Poole Site Specific Allocations and Development Management Policies Development Plan Document

Planning and Regeneration Services Representations and Borough of Poole Response Contents

Questions & Responses Page

Question 1: Soundness of the Site Specific Allocations & Development Management Policies DPD 1 - 4 Question 2: General Comments 4 - 9 Question 3: Proposals Map 4 - 11 Question 4: Policy DM1 - Design 11 - 18 Question 5: Policy DM2 - Heritage Assets 18 - 21 Question 6: Policy DM3 - Shopping 21 - 27 Question 7: Policy DM7 - Coastal Zone 27 - 31 Question 8: Ashley Cross Local Centre 31 Question 9: Policy SSA2 - Bournemouth & Poole College Playing Field, North Road 31 -33 Question 10: Policy DM5 - Tourism & the Evening Economy 33 - 36 Question 11: Policy SSA3 - Fleets Corner & Sopers Lane 36 - 40 Question 12: Policy SSA4 - Crown Closures Ltd, Lake Road 40 - 41 Question 13: Policy SSA5 - Land at Sembcorp Bournemouth Water Ltd, Water Treatment Works, Francis Ave 41 - 44 Question 14: Policy SSA6 - Sterte Ave West, Sterte Ave 44 Question 15: Policy SSA7 - The Regeneration Area - Urban Design 44 - 48 Question 16: Policy SSA8 - The Regeneration Area - Infrastructure 48 - 51 Question 17: Policy SSA9 - The Regeneration Area - Land between Poole Bridge & Twin Sail Bridge 51 - 53 Question 18: Policy SSA10 - The Regeneration Area - Land on Hamworthy side of the Black Water Channel 53 - 55 Question 19: Policy SSA11 - Lagland Street 55 - 56 Questions & Responses Page

Question 20: Policy SSA12 - Goods Yard 56 - 59 Question 21: Policy SSA13 - Land at Lifeboat Quay 59 - 60 Question 22: Policy SSA14 - Former East Quay Depot & Quay Thistle Hotel 60 - 62 Question 23: Policy SSA15 - Land at Park Lake Road 62 - 63 Question 24: Policy DM6 - Accommodation for an Ageing Population 63 - 67 Question 25: Policy DM7 - Talbot Village - House in Multiple Occupation 67 Question 26: Policy SSA16 - Bournemouth & Poole college site, Constitution Hill Road 67 Question 27: Policy SSA17 - St Mary’s Hospital, St Mary’s Road 68 Question 28: Policy SSA18 - Bourne House, Langside Ave 68 Question 29: Policy SSA19 - Land sout of Wallisdown Road, Talbot Village 68 - 70 Question 30: Policy DM8 - Accessibility & Safety 70 - 73 Question 31: Policy DM9 - Demand Management 73 - 74 Question 32: Policy SSA21 - Facilities for Park & Ride 74 - 76 Question 33: Policy SSA21 - Local Centres - Priorities for Investment 76 Question 34: Policy SSA22 - Hamworthy - Redevelopment Site 77 Question 35: Policy SSA23 - Ashley Road Local Centre 77 Question 36: Policy DM10 - Green Infrastructure & Biodiversity 77 - 82 Question 37: Policy SSA37 - Upton Country Park 83 Question 38: Policy SSA38 - Major Developed Sites in the Green Belt 83 - 85 Question 39: Monitoring Framework 85 Appendix 1: Schedule of Saved Policies 85 - 86 Question 1: Soundness of the Site Specific Allocations and Development Management Policies DPD Representation ID 103: Meghann Downing, Highways Agency Yes. The Agency is submitting a separate response to the Delivering Poole‟s Infrastructure DPD, in which we state our The „Delivering Poole‟s Infrastructure‟ DPD provides for funding of belief that mitigation on the SRN should be included in funding from the Community Infrastructure Levy, where improvements to the A31 to be delivered through CIL contributions. appropriate. If this does not happen then we are concerned that improvements to the A31 may become undeliverable, and This will address the concerns of the Highways Agency in respect to that in such a scenario we would be forced to object to future development which had a negative impact upon the SRN. In future development which will have a negative impact on the Strategic our response to the Site Specific Allocations DPD we have assumed that a resolution will be found to the concerns Highway Network. surrounding the Infrastructure DPD, and have therefore based our comments on that assumption. If changes are made to the assumptions in the infrastructure DPD about what CIL will contribute to, then there may be a requirement to make changes to the references to infrastructure requirements within the Site Specific Allocations DPD. Representation ID 146: Mr Geoff Cross (Savills) on behalf of W.H.White and Landowners No, the document is considered unsound for the reasons set out below, and should be changed to incorporate a policy for The Core Strategy at para. 1.6 sets out a timeframe for its review, to reserve employment land at North Poole. Need for a policy for reserve employment land at North Poole Whilst the draft reflect progress on its delivery. It is anticipated that this review would proposals map accompanying the DPD has an allocation for the North Poole safeguarding land, the policy reference is in be carried out in time to have a revised Core Strategy by not later than core strategy PCS30. This is the section of the core strategy which deals with green belt policy. Para. 6.166 identifies that the mid-point of the plan period (i.e. 2016). “the RSS has not identified the North Poole sites as an area of search for new development. However this land offers the The Core Strategy Inspectors Report set out views in respect of the only significant contingency for employment development should the need for further employment land be identified. This supply of employment land and the role of safeguarded land at North land will remain as safeguarded land until such time as it can be clearly demonstrated that the employment requirements Poole in particular. The Inspector was of the opinion that this matter for the conurbation to 2026 as identified by the RSS can be met without this land needing to be considered. The core would need revisiting in the near future. strategy hearing inspector recommended that the land should be safeguarded as potential future employment land unless The Inspector commented on the effect of the „credit crunch‟, but at the it could be clearly demonstrated that it was not needed for employment requirements up to 2026. Policy PCS30 states time was uncertain as to its duration and the difficulties it would cause “within Poole the SE Dorset green belt will continue to follow the existing built-up edge. No changes are proposed to the the economy. Monitoring has shown that little new development is boundary from that shown in the Local Plan 1st Alteration 204. Land at North Poole will continue to be treated as taking place and existing vacant employment land is not currently safeguarded land until such time as it is determined that it would not be needed to help meet the employment land being taken up. Average completions on allocated employment land is requirements of the conurbation.” currently running a little over the average of 1.5ha per annum set out in Poole Council has sought to regard this land as if it were green belt land. However that is incorrect. This land is not in the Core Strategy indicators and targets – thus there is at present no green belt and therefore its safeguarding is as reserve employment land. This correct interpretation has been used by imperative to bring forward any additional employment land to meet Poole‟s planning officers in their published reports and recommendation in relation to the Poole Town Football Club projected need over the plan period. planning application for a football stadium on the reserve employment land site. They correctly refer to this land as the Allied to this is the work currently being undertaken jointly by all Dorset reserve employment land at North Poole and go on to argue that the land is of strategic significance and therefore should authorities, to review the Bournemouth, Dorset & Poole Workspace not be released for non-employment development. Stephen Thorne (head of planning and regeneration) is quoted as Strategy employment land forecast based on a lower growth scenario saying after members approved the Poole Town Football Club application (PTFC) on 22 April 2011 that members also than the aspirational figure used for the Draft RSS. This could well made it clear that the remainder of the land should be safeguarded for future employment use in accordance with the have the effect of identifying a lower forecast requirement for Council‟s Core Strategy. In this respect he was endorsing his policy team‟s comments and analysis of the reserve employment land across the county. When completed in the early employment land‟s importance. His report to the PTFC Planning Committee explained that the football club‟s application autumn, this work will inform a conurbation-wide approach to the could compromise land identified as potentially being necessary to deliver the economic prosperity of Poole and the South availability and role of employment land in meeting forecast

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East Dorset sub region as a whole. This was reflected in his recommended reason for refusal which stated that the requirements. proposed football club development would be „‟incompatible with the purposes of safeguarding the land.... (at North Poole Whilst the matter of safeguarded land at North Poole is currently on which the proposal was made) .....and as such would result in the loss of employment land, identified in 2009 is addressed though the Core Strategy Green Belt policy PCS 30, it is requiring protection in the event it would have a strategic role in delivering economic generating employment within the considered that this provides an appropriate policy framework for this borough and South East Dorset‟. We therefore have a situation where the policy protecting the strategic employment area until such time as the review of Core Strategy is undertaken. reserve land at North poole is contained within the green belt part of the core strategy. No policy is proposed to provide In the light of current economic conditions, it is not considered that a detail as to how and when the North Poole reserve employment land might be needed for development. If Poole regards „trigger‟ policy of the nature suggested is necessary or required prior to this as a strategic employment reserve allocation,, (it is shown as safeguarded land on the key diagram in diagrammatic this review. In any event, the policy as suggested could lead to the form) and since the site is site specific and needs to be shown on an ordnance survey based proposals map, greater area of safeguarded land being considered for development in detail should follow in the subsequent development plan document as recommended by the Planning Advisory Service in advance of any need being demonstrated. its guidance on allocating sites (2011). In the event that it becomes desirable to consider development of the reserve land prior to a review of the Poole Core Strategy (either for Poole Borough or for the wider conurbation needs) then it is important that the criteria and triggers which would allow for the development of the site are set out in the DPD. It is inappropriate to have to refer back to PCS30 which is a green belt policy since the land is not in the green belt. The objective is associated with economic need and therefore should be set out in that way in the DPD. Poole‟s preferred approach set out in their letter of the 21 October 2010 in reply to Savills‟ letter of 21 September 2010 and 30 September 2009 (appended) focuses on the trigger mechanism. However in addition to any trigger the criteria to be applied to development on the site and the extent to which the site may have a broader strategic function beyond the boundaries of Poole Borough also need to be dealt with in the proposed DPD policy. The Regional Spatial Strategy is proposed to be done away with by the Localism Bill. In its place Local Economic Partnerships (which Dorset, Bournemouth and Poole are still considering) and a duty for neighbouring authorities to fully engage and co-ordinate their plan making will replace this. Thus references to the 2026 date and the Regional Spatial Strategy will need to be re-interpreted and re-worked. Poole‟s monitoring of their core strategy only identifies targets within the Borough. Whilst their annual monitoring reports to date suggest that they are meeting those limited targets, the above duty will require them to take a broader view about the needs of the whole SE Dorset conurbation. This reinforces the need for an appropriate o=policy to be included in the DPD to accompany the definition of the boundaries of the reserve employment land area. Since the core strategy was adopted, no significant progress has been made with any of the other LPA‟s strategic employment sites allocated through the RSS, structure planning or previously adopted local plan proposals. Thus while Poole‟s annual monitoring report may suggest that employment land and jobs targets are being met within the Borough, no such position exists for the whole of the SE Dorset conurbation. The ministerial written statement which accompanied the 2011 budget encourages all local planning authorities to review decisions they have taken and to allow all possible development to assist with the national economic recovery. That cannot wait until a 2016 core strategy review; there is an urgent imperative. This reinforces the need for an appropriate policy to be included in the DPD setting out the specific criteria and approach which should be adopted, if this site needs to be released, for necessary employment development in the SE Dorset conurbation. Furthermore, after the Localism Bill has received Royal assent, clause 89 will mean that any previous local or structure plan saved policies will be revoked. Thus the need for the DPD to identify the boundaries of the reserved employment land, otherwise there would be no remaining boundary to reserve allocation. Therefore we believe that the DPD which fails to give adequate detail to support the PCS safeguarding policy and interpret the changing economic circumstances and emerging government national planning policies; and which fails to take account of the duty to fully engage with neighbouring planning

2 authorities on strategic cross-boundary issues inevitably render it unsound. We therefore submit that the pre-submission draft of the Site Allocations and Development Management Policies Development Plan Document should include a policy setting out the criteria and the potential triggers for development of the site if it is required for employment purposes. A draft policy is set out at the end of these representations. However since Poole Borough have erroneously assumed that this area would be part of the green belt no sustainability appraisal has been carried out of the reserve land site. Therefore attached as an appendix is a sustainability appraisal of the safeguarded North poole reserve employment land in the style of the remainder of the site specific allocations and development management policies sustainability appraisal to assist. Representation ID 149: Mr Robert Asquith, Planning Director New Earth Solutions Ltd I consider that the pre-submission DPD meets the tests of soundness as set out in PPS12, in that it is justified, effective Noted. and consistent with national policy. I support the adoption of this DPD. Representation ID 166: Mr Nick Squirrell, Natural England No. Our reasons are set out below. Noted. Representation ID 197: Mr Renny Henderson, Conservation Officer RSPB South West Region No. Our reasons are set out below Noted. Representation ID 207: Mr Terence O'Rourke, Terence O'Rourke On behalf of our client, Neptune Consultants Ltd, the applicants of the development proposals at West Quay Road, we Noted. welcome the opportunity to make representations on the above Development Plan Document (DPD). PPS12 sets out the tests of soundness that Local Planning Authorities must meet when preparing DPDs. Paragraph 5.2 of PPS12 states that to be „sound‟ a DPD should be justified, effective and consistent with national policy. The first two criterion are then further defined: „Justified‟ means that the document must be: 1) founded on a robust and credible evidence base 2) the most appropriate strategy when considered against the reasonable alternatives „Effective‟ means that the document must be: 1) deliverable 2) flexible 3) able to be monitored. We feel that a number of the policies within the DPD fail to meet these tests and are therefore not sound. Our reasons and a more detailed analysis of these policies are set out below. Representation ID 190: Mr Michael Holm, Planning Liaison Officer, Environment Agency No, the document would be considered unsound (National Policy) due to inappropriate reference to flood zones. In the Noted. document and supporting proposal maps reference should be made to your Authority‟s Strategic Flood Risk Assessments The proposals map is not a constraints map. The SFRA is an evidence (SFRA‟s). The SFRA 2126 flood risk area should be delineated on the proposals maps; and evidence submitted that any base which primarily concerns the town centre and regen areas. The site allocation in an identified flood risk area has had a Sequentially Test in accordance with Planning Policy Statement 25 SFRA 2126 flood risk area is a climate change map. Existing flood (PPS25), Development and Flood Risk. zones are on the proposals map because they relate to a policy. Sequential tests for Sterte Avenue West and Fleets Corner have been undertaken.

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Representation ID 219: Mr Christopher Allenby, Poole Old Town Conservation Group We do not feel that the Site Specific Allocations and Development Management Policies Pre-submission DPD meets the Noted. PPS12 tests of soundness. Surely Question 1 should be the last question of this document not the first. Having completed the remaining 38 questions and our answers listed below show a varied performance across the board on Policy options. We would therefore consider the document to be Unsound as per our comments below. Question 2: General Comments

Representation ID 30: Mr Peter Tanner, Tanner & Tilley on behalf of Pennyfarthing Homes Other than this comment box to Question 2, there is no comment box under the heading of "Meeting Poole's Housing Options and preferred options were dealt with at earlier stages. The Needs" to be able to add any suggested sites to be allocated for housing or other purposes. We have made comment pre-submission stage is to assess whether there are any outstanding against Policy DM 5 in respect of the Tourism designation of the block of offices and associated car park adjacent to and soundness issues. north of Compton Acres, Canford Cliffs Road. We consider that this part of that site should be considered for designation for residential development or, alternatively development for a care home or Extra Care accommodation. As set out in our comments on Policy DM 5, these uses would not detract from the use of the adjoining gardens as a tourism attraction and such alternative development would be compatible with the surrounding residential area. Representation ID 40: Mr S I Martin No. It does not meet the need for housing and care home provision. Representation does not provide evidence to support view that the DPD is unsound because it does meet the need for housing and care home provision. Representation ID 76: Mr Brian Tofield, Poole & East Dorset Art Society Well! That was a big read and I must confess that I did not read every word but certainly studied every page and quickly Noted. This representation covers a number of points which are discovered that the proposed plan embraces the suburbs of Poole in just as much detail as the town centre which will general in nature but do not specifically suggest that the DPD is ensure that Poole develops in a progressive and cohesive way a good point. May I now list several comments: - 1. I fully unsound. realise that a town centre must not „die‟ yet the number of vehicles per day is too high which seems to strangle the town and raise „carbon‟ levels. Surely a better way would be to develop „local‟ areas Asda plus several shops at Canford Heath describe this point. 2. Its vital to protect Poole Harbour. In my life time the Holes Bay Road was built and many acres reclaimed for the Ferry Terminal. It has to stop somewhere and the „boat‟ people have to share „restrictions‟ like the rest of us. As a life time „Warden‟ of the harbour shoreline we have to protect the „one‟ thing that is Poole. 3. Yes, a new transport interchange is needed. I don‟t see a bus station in Bournemouth town centre or even Trafalgar Square yet we have one in Poole opposite the Arts Centre, most odd! 4. „Upton Country Park‟ is the lungs of Poole and a place to relax in many different ways and should be maintained. 5. Please give some consideration to residents when the „Thistle Hotel‟ site is developed, high rise has overshadowed Skinner Street for many years! 6. Poole is defined by its Harbour and the Old Town (What‟s Left) and every thought should be given to preserving it with strictly controlled development. We have the

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Heritage in our Harbour and heathland.! Overall the plan is well set out which will keep local areas Local and the Town just that but a great deal of thought must be given to town centre traffic and public transport, especially „Park and Ride‟ and protect the Harbour shoreline. Representation ID 78: Mr Terry Stewart on behalf of CPRE - Dorset Branch, Branksome Park, Canford Cliffs & Sandbanks 1 The introduction section of the document set out that this is the Neighbourhood Watch, Chair of the Southern Poole Chairmens' Group formal consultation stage of the SSA&DM DPD and thus, content and A. Policies Overview wording will have been different from previous stages of production. 1. The document needs to spell out the role and relationship between this and the previous Site Specific Policy document 2. A timetable has now been included in the DPD on page 7. which had different content and wording. 3. An executive summary has now been included in the DPD on pages 2. The document must include a timetable plan showing all the planned future stages for the LDF process - as used to be 1-4. provided - so readers can understand the timing and progress of all the LDF stages. 4. This is a Masterplan approach which is outside the scope of this 3. If the objective of the document is to generate response and consultation with the residents and Poole Stakeholders, DPD. then there should be an Executive Summary of the new policies and changes in policies to focus attention on the key 5. The SSA&DM policies DPD is part of a suite of documents in the elements. Efforts should be made to keep the wording simple and jargon to the minimum. LDF which provide additional detail to the Core Strategy. For the 4. The document must include a table such as that in the Poole Bridge Regeneration 2005 Action Plan showing for each document to be balanced and effective, it must be deliverable and site, the Planned : Area, Residential Units, Employment, Retail Space, Leisure/Community and hotel details. This will flexible. Fixing strict restrictions could compromise this balance so that show the Council‟s planned use for each site, so we can compare the developers‟ later submissions. It will also show the the document would be unsound. split in use for each site. 6. Sites for development must be deliverable within the timescale of the 5. The Site Specific Allocations and Development Management policies DPD is clearly UNSOUND. Following the DPD. The Quay silo site has consent and does not need to form part of Overview of the general Core Strategy policies, the objective of this document should be to provide a guide and the plan. Sainsbury‟s car park is part of Town Centre North and is restrictions to developers for each of the listed sites. At the moment the site descriptions are far too limited. They should covered within the Core Strategy as is any expansion of the Dolphin contain all the key guidelines for the Scoping Report for each site, such as planned residential and employment units, Shopping Centre. Hamworthy Marina is not a scheme that is being building heights, massing, car parking numbers, etc. promoted through the Plan. The Proposals Map shows all sites and 6. It is UNSOUND because the document should include ALL key sites to be developed for the period of this Plan to the land uses related to policy. end of the planning period in 2026. So the sites should include : 6.1. The Quay Silo site which is a key location on the 7. All areas identified as requiring LADS have been taken from the heritage Poole Quay. 6.2. The Sainsbury Carpark which Sainsbury have indicated that they may develop in some 5 years Matrix Characterisation Study of Poole. time. 6.3. The Dolphin Shopping Centre which has recently been sold, and the new owners are planning to expand. There 8. Noted. The Design SPD has a general purpose, to support existing should be a description of the Council‟s plans and limitations for the site. This is one of the most important sites in the design policies in the DPD and a specific purpose, to drive up the Borough and should be central to the Borough‟s planning. 6.4. The Kingland Square and Bus Depot. 6.5. The proposed quality of the built environment of Poole. In producing the Design SPD, major Hamworthy Marina. 6.6. The Proposal Map is UNSOUND since it does not include all the key sites. we will seek the views of local people and engage with groups to 7. The DPD is UNSOUND because if there are going to be 11 Local Area Design Statements and a Masterplan for the ensure that comments inform the content of the SPD. Individual Design University, there should be planned Area Design Statements for each of the 10+ large development sites. Para. 2.5 Briefs are not needed for every site but would be produced where it acknowledges that development in Poole “has contributed to a loss of identity and quality of the built environment, a trend would aid delivery of development on the site and where council that is continuing and which is seen as a threat to the unique character of Poole”. resources are available. 8. So as well as an overarching SPD Design Planning Document for all the major development and regeneration sites to 9. The Lower High Street is covered by Poole Core Strategy Policy ensure development is tightly coordinated with clear architectural and spatial guidelines, there must be individual Site PCS14 which sets out the uses and types of development that will be Design Statements put out for consultation for each development site. suitable in this area. The Lower High Street is also covered by the High 9. The DPD is UNSOUND because rather than producing Policy SSA 11 just for Lagland Street, there should be a total Street Conservation Area and Policy DM2: Heritage Assets sets out Regeneration Plan for the whole of the Lower High Street Area. This Area urgently needs regeneration that coordinates a the criterion for dealing with proposals affecting Poole‟s assets. Policy

5 revitalisation of the whole area, while respecting the Conservation and Heritage criteria. The Policy should include a SSA11 supports these policies and highlights the benefit of small scale review of the Old Town and Lower High Street Conservation Areas. infill development to increased passive surveillance and improvements 10. The DPD is UNSOUND because since a major objective of all this regeneration and development is the provision of to the public realm. These are particular issues which would improve many affordable housing elements, and with the 2 major sites in West Quay road refusing to provide Affordable Housing the footfall and safety of the area and result in a greater cohesive and contributions, the Affordable Housing target should be more clearly set out for each site. revitalised Lower High Street. The 3 Town Centre Conservation Areas 11. The DPD is UNSOUND because Para. 1.7 states that the document must consider the most appropriate strategy are currently being reviewed. against reasonable alternatives. There is no evidence of these “reasonable alternatives”. They must be clearly stated in 10. Development on these sites would be expected to accord with the detail to demonstrate that they have been considered as is required under LDF rules. provisions of the policies contained in the Core Strategy, including the 12. The DPD is UNSOUND because the document does not list “contingency triggers to ensure certainty of delivery over requirement for affordable housing. It is unnecessary to repeat policies the plan period”. With the recession, there will be a serious delay in development of a number of sites. The Core Strategy contained within the Core Strategy. was very questionable in assuming 3.2% economic growth every year for the whole planning period. 11. The reasonable alternatives were considered at the preferred This must be reviewed in the light of national economic forecasts. The DPD is thus UNSOUND as undeliverable. options stage of production of the SSA&DM DPD. 12. There is no evidence to show that contingency triggers are necessary for deliverability of sites. Representation ID 143: Meghann Downing, Highways Agency The Agency welcomes the opportunity to comment on the Site Specific Allocation and Development Management Policies Noted. DPD. In Poole Borough the Agency‟s interest relates to potential impacts on the A31 to the north of Poole and the A35 to the West. The Agency‟s key role and aim within the planning process, as outlined within DfT Circular 02/2007, is primarily to seek to protect the function and capacity of the Strategic Road Network (SRN). The Agency has undertaken strategic level modelling of the SRN which shows that under existing conditions, the section of the A31 directly east of Wimborne Minster, between Merley and the A348 junction south of West Moors, is operating in excess of capacity. By 2026 congestion to the east of Wimborne is expected to intensify. It should also be noted that the Inspector‟s report following the Examination in Public highlighted that the A31 is at capacity and will be unable to accommodate additional traffic without improvements being made (Inspector‟s Report para 4.80). South East Dorset Memorandum of Understanding The Agency is a signatory to the Dorset Transport Agreement, which is a supporting document to the existing Multi Area Agreement, along with Bournemouth, Poole and Dorset. The MOU identifies a protocol to be used in assessing applications in advance of the delivery of the A31 Ameysford to Merley Improvement, which establishes that the Agency will be a statutory consultee on all „major‟ planning applications (as defined in the MOU). The majority of the sites are unlikely to impact upon the SRN, however the Agency wishes to stress that the impact of new development upon the SRN should be a key consideration in all development. Where a site is of such a size that future applications are likely to meet the criteria for „major planning applications‟ as identified by the MOU, I have said so, however this does not preclude the possibility that the Agency would need to be consulted on applications at other sites, where they meet the agreed criteria. The Agency would expect any major development proposals to be supported by a transport assessment and travel plan, with a view to identifying the potential impacts on the local and strategic road network. Furthermore the Agency would seek to work with applicants to agree on an appropriate package of mitigation measures with which to manage any potential impacts on the SRN. I look forward to future involvement with the Poole LDF. However if in the meantime you wish to discuss any of the above, please do not hesitate to contact me. Representation ID 147:

