy 3
NKDC Comments
This policy is generally considered to meet the basic conditions.
Under point 2 of the policy where it references the table under paragraph 7.7 it would be preferable to have the table replicated in the policy itself. The wording could be amended to: “Adequate car parking should be provided for the proposed scheme in relation to the main building access point(s). For residential development this should be provided on-plot and at the following ratios:” [insert table below].
This would both allow for the general parking point to apply to all uses and to introduce the standards for residential developments.
It would also be useful if the evidence behind the car parking standards were presented at paragraph 7.7, such as census data for car ownership or survey work findings, unless it is clearly going to be included within supporting documentation.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
The wording within policy 3 was amended and the table placed within policy. Paragraph 7.7 was amended and some evidence included.
Policy 4
NKDC Comments
NKDC Comments
This policy is considered to meet the basic conditions.
In the first bullet point under part 1 of the policy, it would assist clarity if “for car parking” were added to the end of the point.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Added suggested wording.
Policy 5
NKDC Comments
This policy is considered to meet the basic conditions.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Nil
Policy 6
NKDC Comments
There are some detailed wording issues that require attention to assist in it being sufficiently clear for decision makers and to make it consistent with national policy.
Firstly there is inconsistent terminology for the heritage assets in Appendix B. This should be resolved so that only one term is used for them wherever they are mentioned. The normal term used is “non-designated heritage asset”. [See also comments against Appendix B in terms of qualifying for the NKDC list of non-designated heritage assets].
Secondly, part one of the policy is at odds with the NPPF, specifically paragraphs 197 and 184. This part of the policy seeks to apply a protection that is beyond that appropriate to the assets’ significance. The intent of this part of the policy is covered by the provisions under part 3 of the policy and as such part 1 should be removed.
Part 2 of the policy would also benefit from a minor rewording for clarity. Assuming the above changes are made “locally significant heritage asset” should be amended to just “heritage asset”.
Firstly there is inconsistent terminology for the heritage assets in Appendix B. This should be resolved so that only one term is used for them wherever they are mentioned. The normal term used is “non-designated heritage asset”. [See also comments against Appendix B in terms of qualifying for the NKDC list of non-designated heritage assets].
Secondly, part one of the policy is at odds with the NPPF, specifically paragraphs 197 and 184. This part of the policy seeks to apply a protection that is beyond that appropriate to the assets’ significance. The intent of this part of the policy is covered by the provisions under part 3 of the policy and as such part 1 should be removed.
Part 2 of the policy would also benefit from a minor rewording for clarity. Assuming the above changes are made “locally significant heritage asset” should be amended to just “heritage asset”.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Terminology checked and altered as required.
Part 1 of the policy removed.
Removed ‘locally significant’ from part 2 and part 3.
Removed ‘locally significant’ from part 2 and part 3.
Policy 7
NKDC Comments
This policy is considered to meet the basic conditions. It would be preferable for the marketing period in this policy to be 6 months, consistent with policy 8.Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Changed marketing period from 9 months to 6 months.
Policy 8
NKDC Comments
This policy is considered to meet the basic conditions.
After 1a, the “and” should be directly following the bullet point not in the subsequent line.
After 1a, the “and” should be directly following the bullet point not in the subsequent line.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Changed the setting out as suggested.
Policy 10
NKDC Comments
This policy is considered to meet the basic conditions.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Nil
Policy 11
NKDC Comments
This policy is considered to meet the basic conditions, however in order to make it clear that all of the bullet points apply, an “and” should be inserted after the second bullet point.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Inserted the word ‘and’.
Policy 12
NKDC Comments
The wording of part 2 of this this policy is currently quite messy and this makes it unclear for how it should be applied. The main issue is the definition of ‘community uses’ under paragraph 12.6 of the supporting text, which currently incudes specific businesses as well as uses. Planning cannot protect specific businesses from changes, only the use (in terms of the Use Class) itself. Therefore, for example, a policy cannot protect a car service company from change to another business, but can help to ensure that it remains in B2 use.
In order for such a protective policy to be included it needs to spell out which facilities it is protecting and use a far narrower list of uses. It is recommended that the wording be amended to:
“Proposals for the redevelopment of or change of use of a valued community facility listed in paragraph 12.6 must demonstrate that either:
In order for such a protective policy to be included it needs to spell out which facilities it is protecting and use a far narrower list of uses. It is recommended that the wording be amended to:
“Proposals for the redevelopment of or change of use of a valued community facility listed in paragraph 12.6 must demonstrate that either:
- A suitable replacement community facility provided in a suitable location within the parish; or
- It can be demonstrated that the community facility is no longer fit for purpose or is not economically viable for community use.”
