Appendix 2, However, the Main Additional Issues That Are Not Addressed As Part of the Cyclostyled Responses Are:
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10 Core Strategy Publication Report of responses submitted, Council responses and changes made to Re-Publication Core Strategy in response 15 th January 2010 389 10 Representations on Core Strategy in general Core Strategy Publication Draft Respondent 364564 Ms Sam Turner Principal Planning Officer 4NW Representation CSPUB1740 Legally Compliant? Yes Sound? Yes Issue raised before? If not, why not? Any other comments? Why considered unsound.. It is considered that the Proposed Submission St Helens Core Strategy DPD is in general conformity with the adopted Regional Spatial Strategy for the North West of England, published September 2008. 4NW supports the DPD and its policies, which are in conformity with the adopted Regional Spatial Strategy and will support its implementation. What changes required? No change. Council view Comments Noted Justification Comments noted. Change in Re -Publication Core Strategy No change. Core Strategy Publication Draft Respondent 315747 Mr Kieran Preston Planning and Conservation Adviser Natural England Representation CSPUB749 Legally Compliant? Sound? Issue raised No before? If not, why not? N/A Any other comments? Natural England welcomes this opportunity to comment on the submiussion Core Strategy for St Helens. This is an important document for providing the strategy for developing the Borough to 2025. We wish to commend the Council on the production of a well presented strategy, that for Natural England provides a future strategy to guide development whilst conserving and enhancing the natural environment; and peoples enjoyment and access to it. We particularly welcome the important role that green infrastructure has played in the wording of many of the spatial and topic based detailed policies. Why considered unsound.. 390 10 What changes required? Council view Comments Noted Justification No change. Change in Re -Publication Core Strategy No change. Respondent 365348 Ms Diane Clarke Town Planning Technician Network Rail Representation CSPUB1743 Legally Compliant? Sound? Issue raised before? If not, why not? Any other comments? The comments raised from Network Rail relate to the consultation process and how they had failed to be adequately consulted with during the publication consultation period. Network rail were contacted on the 2nd July and the consultation ended on the 8th July. Network Rail have requested to be properly consulted at the alternative options stage in the future. However, this was as a result of St. Helens Council using a wrong address for Network Rail and as a result gave Network Rail a further six weeks to consult upon the document after the original consultation deadline in order for them to raise any relevant issues. No further comment was received from Network Rail. Why considered unsound.. N/A What changes required? N/A Council view Comments Noted Justification Network Rail were given an additional 3 weeks to comment but no comments were received. Change in Re -Publication Core Strategy No change. 391 10 Chapter 1– Introduction 1 Introduction Respondent 315762 Mrs Dianne Spatial Development Manager Wheatley Government Office for the North West Representation CSPUB246 Legally No Sound? Yes, with minor Issue No Compliant? changes raised before? If not, why not? We made a general comment at preferred options stage stating that the Council should seek its own legal advice on whether it has met procedural requirements. Any other comments? Why considered unsound? The document does not include a list of saved policies from the St Helens Unitary Development Plan which the Core Strategy will replace/supersede. This needs to be included to comply with the legal compliance test and Regulation 13(5) of the Town and Country Planning (Local Development)(England) Regulations 2004. What changes required? Include a list of policies from the St Helens UDP which the Core strategy will supersede. Council view Agree Recommend Change Justification The omission of this requirement was an oversight and the need for it is acknowledged. Change in Re -Publication Core Strategy Include new appendix in Core Strategy summarising which UDP policies are to be replaced. 1 Introduction Res pondent 82491 Miss Lesley Bye Contaminated Land Team Leader Merseyside Environmental Advisory Service Representation CSPUB684 Legally Yes Sound? Yes, with minor Issue Yes Compliant? changes raised before? If not, why not? Any other comments? We note that there is no mention of the Waste Development Plan Document in the Introduction as the Core Strategy should provide context for the Waste DPD. Also, the Waste DPD will assist in implementation of the Core Strategy and forms part of the St Helens LDF. Why considered unsound? 