1

South Kesteven

Local Plan

Representations to the

Main Modifications

Prepared by Fisher German LLP on Behalf of Oldrid & Co. Ltd

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Project Title:

Downtown Site, Grantham

Address:

Document Author Version Date Approved by Comments

Angela Smedley MRTPI

A 11/11/19

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01 Introduction

1.1 These Main Modifications representations are prepared by Fisher German on behalf of Oldrid &

Co. Ltd., and relate to the long-established retail site on land off Occupation Lane, Gonerby Moor,

Grantham, known locally as Downtown Grantham/Boundary Mill. Figure 1 illustrates the location

of the site.

Figure 1: Site Location

1.2 The site is owned by Oldrid & Co. Ltd which was founded in 1804 and is a family-owned retail

business with five major retail stores trading throughout Lincolnshire. The business has been

trading from the site at Occupation Lane, Gonerby Moor for 30 years. Planning consent was

granted for a retail store in 1988 with its subsequent trading commencing in 1989. The garden

centre was later granted planning permission in 1999 and commenced trading in 2000. The

application site measures 9.24 hectares (ha).

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1.3 The retail site comprises a major department store, with a furniture, homewares, clothing and

beauty offering, along with an outlet fashion retailer, Boundary Mill Stores. A large garden centre

providing an extensive outdoor offering is also located on the site. The site is a major retail

destination for the District with over 700 members of staff employed across the business.

1.4 The landowner proposes to redevelop the existing retail/outlet site to provide a premium Designer

Outlet Centre (DOC). At the time of writing (October 2019), a planning application (reference:

S17/2155) for a premium Designer Outlet Centre and associated uses has a resolution to grant

consent, subject to a Section 106 agreement which is in the final stages of preparation with the

Council. The application was referred to the Secretary of State, owing to its departure from the

adopted Local Plan. The Secretary of State decided not to call in the application, having regard to

the policy on call in, he considered that the application did not involve issues of more than local

importance that justify intervention. South Kesteven District Council will issue the decision notice

following engrossment of the Section 106 agreement.

1.5 Core Strategy (2010) Policy E1 Employment Development seeks to ensure that a portfolio of land

and buildings, with a range of sizes, uses and locations, with access to a good transport network

is available to ensure a successful, competitive and well-balanced business environment.

1.6 For Grantham, this means allocating approximately 90 ha (within the Site Specific Allocations and

Policies DPD) to include the identification of a high quality business park with good access to the

strategic highway network; sites which meet the needs of storage and distribution (B8) industries

with excellent access to the A1 and A52; sites for quality modern office, commercial and leisure

development within the town centre; and a broad and flexible portfolio of sites across the town to

accommodate office, commercial and manufacturing opportunities.

1.7 The policy continues to add that “the Council will seek to retain and enhance existing areas of

employment use in Grantham, Bourne, Stamford, the Deepings and villages unless it can be

demonstrated that:

• The site is vacant and no longer appropriate or viable as an employment allocation; and

• Redevelopment will deliver wider regeneration benefits; or

• An alternative use would not be detrimental to the overall supply and quality of employment land

within the district; or

• An alternative use would resolve existing conflicts between land uses”

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1.8 Site Allocation and Policies DPD (2014) Policy SAP5 Locally Important Existing Employment Sites

sets out that proposals for the development, reuse and/or redevelopment of land or premises

within the areas listed for employment-generating uses will be supported.

1.9 The site forms part of a wider employment allocation under this policy as ExE LSC1 (Figure 2) and

comprises the triangular land between the A1, B1174 and railway line to the south. Whilst

‘employment-generating uses’ is generally defined as development which falls within the B Use

Classes, the allocation is actually occupied by various companies including a hotel and petrol filling

station, a major retail store and large garden centre, warehousing as well as undeveloped land. In

addition, the allocation includes four residential properties. As such, it is apparent that the existing

uses do not make up typical B Use Classes; with the majority of the site comprising retail

development.

1.10 Despite the established retail use of the site, it remains designated as part of a wider ‘Local Service

Centre Existing Employment Sites’ allocation under Policy SAP5 / ExE LSC1.