- It can be demonstrated that the community facility is no longer fit for purpose or is not economically viable for community use.”
After this second bullet point it could be beneficial to include a marketing requirement as per policy 8, i.e. amending it to “It can be demonstrated beyond reasonable doubt that the existing use is economically unviable and that at least 6 months of actively marketing the site has not provided another community use or that the community facility is no longer fit for purpose.”
The list under para 12.6 of the supporting text will also need to be rationalised for this wording to work, removing (possibly amongst others) home based child minders, small home based businesses, the specific businesses at St John’s Craft Workshops, and car services within Sleaford Road industrial estate.
Once this change is made it is considered that this policy will meet the basic conditions and will be deliverable.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Wording changed as suggested. Industry based items at St John’s Workshop have been removed as suggested.
Policy 13
NKDC Comments
This policy is considered to meet the basic conditions.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Nil
Policy 14
NKDC Comments
This policy is considered to meet the basic conditions.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Nil
Map 6
NKDC Comments
The key to Map 6 includes “South East Quadrant proposed green areas”. There is no explanation for what these areas are, what their source is and what they mean. This introduces ambiguity to the map and so it is recommended that it is either removed from the map, or some explanatory text (possibly a footnote) is provided to provide this clarity.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Further wording has been added to the key.
Policy 16
NKDC Comments
This policy is generally considered to meet the basic conditions but it does need some minor changes to make it clear and deliverable.
The “or” after the first bullet point under part 1 should be moved up to follow the bullet point directly.
Under part 2, how would a decision maker determine if an open space is of high quality? What is an integrated strategic green infrastructure system (it is much higher level than an individual open space? Should all open spaces be capable of accommodating formal play? Does each open space need to provide a variety of natural and designed landscapes with different functions? It is noted that many of these terms are included in the new National Design Guidance published in 2019, but the creation of policy comes from a different perspective as it seeks to apply to many applications of a variety of types and scales.
Perhaps part 2 would be more deliverable if it were worded along the following lines:
“Proposals for new open spaces or improvements to existing open spaces will be supported. Open spaces should be high quality and designed to satisfy the following criteria wherever suitable and relevant:
- robust and adaptable over time;
- accessible to all users;
- provide opportunities for formal and/or informal play and exercise;
- incorporate natural features such as trees and other vegetation to create opportunities for biodiversity net gains and linking into the wider green infrastructure network, whilst creating an attractive natural landscape; and
- well-considered plan to reduce the ongoing costs for management and maintenance of the open space.”
Perhaps part 2 would be more deliverable if it were worded along the following lines:
“Proposals for new open spaces or improvements to existing open spaces will be supported. Open spaces should be high quality and designed to satisfy the following criteria wherever suitable and relevant:
- robust and adaptable over time;
- accessible to all users;
- provide opportunities for formal and/or informal play and exercise;
- incorporate natural features such as trees and other vegetation to create opportunities for biodiversity net gains and linking into the wider green infrastructure network, whilst creating an attractive natural landscape; and
- well-considered plan to reduce the ongoing costs for management and maintenance of the open space.”
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Wording amended to that suggested.
Policy 17
NKDC Comments
This policy is considered to meet the basic conditions.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Nil
Policy 18
NKDC Comments
This policy is considered to meet the basic conditions.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Nil
Policy 19
NKDC Comments
This policy is considered to meet the basic conditions.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Nil
Appendix B
NKDC Comments
North Kesteven District council maintains a list of non-designated heritage assets and has recently adopted criteria for the inclusion of buildings and sites on the list, the criteria being available to view here:
https://www.n-kesteven.gov.uk/residents/planning-and-building/planning/conservation-and-heritage/local-list-of-non-designated-heritage-assets/
The NKDC Local List for the parish of Bracebridge Heath was last revised in 1991 and while there are some sites which are common both to that list and to the list in the draft Neighbourhood Plan’s Appendix B, there are others which are not. Your Neighbourhood Plan provides an opportunity to update the non-designated heritage assets list that can then be endorsed at a district level as well as at parish level.