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Mr Geoff Cross, Savills, on behalf of W H White and Landowners See comments below in relation to the need to incorporate a policy for reserve employment land at North Poole. No response required. Representation ID 167: Mr Nick Squirrell, Natural England These are set out below. No response required. Representation ID 198: Mr Renny Henderson, Conservation Officer, RSPB South West Region These are set out below. No response required. Representation ID 265: Mrs Ann Smeaton, Hamside Residents Association The Hamside Residents Association‟s response to the above consultation has been restricted to matters where there is Noted. local knowledge and to where this differs from the submissions provided by CPRE, Open Spaces Society and Old Town No response required. Conservation Group. Therefore, apart from the following we would add our support to their submissions. Representation ID 273: Mr Bill Constance on behalf of Vision for Poole Group OTHER SITES The Harbour Commissioners proposals have not been promoted Poole Harbour Commissioners are currently developing proposals for a new Marina at Hamworthy. There are no policies through the Plan. There is no certainty over whether any marina will in the document referring to this development, which will have a significant impact on Poole Harbour and the surrounding come forward. The Plan is not in a position to identify a site. The areas and needs considerate through the development plan process. Development Management Policies and those in the Core Strategy OTHER ISSUES would apply should a scheme requiring planning permission come We note the requirements of the Community Infrastructure Levy and Poole Council‟s plans to establish a Board to forward. determine how S.106 contributions will be distributed. Poole Vision Group is a key stakeholder and would welcome the Other comments noted. opportunity to sit on this board. In the absence of primary legislation, due to be set out in „The Localism Bill‟ it is unnecessary for this DPD to refer to emerging policy. Whilst we query whether some of these policies are premature in the absence of such primary legislation, we recognise the importance of the DPD in providing a clear Development Plan in which planning application can be considered. Poole Vision group look forward to working with you through the following mechanisms: individual planning applications; Refresh of the SPG (Poole Bridge Regeneration Initiative: Planning and Urban Design Guidance for the Central Area) which will be critical in establishing far more detailed assessment criteria for the key development sites; Development of a Neighbourhood Plan, possibly in connection with the above. Representation ID 192: Mr Michael Holm, Planning Liaison Officer, Environment Agency Proposed allocation sites which lie within both current and future Flood Zones 3 & 2, as shown in Poole‟s SFRA (Level 1 Flood Risk Assessments undertaken for affected sites. & 2) and/or FRMS, will need to be supported with a site specific Flood Risk Assessment in accordance with PPS25. We note that reference is made to flood risk assessment and adaptation/mitigation within individual policies for sites shown to lie within such areas (ones lying within areas at risk of flooding from the sea - both now and in the future). However, these

7 sites, including those within the town centre regeneration area, should only come forward for development when the Borough of Poole have secured a mechanism for collecting developer contributions (CIL) toward the wider flood defences identified within their Flood Risk Management Strategy (FRMS). Representation ID 269: Mr Rohan Torkildsen, Planning Adviser - Western Territory (SW, West Midlands) English Heritage Thank you for consulting English Heritage of these emerging DPDs. Our comments succeed those previously made in Expressions of support welcomed. No further response required. September 2010. We note and welcome the focus on Poole‟s town centre as the main area for change over the plan period providing the primary location for significant regeneration and positive transformation. Proposed policy will help to ensure the historic environment plays a positive role in shaping the form of change and will benefit as consequence. We support the involvement of local people in heritage and design planning in the Borough in, for example, the preparation of the Local Assets List and we would also wish to endorse proposed local area schemes such as the Ashley Cross Initiative (SSA1). We welcome a commitment to the sensitive management of historic streets, spaces and places embracing, for example, the principles of Manual For Streets. In addition to the Public Realm Strategy we anticipate the emerging Our Streets and Spaces Strategy will provide a further positive influence. Representation ID 263: Mr Bill Constance Please register my concerns and comments regarding the above document. In time the Regeneration Area sites will become part of the town. One 1) The Old Town is a distinct geographic, business and community area. The definition of the area is the High Street of the purposes of the SSA&DM DPD is to identify sites that will be south of North Street/Methodist Church, the Lower High Street, the Quay and the residential Old Town. This is a distinct developed and to set out the appropriate uses for a site within the and interdependent area, which must be recognised. Such an approach will encourage sustainable investment and overall framework. The sites are then shown on the Proposals Map so development, which will build on the area‟s history and heritage. There must be a joined up approach. that it can be seen where development is proposed. By defining the 2) Defining the Regeneration sites as a distinct area does not make sense. The Regeneration area will be developed over sites does not infer that they will be developed in isolation and other time and the individual developments will become part of the locality in which they are situated. West Quay Road policies in the plan set out design parameters and context for their (between the bridges) and West Quay Marina should become part of the Old Town/Quay area. Similarly the Pilkingtons, development. Sydenhams and Old Power Station sites must be part of Hamworthy. These sites should be planned and developed The Government has encouraged local authorities to introduce CIL as considering other development sites in Hamworthy, such as; Co-operative store, First School and Liberal Hall. soon as possible. 3) There is concern regarding the planning of infrastructure funding. There appears to be too much dependency on the The evening economy is an important part of the overall economy and Council being able to collect S106 and CIL payments. The coalition Government have made clear that changes will be particularly for a town centre. There is no presumption that this is only made in Developer charges. about drinking establishments. A balanced evening economy attracting 4) There is too much emphasis on Poole becoming an Evening Economy. Tourism is important to the economic wellbeing different age groups and different activities will help support the of Poole. The Quay is a major tourist attraction for families and people of all ages. There is a need to develop family attractiveness of the town and other centres. friendly attractions along and around the Quay in line with BoP Tourism Policies. The proliferation of large drinking establishments should be reversed. These premises are, in the main, dead frontages for much of the day. They do not encourage tourism. Representation ID 220: Mr Christopher Allenby, Poole Old Town Conservation Group We would agree with the general comments regarding the Specific Allocations and Development Management Policies Noted.

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DPD as long as the comments are within the common goals as outlined by the Core Strategy adopted 2009. Representation ID 264: Miss Marie Jasper, Barton Willmore, on behalf of Parrs Factory site owners Representation by Barton Willmore in relation to the Parrs Factory Site. The Parrs Factory site was included in an initial round of public The following representation is made on behalf of the owners of the Parrs factory Site in relation to their former sweet consultation undertaken in autumn 2008. A letter was subsequently factory site, Alder Road, Poole. A Site Plan (Drawing Ref: 19122-P001) is enclosed for your reference. The existing sent to the company in June 2009, suggesting that the site progress buildings on the site were developed in the 1950s for the production of sweets. The site continues to be used for sweet through the Plan process. The response received from the company making today, however this is now under a short term lease arrangement which expires in 2017. The existing buildings owner (by telephone), requested that the site not be included in future were designed specifically for sweet production and as they are now reaching the end of their useful life, it is unlikely that consultations and was therefore not progressed as a consequence. the site will be attractive to the commercial business market without wholesale redevelopment. As such our Client is It is not possible to include this site at this late stage in the DPD considering alternative options for the site. There is some doubt about the site‟s suitability, attractiveness to the market process and in any event the site could come forward for and viability for comprehensive redevelopment for Class B uses. The site is located outside of the Existing Employment redevelopment independent of the DPD process. Areas as identified in the Core Strategy and adjacent to an established Retail Park (Branksome). As such our Client Poole‟s approach is to restrict the growth of out-of-centre retail parks considers that the site provides an opportunity for a natural expansion to the established Retail Park. We also note that and it is considered that any future consideration of expanding the the site is adjacent to residential properties on Alder Road, and that continued employment use might not offer the most Branksome Retail Park, to include the Parr‟s site, would most compatible land use option. In this regard we note that the current use has generated complaints from local residents in appropriately be undertaken as part of the review of the adopted Core relation to noise and odour emissions from the site. Accordingly the Site Specific Allocations and Development Strategy, which it is anticipated will be completed by 2016 – a Management Policies DPD should be amended to include a Site Specific Allocation Policy and Plan which confirms the timescale that would align well with the expiry with the current lease allocation of the site as part of the Branksome Retail Park from 2017 onwards. arrangements. Question 3: Proposals Map Representation ID 41: Mr S I Martin No. See answer to Question 1. Noted. Representation ID 56: Mr Harry Alexander, Open Spaces Society Where it details 'New footpaths and cycleways', clarity is required as to whether these will be new Public Rights of Way Noted. both as Footpaths and Bridleways listed upon the Definitive Map. Representation ID 71: Mr Nigel Pugsley, Senior Planning Consultant BNP Paribas Real Estate, on behalf of Barclays Bank Group Property My client is supportive of changes to the proposals map, specifically the expansion of the town centre boundary to include Noted. Barclays House. It is considered that this approach best defines the extent of Poole's Town Centre in meeting both the definition as defined in PPS4 and identifying the spatial strategy in relation to the town centre as set out in the Poole Core Strategy. Representation ID 105: Meghann Downing, Highways Agency Yes. Noted. Representation ID 148:

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Mr Geoff Cross, Savills, on behalf of W H White and Landowners The proposals map is considered unsound insofar as it relates to reserve employment land at North Poole. The attached Policy PCS30 contains reference to the treatment of safeguarded land extract of the proposals map indicates this area is correctly shown as being outside the Green Belt, however there is no at North Poole, It is considered that this provides an appropriate policy key accompanying the plan and the hatched annotation covering the land at North Poole is labelled as „PCS30‟. PCS30 is framework for the area until such time as the review of the adopted the Core Strategy Green Belt Policy, which carries forward Green Belt Boundaries unchanged from the Local Plan, it is Core Strategy is undertaken (anticipated to be completed by 2016). therefore misleading to suggest that this policy applies outside the Green Belt, and the policy status of this land would be The Proposals Map label on the area of safeguarded land at North unclear to any member of the public reviewing the plan. This lack of clarity in the Proposals Map has arisen as a result of Poole of PCS30, is therefore considered appropriate, as it points to the the failure of the Site Specific Allocations DPD to include a separate policy for the reserve employment land at North Core Strategy policy which provides guidance on the treatment of the Poole. The need for such a policy is recognised at Appendix 1 of the Core strategy, which proposes that Local Plan Policy safeguarded land until such time as it is determined that it would not be NE6: North Poole is replaced by a new policy in the Site Specific Allocations DPD. needed to help meet the employment land requirements of Poole.

Representation ID 283: Mr Bill Constance on behalf of Vision for Poole Group The Plan should be amended to incorporate Poole Old Town and Lower Hamworthy as included in Map 3 of the Core The boundaries referred to in Map 3 of the Core Strategy are shown on Strategy. This will enable: the Proposals Map. Improvements to infrastructure to be delivered in the immediate vicinity of the site which will be most affected by development; Community Infrastructure Levy to give priority to areas in the immediate vicinity of the site, rather than the wider Poole Borough. Representation ID 191: Mr Michael Holm, Planning Liaison Officer, Environment Agency In order to make the document sound you should ensure that the proposal maps must have the SFRA 2126 flood risk The Proposals Map will be amended as necessary. area identified rather than the Environment Agency Flood Zones. Evidence of the Sequential Test must be submitted in The appropriate sequential tests have been undertaken for the support of the document. (We note that the SA states that the Sequential Test has been undertaken for the proposed identified sites. Sterte Allocation) Representation ID 159: Mr Richard Shaw, Director, Savills, on behalf of Gallagher Estates Ltd & Lands Improvement Holdings Ltd We understand from previous discussions that there is a drafting error in respect of the Proposals Plan and the area for Proposals Map has been amended to incorporate the electricity development for Policy SSA10 (The Regeneration Area - land on the Hamworthy side of Backwater Channel). This area switching station within the area defined by Policy SSA 10 - The should be extended to include the land currently occupied by the electricity switching station. The inclusion of that land Regeneration Area - land on the Hamworthy side of Backwater would be consistent with the Core Strategy (Maps 3 and 4) and the earlier outline planning application for the Channel. development of the site. At this stage, we would have to object to the soundness of the plan on the basis of that inconsistency (question 3) but this can readily be overcome. Representation ID 156: Mr Robert Lofthouse, Savills Planning & Regeneration, on behalf of Solum Regeneration We note that there is a discrepancy on the key for the proposals map which needs to be rectified. In particular the „Town The site is not considered to be within the Town Centre Primary Centre Boundary‟ and „Town Centre Retail Boundary‟ are not consistent with the approach to the town centre and retail Shopping Area boundary. Incorporating it would extend the potential policies in the DPD. This makes understanding the Council‟s approach to its town centre objectives (Policy DM3 for retail development and potentially harm the retail strategy for the

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„shopping‟, for example) difficult to comprehend. We would specifically request that the site frontage to Serpentine Road town centre that is set out in the Core Strategy. It is therefore not should be included in the Town Centre Retail Area to facilitate retail frontage development, related to and linked closely accepted that this location should support anything other than ancillary with the Dolphin Centre and the rest of the retail area. Having now included the Goods Yard site in the defined Town retail facilities and would not harm the aspiration to improve linkages Centre, it is logical to help consolidate the station with other town centre uses. This can be facilitated by retail back into the town centre. development on the frontage to Serpentine Road, linking Barclays and the station and relating and integrating this area functionally into the town centre and the Town Centre Retail Area. This site has the opportunity to contribute to providing a „vibrant heart to the town through generating a bustling, prosperous and safe environment for all‟. This is the key starting point message in the Council‟s „prospectus‟ for the Town Centre North area. The Goods Yard site will be integral to delivering the objectives in that prospectus, including „improved connections to the rail station‟ and „an extension to the retail offer that broadens the attraction of Poole as a shopping centre whilst complimenting the existing Dolphin Centre‟. We look forward to continuing to work with the Council on this important development site and hope that these constructive comments will facilitate a suitably positive and flexible planning framework for future of the site. Representation ID 221: Mr Christopher Allenby, Poole Old Town Conservation Group We do not feel that the Proposals Map meets the PPS12 tests of soundness. Having completed the remaining 36 No response required. questions and our answers listed below show a varied performance across the board on Policy options. We would therefore consider the Proposals Map to be undeliverable. We would agree with the general comments regarding the Proposals Map as long as the comments are within the common goals as outlined by the Core Strategy adopted 2009. Representation ID 181: Mr Nigel Pugsley, Senior Planning Consultant BNP Paribas Real Estate, on behalf of Royal Mail and Parcelforce My client is supportive of changes to the proposals map, specifically the expansion of the town centre boundary. It is Noted. considered that this approach best defines the extent of Poole‟s Town Centre in meeting both the definition as defined in PPS4 and identifying the spatial strategy in relation to the town centre as set out in the Poole Core Strategy. Question 4: Policy DM 1 - Design Representation ID 10: Mr Mark Howell This policy is unsound. It creates an artificial area (the Regeneration Area) which does not hold together geographically DM1 is the Development Management Policy for Design which all while neglecting the historic core of the town by including its constituent parts in a catch all Rest of the Town Centre development will have to have regard to irrespective of location. It definition in relation to which there are no distinct policies. The area consisting of the Quay, Lower and Middle High makes no reference to any part of the town centre. Streets and Old Town is one coherent area geographically and needs to be recognised as such as it is the key to Poole's identity. It has been ignored because planners have focused on empty spaces instead. However, it does inclde significant development sites - the Silo, Quay Thistle and West Quay. If these sites are developed without relating them to the wider Old Town area, this will be disastrous for Poole. Representation ID 13: Mr Peter Tanner on behalf of Pennyfarthing Homes In the third sentence of Paragraph 2.5 to Policy DM1 it is implied that all new development that has taken place has Noted. Will amend text to clarify that „some‟ development has led to a contributed to a loss of identity and quality of the built environment and that this is a trend that is continuing and which is loss of character. seen as a threat to the unique character of Poole. We do not accept this broad and sweeping statement. It is not The Localism agenda encourages developers to engage with the

11 supported by robust and credible evidence. Whilst we support the general aim of Policy DM1to achieve development of community before drawing up proposals. There is a strong community good design, this part of paragraph 2.5 is not justified. We suggest that the third sentence to paragraph 2.5 be changed to representation in Poole from residents who are interested and read - "...It has identified that over time, in certain specific locations within the Borough, some development has concerned about the nature and form of development and developers contributed to a loss of identity and quality of the built environment." Delete - "...., a trend that is continuing and which is should be engaging with residents to help shape acceptable seen as a threat to the unique character of Poole."In Policy DM 1, we consider that whilst Community Engagement is to development proposals. be encouraged and can be helpful in informing communities of how proposals have had regard to context and drawing out Building for Life is a nationally recognised indicator which Local design issues of concern to the community, we do not feel that there is robust or credible evidence to suggest that the Authorities have been required to report on within their Annual requirement for Community Engagement will itself result in better design or that it should be embodied in the Policy itself. Monitoring Reports. It sets out design rules that it is perfectly We would suggest that reference to Community Engagement be deleted from Policy DM 1 and that reference be made in reasonable to aspire to and therefore include within policy. the supporting text to encouragement to developers to engage in Community Engagement wherever possible. Similarly, Wording in the Trees section will be amended to reflect their whilst scoring development against the Buildings for Life Standard can be a helpful tool in delivering improved design, we contribution to the character of an area. consider that there is no robust or credible evidence to suggest that the Building for Life Standard should necessarily be embodied in the Policy itself. We recommend that reference to it be deleted from Policy DM 1and placed in the supporting text. Policy DM 1 under the heading "Trees" states that "Development proposals which result in the loss of protected or unprotected trees will normally be resisted". However this appears to disregard whether those trees are of poor quality, of limited useful life or whether they make little or no contribution to the visual amenities of the site and its surrounding. We consider that this part of the policy is not effective because it is inflexible as currently worded and is not justified. We suggest that this part of the policy be re-worded to read - "..." Development proposals which result in the loss of protected or unprotected trees that make a significant contribution to character and appearance of the site and its surroundings will normally be resisted" Representation ID 23: Mrs Nicola Brunt, Urban & East Dorset Living Landscapes Manager, Dorset Wildlife Trust DM1 v. New planting to support wildlife and thereby contribute to biodiversity is supported. We recommend use of native Noted. species where possible. We advise a survey of the site prior to developing planting plans to avoid loss of existing good wildlife habitats such as species rich grassland which may exist in fragments in the Borough and not be subject to nature conservation designations. Representation ID 32: Mr Justin Milward, Regional & Local Government Officer Woodland Trust Whilst we are pleased to see the sub-paragraph in policy DM1 headed „Trees‟, we are objecting because the paragraph There is no need to repeat national Policy within LDF documents. does not provide the absolute protection for ancient woodland and veteran trees contained in national policy, and is Section H of policy DM9: Green Infrastructure and Biodiversity will be therefore unsound. This is notwithstanding the separate indirect reference to ancient trees in Policy DM 2: Heritage amended to make explicit that the loss of ancient woodland or trees will Assets. not be permitted. Reason Ancient woodland, together with ancient/veteran trees, represents an irreplaceable semi natural habitat that still does not benefit from full statutory protection: for instance 86% of ancient woodland in the South West has no statutory protection. This is particularly relevant as ancient woodland is still facing considerable threats - research from the Woodland Trust shows that in the last decade 100 square miles (26,000 hectares or 5% of the total amount of ancient woodland remaining in the UK) of ancient woodland in the UK has come under threat from destruction or degradation. Development threats associated with transport and infrastructure appeared to be the most significant (31% of cases), followed by amenity and

12 leisure developments (14%), housing (10%), and quarrying and mineral extraction (6%). Although Poole contains only 0.24% ancient woodland cover compared to 2% for the whole of Great Britain, ancient woodland is our richest habitat for wildlife conserving more species of conservation concern than any other habitat (232 species as outlined in the UK Biodiversity Action Plan, 1994). In addition, many ancient trees are not formally recorded, and the Woodland Trust and Ancient Tree Forum are running a national project – the Ancient Tree Hunt - to identify and map ancient trees (http://www.ancienttreehunt.org.uk/) so they can be protected and enhanced for the benefit of all. This project has already recorded ancient trees in Poole, such as the veteran pines at Broadstone. The Coalition Government has signalled its intention to protect biodiversity: „We will introduce measures to protect wildlife and promote green spaces and wildlife corridors in order to halt the loss of habitats and restore biodiversity‟ („The Coalition - Our programme for government‟, May 2010). The „UK Forestry Standard‟ sets out the UK Government‟s approach to sustainable forestry. It states: “ancient semi- natural woods...are of special value.” The Standard has a series of UK-wide aims for semi-natural woodland and clearly states: “the area occupied by semi-natural woodland should not be reduced.” (Forestry Authority, 1998, UK Forestry Standard: Standard Note 5, pp.41-43). The Biodiversity Strategy for England clearly states that the Government will “take measures to prevent loss or damage to ancient woodland and trees, and their uniquely rich biodiversity, from development.” (DEFRA, 2002, Working with the grain of nature. A biodiversity strategy for England, para 6.9). Planning Policy Statement 9 on Biodiversity and Geological Conservation clearly states: “Ancient woodland is a valuable biodiversity resource both for the diversity of species and for its longevity as woodland. Once lost it cannot be recreated. Local planning authorities should identify any areas of ancient woodland in their areas that do not have statutory protection (e.g. as an SSSI). They should not grant planning permission for any developments that would result in its loss or deterioration...Aged or 'veteran' trees found outside ancient woodland are also particularly valuable for biodiversity and their loss should be avoided. Planning authorities should encourage the conservation of such trees as part of development proposals." (ODPM, PPS9, 2005, paragraph 10). Under section 74 of the Countryside and Rights of Way Act 2000, the Government has a statutory duty to publish lists of priority conservation habitats. Under section 40 of the Natural Environment and Rural Communities Act 2006, all public authorities now have a statutory duty to conserve biodiversity. The UK BAP targets includes a new Habitat Action Plan for Native Woodland which specifies a clear „maintenance‟ target of no more loss of ancient woodland - http://www.ukbap.org.uk/BAPGroupPage.aspx?id=98. It is therefore axiomatic that Poole Council has a statutory obligation to protect ancient woodland. The SW Forestry Framework (Forestry Commission, 2005) contains a key objective to „Protect, improve and manage Ancient Semi-Natural Woodland...‟. As an example of policy used by other local authorities, the Sheffield City Policies and Sites Consultation draft (http://www.sheffield.gov.uk/planning-and-city-development/planning-documents/sdf/city-policies-and-sites) states in Policy G3: “New developments will be required to include appropriate tree planting, to retain and integrate healthy, mature trees and hedgerows and replace any trees that need to be removed. Development will not be permitted that would directly or indirectly damage existing mature or ancient woodland, veteran trees or ancient or species-rich hedgerows”.

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Changes We would like to see the following proposed amendment to the first sentence wording under the Trees heading of Policy DM1 (italics) - “Development proposals which result in the loss of protected or unprotected trees will normally be resisted. Development proposals which would result in the loss of or damage to ancient woodland or ancient trees will be refused.” Representation ID 57: Mr Harry Alexander, Open Spaces Society 2.1 Design „where all members of the community can access the places they want to go….‟ Local Area Design Statements come out of the recommendations of 2.2 Public Art…..excellent platitudes; it is hoped that areas such as the example at Penn Hill, with its art block costing the Borough wide character appraisal. £45,000 will not be repeated and consultation with the local community will be required. Involvement of the community will depend on the location and 2.6 Why are these areas detailed for Local Area Design Statements? importance of development and in developing proposals it is for the Design developers to identify who should be involved. Community engagement. Which organisations will be connected and how and at what stage of the process will they be The Proposals Map is not a Rights of Way Map which is held „engaged‟. separately within the Council. Trees The wording of 'should' include replacements, needs to be replaced with 'must' provide for replacements. Layout & connectivity This certainly needs to include the Rights of Way Improvement Plans. A lot of time and money has been spent on these plans. They are incorporated in the Dorset County Council plans, therefore Public Rights of Way need to also be incorporated within these documents. Representation ID 72: Mr Nigel Pugsley, Senior Planning Consultant, BNP Paribas Real Estate, on behalf of Barclays Bank Group Property My client is supportive of a criteria-based policy, to be supported by a revised Design Code SPD, Local Area Design Support for policy noted. Statements (LADS) and a Public Realm Strategy. Given the strategic nature of my client's landholdings, my client would As a key landowner and stakeholder in the Area North of Towngate wish to be consulted and involved in the preparation of the proposed LADS for Area North of Town Gate Bridge to ensure Bridge, Barclays Bank Group plc would be consulted and involved in that new development in the area would not have an adverse impact on my client's current business operations, or the preparation of the LADS for the area. prejudice its development potential should it become available in future. Representation ID 75: Mr Peter Lamb, Terence O'Rourke Ltd, on behalf of Mr Nick Petford, Pro-Vice Chancellor for Research & Enterprise, Bournemouth University On behalf of Bournemouth University we welcome the opportunity to respond to the Site Specific Allocations and There is no need for a policy that merely states support for Development Management Policies DPD (hereafter referred to as the DPD). development. The most appropriate way of bringing forward a coherent The university generally supports the approach taken by the DPD and specifically paragraph 2.7, which identifies that a strategy is for the completion of the estates strategy embracing the "master plan approach for Bournemouth University (BU) and Arts University Campus Bournemouth (AUCB) at Fern future needs of the University in the form of a Supplementary Planning Barrow is being adopted, prepared in conjunction with key stakeholders and the local community". The university Document. acknowledges that future development at Talbot Campus which generates significant additional student and staff numbers should be planned for comprehensively and that this could be achieved by a masterplan that would be adopted by the council as supplementary planning guidance. Although Bournemouth University and the AUCB are neighbours at Talbot Campus, they are two separate educational

14 institutions with separate estates strategies and growth aspirations. Bournemouth University recognises the potential advantages of considering the growth aspirations of both institutions as part of a single masterplan. However, the future development objectives of the AUCB are currently unknown and the university would not want this to prejudice the delivery of a comprehensive development strategy for its facilities in the future. While the university broadly welcomes paragraph 2.7, the recent Coalition Government education funding cuts and changes to the university tuition fees charging regime have had implications for its estates strategy. The university is currently undergoing a period of further review of its estates strategy to understand how it can continue to deliver a high quality service to its students and staff and attract increasing numbers of students each year. It awaits the publication of the Higher Education Funding White Paper (expected June/July of this year), as it will set out the Government's strategy for higher education funding. Given the potential funding uncertainty ahead, it is essential that the future DPD planning policy framework provides the university with the flexibility to deliver development at the Talbot Campus, whether this is comprehensively or on a scheme-by-scheme basis. The current site-specific policy for Talbot Campus is saved Local Plan policy CF2: University and Arts Institute, which contains a presumption in favour of development by BU and the AUCB at Talbot Campus subject to traffic generation limitation measures. As currently worded, the university does not consider that the DPD contains the same explicit presumption in favour of university development and, if the DPD is found to be sound by an Inspector and policy CF2 is superseded, this positively worded policy will be lost. The university objects to the loss of this policy through the absence of a suitable replacement policy within the DPD. Policy CF2 (or a similarly worded policy) should be brought forward into the DPD. This would carry significant weight as part of the adopted development plan. Representation ID 79: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and the Southern Poole Chairmens' Group B. Locally Distinctive and Self-Reliant Places The list of Local Area Design statements is derived from the Borough‟s 1. We strongly support para 2.5 and the need for a clear and tight design policy supported by an updated SPD. In view of character study. the scale of the Regeneration and Development sites and the shortly pending planning applications, this updated SPG Policy cannot be applied retrospectively to existing should be given top priority and resource over other planning policies. approvals/development. 2. We are glad to hear that the Local Area Design Statements will be developed with full consultation with local residents Agree that all buildings should be of a high standard but 10 is the and key stakeholders. The list of Area Design Statements is UNSOUND since it must include ALL the major development benchmark for recording within the Annual Monitoring Report. The sites - and also for the whole Lower High Street Area. Council does not have the resource to assess every new scheme 3. We support Policy DM 1, but are concerned that point (i) says „development does not become a dominant feature ...on below 10 to BfL standard. the skyline‟, while the Thistle Hotel and West Quay Road sites have both included dominant, ugly 12 storey high There is a Public Art committee which guides and approves projects towerblocks out of keeping with their Conservation and key locations. within the Borough. 4. We support the need to protect trees and the provision of green open public spaces on development sites. 5. The Policy is UNSOUND since we reject the threshold of 10 dwellings for Building for Life standards. We believe that ALL new dwellings in Poole should be built to this standard. 6. We support the importance of Public Art for the community, but insist that the local community must be consulted before the public art item is chosen. There have been several public art items that have controversially been imposed without local or Area Committee approval.

