Revised Development Strategy

Support

Representation ID: 55459

Received: 29/07/2013

Respondent: A C Lloyd

Agent: Framptons

The identified housing allocation listed in paragraph 4.4. - Table RDS5 referring to East of Whitnash as a greenfield Strategic Urban Extension is supported.

Object

Representation ID: 56606

Received: 29/07/2013

Respondent: A C Lloyd

Agent: Framptons

Section 4.1 of the Revised development Strategy (RDS) correctly confirms the fact that the level of housing growth is an interim figure and that this may alter as a result of the findings of the Joint SHMA and the resulting co-operation between the authorities.

Against this background it is considered that the statement at the end of paragraph 1.3 of the RDS is untenable, which states, "the Council believes that the evidence base which underpins the RDS is robust and the housing growth requirements are unlikely to change substantially as a result of the new assessment".

There is no evidence to indicate that the Council's position as expressed at the end of paragraph 1.3 of the RDS is robust. It should be deleted.

Windfall Allowance

It is considered that the windfall allowance is excessive and unjustified. It seems to ignore the evidence from the SHLAA (which provides for 300 dwellings on small urban sites) and assumes an unrealistically high level of windfall sites for the plan period. The Council's evidence is based on a subjective manipulation of past trends rather than any considered examination of the evidence that may exist in terms of the potential capacity of the urban areas to accommodate such a high level of windfall moving forward. Accordingly, in the absence of a clear and robust evidence base from the Council the proposed windfall allowance is rejected.

Further consultation

It is apparent that the publication of the joint SHMA in early 2014 will be an important factor in determining the final format of the Local Plan. As such, it is submitted that the Council should consider a further round of consultation on the output of the SHMA prior to going forward to publish a Submission Draft Plan.

Object

Representation ID: 56608

Received: 29/07/2013

Respondent: A C Lloyd

Agent: Framptons

Preparation of a Master Plan for the area East of Whitnash (south of Sydenham) is underway is taking on-board strategic considerations identified in the draft Plan (Map 4) for Whitnash and south of Sydenham.

It is considered that the precise location of the various facilities referred to in the key to Map 4 but not shown on the plan should be a matter that is, in any event, determined by the master plan process in conjunction with extensive local community engagement.

The text of paragraph 5.2.9 needs to be amended to acknowledge that the northern part of the site has planning permission for 209 dwellings that is served by an access from St Fremund Way (with emergency access from Church Lane). As a result it is likely that the balance of the land will be served by a new access through Campion School

The precise dimension of the buffer required to protect the Whitnash Brook Local nature Reserve and to provide enhanced ecological and recreational space along Whitnash brook should be determined by detailed environmental analysis rather than being pre-determined at this stage in the plan-making process.

The Local Plan can properly record that a local wildlife site is to be provided between the new eastern edge of the built up area and the Whitnash Brook, to form a permanent wildlife and recreational corridor

As provided for in the Site Proposals there will be large areas of open space and other community requirements to meet the needs of the future resident population. The disposition of these uses should be determined through an analytical assessment of the opportunities and constraints with the benefit of stakeholder and public consultation.

For the purposes of this stage in the Local Plan process it is considered sufficient to identify the extent of the allocation as portrayed on Map 4. A consequence of this analysis is that the capacity of the site may change.

Even allowing for additional open space and wildlife buffers capacity of the overall site has been grossly underestimated.

It is estimated that the capacity of the overall site to be about 700 dwellings rather than 500. And the RDS should be amended accordingly.

Phasing:

Objection is made to the proposed phasing provision identified in the site proposals listed under paragraph 5.2.2.

A phasing limitation is likely to artificially constrain strategic sites from being brought forward in a timely manner. Strategic sites require a significant lead-in time. Major infrastructure works are required, involving substantial up-front costs to create developable plots.

Schools, community centre, district centre facilities etc may also need to be built at an early stage of the development process.

It is not appropriate to impose an arbitrary phasing restriction on their delivery which may simply serve to undermine the viability of a development.

Reference to phasing should be deleted from the Local Plan.