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Belfast Local Development Plan 2035

Draft Plan Strategy

Counter Representations

Overvie

We consulted on the draft Plan Strategy (dPS) as part of an ongoing process for creating the Belfast

Local Development Plan 2035. A number of representations, which we have now published, were

received during the public statutory consultation process which ended at 5pm on Thursday 15

November 2018.

Hard copies of the representations received on the dPS are available for inspection during normal

office hours at:

Belfast Planning Service

Belfast City Council

Cecil Ward Building

4-10 Linenhall Street

Belfast

BT2 8BP

The representations can also be viewed on our website at www.belfastcity.gov.uk/LDP.

Counter Representations

Following publication of the representations

received on the dPS, there is now the opportunity for the

submission of

ounter

epresentations. The consultation period for the submission of counter

representations runs from 12 noon on Friday 1 March 2019 to 12 noon on Friday 26 April 2019.

DPS-CR02

Counter representations may only be made in relation to a site specific policy representation seeking

a change to the dPS and should indicate the reasons for doing so in terms of soundness and

sustainability of the dPS.

Any person may make a counter representation, but must not propose alternative sites or any further

changes to the dPS and are without a right of hearing at Independent Examination (IE). Counter

representations of this nature or those supporting a site specific policy representation will not be

considered.

A “site specific policy representation” means any representation which seeks to change a

development plan document (DPD) (in this case, the dPS) by:

1. adding a site specific policy to the DPD; or

2. altering or deleting any site specific policy in the DPD.

A “site specific policy” means a policy in a DPD which identifies a site for a particular use or

development.

The dPS does not include site specific policies as these are dealt with at the next stage of the LDP

process, which is the preparation of the Local Policies Plan (LPP). However, a number of

representations received in response to the public consultation make reference to specific sites and

proposed development or uses. Any counter representation should clearly state the reference number

of the representation to which it relates.

Submitting a Counter Representation

Counter representations on site specific policy representations must be received by Belfast Planning

Service by 12 noon on Friday 26 April 2019. Any counter representation received after this time will not

be considered.

Counter representations can be submitted:

• via the online survey on the Council’s consultation site, yoursay.belfastcity.gov.uk

• by email to localdevelopmentplan@belfastcity.gov.uk; or

• by post, returning the response form to the address above.

Although we have provided a downloadable version of this consultation response form, we would

encourage you to respond via the online survey.

Accessibility

The relevant documents are available, on request, in alternative formats - Braille, audio, large print,

easy read. The council will also consider requests to produce it in other languages. If you require

the documents in these or other formats please contact us:

Belfast Planning Service

Belfast City Council

Cecil Ward Building

4-10 Linenhall Street

Belfast

BT2 8BP

Telephone: 028 9032 0202, ext 2255

Email: planning@belfastcity.gov.uk

1. Data Protection

Belfast City Council is a Data Controller under the Data Protection Act 1998 and the General Data

Protection Regulations (GDPR). The council is committed to protecting your privacy and to process

any personal data submitted by you in a manner which meets the requirements of the Data Protection

legislation. The Privacy Notice below provides more information regarding our commitments to you

under privacy and data protection.

Privacy Notice

Belfast City Council is the Data Controller under the General Data Protection Regulation (GDPR) for

the personal data it gathers for the purposes of sending regular email updates on the Local

Development Plan from Belfast Planning Service.

It should also be noted that in accordance with Regulation 19 of the Planning (Local Development

Plan) Regulations (Northern Ireland) 2015, the council must make a copy of any representation

available for inspection. The Council is also required to submit the representations to the Department

for Infrastructure and they will then be considered as part of the independent examination process.

The council accepts that you are providing your personal data on the basis of consent and are

positively agreeing for the council to hold and further use it, publish it (without personal information

such as address or email address, but may include organisation or name). Belfast City Council must

also share it with the Department for Infrastructure and whoever they appoint to undertake the

independent examination.