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Representation ID 106: Meghann Downing, Highways Agency Yes. Noted. Representation ID 163: Cllr May Haines, C/O Legal and Democratic Services, Borough of Poole Would like to see Canford Cliffs village bounded by Cliff Drive, Spencer Road, Ravine Road and Haven Road included in Character issues are dealt with by policies in the Core Strategy and stronger landscaping. This is an area that is frequented by visitors and should extend to provide the a sylvan feel when Development Management Policies. For conservation areas there is an walking from the Canford Cliffs and Flaghead Chine. Recent development has seen use of metal fencing with additional layer of control through their designation and the mediterranean style plants. With the restoration of the land between Bessborough Rd and Haven Road (behind Loch Management Plans for them. Fyne Restaurant) to open space, there needs to be a verdent follow through from there to the green in Cliff Drive and then down the Chines. This would certainly enhance the area and go some way to restoring some of the inappropriate landscaping that has taken place. With regard to H10 in the Poole Local Plan, something similar that defines what low density housing is (single detached dwellings in large plots) need to be translated over to the site specific. There is already threats of applications for nursing homes in Leicester Road (covered by the Branksome Park Conservation Mgmt Plan) and we need to have a robust policy that spells this out clearly ... to remain as such in areas covers by H10. The same comments for BE23. In the Penn Hill ward, the area bounded by Compton Avenue and Blake Hill Crescent including Compton Close and Gardens has a distinct character of single detached dwellings, well spaced between and little by way of sub-division. This area needs to be protected as single detached area for family homes and given its proximity to Lilliput First School this would be appropriate. Representation ID 168: Mr Nick Squirrell, Natural England Chapter 2 sets out design influences. There is little mention within the policy text regarding design's ability to incorporate Core Strategy policy PCS 32 promotes the use of SUDs and therefore positive measures for biodiversity, and to address and help mitigate effects of climate change in an integrated and does not need repetition elsewhere. Biodiversity is picked up in policy sustainable manner an example being multifunctional features such as SUDs and green roofs. We regard this as an DM9. omission and policy DM1 should make explicit reference to design's role in promoting and enhancing biodiversity and adaptation measures for climate change. New sub-headings will be needed in policy DM1 to achieve this. Without this additional policy wording we do not consider policy DM1 accurately summarises the context in which development is to be delivered in Poole. Representation ID 199: Mr Renny Henderson, Conservation Officer, RSPB South West Region No. Chapter 2 sets out design influences. There is scant mention within the policy text regarding design‟s ability to See response to ID168. incorporate positive measures for biodiversity, and to address and help mitigate effects of climate change. We regard this as an omission and policy DM 1 should make explicit reference to design‟s role in promoting and enhancing biodiversity and adaptation measures for climate change. New sub-headings will be needed in policy DM 1 to achieve this. Without this additional policy wording we do not consider policy DM 1 accurately summarises the context in which development is to be delivered in Poole. Representation ID 209: Lindsay Thompson, Senior Planner, Terence O'Rourke on behalf of Neptune Consultants Ltd. Policy DM1 is not sound because it effectively repeats elements of the Core Strategy but in some cases in more restrictive The policy sets out design issues important to the Borough in its

16 way. For example, policy PCS24 of the Core Strategy sets out the requirements for Design and Access Statements (as consideration of development proposals and provides a basis for does Government guidance). It is not possible for a policy to cover every instance of what is required to be contained development management. within a design and access statement but in attempting to do so the wording of this policy becomes restrictive for instance Reference to Design and Access statements is to be removed as this requiring development proposals to demonstrate that „existing sunlight and daylight to habitable rooms‟ [of neighbouring is covered in the Core Strategy. Amendment to the sunlight/daylight properties] „is maintained‟. Whilst we accept that new development proposals should not harm existing amenity, we think issue will also be amended removing the requirement for „existing‟ to this policy is unduly restrictive in requiring development to maintain the existing situation. We are concerned that this be maintained as this in itself may be overcome without loss of restrictive wording could impede the development particularly in the regeneration area which by its very nature comprises amenity. centrally located redundant, under utilised and vacant land that is allocated to accommodate major new development. It is therefore likely that redevelopment of these sites could have some, but not unreasonably, impact on neighbouring properties. There are adopted policies contained within the Council‟s Core Strategy that cover design principles and the requirement for design and access statements. The wording of these policies has already been agreed through examination of that document. Therefore we do not think this policy is required. Representation ID 216: Gareth Morgan, Director, Nathaniel Lichfield & Partners on behalf of Talbot Village Trust We consider that one change is required to make the policy sound. We do not consider it appropriate to normally resist Will amend text to clarify. development proposals which result in the loss of unprotected trees. The purpose of tree protection orders (TPOs) is to provide protection where justified. If there is a desire to protect trees which are not the subject of TPOs this should be limited to those which make a significant contribution to the setting or character of the site in terms of their value as a landscape feature or for screening or privacy as referred to earlier in the policy. Representation ID 270: Mr Rohan Torkildsen, Planning Adviser - Western Territory (SW, West Midlands), English Heritage Policy DM1 Design. English Heritage supports this design policy. We appreciate the intention to supplement the policy Noted. Policies do not need to cross refer as the Plan should be read with an updated Design SPD and a number of specifically focused Local Area Design Statements (LADS) providing as a whole. guidance on how areas, neighbourhoods and communities can be shaped and enhanced to protect and foster local distinctiveness. It may also however be useful to signpost policy DM2 to ensure the historic environment is considered as an integral part of the design process. Might historic environment matters be considered as part of a design and access statement? – see also below. Representation ID 222: Mr Christopher Allenby, Poole Old Town Conservation Group We do not feel that the Policy DM 1: Design meets the PPS12 tests of soundness Surely clarification that it meets PPS1 The Plan picks up the areas that are recommended within the of Characterisation study April 2010 page 1 refers and the intro on page 3 states “The findings of the character study are Character Study for Local Area Design Statements. then set against the Spatial Strategy for Poole, already defined in the Core Strategy, and which envisages the main concentrations of new development to be concentrated in the town centre, within and around major local centers and key hubs of transport and community activity and along Prime Transport Corridors. The relationship between areas of townscape sensitivity and locations of preferred higher density development can then be identified and the issues arising are then discussed. In recognition of the danger that major new development instigated by the Spatial Strategy for Poole, as well as the continuation of general redevelopment trends can result in the loss of existing urban character and quality, this study provides an outline for setting guidance for maintaining local distinctiveness through design policies as well as identifying,

17 in broad terms, opportunities for future enhancement. Additionally, large areas of the residential hinterland within the Borough of Poole lack clear identity, and so, in general terms, issues associated with improving the identity and local distinctiveness of these areas are also discussed.” As part of the local design brief how come the Old Town of Poole is not considered to be part of the High Street or part of the regeneration area. The proposed expansion of the conservation area increases the area of Poole Old Town. Question 5: Policy DM 2 – Heritage Assets Representation ID 14: Mr Peter Tanner on behalf of Pennyfarthing Homes Whilst the content of Policy DM 2 sets out appropriate guidance on how heritage assets should be considered and Development management policies differ from old style Development appraised in the context of proposals for development, we consider that this guidance does not justify it being embodied in Control policies in that they set out how issues should be addressed, policy. Core Strategy Policy PCS 23G provides the appropriate policy control under which development affecting a what are the important considerations and what may need to be done heritage asset should be considered. We suggest that Policy DM 2 be deleted and its content be placed as supporting text to inform proposals. Policies are no longer there merely to control to guide how developers should go about an assessment of an heritage asset where development proposals are likely to development. affect it or its setting. Representation ID 33: Mr Justin Milward, Regional & Local Government Officer Woodland Trust Objection - Whilst we are pleased to see the reference in the text to ancient trees being included as heritage assets in This is addressed in Section H of policy DM9: Green Infrastructure and Policy DM2, we are objecting because the policy does not appear to actually protect ancient trees. This conflicts with Biodiversity. national policy and renders the Policy unsound. Reason Old and significant individual trees are an important part of our cultural and landscape heritage. They resonate with the history of the landscape and form markers in the lives of individual people and communities. Trees also make a significant contribution to the urban environment both in visual terms and in helping to abate air pollution and create oxygen. It has been estimated that Britain may be home to a substantial proportion of northern Europe's ancient trees and therefore we have a great responsibility in looking after them. Ancient trees have a special conservation value. As they age and become hollow, they provide particular niche habitats including decaying wood, loose bark, sap runs, rot holes and tree humus. Ancient trees are often important cultural features with strong historical links as well. Many ancient trees are not formally recorded, and the Woodland Trust and Ancient Tree Forum are running a national project - the Ancient Tree Hunt - to identify and map ancient trees (http://www.ancienttreehunt.org.uk/) so they can be protected and enhanced for the benefit of all. This project has already recorded ancient trees in Poole, such as the veteran pines at Broadstone. Planning Policy Statement 9 on Biodiversity and Geological Conservation clearly states: “Aged or 'veteran' trees found outside ancient woodland are also particularly valuable for biodiversity and their loss should be avoided. Planning authorities should encourage the conservation of such trees as part of development proposals." (ODPM, PPS9, 2005, paragraph 10). As an example of policy used by other local authorities, the Sheffield City Policies and Sites Consultation draft (http://www.sheffield.gov.uk/planning-and-city-development/planning-documents/sdf/city-policies-and-sites) states in

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Policy G3: „Development will not be permitted that would directly or indirectly damage existing mature or ancient woodland, veteran trees or ancient or species-rich hedgerows‟. Changes We would like to see a specific addition to this policy stating that ancient trees will be protected absolutely without caveat. Representation ID 58: Mr Harry Alexander, Open Spaces Society Historic Environment Noted. This appears to be well-founded on the face of this report, however, there are several examples where Borough of Poole (BoP) has fallen very short of this e.g. Tolkein's house, no plaque was ever erected, development was granted to demolish his dwelling….an apparent lack of foresight with both the historic environment and tourism. There are many other examples in the borough. Various locally listed buildings should be nationally listed. These have been ignored in the past, since many examples of locally listed buildings have been given planning permission to redevelop. 2.9 Heritage as an Historic port This is excellent news, as there may well be charities and groups like Poole Flying Boats Celebration (PFBC) and The Society of Poole Men which will gain from greater recognition and assistance from BoP in the future. 2.10 It details regeneration areas. One of these being 'West Quay Development...' where a highly historical building sits, 'Dorset Iron Foundry'. It is now somewhat encouraging that BoP states that such buildings will now 'continue to make such a positive contribution….' And not succumb to the bulldozers. Representation ID 74: Mr Nigel Pugsley, Senior Planning Consultant, BNP Paribas Real Estate, on behalf of Barclays Bank Group Property The Council's intention to prepare a list of local heritage assets accords with national planning policy in the form of PPS5 Noted. "Planning for the Historic Environment". Policy HE2 of this document states local planning authorities must have evidence about the historic environmental and heritage assets in their area, and that it is publicly document. It is considered that when preparing the local heritage list, it is crucial that the Council considers the potential adverse impacts that identifying local heritage assets may have on other key policy objectives contained within the Site Specific Allocations DPD and adopted Core Strategy. In particular, it is considered that the identification of local heritage assets on sites with acknowledged development potential could frustrate the delivery of new jobs, homes and other public benefits. Representation ID 80: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watc and the Southern Poole Chairmens' Group Policy DM 2 and Para 2.10 are critical in preserving the richness and diversity of Poole‟s heritage and we look forward to Heritage Assets List is an Appendix to the forthcoming SPD. seeing the Heritage Assets SPD. The Policy is UNSOUND in not including the Local Heritage Assets List. The Historical Environment Record should include the finding of the Old Town Alleys project. Representation ID 107: Meghann Downing, Highways Agency Yes. Noted. Representation ID 80:

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Lindsay Thompson, Senior Planner, Terence O'Rourke on behalf of Neptune Consultants Ltd. We feel that this policy is not sound as it is not in accordance with PPS5 and lacks flexibility, therefore is not effective. It is considered that the policy is in accordance PPS5. It is not Policy DM2 fails to include the importance of heritage assets as a catalyst for regeneration. PPS5 states that Local restrictive and does not prevent heritage being a catalyst for Development Frameworks should “set out a positive, proactive strategy for the conservation and enjoyment of the historic regeneration. The proposed wording is pointless in that it adds nothing environment in their area”. (paragraph HE3.1) With its current wording, Policy DM2 does not give enough weight to this to the plan. aim, instead its wording is restrictive and not proactive. PPS12 states that DPDs, “should not repeat or reformulate national or regional policy” (paragraph 4.30). Policy DM2 unnecessarily repeats the wording of PPS5 and does not convey the full flexibility of the policy statement. Policy DM2 is therefore contrary to PPS12 and PPS5, we therefore propose Policy DM2 is changed to simply state that: “Proposals affecting any Heritage Asset in Poole will be expected to be in accordance with Planning Policy Statement 5.” Representation ID 271: Mr Rohan Torkildsen, Planning Adviser - Western Territory (SW, West Midlands) English Heritage Policy DM2 Heritage Assets English Heritage supports this well considered and drafted policy; the commitment to the Welcome support but consider that the policy does not need further associated Heritage Assets SPD and Local Heritage Assets list, and; the proposed indicators of achievement and clarification. monitoring. We appreciate the intention for the policy to cover all heritage assets formally designated or not. To enhance its effectiveness it may be useful to clarify that the policy relates to development including transport related works therefore applying equally to the local highways authority. It may also be worthwhile clarifying in what form an historic environment assessment accompanying a proposal should take. Should it form part of the design and access statement or be submitted separately? Representation ID 223: Mr Christopher Allenby, Poole Old Town Conservation Group We do not feel that the Policy DM 2: Heritage Assets meets the PPS12 tests of soundness. Surely clarification that it It is not for the Plan to say that it meets other guidance. meets PPS5 Site Specific Allocations and Development Management Policies Development Plan Document Pre- Heritage Assets although not by name are addressed in Core Strategy submission Document April 2011 page 106 refers to Local Heritage Assets list. There appears to be no reference to Policy PSC23G. Heritage Assets, in the Core Strategy Feb 2009 or the Characterisation study April 2010. Representation ID 164: Mr Michael Fearn, Shireconsulting, on behalf of Barclays Bank plc As a general point (at a further 162 pages, adding to the Core Strategy‟s 160) the document is overly long. In part its Noted. excessive length is due to its containing policies that are not needed, as they do not add anything to Government policy. We give the example of Policy DM2 concerning „Heritage Assets‟ as being one where the content only duplicates policy in PPS5. Representation ID 183: Mr Nigel Pugsley, Senior Planning Consultant BNP Paribas Real Estate, on behalf of Royal Mail and Parcelforce The Council‟s intention to prepare a list of local heritage assets accords with national planning policy in the form of PPS5 Noted. „Planning for the Historic Environment‟. Policy HE 2 of this document states local planning authorities must have evidence about the historic environmental and heritage assets in their area, and that it is publicly documented. It is consider that when preparing the local heritage list, it is crucial that the Council considers the potential adverse impacts that identifying local heritage assets may have on other key policy objectives contained within the Site Specific Allocations DPD and adopted Core Strategy. In particular, it is considered that the identification of local heritage assets on sites with

20 acknowledged development potential could frustrate the delivery of new jobs, homes and other public benefits. Question 6: Policy DM 3 - Shopping Representation ID 4: Mr Mark Howell The policy is unsound. It fails to recognize that the Quay, Lower High Street and Middle High Street must be treated as a Poole Core Strategy Policy PCS14 already addresses the role for this coherent area focused on independent retail, tourism and leisure. If they are treated individually and no coherent plan is area as part of the overall retail strategy for the Borough. DM3 merely put in place to link them together, these areas will not have the critical mass to be sustainable and successful. sets it in context for the overall approach to retailing. Representation ID 65: Ms Rose Freeman, The Theatres Trust Unsound as ineffective: Policy DM3 Shopping The accompanying text to this policy also concerns town centre uses but Arts and Cultural facilities are referenced in Core Strategy policy the title of the policy refers to retail only. The section is headed Shopping and the wording of the policy reflects the title but PCS10. references to other town centre uses are included at paras. 2.12, 2.21 and 2.29 which should be deleted from the accompanying text as these are not included adequately in the policy. Arts and cultural facilities are usually located in town centres but there is barely any guidance as to their enhancement and development. Representation ID 81: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and the Southern Poole Chairmens' Group 8. We support Policy DM3 in protecting Poole Town Centre from any further edge of town shopping centres which draw Noted. trade away from the centre. The Castlegate Shopping Centre has been a disaster for Bournemouth in drawing custom away with its free parking. But since public transport is poor from certain Poole suburbs into the centre, adequate centre car parking is essential to maintain trade. For Tourism and Shopping, there should be cheap, realistically priced short term parking for visitors. Bullet 3 refers to “better quality shops” - far too vague. Representation ID 108: Meghann Downing, Highways Agency Yes. Noted. Representation ID 155: Southern Planning Practice Ltd., on behalf of Hall and Woodhouse Question 6: Policy DM3 Shopping The policy approach, which recognises that the provision of further retailing across the The Council through its local plan has had long standing floorspace Borough and in various locations to support the local community, is supported. However, objections are raised in two limits for different types of retail location in support of maintaining the regards: The inclusion of specific, maximum floorspace figures for local centres, edge of centre and out of centre locations character and scale of development. This is supported by updated data is not justified, is unlikely to be effective, does not follow national policy and is therefore UNSOUND: evidencing this. Flexibility is built into the policy to allow for exceptional a. There is no explanation offered or reference to any evidence base to support or justify the inclusion of specific figures circumstances. or the particular figures selected. b. The policy already sets out criteria which would need to be satisfied, and are more pertinent to allow for differing circumstances at different locations and over the Plan period. c. The supporting text at paragraphs 2.30 and 2.32 recognises that the floorspace limits may not be appropriate and that more floorspace may be capable of being supported. This approach is fully supported, and further undermines the appropriateness of including a maximum figure in the policy.

21 d. The evidence base available, which dates back to 2007, includes no recommendations to follow this approach. e. The use of artificial floorspace limits serve no useful purpose and in fact may harm the government‟s objectives for the introduction of innovative competitive and dynamic retailing. It will not therefore be effective. The policy approach needs to be modified to delete the reference to specific maximum floorspace figures in respect of local centres, edge-of-centres and out-of- centres. Secondly, there is no justification for requiring proposals in edge of centre and out of centre locations to meet a local need (criterion a): a. This requirement goes beyond the policy guidance set out in PPS4 and is therefore not in accordance with national policy. There is no requirement set out in PPS4 to require retail developments to demonstrate that they meet a local need. b. Furthermore, current government guidance particularly as set out in the recent government Statement Planning for Growth sets out a more pro-active approach to development, and seeks, amongst other things that Councils: consider the range of likely economic, environmental and social benefits of proposals; including long term or indirect benefits such as increased consumer choice, more viable communities and more robust local economies (which may, where relevant, include matters such as job creation and business productivity). The suggestion that the development should meet a local need is therefore inconsistent with the government‟s policy objectives and should be replaced with a policy approach that supports the economic benefits of the provision, including increased consumer choice and more viable communities. c. There is no justification within the evidence base to follow this approach. d. It is accepted that the development should demonstrate that that it would not detract from the function vitality and viability of the Borough‟s hierarchy of centres, but this is already clearly set out under criterion b. This part of the policy accords with national policy guidance but the additional requirement relating to local need should be deleted. This requirement is not justified, is unlikely to be effective, does not follow national policy and is therefore UNSOUND. The policy approach needs to be modified to delete the words meets a local need and under criterion a of sub section 4 of Policy DM 3. Representation ID 224: Mr Christopher Allenby, Poole Old Town Conservation Group We do not feel that the Policy DM 3: Shopping meets the PPS12 tests of soundness. The Core Strategy Feb 2009 Noted. Strategic Objective that the policy is supported by Objective 1 Key Outcomes: Bullet 3 refers to „better quality shops‟ far too vague Strategic Objective 6 Key Outcomes: Improved quality and range of services - diverse and active local centres Higher footfall and patronage of local shops and services Improvements in accessibility in the public realm Improved quality and range of services - diverse and active local centres. The Characterisation study April 2010 only refers to Strategic Objective 6 In order to gain the increased footfall, plans have to be in place to encourage park and ride facilities and cheap realistically priced parking for visitors. The Primary Retail Frontage and Secondary Retail Frontage in Poole Town Centre Lower High Street, Ashley Road, and Hamworthy Road must be more accessible to pedestrians, the road system as it is cuts off these areas from themselves Representation ID 258: Ms Rachel Robinson, WYG Planning and Design, on behalf of Sainsbury‟s Supermarkets Ltd. On behalf of our client we wish to make the following general representation in support of Development Management Noted. Policy 3: Shopping, which is in general accordance with Planning Policy Statement 4 (PPS4): Planning for Sustainable Economic Growth in respect of the following matters. PPS4 identifies that development plans should set out a clear

22 economic vision and strategy for their area which positively and proactively encourages sustainable economic growth (Policy EC2.1a, PPS4). It is also considered that to plan for sustainable economic growth local planning authorities should seek to make the most efficient and effective use of land whilst reflecting the different location requirements of businesses, taking into consideration matters such as the size required, site quality, access and proximity to markets and to the locally available workforce (Policy EC.2d, PPS4). Policy EC.4 (PPS4) recognises that local planning authorities should proactively plan to provide consumer choice by planning for a strong retail mix so that the range and quality of the comparison and convenience retail offer meets the requirements of the local catchment area. Where it is not possible to locate main town centre uses (including retail development) within an existing centre the relevant tests as set out in PPS4 should be adhered to, namely the requirement for a sequential assessment (Policy EC.15) and an impact assessment (Policy EC.16) and the requirements as set out in Policy EC.17. The Site Specific Allocations & Development Management Policies DPD should not give rise to any conflict with national policy in this respect. Representation ID 165: Mr Michael Fearn, Shireconsulting, on behalf of Barclays Bank plc. 1. Introduction & Background We act as planning consultants for Barclays Bank plc („the Bank‟) in respect of the Local The policy approach is not intended to be restrictive but to allow for the Development Framework (LDF) for Poole and this letter forms the Bank‟s response to the above document. As a long- continued vitality and viability of centres. With regard to the town centre established business, the Bank has made a substantial contribution to the vitality and viability of the Borough‟s various primary frontage the policy allows for other A class uses where they do town centres over the years that it has traded and as a significant stakeholder within the area it is therefore concerned not adversely impact on the centre. This is the policy that has been that development plan policies should not fetter the important contribution that it makes to the vitality and viability of town followed in Poole and which has led to a successful primary retail area centres. Through high attraction of footfall, financial services retailers generally (and the Bank in particular) play a key role which includes a number of A2 uses. In maintaining diversity and in promoting town centre health and as a result, the provision of financial services should be allowed to improve and ensuring the role of the centre is not undermined it is appropriate that evolve alongside the significant improvements to shopping provision envisaged over the proposed plan period. Subjecting an assessment is made of whether non A1 uses will affect the overall banks to outmoded restrictive controls on their location is not supported by Government policy or by any evidence and character, role and performance of the centre. there is therefore a need to review any existing policies that restrict such A2 uses in designated frontages or the Council Criterion vi under key principles seeks to protect retail uses not prevent will risk the Development Plan Document (DPD) being found unsound. 2. The Existing Position - Planning Policy & them. Financial Services Retailing ODPM Circular 03/2005 „Changes of Use of Buildings And Land‟ which accompanied the last major revisions to the Use Classes Order specifically states in relation to the A2 Financial and Professional Services use class (which was created to separate those uses “serving the public, from other office uses not directly serving the public” - paragraph 32), that the Class is also “designed to allow flexibility within a sector which is very much a part of the established shopping street scene, and which is expanding and diversifying”. The uses within Class A2 are noted as being those “which the public now expects to find in shopping areas” (paragraph 38). The wider role played by town centres than a pure shopping function is recognised throughout Government policy on town centres. Government Policy in PPS4 „Planning for Sustainable Economic Growth‟ continues the thrust of policy in PPS6 relating to town centres but particularly emphasises the importance of economic growth. The strong emphasis upon the promotion of town centre vitality and viability remains in the current PPS and the Government is clear that there should be a positive attitude towards all development which generates wealth and creates employment. The „over-arching objective is sustainable economic growth‟ (paragraph 9). The Government wants economic growth to be focused in town centres offering „a wide range of services to communities in an attractive and safe environment and remedying deficiencies in provision in areas with poor access to facilities‟. There should be „enhanced consumer choice through the provision of innovative and efficient shopping, leisure, tourism and local services in town centres‟ (paragraph 10). Policy EC10.1 states that: „Local planning

