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Dartford Development Policies Plan - Publication (Pre-Submission) REPRESENTATION FORM Development Policies Plan DARTFORD BOROUGH COUNCIL s1an uo to a-alerts For office use only Reference No: All respondents should complete Sections 1 to 3 of this form. You are requested to complete section 4 equalities monitoring form. Further copies of this representation form are available via: [email protected] Section 1 . ·Your Details and Consultation Procedures Feedback Name G Simpkin Job Title (if relevant) Company/organisation Graham Simpkin Planning name (if relevant) Client's name (if applicable) Mr K Mullner Postal address C!O Agent 2 The Parade Ash Road Hartley Longfield Kent Email address DA38BG Our Statement of Community Involvement says that we will keep consultation methods under review. We need your help with this please. You may also wish to give 'informal feedback'. Please indicate below how you became aware of the consultation. Febsite Do you considet that the document is easy to read? Do you have any general comments on presentation and clarity (other than the content of the Plan)? Were you provided with the information you needed to respond to the document? How could this be improved? Develo men! Policies Local Plan January 2016

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Dartford Development Policies Plan - Publication (Pre-Submission)

REPRESENTATION FORM

Development Policies Plan DARTFORD BOROUGH COUNCIL

~~~Wnected s1an uo to a-alerts

For office use only

Reference No:

All respondents should complete Sections 1 to 3 of this form. You are requested to complete section 4 equalities monitoring form.

Further copies of this representation form are available via: [email protected]

Section 1 .·Your Details and Consultation Procedures Feedback Name G Simpkin

Job Title (if relevant)

Company/organisation Graham Simpkin Planning name (if relevant)

Client's name (if applicable)

Mr K Mullner

Postal address C!O Agent 2 The Parade Ash Road Hartley Longfield Kent

Email address DA38BG

Our Statement of Community Involvement says that we will keep consultation methods under review. We need your help with this please. You may also wish to give 'informal feedback'. Please indicate below how you became aware of the consultation.

Febsite

Do you considet that the document is easy to read? Do you have any general comments on presentation and clarity (other than the content of the Plan)?

Were you provided with the information you needed to respond to the document? How could this be improved?

Develo men! Policies Local Plan January 2016

Dartford Development Policies Plan - Publication (Pre-Submission)

Section 2:

Representations on the Development Policies Plan's soundness and legal compliance

The purpose of this stage is for you to make formal representations on whether the Plan meets national tests of compliance. Representations you make here will be considered, including at Examination in Public hearings, by the Planning Inspectorate.

If you are potentially unclear, or would like further information, please email [email protected] or call 01322 843213. [The National Planning Policy Framework details the tests of soundness at Paragraph 182 (page 43): www.gov.uk/government/uploads/system/uploads/attachment data/file/6077 /2116950. p df

1. To which part of the Development Policies Plan Document does this representation relate? Please specify the Policy or Paragraph number.

Para 1.8

The document fails to fully bring forward the strategic policies of the Core Strategy in respect of CS3, Northern Gateway Strategic Site.

Policy DP5

The policy fails to provide any positive measures to bring forward development of the whole of the land identified in CS3.

New Policy

A new policy is required to address the particular issues set out below in section (4).

Develo ment Policies Local Plan Janua 2016

Dartford Development Policies Plan - Publication (Pre-Submission

2. Do you consider the Plan to be legally compliant? [please circle or highlight]

Yes No

3. Do you consider the Plan to be 'sound'? [please circle or highlight]

a) Yes No

b) If 'No': do you consider the Plan to be unsound because it is: i. Not Positively Prepared

ii. Not Justified iii. Not Effective iv. Not Consistent with National Policy

4. Please use this box below to specify the reasons for your answers to questions 2&3. Please be as precise as possible.

Develo ment Policies Local Plan Janua 2016

Dartford Development Policies Plan - Publication Pre-Submission

The plan is not effective because:

(1) There is a significant constraint of development of a large part of the land within CS3 (Diagram 4) due to the Safety Hazard posed by the gasometer site. At present, it is not possible to bring forward development proposals on this site or on the adjacent land. This effectively prevents the full development potential of CS3 from being met.

