representations on consultation 2020

Representations on Consultation 2020

Comment.

(1155566)Consultee

Email Address

Address

Places & Policies Local Plan Main ModificationsEvent Name

(1155566)Comment by

1Comment ID

11/02/20 15:04Response Date

Table 2.12 MM12 (View)Consultation Point

SubmittedStatus

WebSubmission Type

0.1Version

Test of Soundness

Do you consider the Main Modification is:

Yes2. a) Soundness - Positively Prepared

Yes2. b) Soundness - Justified

Details of your comment

Please use the space below to summarise your comment.

Please give details of why you consider the Main Modification is not legally compliant or is unsoundor fails to comply with the duty to co-operate. Please be as precise as possible. If you wish to supportthe legal compliance or soundness of the Main Modification or its compliance with the duty toco-operate, please also use this box to set out your comments.

I am pleased to see clarification around the setting of new employment allocations in an Area ofOutstanding Natural Beauty.

Suggested modifications

If objecting, please set out what change(s) you consider necessary.

Please Note:Your comments should cover succinctly all the information, evidence and supporting informationnecessary to support/justify the comment and the suggested change, as there will not normally be a subsequentopportunity to make further comments based on the original comment at this stage.

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Please set out what modification(s) you consider necessary to make the Main Modification legallycompliant or sound, having regard to the Matter you have identified above where this relates to‘soundness’.You will need to say why this modification will make the Local Plan legally compliantor sound. It will be helpful if you are able to put forward your suggested revised wording of the MainModification. Please be as precise as possible.

I would like to see some positive reference to the retention of landscape quality.


Comment.

(1155566)Consultee

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(1155566)Comment by

2Comment ID



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Test of Soundness







I fully support the increase in marketing time from 6 to 12 months, as this will help to retain employmentsites.



Comment.

(1155566)Consultee

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Address


(1155566)Comment by

3Comment ID



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Test of Soundness







I support the addition of the wording around parking standards being viewed in a local context. Onesize does not fit all when it comes to parking, especially in villages where there is a particular shortagethat can result in dangerous parking.



Comment.

(1155566)Consultee

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Address


(1155566)Comment by

4Comment ID



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Test of Soundness







I am pleased to see the addition of wording that refers to the need to assess the impact of parking andtraffic movements on adjoining on-street residential parking. A holistic approach is sensible.



Comment.

(1032113)Consultee

Email Address

Kent Downs AONBAddress


(1032113)Comment by

5Comment ID



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Test of Soundness


Yes1. Legally Compliant



Yes2. c) Soundness - Effective

Yes2. d) Soundness - Consistent with National Policy

Yes3) Complies with the 'Duty to Co-operate'




Support the proposed Main Modification



Yes, I wish to participate at the public hearingIf a public hearing is considered necessary for theMain Modification you have commented on, wouldyou wish to participate?


Comment.

(1032113)Consultee

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(1032113)Comment by

6Comment ID



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Support the proposed Main Modification



Comment.

(1032113)Consultee

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(1032113)Comment by

7Comment ID



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No2. d) Soundness - Consistent with National Policy




While the Kent Downs AONB Unit supports the proposed modification, we remain of the view thatadditional safeguards are required to ensure that development in this location is adequately mitigatedin terms of its impacts on the Kent Downs AONB and would welcome inclusion of reference to materialchoice and height of development.







"THE DEVELOPMENT SHALL BE INFORMED BY A LVIA AND BE DESIGNED AND LAID OUT INSUCH A WAY SO AS TO CONSERVE AND ENHANCE THE CHARACTER AND SETTING OF THEKENT DOWNS AONB INCLUDING IN TERMS OF MATERIAL CHOICE AND BE NO MORE THANTWO STORIES IN HEIGHT".

Without such provisions, it is contended that the proposal fails to comply with Section 85 of the 2000Countryside and Rights of Way Act as well as paragraph 172 of the NPPF and therefore remainsUnsound.



Comment.

(1032113)Consultee

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(1032113)Comment by

8Comment ID



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While the AONB Unit retains its concerns about the acceptability of developing this site as we do notconsider development here would conserve or enhance the AONB, should the allocation be found tobe acceptable, the AONB Unit supports the proposed modifications which would reduce the level ofharm to the Kent Downs AONB.



Comment.