Having a list of properties in Appendix B that does not meet the criteria for local listing of non-designated heritage assets adopted at district level could be problematic and it is strongly recommended that the list of properties in Appendix B be revised to only include properties that meet the criteria. This would then allow for consistent terminology and treatment of the heritage assets in a robust fashion.
In order to assist the Steering Group with understanding which properties meet the criteria for local listing, officers at NKDC have assessed them and this assessment is provided in the Tables in Appendix A below. The majority of the properties do meet the criteria.
In order to be consistent with the items on the NKDC list, locations of items to be included as non-designated heritage assets should be given as the full postal address.
If there are any questions or concerns with the proposed change of approach for which properties should be identified, please contact the Council.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Removed the following from the non-designated heritage asset section to conform with NKDC’s updated list:
Methodist Church
Heath View
Stephenson’s Cottages
17-31 Sleaford Road cottages
St John’s Hospital Craft Workshops have been left in, on a section on their own to clarify that although they are not listed separately they are classified as part of the listed hospital buildings.
Postal addresses have been added. (First line address and Post Code.).
Appendix B heritage maps updated.
Church Commissioners Comments
- 5.1 vision / 6.1 objectives
Church Commissioners Comments
2.4 The Commissioners are broadly supportive of the intention of the Vision and Objectives set out within Section 5 and 6 of the Draft Plan. However, we have specific comments around how these objectives have been translated into individual policies, particularly the references to green buffer zones, and address these subsequently.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
- 7.7 housing growth
Church Commissioners Comments
2.6 Whilst not a specific policy, Paragraph 7.7 is referenced in Policy 3: Car Parking and Electric Charging Points. The above pre-amble to the Housing Growth policies sets out very specific development requirements on a matter which should be given consideration in the context of an individual proposed development and site specific analysis and assessment.
2.10 The Draft Plan does not provide any evidence to justify how the specific parking requirements have been determined. Therefore, for the pre-amble text to apply such prescriptive requirements to car parking provision, and not tailored to a specific development, would be inconsistent with national and local policy and should be removed
2.10 The Draft Plan does not provide any evidence to justify how the specific parking requirements have been determined. Therefore, for the pre-amble text to apply such prescriptive requirements to car parking provision, and not tailored to a specific development, would be inconsistent with national and local policy and should be removed
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted.
Table included in policy and paragraph 7.7 altered to include evidence why parking space criteria has been applied.
The SEA/HRA document considers this policy is compatible with the Central Lincolnshire Local Plan.(CLLP)
Table included in policy and paragraph 7.7 altered to include evidence why parking space criteria has been applied.
The SEA/HRA document considers this policy is compatible with the Central Lincolnshire Local Plan.(CLLP)
- Policy 3
Church Commissioners Comments
2.26 The Draft Plan does not provide any evidence to justify the prescriptive parking requirements which have been proposed. Therefore, Policy 3, Section 2 should be removed to ensure that the policy is consistent with national and local policy
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
The SEA/HRA document considers this policy is compatible with the Central Lincolnshire Local Plan.(CLLP)
- Policy 2
Church Commissioners Comments
2.11 However, whilst high-level design principles may be established at a district or local level, more prescriptive design codes would only usually be applied on an individual development basis tailored to the specifics of the site and the proposals.
2.13 Therefore, it is considered that this part of the policy, which seeks to limit development heights to up to two storeys only without specific justification, is removed.
2.15 Policy 2 Section 2e should be edited to remove the requirement for a development to deliver more than the minimum required and the requirement for open green spaces to be provided within the development only to ensure that it is compliant with local planning policy.
2.17(reference: 20/0057/OUT). The Draft Plan states that developments must demonstrate how the Character Profile has informed the design of the proposed development. The current planning application precedes the Draft Plan and therefore does not include an assessment of the development against the Character Profile.
2.19The Bracebridge Heath Character Profile refers to a ‘draft plan’. We assume this is referring to the Draft Framework Plan, which accompanied CLLP17, but is not formally adopted by Central Lincolnshire and is illustrative only. Allocation CL428 within the CLLP17 does not identify the need to comply with the Draft Framework Plan nor does it require ‘a broad swathe of green open space’, ‘a green buffer zone between the roads and housing’ or a ‘wide green buffer zone with no road crossings’.
2.20 The Draft Plan therefore sets out design requirements which are not consistent with the CLLP17.
2.22 As the evidence does not include a map illustrating the location of the proposed ‘green beak’ or the ‘wide green buffer zone’, it is difficult to assess what is being sought or the implications of the proposal.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
2.11 - Wording has been changed in accordance with suggestions from NKDC.