Figure 2: Extract from the Site Allocation and Polices DPD (2014)

1.11 AECOM was commissioned by South Kesteven in early 2015 to undertake an employment land

study (ELS) of the district. The area defined as ExE LSC1 in the SAPD was included as ’Cluster R3’

for assessment purposes.

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1.12 Table 5-1 of the ELS identified the overall cluster area to be 45.4 ha, with 9.1 ha of this forming

vacant land, approximately 20% of the allocation. In addition, the application site, at 9.24 ha,

equates to a further 20% of the total employment land allocation.

1.13 Despite the above, the Submission Local Plan sought to allocate the totality of ‘Cluster R3’ as an

Existing Employment Site, protected by Emerging Policy E3. The associated policy wording stated

that the re-development of such sites, outside of employment generating uses will be resisted. It

is considered that given the existing retail use at the application site for some 30 years, and the

resolution to grant consent for a premium DOC, that the proposed employment allocation was

incorrectly made and that the boundaries for the employment allocation need to be redrawn to

exclude the retail site and the associated application of Policy E3 which relates to B uses only.

1.14 These representations are prepared in the context of the above considerations.

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02 Main Modifications

MM23

Policy E1 E2: Strategic Employment Sites

2.1 We support the proposed amendments as set out below which allows for other employment

generating uses outside of the B-use classes….and an end-user has for the proposals has been

‘positively identified’ rather than ‘secured’. It may be impossible to secure an end-user without the

benefit of a planning permission, thereby this modification seeks to address and overcome this

issue by enabling planning permission to be granted by identifying an end-user.

Other employment generating uses outside of the B-use classes may also be appropriate and will be

considered where the promoter actively engages with the Council and an end-user for the proposal has

been secured positively identified.

2.2 The modification is considered to be justified and effective.

MM24

Policy E2 E3: Employment Allocations

2.3 We support the proposed amendments as set out below which allows for other employment

generating uses outside of the B-use classes….and an end-user has for the proposals has been

‘positively identified’ rather than ‘secured’. It may be impossible to secure an end-user without the

benefit of a planning permission, thereby this modification seeks to address and overcome this

issue by enabling planning permission to be granted by identifying an end-user.

Other employment generating uses outside of the B-use classes may also be appropriate and will be

considered where the promoter actively engages with the Council and an end-user for the proposal has

been secured positively identified.

2.4 The modification is considered to be justified and effective.

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MM25

Policy E3 E4: Protection of Existing Employment Sites

2.5 We support the proposed amendments as set out below:

The following locally important employment sites identified on the Policies Map will be protected to

ensure continued provision of locally important employment opportunities. Proposals for the re-

development of these sites, outside of employment generating uses will be resisted. Appropriate

proposal for new B1, B2 and/or B8 uses and/or redevelopment of for B1, B2 and/or B8 as well as other

employment generating uses outside of the B-use classes will be supported where proposals:

• do not conflict with neighbouring land uses;

• scale does not harm the character and/or amenities of locality; and

• do not impact unacceptably on the local and/or strategic highway network.

2.6 The modification firstly sets out that the employments sites listed in the associated table are

identified on the Policies Map, which clarifies the exact site areas and boundaries. The

modification is considered to be justified and effective.

2.7 We also support the deletion of text which had set out that ”proposals for the re-development of

these sites, outside of employment generating uses will be resisted” which was considered

inconsistent with Policy E1 and E2, now E2 and E3, that include provisions for allowing non B-use

classes onsite.

2.8 NPPF paragraph 22 sets out that planning policies should avoid the long term protection of sites

allocated for employment use where there is no reasonable prospect of a site being used for that

purpose, and that land allocations should be reviewed regularly. The paragraph continues that,

where there is no reasonable prospect of a site being used for the allocated employment use,

applications for alternative uses of and or buildings should be treated on their merits having regard

to market signals and the relative need for different land uses to support sustainable local

communities. The limitations imposed by the Submission Plan policy seeks to prevent forward-

thinking innovation from taking place. The modification seeks to avoid such long term protection

of employment sites and is considered to be justified, effective and consistent with national policy.