(1032113)Consultee

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(1032113)Comment by

9Comment ID



SubmittedStatus

WebSubmission Type

0.1Version

Test of Soundness










Support the proposed Main Modification.



Comment.

(1032113)Consultee

Email Address



(1032113)Comment by

10Comment ID



SubmittedStatus

WebSubmission Type

0.1Version

Test of Soundness










Support the proposed Main Modification.



Comment.

(1204442)Agent

Email Address

Avison YoungCompany / Organisation

Address

(1042695)Consultee

National GridCompany / Organisation

Address


National Grid ( - 1042695)Comment by

11Comment ID


1 Introduction (View)Consultation Point

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0.3Version




We have reviewed the above document and can confirm that National Grid has no comments to makein response to this consultation.


http://shepway.objective.co.uk/portal/pplp/places_and_policies_submission_draft/pplp_mm_1/pplp_mm?pointId=s1576497530108#s1576497530108

Comment.

(1165762)Agent

Email Address

Wood PlcCompany / Organisation

Address

The Crown Estate (130445)Consultee

Address


The Crown Estate (130445)Comment by

12Comment ID



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0.2Version

Test of Soundness













The Crown Estate supports Main Modification 003 which proposes the removal of a reference to amasterplan within Policy RM13: land north and south of Rye Road Brookland.The Crown Estate ownsland to the north of Rye Road which is allocated to deliver up to 15 dwellings. It is considered that amasterplan approach is both unnecessary and would not comply with national planning policy ondelivering sustainable development without delay. The modification is supported for the followingreasons:

The removal of the masterplan approach is considered to be proportionate to the modest scaleof development at Brookland, with land north of Rye Road allocated for 15 dwellings and landsouth of Rye Road allocated for 14 dwellings. A hybrid planning application has already beenapproved for land south of Rye Road without any requirement for a masterplan. Once anapplication is submitted for land north of Rye Road, the Local Planning Authority will have controlover the design, siting and layout of the proposal. They will also consider the compatibility of anyproposal with surrounding development. Therefore, a masterplan would seem superfluous.

A masterplan requirement is very onerous given the scale of development and would be aduplication of the requirements of a planning application. It could also delay the site comingforward for delivery. This approach would be contrary to the NPPF, which is to support theGovernment’s objective of boosting the supply of homes quickly and is also consistent with thepresumption in favour of sustainable development set out in NPPF (paragraph 11) which requireslocal planning authorities to approve development proposals that accord with an up-to-datedevelopment plan without delay.

We therefore support the recommendation that the masterplan wording is removed from Policy RM13to meet the tests of soundness set out in NPPF (particularly positively prepared and effective) and toprovide greater flexibility to enable the site to be brought forward through a more technically robustplanning application process.



Comment.

(1240736)Consultee

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Southern WaterCompany / Organisation

Address


Southern Water ( - 1240736)Comment by

13Comment ID



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Southern Water have no further comments at this stage.



Comment.

(1042306)Consultee

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Historic EnglandCompany / Organisation

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Historic England ( - 1042306)Comment by

14Comment ID



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Historic England’s only comment on the Main Modifications relate to MMO5 – we feel the policy wordingin respect of the Rhee Wall archaeological feature gives insufficient weight to the requirement to protectthis feature as an archaeological asset of potentially national significance. We suggest that in bullet10 the words “properly considered” are insufficiently robust in this context and should be replaced with‘fully assessed by pre-development investigation and its significance fully established, and in the lightof this appropriate preservation in situ or and …’.

The site includes the remnants of the Rhee Wall, a unique feature of the local landscape. The RheeWall is a 13th century canal used as part of medieval attempts to address the major coastal changesthen taking place at Romney Marsh and affecting the then existing ports and routes of navigation.Thebest preserved part of which is a scheduled monument (seehttps://historicengland.org.uk/listing/the-list/list-entry/1010699), although the condition and extent ofsurvival of the structure at this location is not well understood.

The suggested inclusion for a pre-development assessment of archaeological condition of the site isessential in view of the Rhee Wall’s significance, even if currently undesignated. If such assessment



confirms the presence of either buried archaeological remains associated with the Rhee Wall or aboveground evidence of its earthworks, or a combination of the two, then it could be the case that thesemight come under the advice of NPPF footnote 63 for non-designated archaeological remains of anequivalent significance to a scheduled monument. If this level of significance was to be confirmed thenapplying the advice of the NPPF for designated heritage assets would set a high bar against acceptingany development that may be harmful to the significance of the monument, and its preservation in situmay be required.