Any personal details that you provide the Council will be handled in accordance with the GDPR and

Data Protection Act 2018. As such we will only use your data for the purposes that you have given

this information for and will only be shared where necessary to provide the service that you are

contacting us about. If you would like further information in regards please see the

website belfastcity.gov.uk/about/privacy

The personal data is held and stored by the council in a safe and secure manner and in compliance

with Data Protection legislation and in line with the council’s Records Retention and Disposal

Schedule.

If you wish to contact the council’s Data Protection Officer, please write to:

Belfast City Council

City Hall

Belfast

BT1 5GS

or send an email to records@belfastcity.gov.uk

Q. Please tick to confirm that you have read and understood the privacy notice

above.

(Required)

Please select all that apply



I confirm that I have read and understood the privacy notice above and give my consent for

Belfast City Council to hold my personal data for the purposes outlined.

Q. Do you consent for us to publish your response?

Under planning legislation we are required to publish responses received in response to the Plan

Strategy. On this page we ask for your consent to do so, and you may opt to have your response

published anonymously should you wish.

Even if y

ou opt for your comments to be published anonymously, we will still have a legal duty to

share your contact details with the Department for Infrastructure and the inspectorate they appoint

to oversee the examination in public into the soundness of our plan. This will be done in accordance

with the privacy statement above.

(Required)

Please select only one item



Yes, with my name (individuals) or organisation name



Yes, but without any identifying information

Note: Under either option, personal information such as email address or telephone number will still

be redacted from published documents.

✔

2. Your details

Q. Are you responding as an individual, as an organisation, or as an agent acting on

behalf of an individual, group or organisation?

(Required)

Please select

only one item



Individual (Complete this Section, then proceed to Section 5)



Organisation (Complete this Section, then proceed to Section 3)



Agent (Complete this Section, then proceed to Section 4)

Q. What is your name?

Title

Full Name (Required)

Q. What is your address?

Address Line 1

Address Line 2

Address Line 3

City

Postcode

Q. What is your telephone number?

Q. What is your email address?

(Required)

Mrs

Sara Tinsley

Turley

Hamilton House

3 Joy Street

Belfast

BT2 8LE

028 9072 3900

sara.tinsley@turley.co.uk

3 Organisation

If you have selected that you are responding as an organisational respondent, there are a number of

pieces of information that we are legally required to gather from you.

Q. If you are responding as a representative of a group or organisation, please

provide details below:

Organisation

Your Job Title

Organisation address (if different from above):

Address Line 1

Address Line 2

Address Line 3

City

Postcode

4. Agent

If you have selected that you are responding as an agent on behalf of other

people/organisations, there are a number of pieces of information that we are legally required to

gather from you.

Q. Please provide details of the organisation or individual you are representing:

The name of the organisation or individual you are representing:

Client contact details:

Title

Full Name

Address Line 1

Address Line 2

Address Line 3

City

Postcode

Telephone Number

Email Address

Q. Would you like us to contact you, your client or both in relation to this response or

future consultations on the LDP?

Please select only one item



Agent



Client



Both

Belfast Harbour

Graeme Johnston

Harbour Office

Corporation Square

Belfast

BT1 3AL

028 9055 4422

g.johnston@belfast-harbour.co.uk

5. Representation to draft Plan Strategy Consultation

Q. Did you submit a representation to the Belfast Local Development Plan Draft Plan

Strategy 2035?

Note: The formal consultation period for representations to the Belfast Local Development Plan

Draft Plan Strategy 2035 commenced on Thursday 20 September 2018, and closed at 5pm on

Thursday 15 November 2018.

(Required)

Please select only one item



Yes (Complete Sections 5b, then Proceed to Section 6)



No (Proceed to Section 6)

5b. Representation to draft Plan Strategy Consultation

Q. Please provide the reference number assigned to your representation to the

Belfast Local Development Plan Draft Plan Strategy 2035.

Note: Your reference number can be found on the letter sent to you, by Belfast City Council on

Friday 22 February 2019

(Required)

Q. Please provide a summary of the issue(s) raised in your representation to the

Belfast Local Development Plan Draft Plan Strategy 2035.

(Required)

DPS-B-AM-S

A comprehensive submission was made by Belfast Harbour in respect of various

components of the Draft Plan Strategy. You are referred to the body of information

contained within Representation Ref. DPS-B-AM-S. A summary of the key

comments can be found in the Executive Summary of the document.