2.9 The replacement text is supported which reflects the text within Policy E1 and E2, now E2 and E3,

and allows for other employment generating uses, outside of the B-use class, on the sites listed

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within the associated table, subject to a number of criteria which are considered acceptable. The

modification is considered to be justified, effective and consistent with national policy.

2.10 In addition to the above, the proposed modification to Site R3 in the associated Policy E4 table is

supported. The modification reduces the site area from 45.30 ha to 35.83 ha. The modification is

a result of the removal of the existing retail site at Occupation Lane, Gonerby Moor, as this had

been wrongly included as part of the wider R3 designation.

2.11 The site off Occupation Lane, is an established retail destination which has been trading for 30

years and has a resolution to grant consent for a premium DOC. The inclusion of the retail site as

part of the wider R3 employment designation, and the consequential application of emerging

Policy E3, now E4, to the site, which resists re-development of the site outside of employment

generating uses, is therefore wholly inappropriate.

2.12 Whilst the reduction of available “employment land” has been reduced by this modification, there

is adequate employment land available to meet the meet the supply needs of the District.

2.13 The Employment Land Study (ELS) (October 2015) assesses the demand and supply of

employment land in South Kesteven. The ELS has identified a need of between 46.7 ha to 79.1 ha

of additional industrial land (with a central growth rate of 62.1 ha) in the District over the period

2015-2036.

2.14 The Submission Plan set out that it proposes to allocate 154.75 ha of employment land (detailed

under, then, Policies E1 and E2; strategic employment sites and new employment allocations) and

342.68 ha of existing employment sites under Policy E3, now E4. Since the Consultative Draft

2007, which outlined the same figures, a further parcel of land was included in Policy E1, (Land

South of Gorse Land, West of A1- SKLP272), comprising a further 11.29 ha of employment land.

This, coupled with the 154.75 ha of new employment land indicated above, totals 166.04 ha of new

employment provision.

2.15 The Main Modifications sets out amendments to employment allocations through policies E1

(118.91 ha), E2 (40.81 ha) and E3 (20.2 ha), totalling some 179.92 ha of new employment provision;

an increase of 13.88 ha of new provision.

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2.16 In addition, the Submission Plan set out existing employment land totalling 342.68 ha, whereas

the Main Modification (including the reduction at R3) sets out an existing employment provision

of 362.94 ha, an increase of 20.26 ha.

2.17 The overprovision of existing and new employment land, from Submission Plan to Main

Modifications, amounts to some 34.14 ha. Consequently, there is no requirement for the land at

Occupation Lane, Gonerby Moor to be allocated as existing employment land as sufficient

employment land has been made available that more than compensates for the exclusion of the

existing retail site at Gonerby Moor. As such, the modification is considered to be justified,

effective and consistent with national policy.

SKDCMC-8

A0 Policy Map: EMP-R3

2.18 This modification is associated with MM25 and seeks an amendment to EMP-R3 (Policy E4) by

removing the existing retail site at Occupation Lane, Gonerby Moor, as this had been wrongly

included as part of the wider R3 designation.

2.19 The modification reduces the R3 site area from 45.30 ha to 35.83 ha and is fully supported.

2.20 The modification is considered to be justified, effective and consistent with national policy

Summary

2.21 For the reasons outlined, we consider that the proposed Main Modifications (MM23, MM24, MM25

and SKDCMC-8) are welcomed and fully supoported. The modifications are considered to be

justified, effective and consistent with national policy.

South Kesteven District Council – Local Plan 2011-2036

Please fill in a separate form for each representation you wish to make.

This form has three parts:

Part A is for your personal details.

Part B is your representation(s) on Main Modifications

Part C is your representation(s) on the Changes to the Policies Map, OR the Sustainability Appraisal

Addendum, OR the Habitats Regulation Addendum.

How to respond:

Please fill in a separate response form for each proposed main modification you wish to comment on.

It is important that you state the reference number your representation relates to (e.g. MM1). This

will enable us to process your comments efficiently and effectively.

