Proposed Revisions to Draft Local Plan (Preferred Options)

Comment ID 11519137/1/8408180/-
Document Section 2. Sustainability Appraisal (no name) [View all comments on this section]
Respondent April Newing - Kent County Council [View all comments by this respondent]
Response Date 17 Mar 2017
Do you consider the document is Legally Compliant?
Do you consider the document is Sound?
On which grounds do you consider the document unsound? (if applicable)

KCC considers that the following statement used throughout the Sustainability Appraisal (SA) supporting the draft Local Plan is incorrect:

"The effects on with respect to ecology and landscape are likely to be lesser for the development on brownfield land, when compared to development of greenfield land".

The ecological interest of a site should be determined by the District Council’s desk-top assessment of all site applications undertaken as part of the SHLAA exercise. It should therefore not be based on whether the site is located on greenfield or brownfield land. Previously developed sites can contain significant ecological interest and should therefore not be dismissed as a matter of planning policy.

With regard to reference made to Policy G101: Locally Designated Wildlife Sites in the SA document, KCC highlights that for the majority of sites, Local Wildlife Sites are not protected by legislation but policy. It is therefore advised that such reference is revised to reflect this.


What changes do you suggest to make the document legally compliant or sound?
Do you consider it necessary to participate at the oral part of the examination? No
Why do you feel it is necessary to participate at the oral part of the examination?
Officer's Response Not yet available.
Proposed Change