These comments are based on the information provided by you at this time and for the avoidance ofdoubt does not reflect our obligation to advise you on, and potentially object to, any specific developmentproposal which may subsequently arise from this or later versions of the plan and which may, in ourview, have adverse effects on the historic environment.


Comment.

(1228946)Consultee

Email Address

Dover District CouncilCompany / Organisation

Address


Dover District Council ( - 1228946)Comment by

15Comment ID



SubmittedStatus


0.3Version




Dover District Council has no comments on the Modifications, and we look forward to furtheropportunities to cooperate and engage with the Local Plan as it progresses towards adoption.



Comment.

(1204434)Consultee

Email Address

Rother District CouncilCompany / Organisation

Address


Rother District Council ( - 1204434)Comment by

16Comment ID



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0.2Version

Test of Soundness











The main modification that is being proposed during this consultation/representation period is theallocation of a specific Gypsy and Traveller site, a consequence of further work being carried out by



the Council since the hearings of the Examination. Rother District Council is supportive of the furtherwork that the Council has undertaken and the resulting allocation of a site for four permanent gypsyand traveller pitches at land adjacent to ‘The Retreat’ Lydd Road. Old Romney through proposedPolicy RM15 of the Plan. As stated in the reasons for change, this better meets the requirements ofthe National Planning Policy Framework (NPPF) and the Planning Policy for Traveller Sites (PPTS).

Rother District Council supports all other modifications that have been proposed, in order to providethe necessary clarity and further detail to planning policies in the Local Plan.

No, I do not wish to participate at the public hearingsIf a public hearing is considered necessary for theMain Modification you have commented on, wouldyou wish to participate?


Comment.

(1041284)Consultee

Email Address

New Romney Town CouncilCompany / Organisation

Address


New Romney Town Council ( -1041284)

Comment by

17Comment ID



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0.2Version




The above document was considered by the New Romney Town Council Planning and EnvironmentCommittee at a recent meeting when it was resolved unanimously that New Romney Town Councilhad no comment to make but would appreciate being kept advised of developments.



Comment.

(75200)Consultee

Email Address

Highways AgencyCompany / Organisation

Address


Highways Agency ( - 75200)Comment by

18Comment ID



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0.2Version




Highways England agree with the Sustainability Appraisal Document comment to support the removalof the Transport Assessment and Transport Statement within Policy T2. However, Highways Englandwould recommend a replacement statement within Policy T2 directly referring to paragraph 13.27, inorder to enforce the link to the NPPF and in support of the overall general comment above.



Comment.

(1244588)Consultee

Email Address

Natural EnglandCompany / Organisation

Address


Natural England ( - 1244588)Comment by

19Comment ID



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We support the inclusion of a bullet points to address impacts on the setting of the Kent Downs Areaof Outstanding Natural Beauty (AONB), as conserving and enhancing the beauty of landscapes inAONBs is in line with both the NPPF (170. 172.) and the Government’s 25 year environment plan(Chapter 2.).



Comment.

(1244588)Consultee

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Address


Natural England - 1244588)Comment by

20Comment ID



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We support the inclusion of a bullet points to address impacts on the setting of the Kent Downs Areaof Outstanding Natural Beauty (AONB), as conserving and enhancing the beauty of landscapes inAONBs is in line with both the NPPF (170. 172.) and the Government’s 25 year environment plan(Chapter 2.).



Comment.

(1244588)Consultee

Email Address


Address



21Comment ID



SubmittedStatus


0.2Version




Based on the development location and information provided, Natural England considers that theproposed allocation at Land adjacent to ‘The Retreat’, Lydd Road, Old Romney” will not have likelysignificant effects on nearby designated sites and has no in principal objection to the proposeddevelopment.



Comment.

(1244588)Consultee

Email Address


Address



22Comment ID



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0.2Version




Based on the development location and information provided, Natural England considers that theproposed allocation at Land adjacent to ‘The Retreat’, Lydd Road, Old Romney” will not have likelysignificant effects on nearby designated sites and has no in principal objection to the proposeddevelopment.



Comment.