Representations should focus only on the Proposed Main Modifications, this is not an opportunity to

make comments on any other aspect of the Local Plan. At this stage representations should relate to

the soundness of the Main Modification(s) or compliance with legal requirements. A summary of your

response must also be provided if the response is greater than 1,000 words in length. An

accompanying FAQ for this consultation is available on the Council’s website

www.southkesteven.gov.uk/newlocalplan

Please note at this stage representations will only be accepted on the Proposed Main Modifications.

All duly made representations will be sent via the Programme Officer to the Planning Inspector for

their consideration.

Respond by returning forms by:

Email: to planningpolicy@southkesteven.gov.uk

Post: to Planning Policy Team, South Kesteven District Council Offices, St Peters Hill, Grantham, NG31

6PZ

The Deadline for responses is 11:59pm on Monday 11th November 2019

All representations will be made publicly available and must be received by 11:59pm on Monday 11th

November 2019. Any response received after then will not be considered.

South Kesteven District Council Local Plan

Proposed Main Modifications Response Form

Monday 30th September to 11:59pm Monday 11th November 2019

For Official Use Only:

Ref:

1 South Kesteven District Council – Local Plan 2011-2036 Representation Form

Part A: Personal Details

1. Personal Details 2. Agents Details (if Applicable)

Title Miss Mr

First Name Sophie Christopher

Last Name Pryor Roberts

Organisation Commercial Estates Group (CEG) and the Cecil Estate Family Trust

Boyer Planning

Address

Postcode

Telephone

Email Address

Please note: that representations must be attributable to named individuals or organisations. “In

confidence” representations will not be accepted. All representations will be available for public

inspection and cannot be treated as confidential. We will however redact signatures, home/ email

addresses, and telephone contact details from any information that is published.

3. If you are not already on our consultation database and you respond your details will automatically be added to the database

If you do not wish to be added or would like your details to be removed, then please select the following box

4. Please let us know if you wish to be notified of the following Yes No

The Publication of the Inspector’s Report X

The Adoption of the Local Plan X

5. Please sign and date this form:

Signature (please type for an electronic response) Date

07/11/2019

2 South Kesteven District Council – Local Plan 2011-2036 Representation Form

Part B: Your Representation on Main Modification

PLEASE USE ONE FORM FOR EACH PROPOSED MAIN MODIFICATION REPRESENTATION

6. To which Proposed Main Modification does your representation relate to?

MM23

7a. Do you consider the Proposed Main Modification you have identified above makes the Local Plan Legally Compliant?

Yes No X

7b. Do you consider the Proposed Modification(s) makes the Plan Sound*?

Yes No X

Please identify which test of soundness your comments relate to by selecting the box below

Positively Prepared

X Effective X

Justified X Consistent with National Policy

X

* The considerations relating to a development plan being sound are explained in the National

Planning Policy Framework (paragraph 182) – these relate to the plan being positively prepared,

justified, effective and consistent with national policy.

8. Please give details below of why you consider the Local Plan is not Legally Complaint or is unsound. If you wish to support the legal compliance or soundness of the Local Plan, please also use this box to set out your comments. Please be as precise as possible. If your response is more than 1000 words, then please provide a short summary at the start.

MM23 changes the scope of the Policy that addresses Strategic Employment Sites (Submission Plan Policy E1) by removing reference to the Grantham Southern Gateway (GSG) and its constituent strategic employment sites (5 sites in total). The GSG is to be addressed in a separate policy specifically for this area (as proposed in MM22). Scale of Employment Land provision We note that despite evidence presented at the EiP about the significant over provision of employment land, it appears that the new policy for the GSG increases the scale of this strategic allocation from 105.94 ha to 118.91 ha. The Inspector’s letter to the Council dated 11 June 2019 refers to “an appreciable over-provision of employment land”. The Inspector concludes this does not mean the Plan is necessarily unsound. However, given the weight of evidence presented to the EiP about employment oversupply, we consider that this issue does in fact go to the soundness of the Plan and should be addressed through these Main Modifications. It is clear from the Inspector’s letter of 11 June 2019 that concerns about the evidence base for employment land supply and the level of over-provision are key points of justification for the Inspector’s recommended early review process. If, notwithstanding our concerns about the soundness of the Plan, the Inspector decides to leave the matter for resolution through an early Local Plan review, it is important that the current Plan provides a clear framework for that review. We consider that some limited further modifications are necessary to achieve this: First, We consider that the Plan must state in policy, via a Main Modification, the overall level of employment supply that will result from the Plan’s policies as the reference point for the early review process. The current Main Modifications, set out additions and deletions to employment