6. Counter Representation

Any person may make a counter representation in relation to a representation seeking a change to a

Development Plan Document (DPD). The purpose of a counter representation is to provide an

opportunity to respond to proposed changes to the DPD a result of representations submitted under

Regulations 15 and 16 of The Planning (Local Development Plan) Regulations (Northern Ireland)

2015.

A coun

ter representation must not propose any further changes to a DPD.

Q. Please provide the reference number of the representation to which your counter

representation relates.

Please provide only one reference number. If you wish to make a counter representation to more

than one representation, complete a separate sheet (Section 6 only) for each counter representation

you wish to make and append the sheet(s) to your submission.

Note: Your counter representation must relate to a representation made to the Belfast Local

Development Plan Draft Plan Strategy 2035 during the formal consultation period which commenced

on Thursday 20 September 2018 and closed at 5pm on Thursday 15 November 2018. The

representations received during this period can be viewed on the Council’s website at

www.belfastcity.gov.uk/LDP.

Q. Please give reasons for your counter representation having particular regard to

the soundness test in the above representation.

Please note that your counter representation should be submitted in full and cover succinctly all the

information, evidence, and any supporting information necessary to support/justify your submission.

There will not be a subsequent opportunity to make any further submissions based on your original

counter representation. After this stage, further submissions will only be at the request of the

independent examiner, based on the matters and issues he/she identifies at independent

examination.

(Required)

Continue on the next page

Note: If you wish to make a counter representation to more than one representation, complete a

separate sheet (Section 6 only) for each counter representation you wish to make and append the

sheet(s) to your submission.

Please refer to enclosed document

See Enclosed Counter Representation

Counter Objection

Belfast City Council LDP, Draft Plan Strategy – Counter Representation Stage

April 2019

Introduction

1. This counter-representation is submitted on behalf of Belfast Harbour in response to representations received in response to the Council’s consultation on the

Draft Plan Strategy (DPS) in August 2018.

2. For clarity these counter representations relate to representations made under Regulation 15 and 16 of the Planning (Local Development Plan) Regulations

(Northern Ireland) 2015 (‘Regulations’). Under Regulation 17, the Council has made available copies of all representations received in response to consultation

on the DPS. These counter representations are submitted under Regulation 18 as they relate to site specific representations.

3. We have formulated these counter representations having taken account of Regulation 2 of the LDP Regulations which states:

• ‘site specific policy’ means a policy in a development plan document which identifies a site for a particular use or development.

• ‘site specific policy representation’ means any representation which seeks to change a development plan document by:

‒ adding a site specific policy to the development plan document; or

‒ altering or deleting any site specific policy in the development plan document

4. These counter-representations should be read alongside DPS Representation Ref. DPS-B-AM-S submitted on behalf of Belfast Harbour.

2. Counter Representations

5. This section outlines our counter-representations to comments received by Belfast City Council in response to consultation on the DPS.

Reference No &

Author

Summary of Representation Comments

Counter Representation

DPS-B-92-P

(Historic Buildings

Council)

Comments to Draft Policy DES3 – Tall Buildings

Outlines that buildings over 6 storeys should only be exceptionally

permitted in the city centre, with tall Buildings possibly being more

acceptable in the Titanic Quarter.

The Historic Buildings Council objects to the policy criteria set out

in DES 3, and suggests that Council should introduce a policy which

restricts both the height and location of tall buildings.

Belfast Harbour wishes to make a counter-representation to this

statement. It is our view that the approach proposed by the

Historic Building Council is unsound as no evidence has been

provided to support the stance advocated, and the proposed

change is not flexible to address any changing circumstances.

For these reasons the approach proposed by the Historic Buildings

Council fails against soundness tests CE2, and CE4.

We would refer Council to our position set out at paragraphs 5.25

to 5.42 in Draft Plan Strategy Representation Ref: DPS-B-AM-S.

DPS-B-UZ-T

(Organisation)

Comments to Draft Policy DES3 – Tall Buildings

Seeks that high density development should be restricted to the core

city centre.