23 authorities should adopt a positive and constructive approach towards planning applications for economic development. Planning applications that secure sustainable economic growth should be treated favourably‟. Policy EC3.1c states that Planning Authorities should: „at the local level, define the extent of the centre and the primary shopping area in their Adopted Proposals Map‟, following consideration of whether there is evidence of a need to designate „realistically defined primary and secondary frontages in designated centres‟. There is nothing, however, in Government policy that recommends or supports imposing restrictions upon acceptable town centre uses at all and indeed Policy EC3.1 states that local planning authorities should „set flexible policies for their centres which are able to respond to changing economic circumstances‟. It is therefore essential that DPD policies should facilitate the positive approach required by PPS4. The need for a positive stance towards development has been reinforced recently in the Ministerial Statement of 23rd March 2011 from the Rt Hon Greg Clark MP. The Statement provides added emphasis to the Government‟s determination that planning policies and their implementation must facilitate economic investment and „the growth that this country needs‟. The preparation of this DPD is just such an opportunity. „Vital and Viable Town Centres “ Meeting the Challenge (DOE 1994) The policy in this document is still extant and in relation to the impact of planning policy upon town centres (paragraph 4.09) it says that rules restricting a change of use are of little help when it might lead to space being left vacant to decay. Paragraphs 4.11, 13.07, 13.10, 13.12 & 13.20 advise that the private sector (particularly national financial institutions) should be positively engaged in the process of bringing forward regeneration strategies for town centres and to create positive climates for investment. On the matter of policy formulation PPS12 is clear that all DPDs must be: founded on a robust and credible evidence base and the most appropriate strategy when considered against the reasonable alternatives; and must be consistent with national policy. According to paragraph 6.53 of the Poole Core Strategy „revitalising the Town Centre is a key priority for the Council‟, an objective manifested within policy PCS 10. The Poole Local Plan First Alteration (PLPFA) of 2004 is similarly supportive of diversity contributing to town centre vitality and viability. Currently, within the primary retail frontages of the Town, uses such as those within Class A2 are permitted provided that: i. they provide a service to shoppers; and ii. they do not harm the predominantly retail character of the primary frontage, either individually or taken together with other non retail developments. Promoting vitality and viability in town centres are thus common objectives of the Government and the Council. To succeed, town centres need to provide a full range of services and these often need to be located in ground floor premises in accessible locations. Indeed, Class A2 retailers such as the Bank routinely experience very high levels of customer visitation, contributing significantly towards pedestrian movement and therefore the vitality and viability of town centres. The Bank has undertaken a number of comparative footfall surveys in connection with its current acquisitions programme at its branches in various towns and cities in the UK. These conclusively show that the level of footfall associated with Bank branches is commensurate with, and often higher than, the best known national multiple Class A1 traders. The evidence of the Bank‟s footfall surveys have been a key element in helping to change attitudes towards the presence of banks in core shopping areas and primary frontages. Even planning authorities that once strongly resisted Class A2 uses in their primary areas have granted permission for Barclays „flagship‟ outlets. Examples of authorities that have recognised the wider benefits of the „flagship‟ design (following receipt of applications which have been supported by evidence of high footfall, attached as Appendix 1), include Southampton, Reading, Manchester, Milton Keynes, Romford, Southend, Leicester, Plymouth, Sheffield, Kensington & Chelsea and Cambridge. Once the relocation had taken place follow up surveys were carried out in 2010 at Milton Keynes, Southend, Reading and Southampton (attached as Appendix 2). In every case the new „flagship‟ branch had significantly increased its footfall, confirming the Bank‟s beneficial effect on vitality and viability. Banks also have

24 moved away from the traditional style of frontage, preferring to have an open, visually interesting and attractive face to the „high street‟. The Bank has become increasingly retail in its presentation and has introduced an innovative „flagship‟ branch design, which has been developed in association with its customers, to transform banking into what it terms as “a retail focused experience”. The Bank estimates that some 10 million customers use its branches each week and through listening to their feedback, a design has been developed that meets their requirements for modern banking and provides branches similar in appearance and in operation to retail shops. This is an example of the “enhanced consumer choice through the provision of innovative and efficient shopping, leisure, tourism and local services in town centres” that PPS4 expects and to which the Council‟s DPDs must also positively respond. Whilst the design of every new branch has to be flexible in order to be sensitive to the requirements of each building occupied, the aim is generally to ensure that over 70% of the internal space at ground floor is accessible to customers. The Bank‟s managers regularly report that upon the opening of a „flagship‟ branch the customer visitation levels significantly increase and thus the level of activity helps to underpin pedestrian flows to the benefit of surrounding traders. It is therefore important that planning policy recognises the benefit of bank uses in fostering footfall and pedestrian activity and that it should not resist much-needed investment by financial service retailers. 3. Representations On The Consultation Document Despite PPS4‟s statement, at Policy EC3.1c, that the definition of primary and secondary frontages should be „realistic‟, it does not seem that the frontages have been examined in recent times. The LDF process provides an opportunity to revise the Council‟s whole approach to shopping area vitality and viability. Poole Core Strategy Objectives set out in paragraph 6.53 and Policy PCS 10 seek to promote greater diversity as part of a vibrant local retail economy. In the light of such stated objectives it is therefore surprising that the current consultation document contains policies that could work against the achievement of these strategic aims. The Council‟s own “Retail Monitoring Report” of December 2008 notes at Section 3.0 “Diversity of Use” that “land uses in the town centre are constantly evolving in response to changing market forces, roles and functions. Diversity of use based upon a strong comparison retail offer within the centre is essential for any town centre and is most likely the greatest defence against competition from out-of-town retail parks…” (fourth paragraph of 3.1). The following paragraph of Section 3.1 continues “variety within the town centre plays a vital role in contributing to the centre‟s vitality and appeal to different users”. This is supported by the public responses recorded in the Section of the “Retail Monitoring Report” entitled “Town Centre Health- check: Public Perceptions”, where the third most common reason cited for visiting Poole town Centre was “to use services”, such as banks. Both the Council‟s adopted Core Strategy, as well as the current consultation DPD, recognise the need for substantial investment in the authority‟s various town centres and how their potential needs to be released, although the mechanism of how this investment growth is to be achieved is not apparent. The positive impact that financial service retailers such as the Bank have upon vitality and viability should be recognised and the quality of non-Class A1 provision should also be permitted to improve alongside other improvements to shopping provision. The wider role played by centres than mere shopping areas is recognised at various points in the draft plan (for instance paragraphs 2.12 & 2.20-2.25). Accordingly part 2 of Policy DM3, which deals with Primary and Secondary Frontages, would seem to allow for Class A2 uses in the primary frontages subject to maintaining the current “well balanced” (it is not clear how this term is defined and what assessment criteria have been used) range of uses. However, despite the initial positive wording of this part of the policy, this requirement to maintain the existing levels, does rather indicate that there will be no opportunity for any new non-shop

25 uses as this would alter this „balance‟. The Bank‟s scepticism is further borne out when ones examines the first section of Policy DM3, “Key Principles” which relates more widely to any proposals involving the introduction of “town centre uses”. Criterion vi of Part 1 of DM3 seeks to place an embargo upon any changes of use from shop use within any of the Borough‟s centres. Proposals involving the loss of ground floor shopping floorspace are required: “to provide evidence demonstrating the impact test has been satisfied” to show “that reasonable steps have been taken to market the property for a continuous period of at least 12 months at a value reflecting its centre use”. Requiring the „impact test‟ in relation to every proposal involving a change of use from a town centre shop is excessive and goes well beyond the necessary requirements of development control. It is not in accordance with PPS 4 (which exhorts a positive approach to investment and use of flexible policies), nor is it within the spirit of the Government‟s pronouncements regarding the default position for applications to be “yes”. The proposed requirements relating to marketing are also excessive as they fail to recognise the benefits to vitality and viability that can accrue from encouraging new investment into town centres. In this case the Council‟s „default position‟ would seem to be that the loss of any Class A1 will only be accepted as the last resort, when all other possibilities are exhausted. As part of this process the Council is advocating needlessly prolonging vacancies for over a year. Attention is drawn to the Government research in “Vital and Viable Town Centres – Meeting the Challenge”, dating from over 15 years ago, warning of the adverse consequences of maintaining policies of this type. It is also far too simplistic to assume that the Class A1 category is the only one suited throughout primary areas. The Class A1 category includes many „service‟ uses that do not sell goods to the public and many occupiers that make little or no contribution to footfall, have no window display, and do not invest in their premises. The implication that only A1 uses are appropriate derives from very outmoded and discredited thinking that other uses such as banks detract from the vitality and viability of town centre. By definition, any use that falls within Part A of the Use Classes Order is appropriate in a town centre as it is a “shopping area use” and is acceptable without any need for restriction or qualification. This is particularly the case for the financial services sector. Trying to keep those Part A uses that do not harm amenity out of the main part of centres is likely to conflict with the achievement of objectives which seek to regenerate and revitalise those areas. Keeping significant generators of footfall out of primary frontages will actively work against the achievement of the Core Strategy‟s objectives and is inconsistent with national policy. Accordingly, the Bank advises that these proposed criteria in the draft policy be abandoned and replaced with a much more positive and flexible framework designed to encourage investment into town centres (see next section). As a final point on Policy DM3 there is no requirement to „enhance‟ conservation areas as set out at criterion iv, whilst many proposals involving new development or introducing new uses, do „enhance‟, statute merely requires an application to „preserve‟. Planning policy cannot go beyond what is required in law. 4. Closing Comments The Council‟s Core Strategy objectives (and for that matter those of Government) will require major commitment and substantial investment by the private sector. Pursuing restrictive policies to keep significant generators of footfall such as the Bank out of primary shopping frontages will actively work against the achievement of those objectives and is an outdated and discredited approach. The opportunity provided by the preparation of one of the main elements of the LDF should be used to give greater encouragement to appropriate Part A uses to invest and to improve the quality of their representation. The Bank‟s evidence (see Appendices 1 & 2) of how it increases vitality and viability in primary frontages shows that there is considerable benefit in seeking to attract those A2 users such as banks who provide a high level of

26 investment in, and maintenance of, their premises resulting in active and attractive street frontages. This will foster very significant footfall and pedestrian activity and attract investment by others, helping to provide the confidence and commercial viability necessary for any programme of regeneration and investment. In this respect the current consultation document contains no explanation for the decisions taken about the most appropriate strategy to follow when considered against the reasonable alternatives and the published documents show no indication that there has been an objective process and audit trail of assessing alternatives, or that any alternatives have been considered at all. Without the addition of robust evidence to support the stance being taken in Policy DM3, this Development Plan Document will run the risk of failing the PPS12 tests of soundness at public examination. Policy DM3 of the Pre-Submission Consultation Site Specific Allocations and Development Management Policies DPD should be rewritten to make clear that financial services retailers such as the Bank are appropriate in all designated shopping frontages without restriction and as currently written the Policy is „unsound‟ as it is neither consistent with National Policy nor Justified. Therefore, if the Council intends to continue to define primary and secondary frontages, we ask that Criterion vi be deleted entirely. The section of Part 2 of the current draft Policy (beneath the heading “primary retail frontage”) should then be replaced with the following: “Uses such as shops, banks and building societies which contribute to the vitality, viability and diversity of the Town Centre will be encouraged. Such active ground floor uses will be maintained and enhanced throughout the centre and will be appropriate throughout the designated Primary Shopping Area. Other Part A uses may be permitted subject to their likely effect upon the vitality and viability of the town centre and assessment of any adverse impact upon residential amenity”. The Bank trusts that the above comment is helpful and that full regard will be taken of the points raised before making the formal submission of the plan to the Secretary of State. The Bank would like to confirm its continued interest in the LDF process and we shall be grateful if you will continue to notify us of the progress of the submitted document. Question 7: Policy DM 7 – Coastal Zone Representation ID 165: Mrs Nicola Brunt, Urban & East Dorset Living Landscapes Manager, Dorset Wildlife Trust DWT welcome the protection this policy gives to the biodiversity along the coastal cliffs and chines. Much of this is Noted. designated and includes Sites of Nature Conservation Interest interlinked with the internationally important sites. Representation ID 165: Mr Harry Alexander, Open Spaces Society The Coastal Zone. There has been no mention of greater public access points to the Harbour.... The Plan is not proposing any. Representation ID 82: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group 9.We support Policy DM4, but have been concerned at the planning approvals of certain prominent developments on the Flooding policy is dealt with in the Core Strategy. skyline and along Poole cliffs this MUST be more strictly enforced. The DM4 Policy is UNSOUND since the Policy does not mention flooding so must state the effect of flooding on the shoreline and Sandbanks and have a clear restriction on such development. Representation ID 109:

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Meghann Downing, Highways Agency Yes. Noted. Representation ID 169: Mr Nick Squirrell, Natural England No. We would welcome the recognition of the value and importance of the CZ within the Borough. Interests within the CZ Accept that wording can be included to overcome objection. may be competing and these conflicts (as well as positive relationships) are significant planning issues. Paragraph 2.34 recites the requirements of the Poole Core Strategy with regard to the development and the mitigation measures necessary to avoid harm to wildlife sites. As stated above, work continues on identifying how these measures can be delivered and funded. Policy DM4 should reflect the requirement to avoid harm to European, international and nationally important sites within the Coastal Zone. Its omission is surprising given much of the preceding text. The existing comment to "coatal cliffs, chines and maritine archaeology" is too limited in the context of the exceptional biodiversity importance of the zone. Policy DM4 covers the coastal cliffs which support European Protected species. This brings a requirement under the Habitats Regulations to do more than point (iv). Where there are likely significant effects on EPS your authority may need to carry out an Appropriate Assessment. Natural England objects to the policy in its current form but advise that it should be possible to agree to rewording before the Consultation stage. Representation ID 200: Mr Renny Henderson, Conservation Officer, RSPB South West Region No. We welcome the recognition of the value and importance of the Coastal Zone (CZ) within the Borough. Interests As above ID169. within the CZ may be competing and these conflicts (as well as positive relationships) are significant planning issues. Paragraph 2.34 recites the requirements of the Poole Core Strategy with regard to development and the mitigation measures necessary to avoid harm to wildlife sites. As stated above, work continues on identifying how these measures can be delivered and funded. Policy DM 4 should reflect the requirement to avoid harm to international and nationally important sites within the Coastal Zone. Its omission is surprising given much of the preceding text. The existing comment to „coastal cliffs, chines and maritime archaeology‟ is too limited in the context of the biodiversity importance of the zone. Representation ID 186: Margaret Baddeley, Senior Associate Director, Nathaniel Lichfield & Partners, on behalf of Bourne Leisure Ltd. Bourne Leisure endorses the recognition at paragraph 2.33 that the coast is an important tourism and employment asset, Agree that reference to national policy should be updated. The policy a recreational resource and wildlife habitat. Draft Policy DM 4: Coastal Zone is however considered to be unsound. does not prevent tourism development in the coastal zone and indeed As set out in our previous submission dated 7 October 2010, reference is made to PPG20: Coastal Planning at paragraph Rockley Park is specifically addressed in the following DM policy on 2.34 of the emerging DPD. With the exception of three paragraphs relating to development in coastal locations, PPG20 Tourism. was cancelled in March, 2010 and superseded by the PPS25 Supplement: Development and Coastal Change (March, The policy does not need to make reference to landowners etc needing 2010). Reference in the emerging DPD should therefore be made to the PPS25 Supplement and not to PPG20. to make early engagement with the planning authority as this is Notwithstanding making this necessary change to reflect up to date national policy, the PPS25 Supplement also lends encouraged and advised in all development cases. support to the need to protect the coast whilst balancing competing demands upon it. The Government‟s stated aim in the The suggested policy additions do not add anything to the Plan. PPS25 Supplement is to “ensure that our coastal communities continue to prosper and adapt to coastal change”. Moreover, page 5 of the PPS25 Supplement recognises the substantial economic and social benefits that coastal development can deliver, providing that it is managed over its planned lifetime. Therefore in response to Question 7, the Company does not consider draft Policy DM 4 to be justified or effective, nor is it consistent with national policy.

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In order for draft Policy DM4 to be considered sound, a further two issues should be identified, analysed and reflected in the approach taken in emerging Policy DM 4 to development in the Coastal Zone: 1) A balanced approach to the consideration of tourism development Bourne Leisure considers that the DPD should adopt a more comprehensive and balanced approach to tourism development in the Coastal Zone, one of promoting appropriate tourist development that benefits the local economy - such development by its very nature requires a location in the Coastal Zone/in close proximity to the Harbour. At the same time, Coastal Zone policy for tourism development should balance the economic benefits of such development with considering the natural environment. This balanced approach is appropriate even in more sensitive areas, provided that commensurate mitigation measures (such as the inclusion of a buffer zone and appropriate landscaping) can be implemented to mitigate both direct and indirect impacts. Each tourism development proposal should therefore be considered on its own merits and with specific reference to its economic (and social) benefits, as well as taking account of environmental considerations. In the context of Policy DM 4, Bourne Leisure would emphasise the vital importance of needing to ensure that existing coastal holiday parks are able to continue to adapt, improve and potentially expand, to meet the ever changing requirements of holidaymakers for higher standards of facilities. There must be DPD policy scope for such change in the Coastal Zone, not only in order to achieve the wider policy objective of encouraging tourism generally, but also to promote the upgrading and expansion of existing accommodation in order to cross-fund other improvements to Parks, thereby also promoting year-round tourism and the strengthening of the local tourism industry. This revised approach in Policy DM 4 would then provide an appropriate context for, and consistency with a revised draft Policy DM 5, which supports the redevelopment or upgrading of existing facilities at Rockley Park as a key tourist attraction (but which also requires some revision - see below). Taking this promotional stance towards enhancing facilities for tourism in the Coastal Zone is of particular importance for existing operators such as Bourne Leisure. In recent years, the Company has experienced an increased demand and need within its Parks for higher grade accommodation, facilities and landscaping, together with improved and more spacious layouts, better services, entertainment and eating establishments, all being required in order to meet customers‟ expectations. The Company‟s development proposals are therefore increasingly to upgrade its sites, accommodation and facilities, to reduce densities (caravans are now typically 25-30 units per hectare, compared to 62-74 per hectare in the 1960‟s) and to improve landscaping and introduce additional screening. All of these changes are necessary, to ensure that the Cpmpany‟s Parks remain competitive and do not fall behind competitors. However, the upgrading of facilities in these ways often results in the need to extend a site, in order to incorporate an improved layout and additional landscaping without any increase in overall numbers. In addition, Park sites may also need to be expanded, in order to be able to fund the necessary improvements. It is therefore important for draft Policy DM 4 to set out a balanced policy approach to the consideration of proposals for tourism development in the Coastal Zone. The revision of the DPD‟s Coastal Zone policy inter alia to support the enhancement of tourist accommodation and facilities in the Zone would be consistent with the Government‟s recently published Tourism Policy (March 2011) and will help to ensure that Poole does not fall behind other areas of the South Coast, and other parts of the UK, that are actively encouraging improvements to caravan parks and other tourist accommodation, facilities and attractions. 2) Identification of coastal erosion Issues Whilst Bourne Leisure endorses the Council‟s approach of „holding the line‟ for flood protection along its shoreline (para. 2.35), it is important that draft Policy DM 4 ensures engagement with developers/landowners/ business operators of Coastal Zone sites at an early stage in shoreline management and in the

29 development planning process, to address coastal erosion issues through appropriate policies. In order to ensure that sufficient flexibility is built into the emerging DPD, Bourne Leisure considers that draft Policy DM 4 should be revised, to promote such early engagement and also, to allow for coastal landowners and business operators to relocate buildings and other facilities to open space within existing sites or to land immediately adjoining their landholdings, where necessary due to coastal erosion. Also with reference to coastal management, Policy DM 4 should also be revised, to refer expressly to allowing landowners and business operators to contribute to funding for, and to retain coastal defences, in accordance with the Environment Agency‟s national policy for contributing to funding, providing and maintaining defences, and in line with the approach proposed in the Poole and Christchurch Bays Shoreline Management Plan 2 (SMP 2, July 2010). The SMP 2 it is noted advocates „Managed Realignment‟ in the medium term, allowing local management and maintenance by the caravan park owners of existing defences (p. 53), provided that works are funded by holiday park operators. Draft Policy DM 4 should fully reflect this SMP policy; Bourne Leisure considers that existing tourism developments such as theirs should continue to be protected. As a minimum, and in regard to tourism operations, the DPD‟s policies for the Coastal Zone and for tourism should seek to hold and maintain the existing defence line, in order to allow for tourism operators in coastal locations to retain, fund and implement appropriate coastal defence work to protect their property and to enable them to continue to operate and improve their businesses. In light of the above, Bourne Leisure considers that the following suggested text should be inserted as two separate headings within draft Policy DM 4, following the section on „Sandbanks Beachline‟: “Tourism Development Development proposals for tourism uses will be considered on their individual merits. Coastal Management Proposals for coastal management schemes should address the following key considerations: i Public safety ii The need to protect socio-economic interests iii Environmental effects In reaching a determination, all material considerations will be balanced.” Representation ID 193: Mr Michael Holm, Planning Liaison Officer, Environment Agency Unsound. The proposed policy (DM4) takes account of character, appearance and amenity, but does not refer specifically Flooding policy is covered in the Core Strategy. to the flood risk management measures for the next 100 years identified within Poole‟s FRMS and SFRA. We would recommend that this policy be changed to include reference to flood risk management measures as previously. Representation ID 272: Mr Rohan Torkildsen, Planning Adviser - Western Territory (SW, West Midlands), English Heritage We support this policy‟s commitment to the protection of maritime archaeology, landscape character and the social Monitoring amended to reflect this. heritage value of the Boroughs coastline. Unfortunately Section 9 Monitoring and Implementation fails to reflect a balanced approach only emphasising in Key Outcomes Sought natural environment considerations, a relatively straight forward matter to correct. Representation ID 225: Mr Christopher Allenby, Poole Old Town Conservation Group

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We do not feel that the Policy DM 4: Coastal Zone meets the PPS12 tests of soundness. The Core Strategy Feb 2009 The FRMS is addressed through the Infrastructure DPD. Strategic Objective that the policy is supported by Objective 1 To Transform and Revitalsie the Town Centre of Poole And Strategic Objective 6 To deliver high quality, distinctive and self-reliant places The reference to the report Flood Risk Management Strategy (FRMS Jan 2011) has not been considered at this moment. Question 8: Policy SSA 1 – Ashley Cross Local Centre Representation ID 83: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. We support Policies SSA 1 & 2 and welcome the proposed creation of public open space. Noted. Representation ID 83: Meghann Downing, Highways Agency Yes. The Agency particularly supports the emphasis in the Core Strategy (and referenced here) on improving public Noted. transport efficiency and improving pedestrian and cyclist facilities. Representation ID 226: Mr Christopher Allenby, Poole Old Town Conservation Group We do not feel that the Policy SSA 1: Ashley Cross Local Centre meets the PPS12 tests of soundness. The Core Strategy Not explained why the policy is unsound. Feb 2009 Strategic Objectives that the policy is supported by Objective 4 Promote safe, sustainable and convenient access. 5 To provide better life opportunities and improved quality of life for all & 6: To deliver high quality, distinctive and self-reliant places. The Core Strategy Feb 2009 Strategic Objective that the policy is supported by PCS23: Local Distinctiveness - Section D will not be deliverable. The night-time culture that has developed in the centre of the area has to be carefully monitored. Representation ID 182: Mr Nigel Pugsley, Senior Planning Consultant, BNP Paribas Real Estate on behalf of Royal Mail and Parcelforce. It is noted that the draft policy proposes that Ashley Cross Local Centre and the surrounding area will be the subject of a Noted. Local Area Design Statement (LADS). The Council will be aware that the Parkstone Delivery Office is situated within this proposed designation. It is important that my client is notified immediately should this property be considered suitable for alternative uses, as it may be necessary to identify alternative premises to continue the business functions currently undertaken at the property. It is considered that policy generally accords with national policy in the form of PPS1 and the current urban design approaches such as By Design, Manual for Streets, Building for Life, The Code for Sustainable Homes, Lifetime Homes and Secure by Design. My client would wish to be involved in the preparation of a Local Area Design Statement which may have the potential to impact on Royal Mail operations in the area. Question 9: Policy SSA 2 – Bournemouth and Poole College Playing Field, North Road Representation ID 12: Mrs. Karen Dredge 1. The land is very poorly drained and has caused problems within the last 12 months, therefore any usage must support Noted. a robust and adequate ongoing drainage management system. 2. Whilst there are open public spaces at Constitution Hill Viewpoint and Parkstone Heights Playing Fields, there is nothing specifically for Special Needs. An area which can be enjoyed by children and adults with special needs without

31 the trauma of being confronted by dogs, skate boards, bikes, etc. An opportunity to have a community garden for special Needs would improve the lives of so many within our community. 3. However you develop this proposed public open space you will need to consider the safety, protection, privacy and concerns of those residents whose houses back directly onto the playing field and have done so since the early 1960s. The boundaries should prevent the opportunity for the public to access "short cuts" through residents gardens as Cotes Avenue is a Cul-de-sac. Also, parking must be considered to prevent the top of Cotes Avenue becoming a "car park" and preventing residents from accessing/using their own road. Representation ID 20: Mr Richard Stewart Excellent idea as Poole is becoming extremely overdeveloped and very short of public open space. Linking the playing Noted. field site into the existing Constitution Hill and Ringwood Road open space area is beneficial to all. Issues that will have to be looked into are fly tipping which happens fairly regularly in the Cotes Avenue area both on the council owned Constitution Hill area and the playing field boundary to the left. Many of the residents in the surrounding areas are willing to help in the consultation process and possibly help maintain the area. The wildlife within this site is abundant with natural flora and fauna and is also of educational interest to local schools. Historically the playing field has been in existence since the 1880s when it became a disused clay working for the Branksome Pottery. Open grass area with natural habitat to support its wealth of natural wildlife. Representation ID 25: Mrs Nicola Brunt, Urban & East Dorset Living Landscapes Manager, Dorset Wildlife Trust DWT welcome the proposals to enhance biodiversity on this site. Noted. Representation ID 42: Mr S I Martin Yes. Noted. Representation ID 60: Mr Harry Alexander, Open Spaces Society It is very commendable that two new pedestrian access points are to be implemented, however, these need to be placed Noted. on the definitive map as Public Rights of Way. Proposals to open all routes to cyclists as listed in this report would cause major issues; particularly as cyclists at present are unregistered and uninsured, also barred from footpaths. 2. Active Travel routes This needs to be tempered with better enforcement, since speed cyclists and commuter cyclists presently cause a big problem for pedestrians. There is too great an emphasis on utilising the coastal strip as a replacement for green areas within the urban environment. The coasts and harbours need to be seen as one aspect in the overall growth and infrastructure of Green Space not as an alternative to Councils providing more green space and areas of recreation particularly with so many regeneration areas planned in both Poole & Bournemouth. Representation ID 84: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group We support Policies SSA 1 & 2 and welcome the proposed creation of public open space. Noted. Representation ID 111:

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Meghann Downing, Highways Agency Yes. Noted. Representation ID 170: Mr Nick Squirrell, Natural England Yes. Natural England notes and supports the general comment made regarding the limited opportunities for providing Noted. additional public open space in paragraph 2.40. It is critical to plan for the delivery of multifunctional open space within the Borough, and to provide a context for open space that may help address the issues surrounding housing development and recreational pressures on designated heathlands. Natural England supports the recognition that this site has value as continuing open space, possibly in conjunction with alternative uses, including wildlife habitats. Representation ID 201: Mr Renny Henderson, Conservation Officer, RSPB South West Region Yes. We note and support the general comment made regarding the limited opportunities for providing additional public Noted. open space in paragraph 2.40. It is critical to plan for the delivery of multifunctional open space within the Borough, and to provide a context for open space that may help address the issues surrounding housing development and recreational pressures on designated heathlands. We support the recognition that this site has value as continuing open space, possibly in conjunction with alternative uses, including wildlife habitats. Representation ID 201: Mr Christopher Allenby, Poole Old Town Conservation Group We do feel that the Policy SSA 2: Bournemouth and Poole College Playing Field, North Road meets the PPS12 tests of Noted. soundness. We would strongly support the protection of green space. Question 10: Policy DM 5 – Tourism and the Evening Economy Representation ID 5: Mr Mark Howell The policy is unsound to the extent that it states that evening activity will increase safety. Evidence shows that the area is The issue about creating a balanced night time economy. All evidence safe in the daytime and early evening already but becomes more dangerous when more late night bars open. Excessive suggests that where you have a balance of uses and activity crime numbers of bars also deter families from enjoying the area. reduces. Representation ID 15: Mr Peter Tanner, Tanner & Tilley, on behalf of Pennyfarthing Homes Whilst we support the aim of Policy DM 5 to protect against the loss of tourism accommodation that contributes to the Agree that this could be included within the policy as it articulates how tourist economy of the Borough, we consider that the loss of hotels for redevelopment to other uses should be allowed applications are dealt with by the Council. where they are no longer financially viable and which, due to its location or quality, either individually or cumulatively, would not harm Poole‟s tourism economy. Therefore, we suggest that under the sub-heading of "Hotels" the wording of Policy DM 5 be changed to - "...Proposals that would result in the loss of hotels will be resisted unless:- iv)It is clearly demonstrated that such a use is no longer financially viable; and It can be demonstrated that the loss of such accommodation due to its location or quality, either individually or cumulatively, would not reduce the stock of such accommodation to a point where it would harm Poole‟s tourism offer. Representation ID 21: Mr Peter Tanner, Tanner & Tilley, on behalf of Pennyfarthing Homes

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The office building and associated car park immediately adjacent to the north side of Compton Acres, Canford Cliffs Road This option has not been developed through the plan and has not been is designated as a tourism area on the Proposals Map in terms of Policy DM 5. The site has the benefit of a current subject to Sustainability Appraisal therefore it is not possible to planning permission for redevelopment of the offices and associated car park with an hotel. We consider that this site promote an alternative use. could alternatively be developed as a care home or for housing. A care home or housing would be compatible with the neighbouring garden attraction and would not detract from the tourism use of that neighbouring site. A care home development or housing on this site would also be compatible with the surrounding residential area and is well located in close proximity to the local shops and services in nearby Haven Road. We suggest that the north part of the Compton Acres site comprising the office block and associated parking area be designated for housing or a care home development. Representation ID 26: Mrs Nicola Brunt, Urban & East Dorset Living Landscapes Manager, Dorset Wildlife Trust Land at Rockley Park includes a Site of Nature Conservation Interest with protected species. We consider that the SNCI Noted. should be safeguarded and development should have regard to the presence of protected species in this area. Representation ID 69: Ms Rose Freeman, The Theatres Trust Sound: Noted. We note that para.3.8 acknowledges Poole‟s Cultural Quarter (the c of cultural should be capitalised) and The Lighthouse Para. 3.8 – „c‟ of cultural capitalised. venue. The policy also now includes cultural facilities for The Quay. Cultural activity brings economic benefits by providing employment and generating revenue. It attracts people and businesses, inward investment, job creation and supports the visitor economy. Creative industries are the UK‟s fastest growth sector, generating significant revenue and employing hundreds and thousands of people. Activities at museums, libraries and archives generate substantial income and investment and support the tourism and employment economy. Representation ID 85: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group We support Policy DM 5, but it is UNSOUND because we are very concerned that there must be full public consultation The consideration of development proposals is not a soundness issue before any Tourist Attractions or commercial developments such as the Football Stadium or the Solar Pyramid are for the development of policy. Policy is developed to create a considered on public open spaces. We do not want any more large drinking establishments on the Quay, where numbers framework for development proposals to be assessed. are not controlled and are dead frontages for much of the day, contributing little to the Quay. We are glad to see that para. CIL is based on the broad viability of development and development 4.3 recognises that there needs to be a degree of flexibility in the implementation of certain development/regeneration will operate within this framework once it is introduced. sites. The Policy is UNSOUND since it must state that it may be necessary to delay development to ensure an adequate Policies CA1-8 of the Local Plan First Alteration have been available CIL payment is made to fund affordable housing and infrastructure. on the Council‟s website since adoption of the Plan in 2004. Para. 4.5 : please can recommendations from CABE and English Heritage be published on the web and highlighted in the Alternatively copies of the Plan have been available to purchase or email planning Newsletter. Policies CA1- 8 must be published on the web and highlighted in the Planning Newsletter as viewed in any of the Borough‟s libraries. we never seem to hear of them. Representation ID 112: Meghann Downing, Highways Agency No. The policy makes specific reference to support for new hotel accommodation „accessible locations such as […..] sites Comment noted. Policy wording amended by deleting reference to adjacent to junctions on the Strategic Highway Network‟. „Strategic Highway Network„ replacing with „local highway network‟.

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The Agency follows guidance as set out in DfT Circular 02/07 „Planning and the Strategic Road network‟, and also outlined in the MOU. Where a proposed application is likely to have an impact upon the SRN, the Agency will work with the applicant and the local planning authority to identify mitigation measures. In the case of an application for a new hotel close to a junction of the SRN, especially given that the A31 already experiences significant congestion issues, it is the Agency‟s view that this is unlikely to be a sustainable option and that it would be difficult to identify any mitigation to ensure no detriment to the SRN. Therefore we would like to see the reference to sites adjacent to junctions on the Strategic Highway Network removed. Representation ID 171: Mr Nick Squirrell, Natural England No. Tourism is not always benign, as is inferred by the text in paragraphs 3.1 - 3.4. Tourism can have negative effects on Changes are able to be made to the text to clarify status of nature communities and wildlife. We would suggest the inclusion within Policy DM5 of text identifying the potential environmental conservation designations. cost of tourism and suggesting appropriate environmental safeguards. Reference should be made under Rockley Park to Ham Common SSSI, SPA, SAC and Ramsar, not just SSSI. Representation ID 202: Mr Renny Henderson, Conservation Officer, RSPB South West Region No. Tourism is not always benign, as is inferred by the text in paragraphs 3.1 - 3.4. Tourism can have negative effects on See ID171 above. communities and wildlife. We would suggest the inclusion within Policy DM 5 of text identifying the potential environmental cost of tourism and suggesting appropriate environmental safeguards. Representation ID 187: Margaret Baddeley, Senior Associate Director, Nathaniel Lichfield & Partners on behalf of Bourne Leisure Ltd. Bourne Leisure welcomes the overall approach taken in the opening part of draft Policy DM 5, stating that development It is considered that the existing wording is sufficiently positive and that supports growth and generates employment opportunities in Poole‟s tourism sector will be encouraged. The appropriately addresses the key issues for any development at Company in particular notes and endorses the allocation of Rockley Park as a tourist attraction in the Policy. Rockley park. Specifically on tourism, draft policy DM 5 provides a criterion-based policy approach for the consideration of development proposals seeking to redevelop or upgrade existing facilities at identified tourist attractions, including Rockley Park, subject to environmental, visual and strategic objectives being safeguarded. In response to Question 10 however, Bourne Leisure considers that drat Policy DM 5 is unsound, as the proposed criteria for development at Rockley Park present an overly onerous policy approach that does not attach sufficient weight to the vitally important economic role of the Park currently, and its potentially much enhanced economic role in future, as a result of redevelopment, or the upgrading its existing facilities. As it stands, draft Policy DM 5 potentially does not provide sufficient flexibility for Bourne Leisure to respond to the changing needs, demands and priorities of visitors, as reflected in the current thrust of Government policy (Government Tourism Policy, March 2011) i.e. to create the right environment in which the domestic tourism sector can flourish. The failure to have in-built flexibility in the pre-submission consultation DPD means that the draft Policy is not „effective‟. Bourne Leisure considers that draft Policy DM 5 should be amended to take a more comprehensively balanced approach to redevelopment and upgrading at Rockley Park; the revised Policy should promote appropriate development at Rockley Park that benefits the local economy, balanced with environmental considerations. As stated above in the context of revisions to draft Policy DM 4, this balanced approach is appropriate even in more sensitive areas, provided that commensurate mitigation measures (such as the inclusion of a buffer zone and appropriate landscaping) can be

35 implemented to mitigate both direct and indirect impacts. Each proposed tourism development should therefore be considered on its own merits and with specific reference to economic and social benefits, as well as environmental considerations. Bourne Leisure therefore considers that the section on Rockley Park in draft Policy DM5 should be amended to read: “…Rockley Park - Redevelopment, upgrading and expansion of tourism accommodation and facilities:- Development proposals seeking to redevelop, upgrade and expand existing accommodation and facilities, including proposals for the Point, will be considered on their individual merits, with specific reference to economic and environmental considerations…” Representation ID 228: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy DM5: Tourism and the Evening Economy meets the PPS12 tests of soundness. We want to The section entitled „Tourist Attractions‟ in proposed Policy DM 5 at see more tourist uses on the Quay for family entertainment. We do not want any more large drinking establishments, sub-section iii – The Quay, adopts a positive stance in relation to where numbers are not controlled and are dead frontage for much of the day, contributing little to the quay etc. We would development that “contributes to a greater diversity of family centred suggest that this policy is amended to restrict the floorspace and amount of standing room in new bars and/or limit the attractions or cultural facilities.” expansion of the night-time economy on Poole Quay generally. We would suggest that the policy refers to the need to The „Evening Economy‟ section of Policy DM 5 at criterion ii, points to take account of residential amenities i.e. Impact on late night noise and activity as a result of more drinking the need to consult with Environmental & Consumer Protection establishments. The evidence: Has there been an increase in anti-social behaviour on the Quay that is evidenced, by the Services (E&CPS) on proposals requiring an alcohol licence. E&CPS Police? If so this information should be in the public domain. are the responsible authority for issuing such licences. The proposed Policy DM 1: Design, references aspects of „amenity‟ at criterion iv dealing with environmental nuisance such as noise, vibration etc. Representation ID 228: Mr Nigel Pugsley, Senior Planning Consultant, BNP Paribas Real Estate on behalf of Royal Mail and Parcelforce. Draft policy encourages the location of hotel development within „accessible locations such as Poole town centre‟. It is Noted. considered that the „town-centre first‟ approach regarding the location of „town-centre‟, uses accords with national planning policy contained within PPS4. Representation ID 274: Mr Bill Constance on behalf of Vision for Poole Group , Vision for Poole Group. This policy fails to meet the tests of soundness as it excludes Use Classes B1, B2 or B8 and gives priority to Tourism and Core Strategy policies PCS 1, PCS 2 and PCS 4 provide the policy the Evening Economy. It is essential that this policy reflects the need to maintain and enhance employment opportunities framework within which „B‟ Use Class development and employment is for those not in tourism and evening economy and fully reflects Core Strategy Policies PCS1-PCS4. delivered. Proposed Policy DM 5 deals specifically with tourism related issues and development and is considered to be complementary to the traditional „B‟ class employment policies, in that it acknowledges that tourism generates significant levels of employment in what is an important sector of Poole‟s economy. Question 11: Policy SSA 3 – Fleets Corner and Sopers Lane Representation ID 2:

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Mr John Sprackling, Branksome Park, Canford Cliffs & District Residents Association. The ownership of the Sopers Lane site is shown as...."Metnor (Sopers Lane) Ltd own the former Poole Pottery land at the This does not address an issue of soundness. western end of the site extending to approximately 0.94 hectares in area, with the remainder owner by Bridgehouse Capital" but 2.3 of the Statement of Common Ground presented at the Public Inquiry in April 2011 in connection with the Poole Pottery site says that land owner is BRIDGE PROPERTIES. BRIDGE PROPERTIES INVESTMENTS LIMITED is incorporated in the British Virgin Islands. A Land Registry entry dated 20/09/06 showed its address as "Care of Bridgehouse Partners, 2nd Floor, Albemarle House, Albemarle Street, London W1S 4HA", which was the Registered Office of Orb Estates Ltd. Representation ID 39: Mr Martin S I No it needs changing. Two sites: western half of the former Plessey factory (where I used to work). Considering that the A Care Home has been allowed on the Sopers Lane site, following site is bounded to the north and the west by housing, I fail to see why a care home cannot be allowed, given the pressing decision of PINS subsequent to a Public Inquiry appeal. need for such places (due to the dementia epidemic). Representation ID 53: Mr Simon Hawley, Harris Lamb Proprty Consultancy, on behalf of Bridgehouse Capital. Harris Lamb is instructed to submit representations to the Pre-Submission Consultation version of this document on Noted. See answer to Rep 39 above. behalf of our clients, Bridgehouse Capital. My clients own a significant area of land at Sopers Lane. The attached plan shows the extent of their land ownership (in blue). We have previously submitted representations to the Poole Core Strategy and attended the Examination in Public promoting the development of the Sopers Lane site for a mixed use led employment development. We have also submitted representations to earlier consultation version of the Site Specific Allocations DPD. These representations build upon our submissions to the Core Strategy providing additional detail on the mix of uses we believe should be allocated to the site by the Land Allocations DPD. The adopted Core Strategy allocates the Sopers Lane for a broad range of employment generating uses. We fully support the allocation for the Sopers Lane site set out in the Core Strategy. The pre-submission consultation version of the Site Specific Allocations DPD does not however accurately reflect the requirements of the Core Strategy for Sopers Lane. As such it is our opinion that the Site Specific Allocations and Development Management Policies DPD should be amended. These representations demonstrate that the Core Strategy allocation of the site is not correctly reflected in the Site Specific Allocations' and Management Policies DPD, and provide guidance on how the document can be amended so that it is in general conformity with the Core Strategy, and can therefore be considered sound. Site Description The site is a sustainable brownfield site within the urban area of Poole. The site comprises a number of small buildings and areas of open land. Until relatively recently there was a large industrial building on the site, however, this has been demolished as it has not been possible to find an occupier. The smaller buildings on site are leased to Siemens, who own and occupy the land immediately to the east of the Bridgehouse Capital site. If Siemens do not renew their lease' when it expires this will leave the Bridgehouse site entirely vacant. The northern boundary of the site is formed by Sopers Lane. Whilst the land to the south of Sopers Lane is, or was last, in employment use, the land to the north of Sopers Lane is residential in nature. The land to the north of the site is a relatively low density housing estate. The land to the west of the site is owned by

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Metnor Group. This site is currently vacant. An application for the development of a care home on this site was refused by the Council in November 2010. This decision was appealed and an appeal held in April 2011. If the appeal is successful the site will adjoin a three storey care home. Beyond the care home is York Road to the east of which are a number of residential properties. The southern boundary of the site if formed by Broadstone Way. To the south of Broadstone Way are a number of large industrial units, and the south west a housing development. The eastern boundary of the site adjoins land occupied by Siemens, a Barclays data centre, a hotel and a school. This area of land is accesses from Technology Road as well as Sopers Lane. Suitability of the Site for Employment Purposes The Bridgehouse Capital site has been available and marketed for employment purposes for in excess of four years. The site has been marketed for B use class purposes by a local agent, Goadsbys. Despite a significant marketing campaign it has not been possible to find an occupier or developer. We have been advised by the marketing agent that one of the principal reasons why there has been no interest in the site is access. The only access into the site is from Sopers Lane. We have been advised by the Council that it is not possible for a new access onto the site to be created from Broadstone Way. Even if it were possible, the development cost of a new access would threaten the commercial viability of an employment allocation. As such, it is not possible for the access issue to be resolved. In addition, the use of the site must be compatible with the immediately adjoining residential areas. As such, there is a restriction on the amount of noise that the site can generate. Consequently, the employment uses that could potentially come forward on site are greatly restricted. Given that no credible interest has been expressed in the site to date for B class employment uses we do not envisage that the site will come forward for a development of this nature. As such, it is necessary to explore alternative uses on the site that are considered appropriate forms of development in the context of the adopted Poole Core Strategy. Poole Core Strategy The Poole Core Strategy was adopted in February 2009. It contains specific advice on the development of the Sopers Lane employment site, as summarised below. Policy PCS1 - Principal Locations for Economic Development, allocates land at Sopers Lane for the development that consists of development that forms 'Priority Sectors identified in the Regional Economic Strategy for the South West England 2006-2015, and other employment generating sectors'. There is no reference in Policy PCS1 to Sopers Lane been reserved for B use class employment generating activities. Footnote 1 to Policy PCS1 summarise the range of uses identified as Priority Sectors by the RES. This is not, however, a comprehensive list, and a review of the RES confirms that there are additional RES priority sectors. Footnote 2 cross refers to the Policy to Policy PCS2 - Existing Employment Areas. Policy PCS2 is a catch all employment policies that applies to all of Poole's existing employment areas. Helpfully, however, it includes specific guidance on development at Sopers Lane in its accompany test. Paragraph 6.15 states categorically that whilst the site has potential to deliver employment opportunities in relation to the priority sectors identified by the RES, the site also offers opportunities for 'job creation in other employment generating sectors such as health and education.' The Core Strategy makes it quite clear that a wide range of employment generating uses are appropriate on the Sopers Lane employment site. Site Allocations and Development Management Policies DPD

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Policy SSA3 of the Site Specific Allocations DPP provides guidance on development at Sopers Lane. It fails, however, to accurately reflect the range of uses envisaged for the site by the Core Strategy. The policy should specifically state the forms of development that are considered suitable at Sopers Lane. As such, the policy should state clearly that the Council will support planning applications for the following range of uses at Sopers Lane:- Development related to the Regional Economic Strategy Priority Sectors identified in Table 5 of the Regional Economic Strategy. Health related development including care homes (the Economy of Poole document produced by the Council confirms that care home are considered health related developments). Education related development. Other employment generating uses. The inclusion of the above test within the Site Specific Allocations and Policies DPD would ensure that the document is considered sound, and in conformity with the Core Strategy. I trust that you have the above comments useful. We would be grateful if you could continue to keep us informed of the progress of the Land Allocations DPD. Representation ID 113: Meghann Downing, Highways Agency. Yes. The Agency acknowledges the specific reference to the efficient operation of the SRN. Noted. Representation ID 154: RPS Planning on behalf of Costco Wholesale UK Ltd. It is essential that the Site Specific Allocations and Development Management Policies DPD supports the widest range of Core Strategy policies PCS 1 and PCS 2 provide the policy framework employment uses. This approach is advocated by PPS4 (2009), EC2.1 (h) which states that Local Planning Authorities for the consideration of development proposals within Poole‟s „Existing should ensure that the development plan identifies a range of sites to facilitate a broad range of economic development. Employment Areas‟. Policy EC2.1 (b) of PPS4 also states that: Core Strategy policy PCS 1 identifies land at Fleets Corner and Sopers “Policies should be flexible enough to accommodate sectors not anticipated in the plan and allow a quick Lane as suitable for comprehensive rationalisation/redevelopment to response to changes in economic circumstances.” deliver employment opportunities in relation to the priority sectors Therefore, it is considered that a paragraph should be included within Policy SSA 3 „Fleets Corner and Sopers Lane‟ to identified in the Regional Economic Strategy. recognise that sui generis uses may be an appropriate use for employment land. Indeed, the Core Strategy recognises at These have been further refined in supporting text to Policy SSA 3 Paragraph 6.17, that Fleets Corner could offer opportunities for job creation in other employment generating sectors. Core Strategy policy PCS 2 sets out the criteria against which new As a sui generis use that is primarily B8, Costco has been found to be an appropriate use for employment allocated land development will be considered. for the following reasons: The employment density is comparable to if not better than other B Class Uses which are appropriate on the highest graded employment land. A typical Costco directly employs 160-250 people. The employment generating characteristics of Costco were considered by the Inspector at the Chester Inquiry (Appendix 1, Para 10.4.1) who stated that: “A typical B8 warehouse might employ around 150 people but a typical Costco employs approximately 170 people on opening rising to around 250 within 3-5 years. Around 50% of the jobs are full time and even part time jobs offer a minimum of 25 hours per week. This is the equivalent to 145 FTE at opening and 212 after a few years. Costco pays higher wages than the retail sector and warehousing/industrial sectors and around 90% of jobs are filled by locally recruited employees.”

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Appendix 2 contains a copy of the Costco Employment Opportunities Report May 2011. Appendix 1 and 2 Indirect employment benefits are created through local businesses having a cheaper source of supply, and businesses increasing trade as a consequence of supplying goods and services to Costco; and from the construction and subsequent maintenance of the warehouse. Most inventory needs can be obtained under one roof. Costco sells a very wide range of food and non-food goods, however there is a very limited selection within any one product range. Competitive pricing enables Costco members to compete more effectively with national multiples. Costco Wholesale supports and nurtures small businesses that may not otherwise survive in a competitive economy. This has significant employment benefits and adds to the vitality and viability of town and local centres (where many small businesses are generally located) and to the profitability of the whole range of businesses who typically join Costco Wholesale as members. Proposed Amendment For clarity, Policy SSA 3 „Fleets Corner and Sopers Lane‟ should include a paragraph which states that; „Sui generis uses which generate employment which is quantitatively and qualitatively comparable to traditional B class employment uses may be acceptable at Fleets Corner. Applications for such uses will be considered on their merits in accordance with relevant core strategy employment policies.‟ The sui generis uses referred to above are uses that are commonly found in industrial estates and are an established and accepted use of employment allocated land. They each generate employment, often at greater levels than B1, B2 and B8 uses and have characteristics that make them comparable to these uses. Sui generis uses are an important part of the economy. Representation ID 229: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 3: Fleets Corner and Sopers Lane meets the PPS12 tests of soundness. This area is Noted. designated as an employment area. Question 12: Policy SSA 4 – Crown Closures Ltd., Lake Road Representation ID 114: Meghann Downing, Highways Agency Yes. However the Agency would highlight the MOU, and point out that any applications at this site are likely to meet the Noted. criteria for a „major planning application‟, in which case the Agency will need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 268 Mrs Ann Smeaton, Hamside Residents Association Policy SSA 4: Crown Closures Ltd., Lake Road We do not feel that the Policy SSA 4: Policy SSA 4: Crown Closures Ltd., The current site owners have expressed an intention to relocate to a Lake Road meets the PPS12 tests of soundness. Such a change of use does not have the support of the Hamside site (within Poole) better suited to their needs. Residents Association. There has been a factory on this land for over one hundred years. During this period no resident The policy for this site has been developed to reflect the sequential has ever complained about the usage of the site. Therefore, at this time when walking or cycling to work is being approach to the development of „Isolated Employment Sites‟ set out in encouraged in order to create a greener environment, it seems incongruous that consideration should be given to Core Strategy policy PCS 4, should the current premises prove no establishing a housing development on an historic industrial site that will necessitate an increase in car usage. longer suitable or viable for continued employment use.

