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For and on Behalf of Alecta Pensions for Sakring Omsesidgt C/O Aberdeen Property Investors UK Ltd For and on behalf of Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd Representations to Sheffield Development Framework Draft City Polices and Sites Document and Draft Proposals Map Edgar Allen House, 241 Glossop Road, Sheffield Prepared by DLP Planning Ltd AUGUST 2010 Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd Prepared by: Nicola Howarth Approved by: Roland Bolton Date: August 2010 DLP Planning Ltd 11 Paradise Square Sheffield S1 2DE Tel: 0114 228 9190 Fax: 0114 272 1947 DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk. Edgar Allen House, 241 Glossop Road, Sheffield YK1688emailversldfreps 2 Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd Contents Page 1.0 Introduction 4 2.0 Site Context 6 3.0 Policy Appraisal 7 Sheffield Core Strategy (2009) 7 Policy CS17: City Centre Quarters 7 Policy CS23: Locations for New Housing 8 Policy CS27: Housing in the City Centre 8 4.0 Changes to Proposed Policies 10 Reference to Unitary Development Plan Policies 10 Policy H1: Land Uses in Policy Areas 10 Policy Designation: Central Housing Areas 12 5.0 Conclusion 13 Edgar Allen House, 241 Glossop Road, Sheffield YK1688emailversldfreps 3 Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd 1.0 Introduction 1.1 This report has been prepared by DLP Planning Ltd on behalf of Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd in respect of premises Edgar Allen House, located at No.241 Glossop Road, Sheffield and makes representations to the Sheffield Development Framework Draft City Polices and Sites document and Draft Proposals Maps. 1.2 The premises at 241 Glossop Road is identified on the draft Local Development Framework (LDF) proposals map as lying within an area defined as a Central Housing Area within the Devonshire Quarter of the City Centre. 1.3 This representation makes objection in relation to Policy H1 ‘Land Uses in Policy Areas’ and the associated table which is considered to be unclear and lacks clarity and supporting information. 1.4 Objection is also made to the designation of the Central Housing Area within this part of the City Centre and it is requested that this area is re-designated as a City Centre Flexible Use Area. 1.5 It is considered that H1 within the draft City Policies and Site Allocations document and draft Proposals Maps fail the tests of soundness set out in paragraph 4.52 of PPS12 Local Spatial Planning which states that: ‘To be “sound” a core strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY. “Justified” means that the document must be: founded on a robust and credible evidence base the most appropriate strategy when considered against the reasonable alternatives “Effective” means that the document must be: deliverable flexible able to be monitored.’ 1.6 These tests are also applicable to lower tier Development Plan Documents (paragraph 5.2 of PPS12). 1.7 The DPD fails the test of soundness on the basis that there is no credible evidence base for policy H1 against which the percentages can be assessed. 1.8 The document is also insufficiently flexible to accommodate the varying needs of commercial premises within the City Centre location. Edgar Allen House, 241 Glossop Road, Sheffield YK1688emailversldfreps 4 Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd 1.9 The DPD is also considered to fail the test of soundness in so far as it is overly complex and therefore difficult to implement and monitor effectively, without the base evidence for the policy we are unable to advise Clients of whether proposals are in conformity with the policy or not. Given the variety of commercial uses that are already present within the Devonshire Quarter of the City Centre this is considered to be particularly difficult to apply and in fact an inappropriate policy response to this area. Edgar Allen House, 241 Glossop Road, Sheffield YK1688emailversldfreps 5 Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd 2.0 Site Context 2.1 The building which is the particular focus of this objection is located to the south of Glossop Road within the Devonshire Quarter of Sheffield City Centre. 2.2 Photograph 1: Site Location Plan 2.3 It is a four storey brick office building located on the corner of Gell Street and Glossop Road. The building has undercroft and rear car parking provision and is enclosed by boundary walling and gates. 