3 South Kesteven District Council – Local Plan 2011-2036 Representation Form

land allocations but do not state how these modifications change the overall supply figures set out in paragraph 2.69 of the submission plan. Second, it is important that the new policy for an early Local Plan Review (as proposed by MM72) sets out the requirements for this review in relation to employment land, to provide a clear structure and discipline for the review process in this subject area. We have addressed this matter separately in our representations on MM72. Strategic Employment Sites MM23 does not make the changes to the policy for Strategic Employment Sites that are necessary to make it sound. The Inspector’s hearing agenda for Matter 5 “Planning for Economic prosperity” at item 3(ii) included the issue: “Soundness of the proposed Strategic Employment Sites with specific reference to the Grantham Southern Gateway, Exeter Fields Stamford and Peterborough Road Market Deeping”. Our specific concern is the proposed Strategic Employment Site status of Exeter Fields and the change this makes to the current employment allocation of the site in the adopted Site Allocations and Policies DPD. We wish to make clear that we very much support employment provision at the Exeter Fields site and the retention of an employment allocation. Our vision for the site is for an allocation of a scale that is flexible, marketable and viable with high quality commercial uses such as a hotel, public house and care home on the Empingham Road frontage that are important in townscape terms at this gateway to Stamford, with B1 and B2 uses behind this frontage which are of an appropriate scale to meet the proven demand for the mixed use nature of this site. The proposed Strategic Site status for Exeter Fields is not compatible with these proposals. However, regardless of our own proposals and whatever their merits, our key point is that the Strategic Employment Sites designation is not sound because it is not explained, justified or effective. It was clear from the evidence presented to the hearing that the designation of Strategic Employment Areas in this Plan is not soundly based for the following reasons:

First, the Local Plan, the Employment Land Study and the site selection methodology, do not specify the criteria used to identify and allocate strategic and non-strategic employment sites in South Kesteven.

Second, there is little to distinguish between Strategic Employment Sites and other employment allocations, and it is difficult to see how the designation of such sites in South Kesteven is justified or effective.

Third, in relation to Exeter Fields Stamford, it is not clear how this site justifies its strategic status other than its proximity to the A1 which is a very limited, single criterion.

Overall, the categorisation of ‘Strategic Employment Sites’ is not properly defined or articulated in the Plan and its evidence base. This compounds the Inspector’s concerns about the “appreciable overprovision of employment land” in the Plan as a whole.

4 South Kesteven District Council – Local Plan 2011-2036 Representation Form

The evidence base and justification for the inclusion of Exeter Fields as a Strategic Employment Site is clearly unsound. The Council’s “Site Assessments Report” devotes one page to this site and its conclusions are limited to the assertion that “there is no information to suggest that employment is no longer suited to this location”. This concerns only the principle of the site’s employment allocation and contains no justification for its strategic employment site status. Within the ELS, there is no wider review of the market attractiveness of the Exeter Fields site. The criteria adopted only give a very limited assessment and the ELS does not provide any site-by-site assessment as to the deliverability of greenfield sites or the prospects of them coming forward in the context of market demand. In regard to Exeter Fields, the site was previously allocated in the South Kesteven Site Allocation and Policies DPD (adopted in April 2014) for a 10 hectare business park as part of mixed used development including 400 dwellings. The Plan provides no justification for changing the status of this employment allocation. The site has simply been rolled forward from the previous plan but with elevated standing and importance with no evidence or explanation for the change. Exeter Fields cannot now be designated as a Strategic Employment Site without setting out what has changed since the previous Plan to justify this. The Plan has not carried out the requirement of the 2012 NPPF para 22 that land allocations should be regularly reviewed. It is fundamentally important that the status of the site is not changed without such a review. The case for a comprehensive and systematic review, which properly accounts for market signals, is clear. Despite this, there has been no assessment of the appropriateness and market attractiveness of employment allocations (developed or undeveloped), which continue to be proposed for allocation for that purpose. The failure to undertake this exercise is inconsistent with the Planning Practice Guidance (at ID3-019), has material implications for the effectiveness of the Plan’s policies and serves to undermine the extent to which the Plan can be regarded as justified. The mixed use nature of the Exeter Fields site is an important consideration here and requires a scale of employment use (in terms of land area, height and massing and intensity of use) that is compatible with a residential area rather than strategic scale employment delivery for which sites at Grantham are better suited. We have conducted our review of market demand for employment land at Stamford and the prospects for take up of the Exeter Fields site in particular. This suggests a reduction in the scale of the allocation and a more flexible approach to its delivery with an emphasis on the quality, character and employment potential of the development. Our evidence on the Stamford employment land market reveals, in summary:

Stamford is a secondary location for employment development, with Grantham being the focus in South Kesteven, whilst Peterborough is the focus in the FEMA. The quantum of the existing stock of employment floorspace in Stamford (approximately 8% of all B-Class employment space) reflects this status, as do the rates of development within the town.

The employment land provision in Stamford far exceeds its role and function; there is no prospect that all Stamford’s employment sites will be built out for offices/industrial; whilst

5 South Kesteven District Council – Local Plan 2011-2036 Representation Form

effective/realisable market demand in the town, based on market signals and evidence, is limited.

Exeter Fields has undergone five years of marketing for employment development, with limited interest and especially not of a scale which could see the full 10ha developed in the medium-term of the Local Plan. In total, 38 enquiries have been received, but only 13 have been for traditional B-Class uses, and none has led to an active proposition for development.

A reduced employment land component at Exeter Fields of 4ha is considered to have a reasonable prospect of being delivered over the medium-to-long term. This should be for a mix of employment generating uses in line with Policies E1 and E2.

What we consider to be both appropriate and deliverable at this site, is a smaller quantum (approximately 4 hectares) of employment generating uses. This is likely to include a hotel and a care home, fronting Empingham Road, with B1 uses and residential development sitting behind. There is also potential to deliver the ‘innovation hub’ that is now unlikely to be delivered at the vacant S1 and S8 employment sites in the east of the town. In conclusion, the Council has produced no evidence to justify elevating the status of the Exeter Fields site to a Strategic Employment Site. The evidence that we have compiled suggests a more limited higher quality development that is compatible with the mixed-use nature of the site. Without prejudice to the merits of the revised allocation for Exeter Fields that we have proposed, we consider that the minimum action that is necessary to ensure the Plan is sound is to maintain the existing status of the site as established by the 2014 Site Allocations and Policies DPD. If, for whatever reason, the Inspector is not minded to take this course of action, we suggest that the status and justification for the strategic employment sites be specifically included within the scope of the early Plan review process. This would be in the wider context of reviewing progress of employment site delivery against the scale of provision made in this Plan.

(Continue on a separate sheet/expand box if necessary).

6 South Kesteven District Council – Local Plan 2011-2036 Representation Form

9. Please set out what changes you consider necessary to make the proposed Main Modification to the Local Plan legally complaint or sound, having regard to the test you have identified above. You will need to say why this change to the Main Modification will make the Local Plan Legally Compliant or Sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

Policy E1 (now E2) should be modified such that Exeter Fields is deleted as a strategic employment site. The evidence we have presented points to a reduction in the scale of this employment allocation and greater flexibility of employment uses. If the Inspector is not minded to make this change, the Exeter Fields employment allocation should retain its existing employment status as specified in the 2014 Site Allocations and Policies DPD and be included in the Policy to be renumbered E3 “Employment Allocations”. As a minimum requirement, the scale, status and evidence base for the employment allocation at Exeter Fields should be specifically included within the terms of the early Local Plan review process.

(Continue on a separate sheet/expand box if necessary).

