Local Plan Issues and Options (Regulation 18)

Object

Representation ID: 16465

Received: 29/08/2025

Respondent: Grimster Planning

I&O_14599
Please refer to comments in response to Question HO 4 above.

Object

Representation ID: 16466

Received: 29/08/2025

Respondent: Grimster Planning

I&O_14600
No. It is considered that Policy DM19 needs revising and amending accordingly, as per comments set out in response to Question HO 7 below.

Amendments to Policy DM21 and DM22 are also considered to be warranted, for the reasons set out in
response to Question HO 7 below.

Object

Representation ID: 16467

Received: 29/08/2025

Respondent: Grimster Planning

I&O_14601
Policy DM19 is not considered to be an effective policy.
Firstly, it fails to identify and list “infill development” as an appropriate use in the Countryside (including Green Belt) in Parts 1-7 of the Policy. This is contrary to paragraph 154(e) of the NPPF, which clearly identifies “limited infilling in villages” as an appropriate use in the Green Belt and does not restrict infill development to only those villages identified in a development plan (in the way that paragraph 154(f) of the NPPF does, for example).

Secondly, part of Policy DM19 relates to residential development in the “Countryside.” Part 7 of the Policy
then identifies a number of criteria that previously developed land/sites must satisfy in order to be appropriate development in the “Countryside.” This includes “good access to public transport” and being
“location within reasonable walking distance of local services and facilities along a safe route.”

The application of this Policy in practice is such that very few previously developed sites in the “Countryside” can meet these particular policy requirements. This is unsurprising, given it is unclear how previously developed sites in the “Countryside,” which encompasses the rural areas of the Borough which extend beyond the Main Towns, Key Service Centres and Local Service Centres in the adopted Local Plan, can be expected to have access to a bus service, footpaths and streetlights (all of which are commonly cited by the Council when determining such applications)? There are not characteristic features of the rural area and “Countryside” – the Policy effectively applies urban expectations on land outwith. This is simply not realistic.

Accordingly, the tests for previously developed sites in the Countryside (including the Green Belt), need to be re-considered, and the current wording suitably amended to provide for much greater flexibility and a realistic expectation of what previously developed sites in the Countryside will have access to (in terms of public transport, footpaths, streetlights, and distances to services).

In respect of Policy DM21, this has been largely effective in managing residential extensions and outbuildings. However, it is considered that the current 10% allowance to increase the size of replacement dwellings in the Green Belt (over the size of the existing dwelling it replaces) should be amended to 30% as part of the “materially larger” test; this reflects the fact that a replacement dwelling outside of the Green Belt can currently be 30% larger than the dwelling it replaces under the same policy considerations.

Turning to Policy DM22, it is considered that Part 1 of the tests set out under “Countryside” should be deleted. It is not clear why only redundant or disused buildings should be capable of a change of use or conversion; this is overly restrictive and unjustified.