Representation DPS-B-UZ-T objects to the policy criteria set out in

DES 3, and suggests that Council should restrict tall buildings to

core of the city centre.

Belfast Harbour wishes to make a counter-representation to this

statement. It is our view that the approach outlined within DPS-B-

UZ-T is unsound as no evidence has been provided to support the

stance advocated and the proposed change is not flexible to

address any changing circumstances.

For these reasons the approach proposed within DPS-B-UZ-T fails

against soundness tests CE2, and CE4.

We would refer Council to our position set out at paragraphs 5.25

to 5.42 in Draft Plan Strategy Representation Ref: DPS-B-AM-S.

DPS-B-9H-C

(Ulster

Architectural

Heritage, (UAH))

Comments to Draft Policy DES3 – Tall Buildings

Outlines that tall buildings should not be permitted in sensitive

heritage locations such as Conservation Areas or Area of Townscape

Character, and that there is no need for tall buildings in Belfast City

core at all.

UAH objects to the policy criteria set out in DES 3, and notes that

the policy falls far short of an adequate policy for tall buildings.

Belfast Harbour wishes to make a counter-representation to this

statement. It is our view that the approach proposed by the UAH

is unsound as no evidence has been provided to support the

stance advocated and the proposed change is not flexible to

address any changing circumstances.

For these reasons the approach outlined by UAH fails against

soundness tests CE2, and CE4.

We would refer Council to our position set out at paragraphs 5.25

to 5.42 in Draft Plan Strategy Representation Ref: DPS-B-AM-S.

DPS-B-8Z-W

(RSPB NI)

Comments to Draft Policy HOU4 – Housing Density

Page 18 of the Representation notes that ‘while Figure 7.2 of the draft

Plan Strategy sets out a housing supply figure for Belfast Harbour of

3,500 units over the plan period, and Figure 7.3 identifies it as a

Character Areas, it has not however been identified as a

settlement/character area within the main body text of Policy HOU4.

All other character areas depicted in Figure 7.3 have been included

within Policy HOU4. Given the substantial allocation proposed for this

area coupled with its position adjacent to and within internationally

protected sites (Belfast Lough SPA and Ramsar) further detail is

therefore required in this regard)

RSPB are challenging policy HOU 4 on the basis that if fails

soundness test C3.

Belfast Harbour wishes to make a counter-representation to this

statement. It is our view that the approach proposed by RSPB is

unsound.

Policy HOU4 does not make specific reference to the Belfast

Harbour Area (BHA) as a settlement or character area. This is at

odds with all other references within the DPS regarding the

locations for future housing development.

Policy SD2 Settlement Areas clearly identifies the locations

throughout the plan area which are designated as settlement

areas. This includes the BHA. It states that polices will ensure that

new residential development is in keeping with the character of

the surrounding area. The hierarchy presented is reproduced

throughout the draft plan policies, identifying the BHA as

delivering 3,500 units with a clear assessment for residential

development. Policy HOU4 does not expressly identify the BHA in

the density bands and the policy notes that proposals outside of

these broad bands will be considered on their merits, of which

there should be an exception for major regeneration/masterplan

sites including those with a waterfront location.

It is also worth noting that portions of BHA have secured

substantial residential planning permissions, namely City Quays

and Titanic Quarter. In this context we note within the document

that the delineation of the extent of the character areas will be

defined within the Local Policies Plan.

DPS-B-8E-8

(unknown)

Comments to Draft Policy HOU6 – Housing Mix

There is a significant requirement for family housing, amounting to a

significant proportion of the overall housing allocation. However, the

LDP does not demonstrate in the housing allocation proposed that

appropriate provision has been made for family housing. The

allocations made for the City Centre and Harbour Estate will

inevitably be predominantly apartment development, unsuitable for

families.

Belfast Harbour wishes to make a counter-representation to this

statement. It is our view that the position adopted is unsound as

the author provides no evidence to support their stance. Through

initiative and creative design solutions a range of housing options

can be developed within the City Centre and Harbour Estate. For

this reason the approach outlined by DPS-B-8E-8 fails against

soundness test CE 2.

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