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Representation ID 230: Mr Christopher Allenby, Poole Old Town Conservation Group We do feel that the Policy SSA 4: Crown Closures Ltd., Lake Road, meets the PPS12 tests of soundness. We would Noted. support a residential development in accordance with The Core strategy policy PCS 4 a density between 80 and 140 units for the site would be a contribution towards the 4000 new dwelling units proposed in the borough by 2026. Question 13: Policy SSA 5 – Land at Sembcorp Bournemouth Water Ltd., Water Treatment Works, Francis Avenue Representation ID 11: Mr Mark Thackery, Principal Consultant, Walsingham Planning. The site is on the edge of the settlement, accessed by what is effectively a long cul-de-sac and poorly accessed by public The site at Francis Avenue, promoted by the site owners for allocation, transport. It has no valid planning history, having last been officially used as a sports and recreation facility and, more lies within an urban setting and within the boundary of an extensive recently and without a specific consent, for open storage. It's lawful use ought therefore to be considered as private open water treatment works complex located on the southern side of Francis space, and, as such, there should be no presumption in favour of its development and no assumption of any current land Avenue. The site is in a sustainable location, being just over 400 value beyond that which might be associated with a recreational use. As such, the suggestion that it might be metres distant from the A348 Ringwood Road, part of the main appropriately allocated for industrial use is ill-founded, all the more so as it would then be considered an isolated highway network and a high frequency public transport route. employment site, which is, by definition, unsustainable. The site would not appear to be needed for industrial use in the Allocation of the site for employment uses would add to the range and event that Sopers Lane and Fleets Corner, along with established industrial areas, are brought forward to meet the choices of available sites for development and although there is no anticipated shortfall of about 21 hectares over the LDF period. The possible alternative use, as a medical/health facility, is specific identified health related need, there has been long term not justified. In the same context as an industrial development, such a use would be isolated and contrary to Core interest from a health related use in this site. Strategy policy PCS4. The possible allocation of the site for such a use has not been established through research into There is a security issue around the need to protect supplies of treated the need for additional health facilities in the sub-region. Although not a main town centre use, in the context of PPS4, the water. The maintenance of site security at the treatment works is possible allocation of land for this use should first be established through an identified need. The Core Strategy therefore a prime consideration and precludes the development of recognises the need for quality healthcare facilities and supports Bournemouth and Poole PCT in providing them, but certain uses that adjoin supply sites including those that allow access those facilities (para.3.47) are identified as being the expansion of existing facilities and/or town centre facilities, and these to the general public. aims would not be met by the provision of major healthcare facilities on site SSA5. Such facilities should be small-scale, easily accessible and on a community level. Larger scale facilities are provided at Poole Hospital, where provision is made for an extension by "saved" local plan policy CF3, until such time as a specific site allocation supersedes it, and there are currently two private healthcare facilities within a 2-3 mile distance from the site. The Joint Strategic Needs Assessment report for 2010-2015 makes no recommendation as to the need for a new facility that might require a site of 1.46 hectares, nor does it identify this part of the borough as being one of deprivation or a Public Health Action Area. Until such time as a definitive need has been established, it would be inappropriate to allocate a previously undeveloped site for healthcare facilities, when there is no proven need, or for industrial use, when the site is recognised as being isolated and when sufficient and sequentially preferable land is available elsewhere. The site has no lawful use, and there should be no presumption in favour of its development. As a former recreational site, its value and position on the fringe of the borough, close to open land, should be recognised. The allocation for industrial use and for healthcare facilities should not be pursued, and the site should instead be identified as having either an open recreational use or potential for a built recreational facility, which would far better fulfil the health care objectives set out in para. 3.46 of the Core Strategy. Any potential for a built recreational facility should be dependent upon improved access and public transport accessibility. Representation ID 27:

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Mrs Nicola Brunt, Urban & East Dorset Living Landscapes Manager, Dorset Wildlife Trust. DWT welcomes the protection given to the Site of Nature Conservation on this site, alongside the need to avoid any direct Noted. or indirect adverse effects on the nearby Dorset Heaths internationally designated habitat. Representation ID 51: Mr Peter Atfield, Goadsby, on behalf of Sembcorp Bournemouth Water Ltd. Location Supporting text amended to reflect presence of industrial use at the The text that precedes Policy SSA 5 includes a description of the location of the site. Reference is made to the northern eastern end of Francis Avenue and the break in vegetation resulting side of Francis Avenue being predominantly residential. It is submitted that this text is amended to reflect the fact that a from the construction of a new access into the Waterworks site. part of the northern side is in industrial use. In this respect, please refer to the photographs reproduced in Appendix 1. The impact of development on residential amenity to properties in These show the series of factory units that are situated on the north side of Francis Avenue, close to the junction with Francis Avenue was identified as an issue. Criterion ii of policy SSA 5 Ringwood Road and Wallisdown Road. The area is predominantly mixed in character. The text should therefore be is therefore retained but amended by deleting first word „preserve‟ and amended to read: "The area is mixed in character, with the Sembcorp Bournemouth Water Ltd. site running the entire replacing with „have regard to‟. length of Francis Avenue on its southern side. "In addition, the text describing the site location should be amended to reflect the fact that a new access has been constructed to Francis Avenue. This now segregates the site to allow visitors direct access to the Sembcorp Bournemouth Water offices without passing through other operational land. This has resulted in the removal of some landscaping to the Francis Avenue frontage. The approved plan, and photographs, are reproduced within Appendix 2 to this letter. The text of the last sentence of the paragraph dealing with the location of the site should therefore be amended to read: It...... although some of it is screened by mature trees and shrubs along a part of this boundary. "Policy SSA 5 In accordance with the preceding representations, it is submitted that Criterion ii of Policy SSA 5 should be deleted. Whilst protecting the amenities for the occupiers of the residential properties on the north side of Francis Avenue is a material consideration, it can form a part of the normal process of evaluation at the development control stage. There is no need for it to be a policy pre-requisite. . Question 13 Generally, Policy SSA 5 can be supported. However, Sembcorp Bournemouth Water Ltd. request the changes as described earlier in this letter in order to achieve a policy that will provide a suitable framework within which to determine a future application for planning permission. This will assist in achieving the delivery timetable set out on Page 137 of the DPD. Representation ID 77: Ms Angela Best. Re Land at Sembcorp Bournemouth Water Ltd, Water Treatment Works, Francis Ave As I work for DCC in Christchurch, I Comments noted. have not had a chance to attend the Civic Centre to view any information/plans that you have regarding the above item. The proposed policy seeks to deliver the development aspirations of As residents of Francis Avenue, yet again we are having to consider that our quiet, peaceful lives, are going to be the site owner, whilst acknowledging the concerns of local residents in wrecked by whatever is going on opposite our home. It is interesting that Sembcorp managed to 'pop in' a grand new relation to impacts in regard to residential character and amenity and entrance without our prior knowledge, so no doubt whatever anyone says, things will go ahead. I just hope that you are the effects of increased traffic generated by development through the not considering yet another new entrance to whatever facility you have undoubtedly already given approval to. The inclusion of relevant criteria. comings and goings in this road have increased since we moved here in 2000, but how does one cope with all the disturbances of goodness knows what heavy plant when the building starts. Please consider the residents, as this is a residential area, bordering on a protected area of heath and popular golf course. It beggars belief that you cannot leave these oh too few areas alone. I do not find plans to change this area sound, justified or effective. I do not know how this intrusion into residents (of retirement age ourselves), can be beneficial or how it is going towards nurturing economic

42 prosperity! We do not need more traffic, which will have an adverse impact on the roundabout at the end of the road, which is already a nightmare at times. I feel impotent to say or do any more! It would just be nice for our poor little road to be left alone! Representation ID 115: Meghann Downing, Highways Agency. Yes. As above, the Agency would highlight the MOU, and point out that any applications at this site are likely to meet the Noted. criteria for a „major planning application‟, in which case the Agency will need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 174: Mr Nick Squirrell, Natural England. Natural England supports point 1 of the policy but advises that the policy should include the consideration of the provision The site area quoted in the representation is incorrect – site area is of land designed as a SANG. This location and size of allocation (5.13ha) mean that the careful design and landscaping of 1.46ha. the site could effectively intercept some of the adverse effects arising from recreational pressure on Canford Heath. There is a security issue around the need to protect supplies of treated Natural England does not consider that the policy is justified and effective. water. The maintenance of site security at the water treatment works is therefore a prime consideration and precludes the development of certain uses that adjoin supply sites including those that allow access to the general public. Representation ID 115: Mr Richard Shaw, Director, Savills. Support the soundness of Policy SSA5. Noted. Policy recognises the potential of the site at Francis Avenue as a suitable location for development delivering employment opportunities which could include „a health/medical facility‟. The policy provides four further development management criteria to ensure the effectiveness of any such development, namely the relationship and effect of development on nearby habitats; the amenities of nearby residential properties; and traffic impacts, including a travel plan. The Council's approach to the allocation of the site is considered to be sound - on the basis that it is both justified and effective, whilst providing appropriate flexibility for any future development. PPS4 Planning for Sustainable Economic Growth recently broadened the definition of economic development to include development which achieves other objectives including providing employment opportunities, as well as more traditional economic sectors. The identification of the site as being suitable for healthcare and medical facilities is therefore particularly welcomed as part of a strategy for delivering employment opportunities. In addition to the economic development role of the healthcare sector, there is a more fundamental need for medical facilities, including specialist medical facilities to promote the health and well-being of the local community. Promoting health and well being is one of the council's key objectives in its corporate strategy "Striving for Excellence". The land at Francis Avenue can play an important role in the delivery of such facilities and in support of that objective. Representation ID 115: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 5: Land at Sembcorp Bournemouth Water Ltd., Water Treatment Works, Francis Avenue Noted. meets the PPS12 tests of soundness. We would support a health/medical facility, or Industrial units falling within Use Classes B1 and/or B8. Any development on this site must not result in any direct or indirect adverse effects upon the

43 integrity of the nearby designated Dorset Heaths International Habitat and locally important Site of Nature Conservation Interest. Question 14: Policy SSA 6 - Sterte Avenue West, Sterte Avenue Representation ID 6: Mr Mark Howell. This area would also be suitable for a park and ride. There is access to Holes Bay from this site so there is also potential LTP3 sets out the strategic approach to park and ride facilities and for park and boat. does not identify additional park and ride facilities over and above those specified in policy SSA21. Representation ID 61: Mr Harry Alexander, Open Spaces Society. 3.22 Sterte Public access with Public Rights of Way need to be reinstated…. The RSPB has made no representations in respect of this site. This should also be reviewed as a high area for conservation and bio diversity site. It already has a high number of The reference in Policy SSA 6 to encouraging walking and cycling migrating birds, with its water source and reed beds. It should not be developed for commercial use. RSPB needs to be relates to measures that would be implemented to promote such consulted regarding this site. activities by employees of new employment developments on the site It details that BoP are to 'encourage cyclists and walkers'. Therefore, this site needs to incorporate a Public Right of Way to contribute towards reducing trips made by private car. from Sterte to the harbour. At present there is a safe route parallel under the dual carriageway for all users, which the Borough could easily reinstate with some simple signage. It is highly dangerous for pedestrians, particularly small children to cross a dual carriage way to reach the harbour from Sterte. This needs to be incorporated as a Public Right of Way before there is an accident involving further significant loss of life. Representation ID 116: Meghann Downing, Highways Agency. Yes. As above, the Agency would highlight the MOU, and point out that any applications at this site are likely to meet the Noted. criteria for a „major planning application‟, in which case the Agency will need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 194: Mr Michael Holm, Planning Liaison Officer, Environment Agency. Providing that the Sequential Test (PPS25) has been undertaken for this allocation the policy would be sound. Although Sequential test completed. the policy refers to the wrong Core Strategy Policy, it should be PCS34. Policy number amended to read „PCS 34‟. Representation ID 232: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 6: Land at Sterte Avenue West, Sterte meets the PPS12 tests of soundness. This area is Noted. designated as an employment area. Question 15: Policy SSA 7 – The Regeneration Area – Urban Design Representation ID 7: Mr Mark Howell. The policy is extremely unsound. It does not seek to relate the new building to the existing areas surrounding it. It The Regeneration Area has been planned as an integral part of the assumes that the area will be a separate part of Poole once built which is not the case. Geographically, West Quay whole Town Centre with the criteria in Policy SSA7 clearly requiring relates to the Old Town and the remainder of the Regeneration Area to Hamworthy. West Quay development should be development proposals to have regard to their surrounding context.

44 integrated with and respect the existing historic infrastructure of the Old Town. On the Hamworthy side, development The SSA policies deal with the role of specific sites that will ultimately should be integrated with that planned for the Central Hamworthy sites to deliver a coherent entity. contribute to the overall objectives for the town centre and Borough as a whole. Representation ID 62: Mr Harry Alexander, Open Spaces Society. 4.5 Reference to the Flying Boat site at Pilkington's area of regeneration could possibly provide for the inclusion of Not a development plan issue. storyboards with reference also made to the inclusion of Public Rights of Way and Open Spaces for the local community living in this vicinity, to compensate for the loss of the listed building 'The Launch House'. Representation ID 86: Mr Terry Stewart, on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. 3. Policies SSA7 - 10 are UNSOUND as ineffective because they must be much more specific, spelling out numbers of Policies in this document do not need to repeat policies from the Core units, building heights, balance between residential, employment and other uses, etc. As the Proposal Map, there is a Strategy where the mix and quantum of uses is set out. The policies need to create local identity and legibility of development through a variety of building heights, which on the town centre proposed provide greater detail about the design issues that need to side requires development to relate to the human scale of existing development and relationship with the Old Town. On be considered. the quayside, buildings must be designed that relate to the water and ensure the quayside is well connected to the area behind with streets and alleys radiating from the water. The area must be designed so that public, semi-public and private space is clearly distinguishable and that spaces are designed to enable intra and inter-generational spaces and play. The spatial planning should provide for the greening of the town by way of tree planting along transport routes and the incorporation of a variety of open, soft and hard landscaped spaces. Reinforce the street as an integral component of the public realm and townscape with no road or street designed to accommodate speeds greater than 20 MPH. Representation ID 117: Meghann Downing, Highways Agency. Yes. Noted. Representation ID 151: Mr Roger Rippon, RDS Town Planning & Development Consultants, on behalf of Inland Developments plc. Chapter 4 Revitalising the Town Centre Policy SSA7 - the urban design criteria set out in this policy are sensible and Noted. supported. Representation ID 172: Mr Nick Squirrell, Natural England. No. The HRA for the Core Strategy highlighted the environmental sensitivities of developing Poole's town centre namely This can be addressed by adding some explanatory text and wording Poole Harbour SSSI, SPA and Ramsar. This is a significant issue and absent from the introductory text in paragraphs 4.1 to the policy. - 4.5. Recognition of the environmental context of development in the regeneration area is needed within this introduction. Paragraph (v) of Policy SSA7 is weak and needs rewording to include promotion of other multifunctional "in-scheme" biodiversity measures beyond tree planting and landscaping. Representation ID 203: Mr Renny Henderson, Conservation Officer, RSPB South West Region. No. The HRA for the Core Strategy highlighted the environmental sensitivities of developing Poole‟s town centre. This is a As response to NE above.

45 significant issue and absent from the introductory text in paragraphs 4.1 - 4.5. Recognition of the environmental context of development in the regeneration area is needed within this introduction. Paragraph (v) of Policy SSA 7 is weak and needs rewording to include promotion of other „in-scheme‟ biodiversity measures beyond tree planting and landscaping. Representation ID 211: Lindsay Thompson, Senior Planner, Terence O'Rourke Ltd., on behalf of Neptune Consultants Ltd. Policy SSA7 The Regeneration Area - Urban Design We consider that policy SSA7 of the DPD is not sound as it puts The additional design criteria originate from the original PBRI Planning forward further design aspirations for the regeneration sites that are already broadly covered by the Core Strategy and in and Urban Design Guidance SPG Volume 2 2004. It is considered more detail by the supporting design guidance such as the Poole Bridge Regeneration Initiative Planning and Urban helpful and offers greater clarity and certainty about the scale and form Design Guidance for the Central Area of Poole SPG (which is due to be update). This also makes policy SSA7 confusing of development yet does not unduly restrict the opportunity for creative as it adds another layer of tests to development. The confusion with several layers of policy will unduly restrict the delivery and innovative design. Policy should lead and should not defer to SPD of development. therefore the policy position should be prepared ahead of any SPD. Adopted Core Strategy policy PCS23 - Local Distinctiveness (part B) provides design guidance for the town centre and SPDs are there for the exemplification of policy and therefore it would water front location (regeneration sites) setting out key design requirements and the Poole Regeneration Initiative SPG not be appropriate to produce a revised SPD ahead of the policy. and Manual for Streets (Streetscapes, 2005) provides further site specific guidance. We therefore consider it to be unnecessary to provide further design aspirations in a new policy in the site allocations document as this will be confusing and could become conflicting. It is contrary to the key message of the Coalition government (that is to streamline the planning process in order to make it more efficient and effective) by over complicate the policy context for the regeneration sites with this additional layer of policy requirements. If the Borough of Poole decided to keep the policy, the submission of the site allocations DPD should be delayed to follow the consultation on the SPG and master plan refresh which the Borough intend to conduct to update the SPG to SPD. It would be confusing to have several layers of policy and guidance that do not reflect each other and there is a clear danger of this happening if this policy progresses ahead of the refresh of the SPG. If anything the design refresh of the SPG into an SPD should come first to guide and provide a sound evidence base for the policies contained within the DPD. It is important that this policy is considered in the round with consultation on the refresh of the SPG to allow the DPD to set a positive framework for the regeneration, that provides a proactive framework that is based on up-to-date information and sound financial understanding. The presumption should be in favour of sustainable development and offer positive guidance rather than used as a restrictive tool to dictate design detail. Representation ID 161: Richard Shaw, Director, Savills, on behalf of Gallagher Estates Ltd & Land Improvement Holdings Ltd. According to the introductory text in the consultation document, this document updates „…..those aspects of Poole Local Welcome the support of the policy. Whilst it may be possible to Plan First Alteration policies CA3 - 8 needing to be brought within the Local Development Framework‟. Policy CA8 relates combine policies it is considered that the current layout offers greater to the former Power Station, Oil Depot and land east of Rigler Road. clarity about the aspects of design required for the Regeneration Area The relationship between the emerging LDF (including existing Core Strategy and current consultation DPD) and the 2004 as a whole and those of individual sites. Supplementary Planning Guidance („The Poole Bridge Regeneration Initiative: Planning and Urban Design Guidance for the Central Area of Poole‟) is an important issue. The Inspector‟s Core Strategy report addressed the status of the SPG and also the need for flexibility in its interpretation. Para 4.69 of the Inspector‟s report stated at 4.69: The Council suggests that the Masterplan and its requirements are illustrative of what the Council wishes to achieve here and that negotiations, which will consider issues of viability, will determine what can be provided in practice. In turn, the danger expressed by the developers is that without a clear vision

46 and clear priorities the dated Masterplan would provide the decision makers with reasons to refuse planning permission. In my view the Core Strategy needs to set out its requirements as clearly as possible, to provide a degree of certainty, in the absence of any up-to-date alternative vehicle for this. Without this, this key element of the Core Strategy could fail to deliver the vision of the plan. The current consultation document highlights that the 2004 SPG is being „refreshed‟ - that an assessment of the guidance has been undertaken by CABE and English Heritage and that „the findings of the assessment are that the principles and aspirations of the original work are sound and provide a solid foundation for delivering regeneration in Poole‟. What this process has not done however, is to involve the owners of the key development sites in the Regeneration Area. We would welcome the opportunity to be part of such a process as policies and proposals are being prepared for the former Power Station site, if the Council are revisiting any of the principles. We support Policy SSA7 as this provides flexibility in support of the existing policy framework and guidance of the 2004 SPG for the Regeneration Area. However, there are opportunities to combine this with the criteria of Policy SSA10 to provide a more coherent and simplified approach to urban design guidance for the Regeneration Area. Representation ID 233: Mr Christopher Allenby, Poole Old Town Conservation Group We do not feel that the Policy SSA 7: The Regeneration Area - Urban Design meets the PPS12 tests of soundness. The The Core Strategy is not currently part of this process having been Core strategy should be modified to include as a designated area, the Old Town of Poole, at the moment it is not adopted in 2009. Between the Core Strategy, policies proposed in the considered to be part of the High Street or part of the Regeneration area. More emphasis is needed to provide public SSA&DM DPD and the to be updated SPD there is sufficient clarity access to all areas adjacent to the water and a continuous walking route and road crossings etc. We agree as per the and guidance for the Regeneration Area and wider Town Centre. Proposals map, the need to create local identity and legibility of development through a variety of building heights, which on the town centre side requires development to relate to the human scale of existing development and relationship with the old town. On the quayside, design buildings that relate to the water and ensure the quayside is well connected to the area behind with streets and alleys radiating from the water. Incorporate permeability and flexibility in design through a fine grain of street blocks and development, which can be adapted in the future to meet changing needs. Be designed so that public, semi-public and private space is clearly distinguishable and that spaces are designed to enable intra and inter- generational spaces and play. Provide for the greening of the town by way of tree planting along transport routes and the incorporation of a variety of open, soft and hard landscaped spaces. Reinforce the street as an integrated component of the public realm and townscape with no road or street designed to accommodate speeds greater than 20 mph. Representation ID 275: Mr Bill Constance on behalf of Vision for Poole Group , Vision for Poole Group OBJECTION TO Policy SSA7, The Regeneration Area- Urban Design The proposed additions are already covered in other policies or The current policy fails to meet the necessary test of Soundness and should be amended as follows:- guidance. POLICY SSA7- The Regeneration Area - Urban Design Development within the Regeneration Area as shown on the Proposals Map should:- i. create local identity and legibility of development through a variety of building heights which on the town centre side requires development to relate to the human scale of existing development and relationship with the old town and Hamworthy waterfront; ii. on the quayside, design buildings that relate to the water and ensure the quayside is well connected to the area

47

behind with streets and alleys radiating from the water; iii. incorporate permeability and flexibility in design through a fine grain of street blocks and development which can be adapted in the future to meet different needs; iv. be designed so that public, semi-public and private space is clearly distinguishable and that spaces are designed to enable intra and inter-generational spaces and incorporating childrens play spaces on-site rather than off-site contributions; v. provide for the greening of the town by way of tree planting along transport key routes and the incorporation of a variety of open, soft and hard landscaped spaces using high quality materials, with considerations given to long-term maintenance and management ; and vi. reinforce the street as an integrated component of the public realm and townscape with no road or street designed to accommodate speeds greater than 20 mph and which embraces the principles set out in Manual for Streets 1 and 2. vii. the public realm should be designed to enable full public access to all areas adjacent to the water throught the day and a continuos walking route from Poole Old Town and Hamworthy, with pedestrian priority measures installed off and on-site, so as to encourage walking and cycling and „safer routes to school‟. viii. in order to secure the key objectives of Core Strategy Policy PCS11, the layout and elevations should be designed to create a strong relationship between land use and public realm, incorporating active frontages and permeable streets, with consideration given to servicing requirements of all landuses at the outset. Question 16: Policy SSA 8: The Regeneration Area - Infrastructure Representation ID 70: Mr Nigel Pugsley, Senior Planning Consultant, BNP Paribas Real Estate, on behalf of Barclays Bank Group Property. Whilst my client has no plans to vacate its sites at the present time, it is considered that some reference should be Barclays House does not lie within the area covered by Policy SSA8 included within this document recognising the potential contribution it could make towards achieving the Council's but will be the subject of a Local Area Design Statement that will be aspirations for the regeneration of this part of Poole should it ever become so. This is pertinent given the Council has prepared for the Area North of Towngate Bridge (see text to Policy decided (at para 4.9) not to progress the Area Action Plan for Town Centre North. It is therefore recommended that DM1: Design). reference is made to Barclays House and associated land holding in Section 4 of the finalised document. Representation ID 87: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. We support SSA 8 point (ii) in insisting that no planning approval is given while there is a short term lack of affordable The role of the highway network and detailed design principles for housing provision. We are planning for the next 50+ years and so these massive developments must take the long view. streets is set out in the Council‟s LTP1 submission to Government, The policy is UNSOUND since there needs to be emphasis on improvements to the highways and streetscape Planning and Urban Design Guidance SPG Volume 2 2004 for the surrounding the site so as to remove the barrier that the dual carriageway creates between the Quay and these sites. Central Area and Streetscapes SPG. Considerable measures for pedestrian priority need to be made. The owners and developers of these sites have been well aware of the flood defence work that needs to be carried out and that the costs that were involved with the flood protection work that has been carried out on the Quay have been in the public domain for many years. The Core Strategy stated that the West Quay Road site must be „compatible with Poole Quay‟ but the developer‟s

48 planning application was diametrically different. So planning review must be very tight on insisting that site development keeps exactly to the site planning specification. When reviewing the Pilkington Tiles exhibition, we were concerned that the TFA Managing Director indicated that he had only recently talked to Gallaghers about spatial layout and compatibility of their 2 sites. It is essential that there is a tight common plan for the 3 Hamworthy development sites, with clear agreement on roads, traffic flows, access points, architectural design, etc. Representation ID 118: Noted. Meghann Downing, Highways Agency Yes. We note that the infrastructure requirements to be delivered by the town centre are only the flood defences. The Agency has provided a comment for the Delivering Poole‟s Infrastructure DPD that improvements to the SRN ought to be included as part of CIL funding. If this is accepted as part of the Infrastructure DPD then this section may need to be revised. Representation ID 152: Whilst it is true that economic viability is a consideration and already Mr Roger Rippon, RDS Town Planning & Development Consultants, on behalf of Inland Developments plc. forms part of Policy PCS6 in the Core Strategy it has to be recognised SSA8 (ii) - the second sentence of this paragraph contradicts Government guidance, Core Strategy policy PCS6 and the that the delivery of affordable housing is a strategic objective for the policies in the „Delivering Poole‟s Infrastructure‟ DPD. town and the emphasis of regeneration has been one of delivering a There is no justification for stating that economic viability should not be taken into account in determining the level of significant proportion of affordable housing on the regeneration sites. It affordable housing to be provided on site(s) within the Regeneration Area. On the contrary, this is specifically recognised must therefore be for the Council to determine whether strategically as a relevant consideration in, for example, the following:- proposals comply with the town‟s vision and objectives or not. This PPS3, paragraph 29. may mean refusing planning applications for the lack of affordable Written Ministerial Statement by Greg Clark „Planning for Growth‟ dated 23 March 2011. housing provision where not economically viable at this moment in Core Strategy Policy PCS6, paragraph b and supporting text. time. In recognition of the representation the wording will be amended Pre-submission „Infrastructure DPD‟, as commented on above. to say that development may be refused rather than will. As currently drafted, this second sentence clearly renders this policy „unsound‟ because it is neither „justified‟, „effective‟ nor „consistent with national policy‟. To make this policy „sound‟ it should be redrafted in terms as follows:- iii. An appropriate proportion of affordable housing in accordance with Policy PCS6. Representation ID 212: Noted and see response above. Lindsay Thompson, Senior Planner, Terence O'Rourke Ltd., on behalf of Neptune Consultants Ltd. We fully support the inclusion of point i. of Policy SSA8, which relates to flood defence measures. It is important recognition that developers involved in regeneration sites will be intrinsically responsible for delivering flood management infrastructure associated with the site, and therefore because of this contribution to the overall flood risk protection strategy for Poole, these developers do not need to make financial contributions for other strategic flood infrastructure in the borough. However, we are seriously concerned about the impact point ii of policy SSA8 would have on the delivery of regeneration schemes where it states “non provision of affordable housing on the grounds of lack of viability will not be sufficient in itself to justify departure from providing affordable housing”. We think that this statement is too restrictive to affordable housing negotiations and is likely to stall the delivery of regeneration. Through the inclusion of point ii of policy SSA8, the DPD fails to consider the complexity of regenerating former commercial land on a quayside within a European