2.13 - Number of storeys re housing restricted to 1 or 2 storey was a firm desire of parishioners. (Questionnaire conducted by Community Lincs. Appendix A 19)
2.15 - Point 2e has been removed.
2.17 - Noted
2.19 - It does refer to the draft Framework Plan which is being used by NKDC planners as a basis for the development of the SEQ until a masterplan is agreed.
2.20 - Other sections of the Central Lincolnshire Local Plan (CLLP) such as 7.4.5, 7.4.6 , LP30 do refer to green buffer zones and environmental corridors etc. therefore the Neighbourhood Plan can be considered consistent with the CLLP.
2.22 Noted.
Typing error will be rectified.
Is stated in the Central Lincolnshire Local Plan LP30 Quote: ‘as shown on the agreed concept plan.’
Typing error will be rectified.
Is stated in the Central Lincolnshire Local Plan LP30 Quote: ‘as shown on the agreed concept plan.’
- Policy 5 affordable housing
Church Commissioners Comments
2.27Affordable housing is defined within the Glossary of the CLLP17 as social rented, affordable rented and intermediate house, provided to eligible households whose needs are not met by the market. Eligibility is determined with regard to local incomes and local house prices. There are no restrictions on the applicant to prove the suitability of the future occupier. Therefore, in order to be compliant with local planning policy it is considered that this draft policy is removed from the Draft Plan.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. The policy is in line with NKDC’s own policies.
- Policy 6 protecting historic environment
Church Commissioners Comments
Policy 6 does not separate the requirements in relation to designated and non-designated heritage assets, therefore the wording should be amended in order to ensure that the policy is compliant with national and local policy.
North Kesteven District Council are currently updating and revising the local list of non-designated heritage assets. Therefore, to ensure that the Draft Plan is consistent with local policy, Appendix B should be deleted and references to this should be replaced with NKDC’s local list.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Wording has been changed to be in line with NKDC designated and non-designated heritage assets.
NKDC has already compared our list with theirs. NKDC’s list has been updated and the heritage and non-designated heritage assets are now aligned.
- Policy 8 retail and leisure
Church Commissioners Comments
2.32 The Commissioners agree that retail and leisure provision should incorporate parking facilities for visitors and services. Parking standards have been discussed previously within these representations in relation to Paragraph 7.7 and Policy 3 of the Draft Plan.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted.
NKDC states meets basic conditions.
NKDC states meets basic conditions.
- Policy 9 Sleaford Road industrial estate
Church Commissioners Comments
2.33 Section 2 of Policy 9 refers to a green separation ‘buffer zone’ between Bracebridge Heath and Canwick Heath, and the Eastern Bypass, however no plan has been provided to illustrate the proposed location of the buffer zone.
2.35 Policy 9 Section 2 is too prescriptive and does not provide any evidence to support the required access locations or green separation buffer zones. Therefore, in order to comply with the ‘basic conditions’ test Section 2 of Policy 9 should be amended.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted.
It does refer to the Draft Framework Plan (or as stated in CLLP LP 30 ‘as shown on the agreed concept plan) which is being used by NKDC planners as a basis for the development of the SEQ until a masterplan is agreed.
Other sections of the CLLP such as 7.4.5, 7.4.6, LP30 do refer to green buffer zones and environmental corridors etc. therefore the Neighbourhood Plan can be considered consistent with the CLLP.
It does refer to the Draft Framework Plan (or as stated in CLLP LP 30 ‘as shown on the agreed concept plan) which is being used by NKDC planners as a basis for the development of the SEQ until a masterplan is agreed.
Other sections of the CLLP such as 7.4.5, 7.4.6, LP30 do refer to green buffer zones and environmental corridors etc. therefore the Neighbourhood Plan can be considered consistent with the CLLP.
- Policy 14 maintaining separation
Church Commissioners Comments
2.36Section 1 of Policy 14 refers to ‘a landscaped green buffer zone’, however no plan has been provided to illustrate the proposed location of the buffer zone.
2.37There is no requirement within the CLLP17 South East Quadrant allocation or elsewhere within the CLLP17 for a landscaped buffer between Bracebridge Heath and the SEQ. No evidence has been provided to justify this approach. Therefore, the policy as currently worded is not consistent with strategic policies within the Local Plan and it is recommended that it is deleted.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. NKDC consider this policy meets the basic conditions.
