Schedule of Responses
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ED.1.5a Directions for Stratford-on-Avon Consultation Core Strategy Summary of Representations Received February – April 2010 Final Version 21-2-2011 Planning Policy Team Corporate Support Stratford-on-Avon District Council Stratford-on-Avon District Local Development Framework Consultation Core Strategy – Summary of Representations Received February – April 2010 Topic: GEN Core Strategy as a Whole Summary of Matters Raised in Representations 1. Wellesbourne’s position within the hierarchy of Main Rural Centres is not properly reflected; there should be a more proactive strategy to enhance local facilities to assist self containment and assist in creating a more sustainable community. 2. If Stratford-upon-Avon is unable to accommodate the necessary level of development it is recommended that additional land is allocated adjacent to the Main Rural Centres. 3. Tell Stratford Voice to put a sock in it. 4. Council’s approach to preparing the Core Strategy and in allocating sites to achieve the higher housing target proposed by the RSS Revision Panel is commended. 5. By pressing ahead now with this Core Strategy consultation, the District Council may have to carry out the exercise again if the housing allocations are revised. Topic: 1.0 Section 1: Planning for the future of Stratford-on-Avon District - general Summary of Matters Raised in Representations 1. Importance of District Council commitment to a plan led system 2. Important to address affordable housing issues and the District's housing growth requirements 3. Believes the Panel Report will remain a material planning consideration despite changes at a national level 4. Restricting inward migration is inappropriate 5. Supports paragraph 1.2.7 and that there is no justification to not provide the full 7,500 dwellings. Topic: 1.1 Why another stage of consultation? Summary of Matters Raised in Representations 1. Spatial strategy and policies for the District should consider waste in terms of: · efficient use of resources · providing suitable waste facilities in the right places · reducing waste 2. Although, the County Council is the Waste Planning Authority, there may be a need to deliver waste management infrastructure in the District and facilities need to be integrated into land uses proposed in the Core Strategy. 3. To ensure a 'spatial approach' SDC needs to ensure this infrastructure is specifically considered in the document and the County Council Waste LDF is taken into account. Topic: 1.2 What happens next? Summary of Matters Raised in Representations 1. The document is premature and should reflect the possibility of major policy changes at a national level following the General Election. 2. However, there is also support for the decision of the Council to pursue its Core Strategy programme and support for a further consultation opportunity. Source: Corporate Support, Stratford-on-Avon District Council 2 17 January 2011 Stratford-on-Avon District Local Development Framework Consultation Core Strategy – Summary of Representations Received February – April 2010 3. It is essential the Council continues to provide a commitment to a plan-led system and addresses the problems of housing affordability and meeting housing growth requirements. 4. Delays to progressing the Core Strategy are likely to lead to a policy vacuum and leave the Council susceptible to 'planning by appeal'. 5. Although the future of the RSS is uncertain, the requirement for 7,500 dwellings over the plan period (as recommended by the RSS Panel) is appropriate. 6. The Panel Report will remain a material planning consideration. The Core Strategy should be in conformity with the RSS. 7. Restricting inward migration is inappropriate. 8. Regarding paragraph 1.2.8 - there is very little mention of sewerage infrastructure or protection of water quality. Before stating that "there are no fundamental infrastructure constraints to meet the initial scale of development" SDC needs to ensure that sewerage infrastructure is addressed and need to liase with Severn Trent. Sewage Treatment Works may be at, or nearly at, capacity and with an outdated sewerage network may not be capable of transferring either clean water or foul effluent without upgrading. Recommend early discussions, particularly when housing numbers and locations have been confirmed. 9. The Environment Agency questions the statement that "there are no apparent significant impacts in accommodating this level of growth'. 10. A further round of consultation needs to be undertaken prior to the submission draft stage of the Core Strategy to integrate a full Sustainability Appraisal into the process. Topic: 1.3 National and regional requirements Summary of Matters Raised in Representations 1. Targets must be accompanied by evidence of how they have been calculated. District Council should challenge national figures rather than simply accept them 2. Ref in 1.3.7 that RSS 'did not support a major new settlement' is incorrect. Panel Report stated that 'new settlements should not be ruled out....the District should consider options to add a further 2,500-3,000 dwellings...through...selection of the most sustainable new settlement proposal' (ref paras 8.65 & 8.74) 3. Core Strategy appears to have made allowance for more dwellings than RSS targets. 