392 10 What changes required? Council view Agree Recommend Change Justification Please also see response to representation CSPUB701. Whilst table 1.2 is not an exhaustive list of the documents that form the context of the Core Strategy or that make up the Local Development Framework, no objection is raised to including the Waste DPD within this table. Change in Re -Publication Core Strategy Add ‘Waste DPD' into table 1.2 after “Climate Change DPD' and before “Area Action Plans'. Include supporting text “ Which will provide policy guidance standards for waste management and allocate sites for waste purposes' . 1.2 Paragraph Respondent 303551 Mr Alex Naughton Policy Officer Merseytravel Representation CSPUB2 Legall y Yes Sound? Yes Issue Yes Compliant? raised before? If not, why not? Any other comments? Merseytravel (Merseyside ITA/PTE) welcomes this opportunity to engage positively with St Helens Council on the LDF Core Strategy, which once adopted, will form a key Local Development Document (LDD) as part of the LDF. We wish to reiterate our comments dated 14 December 2007 made in response to the Preferred Options stage of the Core Strategy. This organisation considers that the development of the Core Strategy and other spatial and land use development plan documents as part of the Local Development Framework create a key opportunity for policy intervention to closely integrate land use and transport planning, promote the creation of sustainable communities, take into account the need to tackle climate change and make best use of St Helens” strategic assets. Merseytravel believes that the strategic direction set by the LDF Core Strategy should be a balanced and sustainable development approach towards integrating land use and transport, regeneration and economic development, social inclusion, and help tackle climate change. The Core Strategy and Local Development Framework documents should be fully interlinked with the LTP2 and provide for the integration of land use and transport planning. For example location of development in accessible locations, use of Accession software to assist with this, developments based around the need for access by all forms of transport, management of parking in new development, expectation that developers should contribute to cost of public transport access in areas that are not well served by existing public transport services. The LDF Core Strategy and LDF needs to ensure that policies within the LDF documents do not conflict thus ensuring a coherent and integrated approach relating to the development of sustainable land use and transport planning outcomes. We welcome the references made to the Local Transport Plan. Why considered unsound? What changes required? 393 10 Council view No change recommended Justification The Council agrees that the LDF and LTP should be closely linked, and indeed the teams responsible for planning policy and transport policy are co-located, within the same department, share information and liase closely. There are also plans to use traffic modelling software to test any sites allocated in the Allocations DPD. Change in Re -Publication Core Strategy No change. 1.2 Paragraph Respondent 82491 Miss Lesley Bye Contaminated Land Team Leader Merseyside Environmental Advisory Service Representation CSPUB701 Legally Yes Sound? Yes, with minor Issue Yes Compliant? changes raised before? If not, why not? Any other comments? The Waste DPD is part of the suite of documents forming St Helens LDF; we suggest that the Waste DPD is included in the table under section 1.2 with the following wording “which will provide policy guidance and site allocations for new waste management development and, to ensure waste issues are incorporated into all new development. Why considered unsound? What changes required? Council view Partly Agree Recommend Change Justification Partially agree. The list at 1.2 is not intended to be exhaustive, however do not object to adding Waste DPD. Change in Re -Publ ication Core Strategy Add Waste DPD to list at 1.2 after “Climate Change DPD' and before “Area Action Plans'. Supporting text Which will provide policy guidance standards for waste management and allocate sites for waste purposes 1.2 Paragraph Respo ndent 82491 Miss Lesley Bye Contaminated Land Team Leader Merseyside Environmental Advisory Service Representation CSPUB708 Legally Yes Sound? Yes, with minor Issue Yes Compliant? changes raised before? If not, why not? 394 10 Any other comments? We note that Section 1.2 now includes text on the Climate Change DPD, which is good. However, we consider that the description would benefit from some elaboration so that it is clear that it is intended to cover adaptation as well as mitigation. Thus something like "...minimises impact on climate change and is well adapted for climate change that is unavoidable." Why considered