49 protected nature conservation area and the flexibility needed to deliver long awaited regeneration. In addition, point ii is not consistent with PCS6 of the adopted Core Strategy. PCS6 policy states that the level of affordable housing sought will be subject to a number of measures including: “the economics of providing affordable housing”. This statement cannot be ignored by the site allocation DPD. Likewise, statement ii is not in accordance with the national guidance of PPS3 that clarifies that affordable housing targets should be reflective of the likely economic viability of land for housing and likely levels of finance available (paragraph 29). As such we believe that this part of the policy not sound because it is not consistent with the policy context established by the Core Strategy and the national policy context established by PPS3. It is also contrary to the latest Government guidance. The growth plan is a material planning consideration and it “encourages local authorities to put in place development plans that are pro-growth” (Paragraph 2.9 of the Plan for Growth, March 2011). We do not consider point ii of policy SSA8 to be pro-growth. Paragraph 2.15 of the Plan for Growth states local authorities will not be able to adopt plans that block the delivery of required development by imposing unsupportable burdens on developers. For development plans, deliverability will remain a key test of soundness. The Borough of Poole cannot disregard the key part viability plays in the delivery of development and therefore point ii. of SSA8 should be deleted to ensure the policy can be found sound. Representation ID 195: Mr Michael Holm, Planning Liaison Officer Environment Agency. Sound, although the final wording of this policy must be in accordance with the Infrastructure Development Plan Noted. Document wording IN3. Representation ID 160: Richard Shaw, Director, Savills, on behalf of Gallagher Estates Ltd & Land Improvement Holdings Ltd. In conclusion, we mainly support the principles of providing further clarity and flexible policies for the assessment of future Noted. As per response to ID152. proposals for the Power Station site apart from Policy SSA8 (ii) affordable housing which is unsound. Any such policies need to add further practical guidance to the existing Core Strategy policies and other Council guidance. They also need to comply with Government policy and guidance. Proposal SSA8 (ii) does not and is unsound for the reasons indicated. It should be deleted or modified. We look forward to working with the Council on the preparation of the scheme of the development for the Power Station site and hope that these constructive comments will facilitate and suitably positive and flexible planning framework for the assessment of those proposals. Representation ID 234: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy SSA 8: The Regeneration Area - Infrastructure meets the PPS12 tests of soundness. There The integration of development and the transport network is covered in needs to be emphasis on improvements to the highways and streetscape surrounding the site so as to remove the barrier policy SSA7 (vi). that the dual carriageway creates between the quay and these sites. Considerable measures for pedestrian priority need The Dorset Heathlands contribution cannot be set aside otherwise to be made. This section can also cover the need for more community infrastructure, off-setting the impact of development residential development would fall foul of the Habitats Regulations. in terms of education, open space, public transport and jobs. The owners and developers of these sites have been well aware of the flood defence work that needs to be carried out and that the costs that were involved with the flood protection work that has been carried out on the Quay have been in the public domain for many years. When proposals are placed before the planning committee consideration should be given regards to 106/CIL contributions. The contributions to Dorset Heath lands should be excluded. The heath land is a very important item, but without the flood protection to the

50 whole town of Poole, we could be in the position that there could be only the heath lands left and the town of Poole is washed away. Therefore 106/CIL contributions to sites along the Back Water Channel on both sides should be exempt from heath lands contributions. Representation ID 276: Mr Bill Constance on behalf of Vision for Poole Group , Vision for Poole Group. OBJECTION TO POLICY SSA8, The Regeneration Area - Infrastructure Criteria iii is already dealt with in Policy PCS11 of Poole Core Strategy The Regeneration Area - Infrastructure as is the provision of cycling and pedestrian links. Streetscapes SPG Land within the Regeneration Area as shown on the proposals map is expected to deliver the priorities, key requirements addresses the integration of the transport network and development and mix of development set out in Core Strategy policy PCS 11. sites. In addition each development site will need to deliver:- Dorset Heathlands contributions cannot be set aside. i. Flood defense measures that provide protection for future users/occupiers of development. Such defenses will also form part of the wider strategic flood defenses for the town centre. Given the considerable cost of such works development will not be expected to contribute to other flood defense measures unless directly related to their own development proposals; and ii. Affordable housing in accordance with Core Strategy policy PCS 6. Given the priority to deliver affordable housing and the role of the regeneration sites in supporting this aim the non provision of affordable housing on the grounds of lack of viability will not be sufficient in itself to justify departure from providing affordable housing. iii. Community facilities and other social infrastructure including contributions towards education and employment opportunities for local people. iv. give priority to the provision of a high quality public realm within and adjacent to the site including removing the barrier that the existing and proposed dual carriageway creates to pedestrian movement, with pedestrian and cycle priority measures incorporated. v. exclude the need for contributions towards Dorset Heathland by prioritizing the above measures. Question 17: Policy SSA 9 – The Regeneration Area – Land between Poole Bridge and Twin Sails Bridge Representation ID 8: Mr Mark Howell. There is no justification for a gateway building adjacent to the Old Bridge as the intention of the policy is to integrate it with The urban design analysis led to a set of principles and detailed design the Old Town and create a sweep from the Quay. Placing a larger building at this point would create a blockage which guidance for the site that concluded a landmark building could be would interrupt this sweep and be more likely to deter than attract pedestrians. accommodated. Representation ID 89: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. Policy SSA9 is UNSOUND in that in order to ensure that the schemes provide local housing and meet the area‟s housing Restricting the tenancy of private property is beyond the scope of needs, the housing should be controlled so it cannot be rented out as short-term lets (less than 3 months.) planning. Representation ID 214: Lindsay Thompson, Senior Planner, Terence O'Rourke Ltd., on behalf of Neptune Consultants Ltd. We strongly feel that this policy is too specific and not flexible enough to enable development to be delivered. Neither is The policy does not restrict the number of units on site. It provides there any evidence available to us at this stage to show that this policy is based on sound and most importantly up to date additional design criteria that should inform the design process. The

51 evidence. It is therefore not effective or justified and as such cannot be sound. criteria are not new and are being brought forward from the adopted It is important to recognise that the Core Strategy requirement of 250+ homes and 11,000 square metres of commercial PBRI SPG Vol 2 2004. The policy position and design criteria for the floor space for the site between the two bridges is a baseline figure. The Habitat Regulations Assessment (2008) Regeneration sites has been known for nearly a decade and whilst concludes that 384 homes is an appropriate number on the site. Mixed used development of this level requires buildings there are significant costs associated with brownfield development any above 6 storeys in order to achieve the level of development required and the urban design objectives such as ultimate scheme needs to be contexturally right for its setting. The permeability and grain. whole approach to Regeneration in Poole was premised on delivering By imposing restrictions on the height and design of the regeneration area, delivery of major schemes is likely to be new homes and jobs in an attractive environment. It was this ambition compromised. As recognised by the policy, taller landmark buildings at the two gateways (north and south) are needed articulated through policy that has attracted development to the town and will help to deliver this housing number and mark these keys locations. But prescriptive limits of height should not be centre. It is largely public sector funding that is paying for a new bridge placed these buildings. Landmark buildings should be a function high quality design. Discretion and flexibility should be to facilitate regeneration and that regeneration has to be right for the retained by the development control team to consider development of a bespoke or exemplary nature on its merits. town. As a sustainable site designated for regeneration, it is important to make effective and efficient use of this land. The Plan for Growth (March 2011) states that: “The Government is committed to ensuring that the planning system does everything it can to support growth” (paragraph 2.9). Policies within emerging documents, such as Policy SSA7 should conform to this aim rather than imposing stringent stipulations upon developers. Turning to the specific wording, point iv repeats point B in Core Strategy policy PCS23 and therefore is unnecessary. In addition, we consider the use of the word „emulate‟ in point iv is wholly inappropriate. Although new design should aim to reflect and be sympathetic to the historic character of the Poole old town, design should be of its time and not aim to duplicate or copy the past. More appropriate wording for the policy would be to „reflect‟ as opposed to „emulate‟. It is not clear what this policies relationship will be with the existing design guidance and adopted Core Strategy. This could in turn lead to confusion. We understand the SPG for the Regeneration Area has been reviewed by CABE and will now go through the formal process of being converted to an SPD. With the emergence of an SPD on urban design guidance for the regeneration area we question the need for additional design policies in this DPD, particularly being produced in advance of the formal publication of the CABE review and consultation on the SPD. If anything the design refresh of the SPG into an SPD should come first to guide and provide a sound evidence base for the policies contained within the DPD. Given the reasons stated above we suggest that policy SSA9 is deleted. Representation ID 235: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy SSA 9: The Regeneration Area - Land between Poole Bridge and Twin Sails Bridge meets Restricting the tenancy of private property is beyond the scope of the PPS12 tests of soundness. In order to ensure that the schemes provide local housing and meet the areas housing planning. needs, the housing should be controlled so it cannot be rented out as short-term lets (less than 3 months). Outrageous developments that are supposed to be in accordance with the Core Strategy increase densities above the Core Strategy, these should be discouraged until a new Neighbourhood Forum is formed. Representation ID 277: Mr Bill Constance on behalf of Vision for Poole Group , Vision for Poole Group. OBJECTION TO POLICY SSA9, The Regeneration Area – Land between Poole Bridge and Twin Sails Bridge The additional criteria proposed are already covered either in existing The Regeneration Area – Land between Poole Bridge and Twin Sails Bridge or emerging policy, in more detail in SPG or are beyond the scope of planning. Planning policies should not repeat policies elsewhere within

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In addition to meeting the requirements of core strategy policy PCS 11, development will be expected to deliver:- the documents that make up the LDF. There is no need to say that i. A variety of building height that does not exceed 6 storeys in height except in justified gateway locations at the policy should comply with other policies in the development plan as this northern and southern end of the site adjacent the bridges. Here an additional 2 storey‟s can be accommodated is a given. without harming the relationship with the old town; ii. In each development block a variety of building heights particularly on those fronting Back Water Channel; iii. Distinctive buildings, active frontages, spaces and features at the land end of both bridges reinforcing the sense of arrival at gateway locations; and iv. A series of plots within blocks which are sensitive to the existing urban grain of the old town and designed to emulate the vertical rhythm of the warehouse plots on the old quay. v. the public realm should be designed to enable full public access to all areas adjacent to the water throught the day and a continues walking route from Poole Old Town, with pedestrian priority measures installed off and on-site, so as to encourage walking and cycling and „safer routes to school‟. vi. in order to secure the key objectives of Core Strategy Policy PCS11, the layout and elevations should be designed to create a strong relationship between land use and public realm, incorporating active frontages and permeable streets, with consideration given to servicing requirements of all land uses at the outset. vii. There should be no over dominance of one single land use in particular areas and large A3 uses which have inactive frontages for large parts of the day should be discouraged. viii. In order to secure the key objectives of Core Strategy Policy PCS11 (d) namely social regeneration: (a) the tenancy of the residential accommodation will be controlled to prohibit holiday accommodation or short-term lets less than 3 months in duration; (b) affordable housing to be provided on-site in accordance with Development Plan Policy; (c) residential density to be in accordance with the development plan; (d) a suitable mix of residential units, to include family accommodation, small private gardens and balconies. Question 18: Policy SSA 10 – The Regeneration Area – Land on Hamworthy side of the Back Water Channel Representation ID 90: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. The Policy is UNSOUND since there must be a spatial and design statement for Town Centre North included in the The Regeneration Area does not include Kingland Road, the Dolphin document since the Kingland Road, the Dolphin Centre and Sainsbury‟s car park are so central and important to the Centre and Sainsbury‟s Car Park. Core Strategy policy PCS 12 future of Poole. addresses development mix for Town Centre North. Representation ID 119: Meghann Downing, Highways Agency. Yes. Applications at this site are likely to meet the criteria for a „major planning application‟, in which case the Agency will Noted. need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 266: Mrs Ann Smeaton, Hamside Residents Association. We do not feel that the Policy SSA 10: The Regeneration Area - Land on the Hamworthy side of Backwater Channel Open space as an alternative to development on the power station site meets the PPS12 tests of soundness. is not an option. The site provides a major opportunity to provide

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Hamworthy is already densely populated. The development of the regeneration area is seen as the last opportunity of homes for people and contribute to the sustainable development and providing useable open space. Therefore, instead of 106 or CIL monies, where achievable, open space would be a regeneration of Poole. Whilst it will be important to ensure that the preferred option. development provides space on site it will be equally important to ensure that routes to and from existing spaces are created. Representation ID 158: Richard Shaw, Director, Savills, on behalf of Gallagher Estates Ltd & Land Improvement Holdings Ltd. As you will appreciate, our clients have a significant interest in the future planning policies and strategy of the Council - Support noted and largely agree with proposed changes to policy being joint owners and developers of the former Poole Power Station site. This 13ha site is the largest single development suggested. site in the Regeneration Area and will therefore play a significant role in delivering the Council‟s development objectives for the period of the plan. Viability is a big consideration in the current economic climate. The importance of the former Power Station site to the Borough is recognised by the allocation of this and other key sites in the Regeneration Area in the Core Strategy. We recognise and welcome the fact that the current consultation document seeks to review the „saved‟ policies of the Poole Local Plan First Alteration and to develop more detailed policies for sites. In making these representations, we are conscious of the existing positive planning framework in the current development plan (the adopted Local Plan and the Core Strategy) and the further material consideration provided by the 2004 SPG for the Poole Bridge Regeneration Initiative. It is important that any further development plan policies are both justified and effective - meeting the principles of „soundness‟. We welcome the recognition in the DPD given to the Inspector‟s Report into the Core Strategy - that, whilst accepting the principles for development and the broad quantum of development across the Regeneration Area, there needs to be a degree of flexibility to ensure delivery. At para 4.70 of his report, the Inspector highlighted that, in respect of the Core Strategy policy: It is also appropriate for the policy to continue to set out the individual site aspirations, subject to an explanation that these key requirements and figures given are aspirational, with flexibility between sites; that they may need to be subject of negotiation, having regard to both to issues of deliverability and the overall vision and strategy for the area. This is acknowledged in paras 4.3 and 4.4 of the consultation document and is fully supported. Policy SSA10 is supported insofar as the policy is justified to provide additional guidance for the development. This policy could better be combined with SSA7 (Urban Design), as this provides further urban design guidance. Criterion i) of the policy should be revised to provide a more effective („flexible‟) approach to building heights. We would suggest this could be revised to “A variety of building heights, generally not exceeding 6 storeys in height. Opportunities for taller, landmark, buildings will need to be coherent and justified within the overall design solution for this area”. We acknowledge that public access should be limited to the northern shore area and that development should provide an appropriately designed green edge in this area to avoid potential harm to the Poole Harbour SPA. Representation ID 236: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy SSA 10: The Regeneration Area - Land on the Hamworthy side of Back Water Channel Restricting the tenancy of private property is beyond the scope of meets the PPS12 tests of soundness. In order to ensure that the schemes provide local housing and meet the areas planning. housing needs, the housing should be controlled so it cannot be rented out as short-term lets (less than 3 months). Outrageous developments that are supposed to be in accordance with the Core Strategy increase densities above the Core Strategy, these should be discouraged until a new Neighbourhood Forum is formed.

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Representation ID 278: Mr Bill Constance on behalf of Vision for Poole Group , Vision for Poole Group. OBJECTION TO POLICY SSA10, Land on the Hamworthy side of Back Water Channel It is not necessary to repeat policies that are elsewhere in the The Regeneration Area – Land on the Hamworthy side of Back Water Channel development plan. Other aspects of the criteria proposed are either In addition to meeting the requirements of Core Strategy policy PCS 11, development will be expected to deliver:- already covered by policy or are not appropriate for planning to try and i. A variety of building height that does not exceed 6 storey‟s in height. Opportunities exist for landmark buildings that control. may be higher that will need to be coherent within the overall design solution for this area; ii. A responsive grain of development with active frontages throughout and quality public spaces; iii. In each development block a variety of building heights particularly on those fronting Back Water Channel and main routes through the site; and iv. Limited public access to the northern shore overlooking Holes Bay and a green edge to avoid harm to the nature conservation value of Poole Harbour Special Protection Area. v. in order to secure the key objectives of Core Strategy Policy PCS11, the layout and elevations should be designed to create a strong relationship between land use and public realm, incorporating active frontages and permeable streets, with consideration given to servicing requirements of all land uses at the outset. vi. In order to secure the key objectives of Core Strategy Policy PCS11 (d) namely social regeneration: (a) the tenancy of the residential accommodation will be controlled to prohibit holiday accommodation or short-term lets less than 3 months in duration; (b) affordable housing to be provided on-site in accordance with Development Plan Policy; (c) residential density to be in accordance with the development plan; (d) a suitable mix of residential units, to include family accommodation, small private gardens and balconies. Question 19: Policy SSA 11 – Lagland Street Representation ID 91: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. As stated earlier, the Policy is UNSOUND since it is essential that there is a Local Area Design project to re-vitalise the While Lagland Street is part of the town centre the policy deals with whole of the Lower High Street - and not just consider Lagland Street in isolation. specific issues and opportunities in this area. Representation ID 120: Meghann Downing, Highways Agency. Yes. As above, applications at this site are likely to meet the criteria for a „major planning application‟, in which case the Noted. Agency will need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 237: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 11: Lagland Street meets the PPS12 tests of soundness. It is appropriate for this to be infill Noted. development and has a chance of being deliverable. Representation ID 279: Mr Bill Constance on behalf of Vision for Poole Group , Vision for Poole Group. OBJECTION TO POLICY SSA11- Lagland Street While Lagland Street is part of the town centre the policy deals with

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Whilst Lagland Street is in need of regeneration, the policy should extend to the whole of the Lower High Street Area. Co- specific issues and opportunities in this area. ordinated regeneration could revitalise the area whilst respecting the Conservation and Heritage assets. It should include the Old Town and Lower High Street Conservation Areas. Question 20: Policy SSA 12 – Goods Yard Representation ID 43: Mr S I Martin. No. It needs to explicitly mandate a new pedestrian/cyclist bridge over the railway to Sterte Road. Not a specific requirement for development of this site. Representation ID 63: Mr Harry Alexander, Open Spaces Society. 4.12 The railway station was previously reviewed to be moved; however it was decided that the railway on a steep bend No response required. would be inappropriate for rail users particularly for those with mobility issues and all others under the umbrella of the Equality Act /DDA. Representation ID 73: Mr Nigel Pugsley, Senior Planning Consultant, BNP Paribas Real Estate, on behalf of Barclays Bank Group Property. My client is supportive of draft policy which recognises that the Goods Yard site forms part of a larger area, and that this Noted. will be subject to a LADS setting out a clearly defined design vision and strategy for the area. As the scope of the wider The LADS for the „Area North of Town Gate Bridge‟ will incorporate "area" should also incorporate Barclays House, my client would wish to be consulted and involved in the preparation of a Barclays House. The property owners would be consulted and involved LADS for "Area North of Town Gate Bridge". as a stakeholder in the preparation and development of the LADS. Representation ID 92: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. We welcome para 4.13 as an example of the kind of detail that should be spelt out as Poole‟s ideal for each of the Breakdown of ownership is not a soundness issue. For information the development sites, so we can understand the objectives for each site. But SSA12 is UNSOUND since there is no Council‟s land ownership relates solely to highway land. declaration as to the proportion of ownership between the Borough of Poole and Network Rail. The proposed applications for a site of 2.98 Ha appear to be an excessive density. Representation ID 121: Meghann Downing, Highways Agency. Yes. As above, applications at this site are likely to meet the criteria for a „major planning application‟, in which case the Noted. Agency will need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 175: Mr Nick Squirrell, Natural England. Natural England supports point iii and iv of this policy which acknowledge the need to ensure the Poole Harbour SPA and Comments noted. Ramsar is not harmed by nitrogen inputs arising from the developments. I advise you that the wording used is not Natural England have proposed an appropriate form of wording to consistent with the legal position regarding European sites and Natural England would wish to offer advice on appropriate provide consistency with the legal position regarding European sites text modifications. and document amended accordingly. Representation ID 162: Mr Stephen Austin, Network Rail, Town Planning Team.

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Network Rail wishes to respond specifically on Policy SSA12: The Goods Yard, a site within its land ownership. As joint Support for the policy is noted. applicants of planning application Ref: 05/17054/021/F, lodged in 2005, which currently has a resolution to grant subject The site is not considered to be within the Town Centre Primary to the signing of s.106, Network Rail remains fully supportive towards comprehensive mixed-use development on this site. Shopping Area boundary. Incorporating it would extend the potential Where land in our ownership is no longer required for operational railway use there is often potential for development that for retail development and potentially harm the retail strategy for the in turn would bring wider regeneration benefits for the area. Furthermore, much of our estate by virtue of its historical use town centre that is set out in the Core Strategy. It is therefore not is typically in very sustainable locations (i.e. brownfield land, and within or adjoining developed areas and good links to accepted that this location should support anything other than ancillary other modes of transport) and therefore ideally situated for redevelopment; the Goods Yard site being an excellent retail facilities and would not harm the aspiration to improve linkages example. Network Rail is funded to maintain the existing railway and does not have monies for enhancements, thus in back into the town centre. order to upgrade capacity to meet additional demand we are reliant upon additional funding streams through redevelopment with third parties or maximising the commercial value of our estate. This response has therefore been composed alongside that submitted by Savills on behalf of Solum Regeneration; the partnership between Network Rail and Kier Property as a vehicle to regenerate a number of railway stations and adjacent land in the South East of England. This response echoes the comments made by Savills and therefore the two representations should be read alongside each other. Network Rail supports the flexibility afforded by the policy with regard to uses and floorspace. In order to maximise commercial receipts for re-investment into the operational railway, it is essential that the development potential of the site is not unnecessarily restricted by a rigid quantum of development. Network Rail would encourage the amendment of the policy from „ancillary retail/A3/A5‟ to read „retail and other commercial uses, including A3/A5‟. Similar to above, this would expand the range of commercial uses possible within any future development proposals for the site, bringing the policy in accordance with PPS4: Planning for Sustainable Economic Growth‟s requirements for competitive retail environments and consumer choice. Network Rail would also request the synchronisation of the Town Centre Boundary and the Town Centre Retail Boundary in this location in order to accommodate the site within the latter designation. The southern part of the site in particular has the potential to provide a coherent link to Falkland Square and to provide an integral component of the town centre. The inclusion of the site frontage to Serpentine Road should be included within the Town Centre Retail Boundary to facilitate retail frontage development, related to and linked closely with the Dolphin Centre and the rest of the retail area. This would bring the policy in line with the objectives of Policy PCS10 of the Core Strategy. Network Rail trusts that these recommendations will aid the document in its assessment against the tests of soundness and lead to its adoption into Poole‟s Local Development Framework. Representation ID 157: Mr Robert Lofthouse, Savills, on behalf of Solum Regeneration. The draft DPD provides a site specific policy (SSA12) to replace that of the Local Plan. Policy SSA12 is based on the mix See response above to ID 162. of uses from the current planning application for the site and reflects a broad and flexible approach for future In addition, it is appropriate for the policy to set out any specific development. It does not provide a quantum of development for any of the uses mentioned, which we welcome as this considerations for the site to aid clarity and certainty for those provides a degree of flexibility for any future development proposals. interested in the site. While it does not represent the full range of However, we consider that there is the opportunity to provide greater flexibility on the range of commercial uses. We issues it does represent key aspects that are not elsewhere covered in would suggest that Policy SSA12 be amended to omit the „ancillary‟ component of retail/A3/A5 uses that could be policy such as design issues. accommodated at the site. That part should read „retail and other commercial uses, including A3/A5)‟. We note the inclusion of the Goods Yard site within the „Town Centre‟ boundary as shown on the Proposals Map and recognise that Policy PCS10 of the Core Strategy provides support for proposals intended to „revitalise‟ the town centre.

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The site should be included in the Town Centre Retail Boundary, as are other areas of underdeveloped land close to the Dolphin Centre. The southern part of the former Goods Yard site in particular has the potential to provide a coherent link to Falkland Square and to provide an integral component of the town centre. This would make the policy consistent with the objectives of PCS10. In relation to the three criteria referred to in the policy (related to flood risk, contamination and the harbour), these represent some of the planning considerations when the earlier application was considered. There were other planning issues in relation to layout, access and design which are not referred to. We would query the inclusion of the three specific criteria and question their necessity as part of the site specific policy for the development of the site. In this respect the Policy is unsound as there is no justification for these three criteria to be singled out. The policy also refers to the site being '...part of a larger area that will be the subject of a Local Area Design Statement which will set out a clearly-defined design vision and strategy for the area.' Individual sites should be capable of independent but complementary development. We would welcome the opportunity to explore the Council‟s approach on its vision and strategy for the area further. It is noted that the boundary for the Town Centre North Area is not included in this current consultation and that, contrary to the adopted Core Strategy, the Council has decided not to progress with an Area Action Plan for this part of the town centre, instead „…considering that the policy base established in the Core Strategy provides sufficient coverage of the town‟s aims for this area‟. It is further noted that the Council has „….produced a prospectus that sets out the ambitions for this part of the town and will be moving forward with a market sounding exercise to seek a development partner to deliver the regeneration.‟. It would be helpful for those adjacent landowning stakeholders to be provided with a copy of any such „prospectus‟ given the importance and potential for adjacent sites to integrate with any such „vision‟ for this area. Representation ID 238: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy SSA 12: The Goods Yard meets the PPS12 tests of soundness. There is no declaration as Breakdown of ownership is not a soundness issue. For information the to the proportion of ownership between Borough of Poole and Network Rail. The proposed applications for a site of 2.98 Council‟s land ownership relates solely to highway land. ha appear to be excessive densities, but with an allocation of 66 units of affordable housing, the 106 agreements should be easier than on other sites. Representation ID 280: Mr Bill Constance on behalf of Vision for Poole Group . SUPPORT POLICY SSA12- The Goods Yard Noted. This policy meets the necessary tests of soundness, and we support this policy on the grounds that it will contribute to the wider regeneration of Poole, improve accessibility and promote sustainable travel options and development in accordance with Government Policy. We raise the following issues: Ownership issues will need to be considered and resolved. Densities should be in accordance with Development Plan Policy taking account of the public transport accessibility of the site. Priority should be given to delivering a high quality public transport interchange, which can cater for the diverse

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needs of all operators and users well into the future and mitigate the need for a separate bus interchange at the Dolphin Centre. Viability issues in terms of delivering affordable housing and high quality public transport interchange should be taken into consideration in determining the planning application. Question 21: Policy SSA 13 – Land at Lifeboat Quay Representation ID 44: Mr S I Martin. No. It needs to explicitly mandate the retention of the pedestrian/cyclist path from the Holes Bay Road crossing opposite Planning permission has already been granted on the eastern portion the station to the NE doorway of Asda. of this site fronting Holes Bay Road. Pedestrian links have been incorporated into the approved scheme. Cycle access to the development is available via Lifeboat Quay. Representation ID 93: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. Para. 4.17: presumably the wording „land is developed for offices‟ is wrong when the outline planning permission is for a Para 4.17 revised to set out a clearer explanation of the „Phasing‟ of hotel. 14. Otherwise we support Policies SSA 11 - 13 as long as they include greater scoping detail. development on the site. Representation ID 122: Meghann Downing, Highways Agency. Yes. Noted. Representation ID 239: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 13: Land at Lifeboat Quay meets the PPS12 tests of soundness. Subject to 106 Noted. agreements, the development has a chance of being deliverable. Representation ID 281: Mr Bill Constance, Vision for Poole Group. SUPPORT POLICY SSA13- Land at Lifeboat Quay There is already detailed planning consent for the hotel and outline This policy meets the necessary tests of soundness, and we support this policy on the grounds that it will contribute to the consent across both phases of the site. It is recognised that this is a wider regeneration of Poole, create jobs and promote tourism. high profile and important site but it is considered that other policies, Consideration should be given to inserting the following additional text: e.g. SSA 7 is sufficient to ensure the expected high standard of design. iii. be designed to a high standard, as a landmark building and gateway to Poole, which relates to the human scale and creates interest at street level for pedestrians. Servicing requirements and vehicular access to be carefully considered. Representation ID 284: Mr Harry Alexander, Open Spaces Society. 4.13 Lifeboat Quay: This area should be developed for the People of Poole as an enjoyable Open Space. As a major The site forms part of the existing permission granted to Asda in 2003 entrance to Poole it should be an attractive area not one for multi-storey commercial buildings as the "Borough strives for for hotel and offices as well as ancillary uses. The design strategy set excellence...Poole is a beautiful place" as its slogan and marketing message. The People of Poole need to see evidence out in PBRI Supplementary Planning Guidance Volume 2 2004 of this. identifies this as gateway site and entrance to Poole and that