It does refer to the draft Framework Plan (or as stated in CLLP LP 30 ‘as shown on the agreed concept plan) which is being used by NKDC planners as a basis for the development of the SEQ until a masterplan is agreed.
Other sections of the CLLP such as 7.4.5, 7.4.6, LP30 do refer to green buffer zones and environmental corridors etc. therefore the Neighbourhood Plan can be considered consistent with the CLLP.
- Policy 16 open spaces
Church Commissioners Comments
2.41Therefore, to ensure consistency with National and Local Plan policy, the wording of Section 1 should be amended to permit in principle the development of recreational land or buildings where those land or buildings are surplus to requirements.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. NKDC generally consider this policy to meet basic condition with some changes in wording for clarity.
This has been done.
This has been done.
- Policy 19 Views (Actually is Policy 17)
Church Commissioners Comments
There is no evidence in the Draft Plan or in any supporting documents that justify why the listed views have been designated as ‘locally important’. This evidence is required to ensure the policy has been made on robust grounds.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted NKDC states this policy is consistent to meet the basic conditions.
Anglian Water comments
- Policy 2: Design of new housing developments
Anglian Water comments
Anglian Water as water company for the Parish supports the requirement for new residential proposals to incorporate rainwater harvesting systems as this will help to reduce water use.
There are a number of systems including surface water/stormwater harvesting and grey water recycling which would also be appropriate to residential proposals which are actively promoting as part of our Green Water Programme.
(https://www.anglianwater.co.uk/developers/development-services/green-water/ ). Therefore we would suggest the policy includes reference to surface water harvesting and grey water recycling as well as rainwater harvesting systems.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. Surface water harvesting and grey water recycling added to the policy
- Policy 10: Renewable technologies for employment
Anglian Water comments
Anglian Water as water company for the Parish supports the requirement for new employment proposals to incorporate rainwater harvesting systems as this will help to reduce water use.
There are a number of systems including surface water/stormwater harvesting and grey water recycling which would also be appropriate to employment proposals. Therefore we would suggest the policy includes reference to surface water harvesting and grey water recycling as well as rainwater harvesting systems
Environment Agency Comments
Based on the environmental constraints within the area, we have no detailed comments to make in relation to your Plan at this stage. However, your plan includes areas which are located on Source Protection Zones 2 and 3. These should be considered within your plan if growth or development is proposed here. The relevance of the designation and the potential implication upon development proposals should be considered with reference to our Groundwater Protection guidance: https://www.gov.uk/government/collections/groundwater-protection
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. No growth planned in Zone 2 or 3.
Historic England Comments
The area covered by your Neighbourhood Plan includes a number of important designated heritage assets. In line with national planning policy, it will be important that the strategy for this area safeguards those elements which contribute to the significance of these assets so that they can be enjoyed by future generations of the area.
If you have not already done so, we would recommend that you speak to the planning and conservation team at your local planning authority together with the staff at the county council archaeological advisory service who look after the Historic Environment Record. They should be able to provide details of the designated heritage assets in the area together with locally-important buildings, archaeological remains and landscapes. Some Historic Environment Records may also be available on-line via the Heritage Gateway (www.heritagegateway.org.uk <http://www.heritagegateway.org.uk>). It may also be useful to involve local voluntary groups such as the local Civic Society or local historic groups in the production of your Neighbourhood Plan.
Historic England has produced advice which your community might find helpful in helping to identify what it is about your area which makes it distinctive and how you might go about ensuring that the character of the area is retained. These can be found at:-
<https://historicengland.org.uk/advice/planning/plan-making/improve-your-neighbourhood/>
Historic England has produced advice which your community might find helpful in helping to identify what it is about your area which makes it distinctive and how you might go about ensuring that the character of the area is retained. These can be found at:-
<https://historicengland.org.uk/advice/planning/plan-making/improve-your-neighbourhood/>
You may also find the advice in “Planning for the Environment at the Neighbourhood Level” useful. This has been produced by Historic England, Natural England, the Environment Agency and the Forestry Commission. As well as giving ideas on how you might improve your local environment, it also contains some useful further sources of information. This can be downloaded from:
<http://webarchive.nationalarchives.gov.uk/20140328084622/http://cdn.environment-agency.gov.uk/LIT_6524_7da381.pdf>
<http://webarchive.nationalarchives.gov.uk/20140328084622/http://cdn.environment-agency.gov.uk/LIT_6524_7da381.pdf>
If you envisage including new housing allocations in your plan, we refer you to our published advice available on our website, “Housing Allocations in Local Plans” as this relates equally to Neighbourhood Planning. This can be found at <https://content.historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans.pdf/>.