(1244588)Consultee

Email Address


Address



23Comment ID



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We support the amendments made to policy ND6 to reflect the site’s location within the setting of theKent Downs AONB, as conserving and enhancing the beauty of landscapes in AONBs is in line withboth the NPPF (170. 172.) and the Government’s 25 year environment plan (Chapter 2.).



Comment.

(1244588)Consultee

Email Address


Address



24Comment ID



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We support the addition of a new clause to the end of policy E1 to highlight the need to consider thesetting of the Kent Downs AONB for new employment allocations, as conserving and enhancing thebeauty of landscapes in AONBs is in line with both the NPPF (170. 172.) and the Government’s 25year environment plan (Chapter 2.).



Comment.

(329173)Consultee

Email Address

Environment Agency, Company / Organisation

Address


Environment Agency, ( - 329173)

Comment by

25Comment ID



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Pleased to note Policy RM15 – Land adjacent to the Retreat requires new residential units to be placedin FZ1.



Comment.

(329173)Consultee

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Address



Comment by

26Comment ID



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0.4Version




Bullet point 8 should be amended. Permanent residential mobile homes/caravans are classified asHighly Vulnerable and should not be permitted in FZ3 regardless of Sequential and Exception Tests.

This modification is contrary to national planning policy and should be amended. As such we considerthis UNSOUND.

We note that the SA has been amended to reflect the main modifications. As we have raised issueson the main modifications we would expect the SA to be amended to reflect our concerns.



Comment.

Consultee


Address


Environment Agency, ( -329173)

Comment by

27Comment ID



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Please give details of why you consider the Main Modification is not legally compliant or is unsound or failsto comply with the duty to co-operate. Please be as precise as possible. If you wish to support the legalcompliance or soundness of the Main Modification or its compliance with the duty to co-operate, please alsouse this box to set out your comments.

We regret that we find the following modification UNSOUND, in that the added text appears to permit negotiationover a standard that the Council is entitled to require. If it does not require this standard, the Council will appearexceptionally lax, among local authorities in the South East of England, in respect of water efficiency. In the CoreStrategy Review, Policy CSD5 (Submission version, para a, p135) does not support any such relaxation.

On p50, Policy CC2 para 1, in the text...

"so as to achieve a maximum use of 110 litres per person per day including external water use where technicallyfeasible and viable"

The words "where technically feasible and viable" are inappropriate, and perhaps we should have pointed thisout before. It has been demonstrated that this design target is not hard or costly to achieve, which is why it wasset at this level as the Building Regulations optional target. Waterwise quotes "Requiring all new homes to bebuilt at 110lpd under Part G would only cost an additional £9 perhome" (https://waterwise.org.uk/knowledge-base/advice-on-water-efficient-new-homes-for-england-september-2018/)

We would suggest rewording as follows:



"so as to achieve a designed maximum use of 110 litres per person per day including external water use".

We note that the SA has been amended to reflect the main modifications. As we have raised issues on the mainmodifications we would expect the SA to be amended to reflect our concerns.


Comment.

(329173)Consultee

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Address



Comment by

28Comment ID



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0.2Version




We note that there still is no reference to the Hythe Bay MCZ in these documents or in Policy NE2 onBiodiversity.

This area (within the boundary defined in the Habitats Regulations Assessment) is of such greatecological interest that it warrants explicit mention in this document.



Comment.

(1244593)Agent

Email Address

Indigo PlanningCompany / Organisation

Address

(1043780)Consultee

Email Address

McKay Securities PLCCompany / Organisation

Address


McKay Securities PLC ( - 1043780)Comment by

29Comment ID



SubmittedStatus


0.3Version

Test of Soundness


No1. Legally Compliant

No2. a) Soundness - Positively Prepared

No2. b) Soundness - Justified

No2. c) Soundness - Effective

No2. d) Soundness - Consistent with National Policy

No3) Complies with the 'Duty to Co-operate'






Paragraph 81d of the NPPF (2019) states that planning policies should be flexible enough toaccommodate needs not anticipated in the plan, allow for new and flexible practices, and to enable arapid response to changes in economic circumstances.The proposed length of 12 months of marketingis too restrictive, unjustified, and not consistent with national planning policy because it will preventrather than encourage a rapid response to changes in economic circumstances.