(2) The existence of this derelict infrastructure harms the local environment at one of the key gateways into the Town Centre, detracting from the efforts to regenerate and reinvigorate this part of the Town. It clearly conflicts with the positive approach to new development within this strategic development site.

(3) The existence of this derelict site represents a significant detraction from the aspirations of the Core Strategy to raise the quality of the environment and create a vibrant new image for the Northern Gateway.

(4) Correspondence with the Council and the relevant Statutory Undertaken reveals no commitment to secure the decommissioning, clean-up and removal of the gasometer, to allow development to proceed and improve the image of the area. Accordingly, there is no timescale or programme for this work and the result is likely to be that the full aspirations of the Core Strategy will not be met in CS3 and general policies for the improvement of the environment.

(5) Policy DP5 which seeks to address issues of the impact of new development on the environment does not address this issue of the blighting effect that this redundant facility has on the future development of a significant part of the Northern Gateway.

(6) What is clearly needed is a new policy to bring forward removal of this redundant facility by decommissioning, clean-up and removal of the derelict structure to allow the site to be developed in accordance with Policy CS3. This will require the Council to use necessary powers and commit resources to securing the removal of this redundant facility.

The Plan therefore will fail to deliver the development strategy set out in CS3 because it fails to bring forward a positive policy to address the issue of the gasometer.

Develo ment Policies Local Plan Janua 2016

Dartford Develo ment Policies Plan - Publication Pre-Submission

5. If you answered 'No' to questions 2 or 3a above on legal compliance/ soundness, please set out in the box below specific change(s) you consider necessary to make the Development Policies Plan legal/ sound. (For soundness matters, you should refer to the particular issue of soundness you selected in question 3b. For legal compliance, if you are considering matters of the Duty to Cooperate, please note that changes cannot be made through modifications on this at examination stage). You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or supporting text.

Develo men! Policies Local Plan Janua 2016

Dartford Development Policies Plan - Publication Pre-Submission

The DOPP should incorporate a new additional policy to make the document sound in accordance with the criticisms set out in (4) above, as follows:

"In order to address the constraints and undesirable impact arising from the existence of the derelict gasometer site in Victoria Road, Dartford, the Council will:

1. Bring forward a programme of measures to secure the removal of this facility by:

A. Negotiate with the relevant principals of the Statutory Undertaker to secure a timetable for the removal of this facility within the timescale of the future development envisaged in CS3.

B. In the event of lack of cooperation by the Statutory Undertaker, to consider use of Statutory Powers of Action to secure the removal of this facility.

C. Provide the necessary resources to secure the removal of this facility from public funding.

2. Alternatively, the Council will review proposals for the redevelopment of the site and the immediate environs with a significant level of new development that will provide the necessary funds and an incentive for the Statutory Undertaker to bring forward the removal of this facility at an early date.

In this way, there will be a measure in place to ensure that the DOPP brings forward the early development of this part of the Northern Gateway site as envisaged in Policy CS3."

With this additional policy added to the DOPP the plan will be effective in delivering the Core Strategy and will therefore become sound.

Develo ment Policies Local Plan Janua 2016

Dartford Develo ment Policies Plan - Publication Pre-Submission

Develo men! Policies Local Plan Janua 2016

Dartford Development Policies Plan - Publication Pre-Submission

Section 3: Final Representation Matters

6. Would you like to be notified of the following: [please circle or highlight]

i. The submission of the Development Policies Plan Document for independent examination by the Secretary of State?

Develo ment Policies Local Plan Janua 2016

Dartford Development Policies Plan - Publication Pre-Submission

ii. The publication of the Inspector's recommendations following the examination?

Yes No

iii. The adoption of the Development Policies Plan Document if found sound?

Yes No

Your signature:

Data Protection Statement: The information you provide will be held and used by Dartford Borough Council, in accordance with the Data Protection Act 1998, to help in the preparation of the Development Management Plan Scoping Report. Please note that all responses received will be available for public inspection. Your personal details will however remain confidential.

Development Policies Local Plan Janua 2016