Natural England
Natural England does not have any specific comments on this draft Neighbourhood Plan.
Natural England does not have any specific comments on this draft Neighbourhood Plan.
Jesus College Oxford
Responses provided for Jesus College Oxford by Pegasus Group
Responses provided for Jesus College Oxford by Pegasus Group
- Policy 14 Maintaining Separation
Jesus College Oxford
This representation specifically focuses on Policy 14 of the draft Neighbourhood Development Plan, 'Maintaining Separation'.
The proposals as set out in the application are therefore in accordance with the adopted Local Plan Policy and are also consistent with the proposed Policy 14 in the Draft Neighbourhood Plan.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted.
Responses to consultation (Regulation 14) with parishioners of Bracebridge Heath
Comments from the Consultation (Regulation 14) with Bracebridge Heath Parishioners
- Question 1: Do you agree with the Community Vision for Bracebridge Heath contained in the draft Neighbourhood Plan?
I believe that we should not be actively preventing positive development in the village.
Unfortunately the parish council is not representative of the young people and families that will benefit from this considerable investment Sadly retired people with too much time on their hands and prejudiced opinions get in the way of the young families who are more representative of the village
Unfortunately the parish council is not representative of the young people and families that will benefit from this considerable investment Sadly retired people with too much time on their hands and prejudiced opinions get in the way of the young families who are more representative of the village
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
Bracebridge Heath is located between three major Roman Roads, A15 Sleaford Road, A607 Grantham Road, and Cross O' Cliffe Hill going in to Lincoln, without the inclusion of Canwick Avenue (B1131) a main access road which connects to the B1188 at the junction at the top of Canwick Hill (B1188) which connected to the A15. It is well documented at how congested these road have already become especially during rush hour. Bracebridge Heath has already significantly expanded over the past 25 years with major housing developments, on the Sycamore Grove Estate and the St. John’s Hospital which are still being developed. As stated in North Kesteven District Council, 2017 Air Quality Annual Status Report (ASR) 'The main source of air pollution in the district is road traffic emission from roads.....significant housing developments with the District will lead to an increase in population and therefore in vehicle usage (NKDC, 2017,pi). NKDC (2017) also state that 'air quality is recognised as a contributing factor in the onset of heart disease and cancer (pi)'. Since 2017 there has been significant housing developments not only in Bracebridge Heath, Waddington and Branston to name and they are all connected by the main artery routes into Lincoln. The last air quality monitoring was carried out in 2016/17 with no monitoring in Bracebridge Heath on the roads mentioned above during rush hour, with the nearest monitoring being in Branston. Under the LAQM the council is legally obliged to carry out a review and assess the air quality in the region. I therefore request that the monitor and assess the above mentioned roads at rush hour and also consider the impact upon health of the existing residents, as I have noted that the air pollution has typically increased year upon year. Bracebridge Heath needs to keep its existing buffer zones to protect the residents from air pollution and allow there needs to address by the local authority about increasing access routes into Lincoln to ease existing congestion and not create extra congestion. Also there is an increasing number of road traffic accidents in and around Lincoln, with the city grinding to a standstill causing more air pollution and impeding the emergency services in reaching people requiring urgent assistance.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. A number of policies are include environmental and health elements.
There is too much land allocated in the BBH area. The village is going to lose its identity as a village and becomes part of Lincoln
Too much land allocated to housing, loss of village identity, will become part of Lincoln
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
A number of policies are designed to aid ‘the village feel.’
A number of policies are designed to aid ‘the village feel.’
- Question 2: Do you agree with the Community Objectives for Bracebridge Heath contained in the draft Neighbourhood Plan?
I believe that there is need for improvement to Bracebridge Heath to ensure its 'village like feel', to improve the services and amenities for residents, such as a youth centre, leisure centre, dentist, and an additional doctor's surgery. Also its heritage needs preserving for future generations.
There needs to be an infrastructure to support this, we have a shortage of GP's in the whole of Lincolnshire, we cannot recruit ,the road network is so poor, schools!