Furthermore, the Council does not provide justification for the extended marketing period and theavailable guidance on what to provide as marketing evidence is not available within the Places andPolicies Local Plan. This restricts development and will make it more difficult to come forward and istherefore not compliant with national policy, especially Paragraph 35 of the NPPF which states thatlocal plans and spatial development strategies need to be positively prepared, justified, effective, andconsistent with national policy to be sound, as follows:

“a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectivelyassessed needs; and is informed by agreements with other authorities, so that unmet need fromneighbouring areas is accommodated where it is practical to do so and is consistent with achievingsustainable development;b) Justified – an appropriate strategy, taking into account the reasonablealternatives, and based on proportionate evidence;c) Effective – deliverable over the plan period, andbased on effective joint working on cross-boundary strategic matters that have been dealt with ratherthan deferred, as evidenced by the statement of common ground; andd) Consistent with national policy– enabling the delivery of sustainable development in accordance with the policies in this Framework.”

A 12 months marketing period – without guidance on what evidence is required – is an uncertain hurdleto overcome, giving no clarity and certainty. If the policy remains in this form it will prevent employmentsites from coming forward for re-development. This will prevent sites from being able to be suitablyredeveloped to more appropriate alternative uses for which there is demonstrable need. This policyas drafted will not deliver sustainable development and will conflict with guidance contained in theNPPF, particularly that in Paragraph 35 of the NPPF which states that local plans and spatialdevelopment strategies need to be positively prepared, justified, effective, and consistent with nationalpolicy to besound.

The policy should be reworded to better reflect the NPPF and to ensure development is not restrictedand is allowed to come forward. If employment uses are no longer necessary, planning policy shouldallow other beneficial development to come forward.





MM13 – paragraph 10.26

Amended paragraph to extend marketing period to twelve months should remain at six months orremoved altogether.


In addition, a set of marketing criteria should be defined to ensure that exercises can be undertakenon a like-for-like basis between different applications with minimal waste of resources and time.

A six months marketing period will better ensure the long-term viability and intensification of thesesustainably located employment sites to meet objectively assessed needs at the same time as ensuringthat such sites remain in productive, sustainable uses rather than become long-term vacant.

MM13 – Policy E2

Amended bullet point 2 to extend marketing period to twelve months should remain at six months orremoved altogether.

In addition, a set of marketing criteria should be defined to ensure that exercises can be undertakenon a like-for-like basis between different applications with minimal waste of resources and time.

A six months marketing period will better ensure the long-term viability and intensification of thesesustainably located employment sites to meet objectively assessed needs at the same time as ensuringthat such sites remain in productive, sustainable uses rather than become long-term vacant.

No, I do not wish to participate at the public hearingsIf a public hearing is considered necessary for theMain Modification you have commented on, wouldyou wish to participate?


Comment.

(75200)Consultee

Email Address


Address



30Comment ID



SubmittedStatus


0.4Version




Highways England made the following comments on Additional Modifications Document

Paragraph 6.5:

Highways England note the operator of Lydd Airport has planning consent to increase the capacitythrough runway extension and new terminal buildings. HE would expect to be consulted with early onwithin the planning process as any development progresses and a full Transport Assessment isproduced under the Sui Generis land use, outlined in para 13.27.

Paragraph 6.6:

We also note the revised date for the decommissioning of the Magnox ‘A’ power station is now 2025/26.HE would need to be consulted on any future development at the site following its decommissioning.We also expect that any proposals will have a corresponding Transport Assessment or TransportStatement supporting the planning application.



Paragraph 9.48:

Highways England position is to facilitate development whilst encouraging sustainable travel options,in line with guidance contained within the NPPF and Circular 02/13. Therefore with the requirementfor rural exception sites to be supported by public transport infrastructure, HE would expect that anydevelopment coming forward for a rural ‘exception site’ will have a corresponding Transport Assessmentor Transport Statement supporting the planning application outlining public transport options andidentifying any transport mitigation measures required as a result of the proposed development.

Paragraph 10.13:

‘Million Marsh’ economic growth fund for the Romney Marsh area. We recommend early engagementwith Highways England in any discussions regarding the transport implications for this programme.Please refer to the Highways England document Strategic Road Network: Planning for the Futuredocument for guidance.

Policy RL11:

Recommend inclusion of reference to DfT Circular 02/13 as well as Section 9 of the NPPF to ensurepolicy meets Highways England requirement for sustainable transport. In particular, plans and proposalsthat have the potential to impact on the safe and efficient operation of the SRN should be developedin line with the DfT Circular 02/13 paragraphs 9 & 10, DCLG NPPF particularly paragraph 109, andHighways England Strategic Road Network: Planning for the Future (paragraph 18).