2.4 It lies within a mixed use area with housing, restaurants, pubs, shops and other commercial uses lying adjacent and within very close proximity of the site. Edgar Allen House, 241 Glossop Road, Sheffield YK1688emailversldfreps 6 Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd 3.0 Policy Appraisal 3.1 Within the draft Local Development Framework (LDF) proposals map the whole of the site is to be designated as lying within the Central Housing Area as well as remaining within the City Centre and also falling within the Devonshire Quarter of the City Centre as illustrated below. Sheffield Development Framework Draft Proposals Map Sheffield Core Strategy (2009) 3.2 The following policies are applicable to sites located within Central Housing Areas. Policy CS17: City Centre Quarters 3.3 With regard to the Devonshire Quarter of the City Centre, Policy CS17 states the following: ‘The distinctive and fundamental roles of different ‘quarters’ of the City Centre will be consolidated and strengthened, namely: f. Devonshire Quarter – a thriving, distinctive and vibrant area with city living, niche shops, restaurants and bars and a variety of business uses with the City Centre’s largest green space, Devonshire Green; Complementary relationships, interaction and physical links between the Quarters will be promoted.’ Edgar Allen House, 241 Glossop Road, Sheffield YK1688emailversldfreps 7 Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd 3.4 The application of Policy H1 described below is considered to be at variance to this description of a thriving, distinctive and vibrant area with city living, niche shops, restaurants and bars and a variety of business uses within the Devonshire Quarter of the City Centre as set out above in Policy CS17. As such there would appear to be conflict between the Core Strategy and this draft plan. Policy CS23: Locations for New Housing 3.5 Policy CS23 provides guidance on the location of new housing within the City and states the following: ‘New housing development will be concentrated where it would support urban regeneration and make efficient use of land and infrastructure. In the period 2008/09 to 2020/21, the main focus will be on suitable, sustainably located, sites within, or adjoining: a. the main urban area of Sheffield (at least 90% of additional dwellings); and b. the urban area of Stocksbridge/Deepcar. After 2020/21, and before then as opportunities arise, additional housing growth will occur in parts of the city where significant change and regeneration are taking place. This will be primarily in the main urban area of Sheffield (with an emphasis on the Lower Don Valley and North East Urban Area) and Stocksbridge/Deepcar. In Chapeltown/High Green and in the larger villages of Oughtibridge, Worrall and Wharncliffe Side housing development will be limited to suitable, sustainable sites within the existing built-up areas. Outside the urban areas and larger villages, housing development will be limited to that which is consistent with policies for the Green Belt and countryside areas.’ 3.6 The supporting text, (paragraph 8.8) of the Core Strategy states: ‘In the main urban area of Sheffield, over a third of total supply is concentrated in the City Centre and concerns have been expressed about supply outstripping demand, though a recent study supports current confidence here. 3.7 Circumstances have changed significantly regarding the ability of developers to bring forward even existent planning permissions in the City Centre so while the Core Strategy Policy remains achievable this supporting statement is no longer considered accurate. Policy CS27: Housing in the City Centre 3.8 Policy CS27 is applicable in Central Housing Areas and states the following: Edgar Allen House, 241 Glossop Road, Sheffield YK1688emailversldfreps 8 Alecta Pensions for Sakring Omsesidgt c/o Aberdeen Property Investors UK Ltd ‘Further expansion of City Centre living, with a mix of tenures and sizes of unit, including affordable housing, will form part of a mix of uses: a. at Kelham/Neepsend and Wicker/Nursery Street b. between Netherthorpe Road and Edward Street c. between Netherthorpe Road and St. Vincent’s Church d. at West Bar, north of the Crown Courts e. around Devonshire Green f. on upper levels along the Moor and in the New Retail Quarter g. around the Peace Gardens h. at Victoria Quays/Castlegate i. within the Cathedral Quarter j. within the Cultural Industries Quarter. Limited housing will also be appropriate in other parts of the City Centre where needed as part of mixed schemes to achieve a viable balance of uses.’ 3.9 The reference made at criteria e) is to the Devonshire Green area of the Devonshire Quarter and yet the Central Housing Area allocation requires the preferred uses of housing and residential institutions provide except where such provision is impractical does not reasonably relate to this policy which refers to a mix of uses.
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