Ok apart from the amount of new build and lack of roads, infrastructure to support it.
There needs to be an infrastructure to support this, we have a shortage of GP's in the whole of Lincolnshire, we cannot recruit ,the road network is so poor, schools!
Ok apart from the amount of new build and lack of roads, infrastructure to support it.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
- Question 3: Do you agree with Policy 1 Housing Mix of the draft Bracebridge Heath Neighbourhood Plan
I agree with the need to preserve and protect the Green Infrastructure, buffer zones and to keep the rural cliff village feel to Bracebridge Heath and to prevent it from becoming an extension of Lincoln. I believe that Bracebridge Heath needs to be protected from over expansion for the sake of greed and profit with the guise of meeting housing needs over the quality of air in the area. There are many disused properties, or retail units areas in Lincoln that could be developed to provide housing for everyone and not just student accommodation that is only occupied for approximately 8 months out of a year.
There are too many new developments, where are all the jobs for people wanting to purchase.
To many new builds.
There are too many new developments, where are all the jobs for people wanting to purchase.
To many new builds.
Need for some 'care' housing in the area.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
- Question 4: Do you agree with Policy 2 Design of new housing developments of the draft Bracebridge Heath Neighbourhood Plan?
As previously stated in my previous responses to my concerns about new developments that are linked to the air quality annual status report by NKDC in 2017, increased traffic, pollution and road traffic incidents. Also the environmental impact by removing hedgerow, animals habitats, the fields also help with run off when we have heavy rains and storms.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. Policies are included to help link wildlife habitats.
It will increase the population with no real promise of better facilities (shops, doctors, schools etc).
Completely will be a blot on the landscape.
As above. (To many new builds)
Completely will be a blot on the landscape.
As above. (To many new builds)
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted.
Noted.
- Question 5: Do you agree with Policy 3 Car parking and electric charging points of the draft Bracebridge Heath Neighbourhood Plan?
We do need better parking as there is issues with parking in the area, but where would the electric charging points be placed and how is that electric generated? There is pollution caused by generating electricity so by increasing electric cars it artificially looks like pollution is being reduced.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. Policy 3 covers the point re charging points
I agree with charging points.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted.
- Question 6: Do you agree with Policy 4 Cycle parking and storage of the draft Bracebridge Heath Neighbourhood Plan?
It would also be good to consider cycle parking in the village itself at the shops for example
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
- Question 7: Do you agree with Policy 5 Allocation of affordable housing of the draft Bracebridge Heath Neighbourhood Plan?
I do not agree with the expansion of Bracebridge Heath, and also affordable housing is only a small percentage of the overall development, the vast majority of the development is out of the reach of the majority of people in the area, due to low wages.
They will be given to people on benefits.
Affordable housing should be accessible to all.
The plans are on to much of huge scales. Perhaps keep affordable housing in one area and not spread over all planned developments.
I agree with the principle but cant see how this can be enforced.
I agree with the policy but question how it can be enforced. Who will be responsible for monitoring applicants and making sure that developers or agents apply the policy?
First time buyers/renting - it’s a struggle.
Affordable housing should be accessible to all.
The plans are on to much of huge scales. Perhaps keep affordable housing in one area and not spread over all planned developments.
I agree with the principle but cant see how this can be enforced.
I agree with the policy but question how it can be enforced. Who will be responsible for monitoring applicants and making sure that developers or agents apply the policy?
First time buyers/renting - it’s a struggle.
There needs to be some affordable housing but not on such a grand scale.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. Amount of affordable housing set by CLLP.
- Question 8: Do you agree with Policy 6 Protecting the historical environment of the draft Bracebridge Heath Neighbourhood Plan?
No comments made.
- Question 9: Do you agree with Policy 7 St John’s Craft Workshops of the draft Bracebridge Heath Neighbourhood Plan?
This policy is clearly prejudiced by personal relationships and how they can beat benefit from misrepresentating the policy.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
- Question 10: Do you agree with Policy 8 Retail and leisure provision of the draft Bracebridge Heath Neighbourhood Plan?
Discrepancy between marketing times is discriminatory. St Johns craft doesn’t contribute to the economy the same way other facilities/business do.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Length of time been altered to 6 months.
I don’t want a leisure centre/skating rink, these are for towns.
We need to keep the identity of BBH as a village and not a town like North Hykeham. The whole development needs to be scales down!!
