North West of England RSS to 2021 Summary of Representations
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The North West of England Plan Regional Spatial Strategy to 2021 Summary of Representations Statement of Reasons for Further Changes The North West of England Plan Regional Spatial Strategy to 2021 Summary of Representations Statement of Reasons for Further Changes Summary of Representations Received Number, Type and Origin of Representations Received Background The Secretary of State’s proposed changes were published for consultation on 20 March 2008, with comments invited by 23 May 2008. Every organisation and person involved in earlier stages of RSS preparation were consulted on the Proposed Changes and associated documents, which were placed on deposit at Libraries and Council offices throughout the region and also made available on the GONW and Regional Assembly’s websites. A press release was also issued. In response to the consultation exercise a total of 1836 representations were received from 149 people and organisations. More details about the origin and nature of these representations are set out in the two tables below. All representations made are available to view along with the consultation documents on the GONW consultation portal website. Type of Respondent Number of Respondents Number of Responses Campaign Group 3 6 Government Agency 10 511 Local Authority 35 579 Parish Council 7 12 Other Company/Business 35 201 Other Public Sector Body 9 174 Private Individual 26 78 Business/Trade Association 4 28 Voluntary/Community/Charity Group 20 247 Total 149 1836 Representations by Chapter Proposed Changes Chapter Support Object Comment Total General Comment 5 1 0 6 Our Vision 2 5 3 10 1 Role & Purpose 11 0 2 13 2 Our Region 41 12 3 56 3 Policy Context 14 4 0 18 4 Spatial Principles 78 110 27 215 5 Regional Spatial Framework 83 100 29 212 6 Working in the North West 76 93 21 190 7 Living in the North West 94 140 4 238 8 Transport in the North West 59 145 5 209 9 Environment, Minerals, Waste & Energy 120 139 25 284 10 Manchester City Region 21 32 4 57 11 South Cheshire 7 5 0 12 12 Liverpool City Region 49 36 5 90 13 Central Lancashire City Region 29 26 9 64 14 Cumbria & North Lancashire 25 22 7 54 15 Implementation, Monitoring and Review 12 14 0 26 16 Assessment of Replaced and Potentially Saved Structure 3 15 0 18 Plan Policies Appendix RT 2 3 0 5 Maps & Diagrams 6 53 0 59 Total 737 955 145 1836 Percentage of Representations by Chapter Maps & Diagrams General Comment Our Vision 1 Role & Purpose 16 Assessment of Replaced and 3.2% 0.3% 0.5% 0.7% Potentially Saved Structure Plan Policies Appendix RT 1.0% 0.3% 2 Our Region 3.1% 15 Implementation, Monitoring and Review 1.4% 3 Policy Context 1.0% 14 Cumbria & North Lancashire 2.9% 4 Spatial Principles 11.7% 13 Central Lancashire City Region 3.5% 12 Liverpool City Region 4.9% 5 Regional Spatial Framework 11.5% 11 South Cheshire 0.7% 10 Manchester City Region 3.1% 6 Working in the North West 10.3% 9 Environment, Minerals, Waste & Energy 15.5% 7 Living in the North West 13.0% 8 Transport in the North West 11.4% SUMMARY OF REPRESENTATIONS RSS Chapter / Policy / Maps & Summary of Representations (No. of Respondents/Responses) Diagrams General Comment (6/6) Our Vision Most comments relate to the proposed deletion of the wording "live within its means", either wanting its retention or replacement by alternative wording. Some support for the redrafted Vision. (10/10) 1 Role & Purpose The majority of respondents supported the changes made at the Proposed Changes stage. (4/13) 2 Our Region The majority of the comments are in favour of the changes. Concerns expressed that the transport network needed improvements, that the diagrams should be based on Super Output level data, that development would be directed to South Manchester and West Cheshire, which was not considered sustainable, instead of areas which required urban renaissance. Some concern was raised about the three authorities that will become Cheshire East in two separate areas, transport links between Deeside and economically deprived communities of Wirral and Merseyside. (14/56) 3 Policy Context Comments received that indicate that it would be helpful to see how AfS fits in with other Strategies and the RSS, and that the North West Green Infrastructure Guide, published by North West Green Infrastructure Think Tank Partners, should be added to the list of Regional Strategies. (8/18) 4 Spatial Principles General support. DP1-DP9 particularly. DP6 subject to minor changes. (2/2) The responses received highlighted general support for the policy but considered more detail should be added relating to engagement, DP1 Spatial Principles accessibility and regeneration through cultural identity. Consultees however raised concern at the loss of bullet points on safeguarding rural communities. Issues of access to public transport in rural areas - if this applied inflexibly this could stifle development in rural areas and be a barrier to development. Concern about the change from “development control” to “development management “. The principles of this policy should be followed in the RSS and not delegated to other tiers and plans and strategies. (22/25) 5 RSS Chapter / Policy / Maps & Summary of Representations (No. of Respondents/Responses) Diagrams A mix of responses was received from consultees. Support was received in the form of the emphasis place on sustainable communities, and the DP2 Promote Sustainable links to policy EM3 and the Housing Market Renewal schemes. Consultees however objected to the removal of “means of travel”. Further clarity is Communities required about the Housing Market Renewal Areas and Cumbria Local Authorities inclusion in these areas, if excluded both Furness and West Cumbria need to be listed. Consultees raised issues about managing travel and reducing need to travel as this does not align with the national and Cumbria policy. The policy should include a more proactive phrase on conserving regions heritage. Flood risk to existing population needs to be addressed in bullet point 5. (16/19) A number of consultees support this policy and the proposed changes. However consultees requested clarification of the meaning of sustainable. DP3 Sustainable Economic It was highlighted that economic growth may not reduce inequalities and should say “sustainable economic development”. Consultees also Development suggested an amendment to GVA reference to Cheshire. (12/14) Consultees raised issues relating to the issue of access to rural areas by public transport. A mismatch was identified between water resources DP4 Make the best use of Existing and development, as housing development should be at a scale which can be supported by known and predicted water resources. Consultees Resources & Infrastructure highlighted concern about the removal of reuse of buildings from the 1st priority. The infrastructure requirements were considered to be too restrictive. A mismatch exists between the policy which draws heavily on the PPG3 approach and PPS3 approach. There are issues relating to the phrase “normally on the fringes”. Further consideration should be given to urban extensions and new towns. An emphasis should be placed on non coastal European sites in North Wales and partnership working cross border to minimise impacts. (21/23) A number of consultees support the policy it provides underpinning principles for the rest of the RSS. However, issues were raised relating to DP5 Manage Travel Demand access for public transport in rural areas. Local Service Centres should be included in the policy. There is a need to include a consideration of the management of freight. There is a need to include the sustainable transport hierarchy as recommended in SA. (22/28) Consultees raise issues about the links between areas of opportunity and need and the challenges that this will bring. Concern was riased about DP6 Marry Opportunity & Need the policy as it does not address the regeneration and employment issues of the areas of need and just uses them as feeder areas for areas of opportunity, Consultees were concerned that depending upon the scale at which this operates this will lead to unsustainable development and commuting. This policy should underpin RDF1 and prioritise City Regions. The policy should be linked to policy DP5. Concern that access may be seen as more important that sustainability and that access by cycling and walking should be included. (17/21) Support for the policy relating to green infrastructure and the tranquillity of the countryside, and the recognition of the commitment to European DP7 Promote Environmental sites. However consultees have indicated that in order to align with National Biodiversity targets there needs to be a presumption to “maintain and Quality enhance Biodiversity and assessments” of all designated sites not just European sites where development is likely to have an impact. The policy should reflect the historic environment in greater detail. Concern about phrase “assessing traffic growth”. Concern that it repeats national guidance and issues regarding Habitats Regulation Assessment and air and water quality could be dealt with more succinctly. Text could be added relating to culture and avoiding urbanisation of high value rural areas. Text should be added relating to the combination of effects and more emphasis should be placed on non coastal Welsh sites and cross boundary working. The policy should refer to inland and coastal waters and the need for 6 RSS Chapter / Policy / Maps & Summary of Representations (No. of Respondents/Responses) Diagrams improvement of coastal waters. (26/40) DP8 Mainstream Rural Issues Consultees largely support the policy however they indicate that it should consider the meaning and necessity for the word mainstream. In addition the policy should provide guidance for areas outside Local Service Centres and Key Service Centres. (10/12) The majority of consultees object to the policy and are concerned about the loss of targets which many think should be reinstated or increased in DP9 Reduce Emissions & Adapt to line with IPCC targets.