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Appendix Aii – Representations Received on Chapter 5

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Appendix Aii – Representations Received on Chapter 5 Appendix Aii – Representations received on chapter 5 (community area strategies) (TPL14 – TPL59) with officer comments June 2014 Consultee Agent Is the Change Miss Katherine Dawson legally Comment 423 Gleeson Developments Limited Terence O'Rourke Limited compliant? ID: Is the Change No Person ID: 840669 Person ID: 840663 sound? Positively prepared Justified Identified proposed Reasons for TPL14 change unsound Effective Consistent with national policy This amendment to the plan, referencing again indicative requirements, is not positive and is ineffective. It introduces uncertainty about the scale of development to be planned in each of the Community Areas, and, to that extent, fails to meet the guidance in the NPPG (ID 12-002-20140306). Instead of providing flexibility it provides uncertainty and therefore fails to ensure the delivery of sufficient housing supply to meet the objective assessment of need. It is inconsistent with national policy. The justification given is that: Please give details of "The indicative figures also allow a flexible approach which will allow the Council including through the preparation of the Site why you support or Allocations DPD and local communities preparing neighbourhood plans to respond positively to opportunities without being inhibited by do not support the an overly prescriptive, rigid approach which might otherwise prevent sustainable development proposals that can contribute to consultation material. maintaining a deliverable five year housing land supply and delivering the strategic objectives of the plan." (para 4.28) However, the ability to achieve a positive approach and the potential to prevent sustainable development is un-evidenced. Conversely, using minimum targets provides a positive approach, where communities have a clear steer on what they must provide and the ability to introduce additional sustainable sites above the minimum requirement. The fact that part of a HMA is delivering more quickly should not be justification to delay of slow down the delivery required at any of the Community Areas. The requirements for the Community Areas have been set against the settlement hierarchy and to meet the needs of those individual areas, to support sustainable development. It is important that the requirements are delivered if the overall strategy is to be delivered. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection Attached files (Please see Objective) Officer Response See response to comments made on TPL11 under representation 422. Consultee Agent Is the Change Miss Katherine Dawson legally Comment 498 Waddeton Park Limited Terence O'Rourke Limited compliant? ID: Is the Change No Person ID: 836038 Person ID: 840663 sound? Positively prepared Justified Identified proposed Reasons for TPL14 change unsound Effective Consistent with national policy Representation TPL11 & TPL14 This amendment to the plan, referencing again indicative requirements, is not positive and is ineffective. It introduces uncertainty about the scale of development to be planned in each of the Community Areas, and, to that extent, fails to meet the guidance in the NPPG (ID 12-002-20140306). Instead of providing flexibility it provides uncertainty and therefore fails to ensure the delivery of sufficient housing supply to meet the objective assessment of need. It is inconsistent with national policy. The justification given is that: Please give details of "The indicative figures also allow a flexible approach which will allow the Council including through the preparation of the Site why you support or Allocations DPD and local communities preparing neighbourhood plans to respond positively to opportunities without being inhibited by do not support the an overly prescriptive, rigid approach which might otherwise prevent sustainable development proposals that can contribute to consultation material. maintaining a deliverable five year housing land supply and delivering the strategic objectives of the plan." (para 4.28) However, the ability to achieve a positive approach and the potential to prevent sustainable development is un-evidenced. Conversely, using minimum targets provides a positive approach, where communities have a clear steer on what they must provide and the ability to introduce additional sustainable sites above the minimum requirement. The fact that part of a HMA is delivering more quickly should not be justification to delay of slow down the delivery required at any of the Community Areas. The requirements for the Community Areas have been set against the settlement hierarchy and to meet the needs of those individual areas, to support sustainable development. It is important that the requirements are delivered if the overall strategy is to be delivered. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection Attached files (Please see Objective) Officer Response See response to comments made on TPL11 under representation number 495. Consultee Agent Is the Change Mr Tim Baker Mr John Baker legally Yes Comment 541 Strategic Land Partnerships Peter Brett Associates LLP compliant? ID: Is the Change No Person ID: 841158 Person ID: 841162 sound? Positively prepared Justified Identified proposed Reasons for TPL/14 change unsound Effective Consistent with national policy (5.12) This says that para 4.28 clarifies ‘where additional growth above these requirements will be appropriate in accordance with the Please give details of Plan.’ However, this is not what the paragraph 4.28 does and it certainly should not do. It must be for the Housing Allocations DPD to why you support or identify where there is scope for additional sites to be accommodated. Again there is confusion between the terms ‘indicative’ and do not support the ‘minimum’ and this should be sorted out to make the intention clear and precise. consultation material. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection Attached files (Please see Objective) Paragraph 4.28 is consistent with paragraph 5.12 and clarifies that the indicative figures allow for a flexible approach through the Officer Response preparation of the Housing Site Allocations Development Plan Document. No further change is necessary. Consultee Agent Is the Change Mr John Baker legally Yes Comment 611 Waddeton Park Limited Peter Brett Asscoiates compliant? ID: Is the Change No Person ID: 836038 Person ID: 556318 sound? Positively prepared Justified Identified proposed Reasons for TPL/14 change unsound Effective Consistent with national policy Please give details of (5.12) This says that para 4.28 clarifies ‘where additional growth above these requirements will be appropriate in accordance with the why you support or Plan.’ However, this is not what the paragraph 4.28 does and it certainly should not do. It must be for the Housing Allocations DPD to do not support the identify where there is scope for additional sites to be accommodated. Again there is confusion between the terms ‘indicative’ and consultation material. ‘minimum’ and this should be sorted out to make the intention clear and precise. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage Attached files (Please see Objective) Paragraph 4.28 is consistent with paragraph 5.12 and clarifies that the indicative figures allow for a flexible approach through the Officer Response preparation of the Housing Site Allocations Development Plan Document. No further change is necessary. Consultee Agent Is the Change Mr Mark Simpson legally No Comment 662 Primegate Properties (Hooksouth) Ltd DPDS Consulting Group compliant? ID: Is the Change No Person ID: 836270 Person ID: 556688 sound? Positively prepared Justified Identified proposed Reasons for TPL14 change unsound Effective Consistent with national policy These comments are made in the context of representations submitted by Primegate Properties (Hooksouth) Limited on the emerging Wiltshire Core Strategy, with respect to the promotion of Land North of M4 at Hook Street (SHLAA Site 2042), west of Swindon, for potential mixed use development including employment and housing land. At this stage we believe that it would be premature to limit the scope of any future proposed Wiltshire Site Allocations DPD and Settlement Boundary review to the geographical locations specified; the plan period specified; and to the consideration of housing land in isolation of employment land provision. We believe that a wider scope of such studies would be necessary to appraise and identify the most sustainable development option available to accommodate the development needs and aspirations of both Wiltshire and adjacent authorities, including Swindon Borough. Our comments are made in the context of aligning the requirements of the emerging Wiltshire Core Strategy 2026 and the emerging Swindon Local Plan 2026 (SLP2026), which has been subject to examination during May 2014, closing on 22 May. Please give details of why you support or Main Modifications of the SLP2026 that will be required prior to its
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