Leisure centres are not located in villages. If BBH is to retain a 'village feel' a leisure centre should be avoided.
If the development was smaller all this would not be needed.
Need for 'fresh' butcher.
We need to keep the identity of BBH as a village and not a town like North Hykeham. The whole development needs to be scales down!!
Leisure centres are not located in villages. If BBH is to retain a 'village feel' a leisure centre should be avoided.
If the development was smaller all this would not be needed.
Need for 'fresh' butcher.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
- Question 11: Do you agree with Policy 9 Sleaford Road Industrial Estate of the draft Bracebridge Heath Neighbourhood Plan?
No comments made.
- Question 12: Do you agree with Policy 10 Renewable technologies on employment sites of the draft Bracebridge Heath Neighbourhood Plan?
Should provision be made for future technologies as well as the ones listed? What about wind generators?
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
The policy includes future technologies as mentioned are just examples.
- Question 13: Do you agree with Policy 11 Small scale business developments of the draft Bracebridge Heath Neighbourhood Plan?
However, there are already business' operating outside the policy. Gym on industrial estate slamming tyres around at 5am/6am on average. Small beer could also be less noise pollutant.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. This policy will protect the remaining units.
- Question 14: Do you agree with Policy 12 Protecting community facilities of the draft Bracebridge Heath Neighbourhood Plan?
Provided existing trees are chopped at a minimum.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
- Question 15: Do you agree with Policy 13 Green infrastructure of the draft Bracebridge Heath Neighbourhood Plan?
Old cemetery to become Nature Park with wild grass and bushes.
Green infrastructure is really important in making BBH a pleasant place to live.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted.
- Question 16: Do you agree with Policy 14 Maintaining separation of the draft Bracebridge Heath Neighbourhood Plan?
Should the extent of the landscaped green buffer zone be identified? Is there a minimum width along the whole of the zone?
So long as the spaces are left untouched and unaffected by the work.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Is in accordance with CLLP policy 20 and 30.
- Question 17: Do you agree with Policy 15 Viking Way and Lincoln Edge green wedges of the draft Bracebridge Heath Neighbourhood Plan?
No comments made
- Question 18: Do you agree with Policy 16 Open spaces, sports facilities and recreation facilities of the draft Bracebridge Heath Neighbourhood Plan?
If you have no care-need to retain or increase leisure facility in the village.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted
- Question 19: Do you agree with Policy 17 Locally important views of the draft Bracebridge Heath Neighbourhood Plan?
No comments made
- Question 20: Do you agree with Policy 18 Designating local green space of the draft Bracebridge Heath Neighbourhood Plan?
Reduces the number of properties that can be built
Are there other green spaces that could be designated and included in the policy.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted Not that the sub-committee is aware of.
- Question 21: Do you agree with Policy 19 Protecting existing and establishing new non-vehicular routes for pedestrians and cyclists of the draft Bracebridge Heath Neighbourhood Plan?
The roads are particularly narrow and there are cars parked along Cross O' Cliffe Hill, reducing the vehicle access especially for wider vehicles and with the new laws on giving extra space to cyclist this would not be possible without crossing over the centre line. Also there are a lots of pot holes, and pavements in need of repair. While I respect the need to provide safe spaces for cyclists and pedestrians this cannot be addressed without dealing with the inadequate infrastructure which is not fit for purpose.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted. This Neighbourhood Plan has included policies to aid the use of alternative means of transport.
Public footpath through St John's to Litchfield Rd used by many people and children not moficated!
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
This footpath is temporary based on many years of use. When the St John’s Hospital development is completed, the footpath will close and the right of way between Sleaford Road and Lichfield Road will divert along the new Medland Way.
- Question 22: Do you agree with Community Projects of the draft Bracebridge Heath Neighbourhood Plan?
5,6 Extensions to the village hall and pavilion should allow for partial redevelopment or complete rebuild. The suggestion here only allows for extending. 7 Village green- this land is currently woodland. These trees would need to be removed to create a village green which would affect the landscaping of the centre of the village.
Whitegates are a waste of money. Not sure we really need a Heritage Centre.
I don’t think white gates will be effective/value for money.
I hope you can fulfill all these proposals without to much alterations to what you have proposed.
Congratulations! Priority should be given to cycleway/pathway from BBH to Branston and Lincoln via Canwick.
Remarks from Bracebridge Heath Neighbourhood Plan sub-committee
Noted.