4. Re para 1.2.6 - Core Strategy should clearly state that a future review of the document is expected to be required to provide an additional 2,500-3,000 dwellings in the District over the period 2021- 2026. 5. Opposition to an additional 2,500 - 3,000 dwellings post 2021. 6. New settlement would be the preferred option for accommodating growth post 2021; urban extensions on Stratford upon Avon would harm the character of the town and are not a suitable option for that level of growth 7. Core Strategy should be delayed until housing targets have been confirmed. 8. Accepting immigration as a means of counterbalancing the ageing indigenous population is not a long term or viable policy approach Source: Corporate Support, Stratford-on-Avon District Council 3 17 January 2011 Stratford-on-Avon District Local Development Framework Consultation Core Strategy – Summary of Representations Received February – April 2010 9. Growth proposals should protect the standard of living for existing residents. 10. Not clear from paras 1.3.7, 1.4.3 & 1.4.4 whether or not expansion of Long Marston (perhaps into an eco town) is supported. 11. The Core Strategy builds on previous issues and options and previous consultation documents. It is based on further research and assessment undertaken by the District Council, as well as taking into account the comments received at the various stages of consultation. 12. It is acknowledged that the emerging RSS does not see Stratford District as taking a large proportion of the CSW Sub-Regions growth. As such, Stratford upon Avon has not been identified as a Settlement of Significant Development. Topic: 1.4 Cross border and sub-regional planning arrangements Summary of Matters Raised in Representations 1. Support for cross border and sub-regional planning arrangements. Due to Stratford District's links with Warwickshire, Gloucestershire, Oxfordshire and other areas of the West Midlands it makes sense for future planning to take account of development in these areas too. 2. The meaning of paragraphs 1.4.3 and 1.4.4 is not clear - it seems very up in the air at the moment, particularly in light of the RSS and whether it survives or not. Topic: 2.0 Section 2: A Spatial Vision for the District - general Summary of Matters Raised in Representations 1. The improvements made to Section 1 of the document are acknowledged - it is now more focused and succinct. 2. The portrait should clarify the key, critical issues that the Core Strategy will address. Some are mentioned but not all (for example, lack of public transport, provision of a quality education service, support for the tourism industry). Clarity over the priority issues should be set out to directly inform the vision and the strategy. 3. The visions for each market town should be included in the overall vision. A more locally distinctive and place based vision is supported. 4. There should be a link between the vision and the strategy - the spatial objectives should set out how different elements of the vision will be delivered. The Objectives remain a little 'bland' and could be made more meaningful. Topic: 2.1 The challenges facing Stratford-on-Avon district - where we are now Summary of Matters Raised in Representations 1. Paragraph 2.1.3 - There is no evidence to support that the proposals retain the character of the town and the quality of life for its residents. In fact, quite the opposite. 2. Paragraph 2.1.5/8 - The importance of heritage and the rural nature of teh District as a local, Source: Corporate Support, Stratford-on-Avon District Council 4 17 January 2011 Stratford-on-Avon District Local Development Framework Consultation Core Strategy – Summary of Representations Received February – April 2010 regional and national asset is supported. 3. Paragraph 2.1.7 - the pressures also relate to species, not just habitats, and this should be reflected. 4. Paragraph 2.1.9 - The Strategic Flood Risk Assessment should be referred to in this paragraph. 5. Paragraph 2.1.15 - should also mention Honeybourne station where Network Rail are adding two more platforms, extra tracks and a footbridge. 6. Paragraph 2.1.23 - There is support for supporting the local economy and providing opportunities for existing businesses to expand and new ones to set up and relocate in the District. there is agreement that the role of technology and knowledge based jobs will assist. 7. The change of economic circumstances in the UK warrants a complete review of the 'pace of growth' projections contained in this consultation. Despite new business premises being built, they are not necessarily occupied and other pre-existing business premises have been left empty.