Please note: your representation should cover succinctly all the information, evidence and supporting

information necessary to support/justify the representation and the suggested modification.

10. Are you attaching any additional sheets that relate to this representation?

Yes No X

If yes, please indicate total additional sheets

Part C: Representations on Policy Map Changes, Sustainability Addendum, and Habitat Regulations

Assessment Addendum (please complete a separate Part C form for each representation you wish

to make)

7 South Kesteven District Council – Local Plan 2011-2036 Representation Form

11. To which Policies Map Change or Section of the Sustainability Appraisal Addendum, or Habitats Regulation Assessment Addendum does this representation relate to?

Proposed Policies Map Change (e.g. SKPMC-1)

Sustainability Appraisal Addendum

Habitat Regulations Assessment Addendum

12. Please set out your comments below.

(Continue on a separate sheet/expand box if necessary). 12a. Are you attaching any additional sheets that relate to this representation?

Yes No X

If yes, please indicate total additional sheets

Thank you for taking time to complete this representation

SouthKestevenDistrictCouncil–LocalPlan2011-2036

Pleasefillinaseparateformforeachrepresentationyouwishtomake.

Thisformhasthreeparts:

PartAisforyourpersonaldetails.

PartBisyourrepresentation(s)onMainModifications

PartCisyourrepresentation(s)ontheChangestothePoliciesMap,ORtheSustainabilityAppraisalAddendum,ORtheHabitatsRegulationAddendum.

Howtorespond:

Pleasefill inaseparateresponseformforeachproposedmainmodificationyouwishtocommenton. It is importantthatyoustatethereferencenumberyourrepresentationrelatesto(e.g.MM1).Thiswillenableustoprocessyourcommentsefficientlyandeffectively.

RepresentationsshouldfocusonlyontheProposedMainModifications,thisisnotanopportunitytomakecommentsonanyotheraspectoftheLocalPlan.Atthisstagerepresentationsshouldrelatetothe soundness of theMainModification(s) or compliancewith legal requirements. A summary ofyour response must also be provided if the response is greater than 1,000 words in length. Anaccompanying FAQ for this consultation is available on the Council’s websitewww.southkesteven.gov.uk/newlocalplan

PleasenoteatthisstagerepresentationswillonlybeacceptedontheProposedMainModifications.AlldulymaderepresentationswillbesentviatheProgrammeOfficertothePlanningInspectorfortheirconsideration.

Respondbyreturningformsby:

Email:toplanningpolicy@southkesteven.gov.uk

Post: to Planning Policy Team, South Kesteven District Council Offices, St Peters Hill, Grantham,NG316PZ

TheDeadlineforresponsesis11:59pmonMonday11thNovember2019

Allrepresentationswillbemadepubliclyavailableandmustbereceivedby11:59pmonMonday11thNovember 2019. Any response received after then will not be considered.

SouthKestevenDistrictCouncilLocalPlan

ProposedMainModificationsResponseForm

Monday30thSeptemberto11:59pmMonday11thNovember2019

ForOfficialUseOnly:

Ref:

1SouthKestevenDistrictCouncil–LocalPlan2011-2036RepresentationForm

PartA:PersonalDetails

1.PersonalDetails 2.AgentsDetails(ifApplicable)

Title MRS MR

FirstName HELEN MIKE

LastName MACROW SIBTHORP

Organisation SUMMER ESTATE HOLDINGS

MIKE SIBTHORP PLANNING

Address

Postcode

Telephone

EmailAddress

Pleasenote: that representationsmustbeattributable tonamed individualsororganisations. “Inconfidence” representations will not be accepted. All representations will be available for publicinspectionandcannotbetreatedasconfidential. Wewillhoweverredactsignatures,home/emailaddresses,andtelephonecontactdetailsfromanyinformationthatispublished.