Paragraph 13.11:


Paragraph 13.27:


Policy T2:

Highways England agree with the Sustainability Appraisal Document comment to support the removalof the Transport Assessment and Transport Statement within Policy T2. However, Highways Englandwould recommend a replacement statement within Policy T2 directly referring to paragraph 13.27, inorder to enforce the link to the NPPF and in support of the overall general comment above.

Paragraph 16.10:

We recommend an amendment to this paragraph to include the promotion of active travel modes andsustainable transport in healthier lifestyles, referencing NPPF and DfT Circular 02/13.

Glossary / Appendix:

We recommend the Glossary is updated to include Highways England as a Statutory consultee.


We also recommend the Glossary is updated to include documents DfT Circular 02/13, HighwaysEngland The Strategic Road Network: Planning for the future


Comment.

(75200)Consultee

Email Address


Address



31Comment ID



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0.3Version




Highways England made the following general comments to all documents:

Highways England would expect that transport impacts are assessed for any application / developmentin the vicinity of the SRN, with particular focus on M20, A20 and A259/A2070 in accordance withguidance found within the NPPF, in particular Para 102 and 103. Highways England would recommendthat this caveat statement is applied to any of the identified modifications and policies within thedocuments, or implemented as an overall statement within the beginning of each document.

Where we have not made comments, the information has been viewed but is not relevant to transportor Highways England.



Comment.

(1244588)Consultee

Email Address


Address

Places & Policies Local Plan Main Modifications SAEvent Name


1Comment ID


PPLP MM SA Document (View)Consultation Point

SubmittedStatus


0.2Version

IntroductionWhich section of the Sustainability AppraisalAddendum are you commenting on?

Which paragraph or Main Modification assessment (MM01 - MM21) does your representation relateto?

MM01 - MM21

SupportingAre you:

Please type your comments in the space below.

Natural England concurs with the findings of your SA for the proposed Main Modifications to theFolkestone and Hythe Places and Policies Local Plan.


http://shepway.objective.co.uk/portal/pplp/places_and_policies_submission_draft/pplp_mm_1/places__policies_local_plan_main_modifications_sa?pointId=1578482031215#1578482031215

Comment.

(75200)Consultee

Email Address


Address

Places & Policies Local Plan Main Modifications SAEvent Name


2Comment ID


PPLP MM SA Document (View)Consultation Point

SubmittedStatus


0.5Version

IntroductionWhich section of the Sustainability AppraisalAddendum are you commenting on?


MM01 - MM21

SupportingAre you:


Highways England has reviewed the Sustainability Appraisal Final document. This SA Addendumpresents a Sustainability Appraisal of the proposed Main Modifications to the PPLP and considerstheir implications for the SA findings reported previously. In combination with the Proposed SubmissionDraft SA Report, this addendum represents an appraisal of the PPLP as proposed to be modified,updating the findings that were presented in the SA Report. It should be noted that this is an addendumto that SA Report and that the two documents should therefore be read together (Para 1.2)

The SA provides comments on the main modification document, therefore where we have no furthercomments to make upon the SA response of the Main modification document - we have not providedany.


http://shepway.objective.co.uk/portal/pplp/places_and_policies_submission_draft/pplp_mm_1/places__policies_local_plan_main_modifications_sa?pointId=1578482031215#1578482031215

Comment.

(1244588)Consultee

Email Address


Address

Places & Policies Local Plan Main Modifications HRAEvent Name


1Comment ID


PPLP MM HRA Document (View)Consultation Point

SubmittedStatus


0.2Version

1. IntroductionWhich section of the Habitats RegulationsAssessment are you commenting on?


MM01 - MM21

SupportingAre you:


Natural England concurs with the finding of your HRA insofar that the proposed Main Modificationsfor the Folkestone and Hythe Places and Policies Local Plan are unlikely to have an adverse effecton the integrity of European sites alone or in-combination with other plans or projects.


http://shepway.objective.co.uk/portal/pplp/places_and_policies_submission_draft/pplp_mm_1/places_and_policies_local_plan_main_modifications_hra?pointId=1578481643442#1578481643442

representations on consultation 2020

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