3. If you are not already on our consultation database and you respond your details willautomaticallybeaddedtothedatabaseIf youdonotwish tobeaddedorwould like yourdetails tobe removed, thenpleaseselectthefollowingbox

4.Pleaseletusknowifyouwishtobenotifiedofthefollowing Yes NoThePublicationoftheInspector’sReport X TheAdoptionoftheLocalPlan X

5.Pleasesignanddatethisform:

Signature(pleasetypeforanelectronicresponse) Date

11/11/2019

2SouthKestevenDistrictCouncil–LocalPlan2011-2036RepresentationForm

PartB:YourRepresentationonMainModification

PLEASEUSEONEFORMFOREACHPROPOSEDMAINMODIFICATIONREPRESENTATION

6.TowhichProposedMainModificationdoesyourrepresentationrelateto? MM23/MM25

7a. Do you consider the Proposed Main Modification you haveidentifiedabovemakestheLocalPlanLegallyCompliant?

Yes X No

7b. Do you consider the Proposed Modification(s) makes the PlanSound*?

Yes X No

PleaseidentifywhichtestofsoundnessyourcommentsrelatetobyselectingtheboxbelowPositivelyPrepared

Effective

Justified Consistent with NationalPolicy

*The considerations relating to a developmentplanbeing soundare explained in theNationalPlanningPolicyFramework(paragraph182)–theserelatetotheplanbeingpositivelyprepared,justified,effectiveandconsistentwithnationalpolicy.

8. Pleasegivedetailsbelowofwhyyouconsider theLocalPlan isnotLegallyComplaintor isunsound.IfyouwishtosupportthelegalcomplianceorsoundnessoftheLocalPlan,pleasealsousethisboxtosetoutyourcomments.Pleasebeaspreciseaspossible.Ifyourresponseismorethan1000words,thenpleaseprovideashortsummaryatthestart.THE REPRERESENTOR SUPPORTS THE PROPOSED MAIN MODIFICATIONS IN RESPECT OFROSELANDBUSINESSPARK–NOTABLYTHEPROPOSEDALLOCATIONSWITHINPOLICYE1ANDTHEPROTECTIONOFEXISTINGEMPLOYMENTSITES,POLICYE3(REVISEDSITEAREAMEASUREMENT).(Continueonaseparatesheet/expandboxifnecessary).

3SouthKestevenDistrictCouncil–LocalPlan2011-2036RepresentationForm

9.PleasesetoutwhatchangesyouconsidernecessarytomaketheproposedMainModificationto the Local Plan legally complaint or sound, having regard to the test you have identifiedabove.YouwillneedtosaywhythischangetotheMainModificationwillmaketheLocalPlanLegally Compliant or Sound. It will be helpful if you are able to put forward your suggestedrevisedwordingofanypolicyortext.Pleasebeaspreciseaspossible.(Continueonaseparatesheet/expandboxifnecessary).

Please note: your representation should cover succinctly all the information, evidence andsupporting information necessary to support/justify the representation and the suggestedmodification.

10. Are you attaching any additional sheets that relate to thisrepresentation?

Yes No X

Ifyes,pleaseindicatetotaladditionalsheets

4SouthKestevenDistrictCouncil–LocalPlan2011-2036RepresentationForm

PartC:RepresentationsonPolicyMapChanges,SustainabilityAddendum,andHabitatRegulationsAssessmentAddendum(pleasecompleteaseparatePartCformforeachrepresentationyouwishtomake)

11. To which Policies Map Change or Section of the Sustainability Appraisal Addendum, orHabitatsRegulationAssessmentAddendumdoesthisrepresentationrelateto?ProposedPoliciesMapChange(e.g.SKPMC-1) X

SustainabilityAppraisalAddendum

HabitatRegulationsAssessmentAddendum

12.Pleasesetoutyourcommentsbelow.

THE REPRESENTOR SUPPORTS THE CHANGES TO THE POLICIESMAP IN RESPECTOF ROSELANDBUSINESSPARK-SKDMC-4,SKDMC–4(PART2)POLICYE1ALLOCATIONR1POLICYE4SITE(Continueonaseparatesheet/expandboxifnecessary).12a. Are you attaching any additional sheets that relate to thisrepresentation?

Yes No X

Ifyes,pleaseindicatetotaladditionalsheets

Thankyoufortakingtimetocompletethisrepresentation