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development should be appropriate to its town centre location. Open space is not one of the component uses identified for this site albeit that a waterside walk has been incorporated. Question 22: Policy SSA 14 – Former East Quay Depot and Quay Thistle Hotel Representation ID 9: Mr Mark Howell. As much of this land is owned by the Borough, it would be a suitable place for a landmark public building. This option This has not formed part of previous planning policy or been proposed should be included in the plan. as part of the options for the site. Given the state of public finances and that no evidence of the need for a public sector use on the site has been forthcoming it would not be appropriate to allocate for this purpose. It is agreed that development of the site should be a landmark building given the sites prominence and context. Representation ID 52: Guy Green. I jointly own the Freehold of the Premises known as 2, Ballard Road, Poole, Dorset. There is a long standing planning history to redevelopment of this site The Development Plan Document, as indicated in you letter will all be of great detriment to our premises and the two and many of the issues raised are more appropriate dealt with through adjoining houses. The original house on the proposed site was two stories high and set well back from Ballard Road. The the detailed planning application process. Additional text can be added proposed new buildings will look directly into the reception and bedrooms of our premises, reducing the privacy currently that sets the context for the site and the need to respond to the enjoyed. The view from our windows will be greatly restricted by these monolithic constructions and the vastly increased different scale of development either side of the site. volume of traffic to any parking area and service areas passing our front door, will spoil the enjoyment we have experienced over the last fifty years of ownership. In addition, our property will be greatly reduced in value. Therefore, should planning permission be granted, I shall take action for compensatory loss, the loss of privacy, loss of light and view, loss of peaceful enjoyment of our premises and the damage caused by dust and dirt during the considerable time it will take to erect this construction. I strongly object to any of these proposed developments, therefore, before I enlist further opposition to this scheme, I suggest a site meeting with the Planning Officers to discuss this matter at greater length and to avoid expensive legal fees. I also refer you to my previous letters on the subject of planning for this site. I draw your attention to the Poole Borough Council's own Report of 2008 relating to Assessment of Flood Risks, in particular to Item 14 and in addition to the paragraph referring to Climatic Change, Items 3.10, 3.12 and 3.25 concerning the expected rise in sea levels. In my opinion, the displacement caused by any large development will endanger all the properties surrounding this site, emphasised by the raising of the floor levels indicated on some of the proposed plans. I note the responsibilities of the Landlords and Property Owners under the. Development Control Paragraph, Items 4.13, 4.14 in the aforesaid Report. I also note the item 7.1 under Paragraph 7 containing Recommendations in the same report, which states "unsuitable development within the flood risk area may increase flood risk elsewhere". This would appear to indicate that any flooding in the future, caused by the grant of these proposed developments will become the responsibility of the individual owners of all surrounding properties. In this event, I imagine the likely costs of litigation and clearance to the Poole Council and the Developers involved would be enormous. I recall, fifty years ago, the Council provided sandbags for the houses in that area, in order to protect against flooding at high tides - in those days some of the flood water rose up through the ground. Admittedly since then, there have been

60 substantial improvements to the harbour wall, but with a proposed displacement of these magnitudes, it is likely that this could occur again, particularly in the light of the Poole Council's own report. For example, the height of an Hotel consisting of ten floors on the quayside, is absolutely out of keeping with rest of the proposed development, all just to accommodate four more apartments, one only on each floor on floors 7, 8, 9 and 10 and 5 on floor 6. I am greatly opposed to these proposed developments, and the manner in which it will affect the occupiers of the existing homes in the area, which includes many elderly and retired people. I would suggest that a small park and seating area for the enjoyment off the general public, would be suitable for the east end of this site where the land is currently unused - this would enhance the Fishermans' Harbour, Old Lifeboat Station, New Marina and the general environs of this part of Poole Quay. The High Street in Poole is greatly in need of an upgrade, and it would be better to improve the commercial development of that area rather than spoil the Quay any further. Representation ID 123: Meghann Downing, Highways Agency. Yes. Applications at this site are likely to meet the criteria for a „major planning application‟, in which case the Agency will Noted. need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 176: Mr Nick Squirrell, Natural England. Natural England supports point iii and iv of this policy which acknowledge the need to ensure the Poole Harbour SPA and Comments noted. Ramsar is not harmed by nitrogen inputs arising from the developments. I advise you that the wording used is not Natural England have advised on an appropriate form of wording to consistent with the legal position regarding European sites and Natural England would wish to offer advice on appropriate provide consistency with the legal position regarding European sites. text modifications. Representation ID 240: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy SSA 14: Former East Quay Depot and Quay Thistle Hotel meets the PPS12 tests of It is not considered unreasonable for a replacement hotel to have soundness. If we must have another A3 establishment here! The size should be limited to ensure no additional noise etc restaurant/bar facilities associated with it. to the neighbouring housing. We agree as per the Proposals map the need to create local identity and legibility of development through a variety of building heights, which on the town centre side requires development to relate to the human scale of existing development and relationship with the old town. On the quayside: Design buildings that relate to the water and ensure the quayside is well connected to the area behind with streets and alleys radiating from the water. Again the Borough of Poole is the majority landowner; therefore there should be more involvement from the people of Poole. Reference to the need for S.106 contributions towards the establishment of the community use and introduce some public open space within the scheme. Representation ID 282: Mr Bill Constance, Vision for Poole Group. OBJECTION TO POLICY SSA14- Former East Quay Depot and Quay Thistle Hotel Policies do not need to repeat other policies or normally cross Former East Quay Depot and Quay Thistle Hotel reference as the plan should be read as a whole. Likewise the policy Land at the former East Quay Depot and Quay Thistle Hotel is considered suitable for a Development that will deliver a does not need to state that the design should be of a high standard as hotel and could include a mix of the following elements:- this should flow from the site context and design policies of the plan.

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Residential; The plan cannot deal with revenue matters as this is outside the plan‟s A3 café and bar or restaurant; remit. It is considered that PCS23 adequately sets out the key issues in Community space and/or facility; and formulating an appropriate design solution. A level of car parking provision appropriate for a town centre location. Provided that:- i. Development proposals preserve and enhance the character and appearance of the Quay Conservation Area (designated August 1981 and as amended December 1992) and respond to the provisions of Policy DM 2: Heritage Assets and are a high quality design reflecting the high profile location compatible with the scale and bulk of the neighbouring area; ii. Development proposals adopt the approach to flood risk assessment and adaption/mitigation set out in Core Strategy policy PCS 34 – Flood Risk; iii. As a consequence of past operations on the site, there will be a need to establish the presence and nature of any potential ground contamination that could adversely impact on the environment or human health. If it is established that potentially harmful substances are present, appropriate remediation measures will be required to avoid risk from contaminants or gases as a result of development: and iv. It can be demonstrated that development proposals would not contribute to an increase in nitrogen entering Poole Harbour SPA and Ramsar site, which could cause environmental harm, as a result of treated water discharges. v. the land use mix contributes to the vitality and viability of the area and does not harm the residential amenity of the neighbouring area in terms of increased late night noise and activity to a detrimental level. vi. the provision of a community facility or space to be provided at the developers expense together with revenue contributions to the prospective operator. vii. In order to contribute to the overall Housing Needs of the Borough: (a) the tenancy of the residential accommodation will be controlled to prohibit holiday accommodation or short-term lets less than 3 months in duration; (b) affordable housing to be provided on-site in accordance with Development Plan Policy; (c) residential density to be in accordance with the development plan; (d) a suitable mix of residential units, to include family accommodation, small private gardens and balconies. Representation ID 285: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. Policy SSA 14 is UNSOUND as ineffective: We are concerned at the proposal to include retail space since about half of No A1 retail space is proposed in the policy. It is considered that the Dolphin Quays retail spaces remain unlet after some 4 years. 16. In view of the controversy about the Dolphin Quays PCS23 adequately sets out the key issues in formulating an design, it is essential that the policy states the requirement that the architectural design is compatible with the appropriate design solution. neighbouring buildings and the height is restricted to no more than the Dolphin Quays. 17. Buildings on the quayside must relate to the water and ensure the quayside is well connected to the area behind with streets and alleys radiating from the water. There is a need for S106 contributions towards the establishment of the community use, introducing some public open space within the scheme, since the Council owns most of the land. Question 23: Policy SSA 15 – Land at Park Lake Road

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Representation ID 45: Mr S I Martin. No. It needs to explicitly mandate the retention of the pedestrian/cylist path from Poole Park past the Seldown eco-homes Policy SSA 15 amended to include additional bullet point requiring the and the Holiday Inn. retention of the existing pedestrian/cycleway link between Park Lake Road and Walking Field Lane. Representation ID 124: Meghann Downing, Highways Agency. Yes. Noted. Representation ID 241: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 15: Land at Park Lake Road meets the PPS12 tests of soundness. We would support Noted. leisure development considered appropriate for this location. This would include a facility supporting water based activities on the adjacent Poole Park Lake or informal public open space, or a mixed development incorporating these uses. This option has a chance of being deliverable. Representation ID 94: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. Policy SSA 15 is strongly supported in ensuring that the site is not allowed for commercial or housing development. Noted. Question 24: Policy DM 6 – Accommodation for an Ageing Population Representation ID 18: Mr David Williams, Planning Associate, The Planning Bureau Ltd., on behalf of McCarthy and Stone Retirement Lifestyles Ltd. Accommodation for the ageing population is quite rightly given a higher profile in the emerging Development Management This policy builds upon strategic objective laid down in the Core Polices DPD compared to previous Development Plan policies and will be a very significant planning issue in the next 30 Strategy to Meet Poole‟s Housing Needs. Poole Core Strategy Policy years as the proportion of the population over 60 (para 5.1 of DPD) increases at a very high rate. Policy DM6 quite rightly PCS7 Care Homes and Policy PCS8 Lifetime Homes contained acknowledges a need for a wide range of high quality, well designed accommodation for the ageing population. This specific requirements for elderly persons accommodation but was should be amended to emphasis the benefits and role played by Owner Occupied Retirement Housing.(OORH) The silent on alternative types of new development suitable for the older Department of Health and Communities and Local Government document „Lifetime Homes, Lifetime Neighbourhoods - A generation, such as assisted living or retirement communities. A National Strategy for Housing in an Ageing Society‟ dated February 2008 takes this further in looking at the wide range of criteria based, flexible policy sets out the framework for securing high options that policy makers need to include in formulating future plans. The Strategy identified providing a positive vision quality homes, picking up on meeting best practice in design. It is for specialised housing and providing more homes and more choice through public funding and encouraging private unnecessary to pick out every government publication or guidance sector provision through planning system reforms(para 27). The strategy also noted that the vast majority of older document. However, it was important to pick up on the HAPPI householders (68%) owned their own home in 2001, and the figure was projected to rise to 75% by 2026. As such, these principles which can be applied to care/nursing homes, extra care people are expected to wish to maintain their own independence by continuing to own their own homes. Owner Occupied accommodation and retirement communities equally and it is important Retirement Housing such as that provided by McCarthy and Stone meets such a need. At the same time this meets other to have a consistent approach. The benefits of well designed internal planning policy objectives in terms of sustainable development, maximising the use of brownfield sites, freeing up the circulation and shared spaces, promoting natural surveillance, local housing market, boosts to the local neighbourhoods, energy efficient flats, improved health facilities and reduced designing to maximise opportunities for social interaction should be impact on the NHS as well as a higher quality of life for its residents. Chapter 11 of the Lifetimes Homes strategy encouraged in new retirement properties as it reduces isolation and

63 specifically deals with specialised housing identifying that there is a continuing need for specialised housing and that such mental health issues, particularly for the older/retired generation. accommodation will continue to offer a certain advantage over private housing, particularly to those who need a physical These principles are essential to well-being of residents and to the environment designed for those with impairments, better access to help and care, company and a sense of safety. In the creation of sustainable communities. provision of appropriate accommodation for the elderly it is also recognised that the private sector has a major strategic role in this. National Planning Policy guidance contained in PPS3 also has regard to the ageing of the population and the implications it will have on housing needs. Paragraph 21 of PPS3 identifies that authorities should have particular regard to “the current and future demographic trends” and also “older and disabled people”. Paragraph 69 of PPS3 also advises that in determining applications for residential development, Local Planning Authorities should have regard to achieving a good mix of housing reflecting the accommodation requirements of specific groups, in particular, older people. It is welcomed that the The Sites and Development Management DPD has become more positive towards accommodation for the ageing population but this does not go far enough in our view. Retirement Housing and Assisted Living Close Care brings older people closer to transport links, local shops and services reducing car dependency. It enables older people to release equity, It frees up the housing chain, reduces under occupation and meets the wider Core Strategy aims of retaining and enhancing much needed housing stock to families (85% of McCarthy and Stone customers downsize from houses to move to retirement housing), it creates opportunities for more efficient provision of local care services eg GP services, reduces the need for respite care after hospital stays, offers a supportive setting with close family, neighbours and house manager, reduces pressure on working families to provide informal care and it makes optimum use of centrally located brownfield sites. Reference is made to the HAPPI report as an example of good practice guidance and the policy goes on to list criteria included which a development should reflect. On face value the list appears to repeat most of the conclusions of the HAPPI report itself. McCarthy and Stone generally support the principles of the HAPPI report however Policy DM6 places undue prominence to this report when there are alternative well founded solutions available depending upon the specific site constraints, location and the most efficient design of a scheme for a particular site. Many of which have been tried and tested over a number of years and may not follow all the aspirations of the HAPPI report. eg the negative reference to internal corridors. On many sites these are critical in enabling schemes to provide efficient sustainable buildings, communal areas and homely features in a viable effective way. The criteria as set out in Policy does not appear to be applied to non age restricted flats. This is not a consistent approach and is again unnecessarily prescriptive for retirement properties. Other criteria such as making public access available is unrealistic and unreasonable to specialist retirement housing where safety and security is paramount. Whilst invited guests and family are welcome along with the occasional function, to open the scheme up to wider public access would compromise the principles and characteristics of such a development. A typical edge of town centre retirement housing scheme in a single block of say 45 apartments has very different characteristics to a retirement community/village of say 150 + people where greater flexibility of space, communal day centres, and interaction will lend itself to greater public access. Setting this out in the main policy is not justified. The conclusions of the HAPPI report should be considered as one of several options and best practice available without dictating a particular aspirational design approach. The policy should be amended accordingly to reflect this. McCarthy and Stone are the leading retirement housing specialist in the Country having developed over 40,000 retirement / care apartments over the last 40 years or so and have undertaken extensive research and appraisal of its developments to provide a form of accommodation that is overwhelmingly supported by its residents. The most recent and up to date of which has just been completed by the University of Reading by Professor Michael Ball entitled "Housing Markets and Independence in old Age: Expanding Opportunities." Amongst this detailed report a survey

64 and assessment was undertaken of residents living in OORH. Amongst the conclusions there is strong support for the established OORHs which may not include all of the HAPPI criteria. Reference is made to considering Healthcare implications within the policy which on face value appears to be singling out older persons accommodation as being a drain on local resources within the healthcare system, unlike open market flats. In the majority of cases the development of Owner Occupied Retirement Housing will reduce the drain on local healthcare resources. A large proportion of residents will be from the local area and will retain existing GP and healthcare contacts and the economies of scale with a number of people requiring similar services at one location will aid and reduce the cost of delivery of certain healthcare facilities. Again this is supported by the Professor Hall research paper. An objection is also therefore raised to this aspect in isolation when the appropriate mechanism for delivering healthcare infrastructure, where justified, will be through the CIL. Representation ID 28: Mr Peter Tanner, Tanner & Tilley, on behalf of Pennyfarthing Homes. We generally welcome the inclusion of Policy DM 6 that encourages the provision of accommodation aimed at meeting Proximity to local services, amenities or community hubs is essential the special needs of the elderly. However, we consider that the following changes should be made to the policy. Whilst for sustainable communities to grow. It would not be justified to single sheltered housing and some types of assisted living development rely on having a close proximity and easy access to out care homes and extra care development and exclude them from local shops and services and good access to public transport, care homes and Extra Care development providing for the being built within close proximity to local services and facilities. It is very frail elderly are not so reliant on having close proximity to local services, amenities, local centres or community hubs essential as people grow older to ensure that they can access local with high levels of community activity. Therefore, proposals for care homes and Extra Care development providing for the services easily. The staff and services that regularly attend to elderly very frail elderly should not be precluded from locations that are not in close proximity to local services, amenities, local residents and maintain the lives of the occupants often rely on close centres or community hubs. Therefore, we suggest that the following be added to the end of criterion i - " i) It is located links with shops and transport routes to enable them to travel. Those close to local services, amenities and local centres or community hubs with high levels of community activity (with the residents who are mobile can feel feel less trapped if shops are hard to exception of care homes and Extra Care development providing for the very frail elderly, which development is not so get to on foot. It is important that any new building is accessible to reliant on having close proximity to those facilities);....ii)"Whilst best practice guidance referred to in the policy such as that everyone, regardless of age, or health or disability and provided by Housing our Ageing Population Panel for Innovation (HAPPI) is generally supported, there are some aspects that a neighbourhood is sustainable in terms of housing, public of that guidance that is not wholly endorsed by many in the care sector. In particular, it is considered that whilst services, civic space and amenities. opportunities should be taken to design schemes without internal corridors or single aspect flats, this may not be possible in many cases because of particular site constraints or site orientation. That is not to say that schemes with internal corridors or single aspect rooms or apartments are unacceptable, per se. Such a restrictive criterion could seriously impede what might otherwise be acceptable development from proceeding and could seriously impact on the amount of care accommodation that could reasonably be achieved on certain sites. Therefore, we suggest that the fifth bullet point be deleted from Policy DM 6. More generally, the Local Planning Authority should recognise that Care operators such as our Clients are far more experienced and better placed than the Local Planning Authority to determine how best to design the internal arrangements of care accommodation to provide attractive and successful schemes for their elderly residents. Therefore, such internal arrangements should not be prescribed by the Local Planning Authority. Representation ID 46: Mr S I Martin. No. It's too restrictive. Comment noted. Representation ID 96: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks

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Neighbourhood Watch and of the Southern Poole Chairmens' Group. In view of the strong forecast increase in 65+ aged residents we support Policy DM 6, but want to ensure that there are Comment noted. adequate parking spaces at such accommodation, since elderly persons are retaining their cars with growing affluence. The updated Parking & Highway Layout in Development SPD (2011), sets out required car parking provision for care home developments. Representation ID 125: Meghann Downing, Highways Agency. Yes. Noted. Representation ID 217: Gareth Morgan, Director, Nathaniel Lichfield & Partners, on behalf of Talbot Village Trust. We suggest one minor change to criterion iv to make it justified. We suggest the words "or for the care of other residents The wording used in the policy relates to those forms of care provision who would have no impact on the heathland". The change is to ensure that the policy cannot constrain development that considered acceptable by Natural England with 400 metres proximity to should be acceptable. It does this by identifying the test that would have to be passed. a designated healthland habitat. Representation ID 242: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy DM 6: Accommodation for an Ageing Population meets the PPS12 tests of soundness. Noted. Representation ID 259: Mr Jamie Sullivan, Tetlow King Planning, on behalf of South West Housing Association Registered Provider‟s Planning Consortium. We support the use of a criteria-based policy on this matter but do not consider it sound in its current form. We are The respondent has failed to supply any evidence to support his concerned that the current wording is too restrictive and may reduce the ability to bring forward high quality development contention that the policy is unsound or that the policy would be in sustainable locations, rendering the policy unsound due to it not being deliverable. We consider a more flexible policy is undeliverable. Aspects of the suggested wording are incorrect or are required that makes allowance for a range of developments, suitable to their locality: repeated from other guidance/policies that would be considered in new “Proposals for development that help to deliver a range of high quality, well designed accommodation for the growing development proposals. Location, quality of internal space and space ageing population of Poole, including residential care homes, nursing homes, close care, extra care and assisted care standards are essential considerations when determining applications housing; and in particular Continuing Care Retirement Communities, will be permitted where due regard is shown to:- for a range of accommodation for the elderly population. Care Quality Commission and other operational requirements; It is essential, as people grow older, to ensure that they can access Locational sustainability; suitable sites at defined settlements will be prioritised, but where such sites are not local services easily. The staff and other services that regularly attend available regard will be had to the availability of public transport, submitted green travel plans and the potential to elderly residents and maintain the lives of the occupants often rely for development to be self-contained, thereby reducing travel requirements; on close links with shops and transport routes to enable them to travel. The potential to co-locate a nursing/residential care home and other care related accommodation on the site Those residents who are mobile can feel less trapped if shops are hard where there are demonstrated needs. to get to on foot. It is important that any new building is accessible to The Council will also work with its partners in identifying suitable sites and securing the provision of schemes.” everyone, regardless of age, or health or disability and We do not consider the restriction of care home developments for people with dementia and the frail elderly in close that a neighbourhood is sustainable in terms of housing, public proximity to designated heathland habitat to be appropriate. The above suggested text would instead place emphasis on services, civic space and amenities. the need for locational sustainability, allowing enough flexibility for the Council to negotiate with developers. We do not consider that there is a need for the text on internal and external environment requirements. In its current form the policy may place a heavy burden on development management officers. Furthermore, we do not consider the restrictions to be justified. Incorporating our recommended amendments into the policy ensures that development

66 proposals come forward having been designed according to industry standard operational requirements. We strongly support text on CCRCs as being justified and effective. To ensure effective monitoring, the Council should indicate in the Monitoring and Implementation section that the targets and milestones will be kept under review and updated in accordance with relevant evidence of need. Question 25: Policy DM 7 – Talbot Village – House in Multiple Occupation Representation ID 126: Noted. Meghann Downing, Highways Agency. Yes. Representation ID 173: Mr Nick Squirrell, Natural England. Natural England support this policy and advise you that the area covered falls within the Consultation Area for the Dorset Comment noted. Heathlands, as such your authority may wish to consider the proposal in light of the Habitats Regulations and the effect of increased recreational pressure which could arise from not implementing this policy. Representation ID 218: Gareth Morgan, Director, Nathaniel Lichfield & Partners, on behalf of Talbot Village Trust. We consider that the inclusion of the Policy SSA19 site as an area to which an Article 4 Direction may be applied is not It is understood, following discussions with representatives of justified. The provision of 450 units of the student accommodation on this site will reduce pressure for HMOs by providing Bournemouth University and their appointed consultants, that the 450 student accommodation. However, should the decision be made to retain the policy, we consider first, that the criteria set units of student accommodation proposed as part of the Talbot Village out within the policy are reasonable but secondly, that the policy should set out that the Article 4 Direction will not be Trust application will be provided for housing first year students only. introduced immediately but only be introduced if there is evidence from the initial stages of development that a cluster or The pressure for additional HMO accommodation in Talbot Village concentration of HMO properties is likely to arise such as would result in material harm to the character and amenity of could stem from the accommodation needs of students studying the surrounding residential area and neighbouring properties (i.e. the considerations in criterion ii of the policy). This beyond the first year of courses and the approach adopted by should avoid introducing an unnecessary Article 4 Direction. Bournemouth Borough Council in restricting levels of HMO development through the implementation of a Borough-wide Article 4 Direction, particularly its effect on nearby Winton/Moordown. Representation ID 243: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy DM 7: Talbot Village - Houses in Multiple Occupation meets the PPS12 tests of soundness. Noted. Question 26: Policy SSA 16 – Bournemouth and Poole college Site, Constitution Hill Road Representation ID 127: Meghann Downing, Highways Agency. Yes. Applications at this site are likely to meet the criteria for a „major planning application‟, in which case the Agency will Noted. need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 244: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 16: Bournemouth and Poole College Site, Constitution Hill Road meets the PPS12 tests of Noted. soundness.

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We also support the consideration of the impact of new development on the character and appearance together with the setting of the locally listed building (Lady Russell Cotes House), on the site. Question 27: Policy SSA 17 – St. Mary‟s Maternity Hospital, St. Mary‟s Road Representation ID 128: Meghann Downing, Highways Agency. Yes. Noted. Representation ID 245: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 17: St. Mary's Maternity Hospital, St. Mary's Road meets the PPS12 tests of soundness. Noted. We would support the development of a care/nursing home facility providing a minimum of 50 bed spaces or a health or medical facility or a community facility or a residential scheme that could incorporate an element of extra care accommodation. Question 28: Policy SSA 18 – Bourne House, Langside Avenue Representation ID 129: Meghann Downing, Highways Agency. Yes. Noted. Representation ID 246: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 18: Bourne House, Langside Avenue meets the PPS12 tests of soundness. Noted. We would support the development of a care home that will deliver a minimum of 50 bed spaces and believe that this development could be deliverable. Question 29: Policy SSA 19 – Land south of Wallisdown Road, Talbot Village Representation ID 29: Mrs Nicola Brunt, Urban & East Dorset Living Landscapes Manager, Dorset Wildlife Trust. We do not consider that Policy SSA 19 passes the test of soundness and object to the current proposal. We do not A Public Inquiry into the decision of the Borough of Poole to grant consider this site is suitable for standard residential development and are submitting a representation to the public inquiry. planning permission for development on land south of Wallisdown We consider the best alternative use would be to develop a Suitable Alternative Natural Greenspace (SANG). Road, Talbot Village, will commence on 12th July 2011. The policy relating to this development will be amended if/as necessary to reflect the outcome of the Inquiry. Representation ID 130: Meghann Downing, Highways Agency. Yes. Noted. Representation ID 178: Mr Nick Squirrell, Natural England. No. On 9 June 2010 the Council resolved to grant approval for the:"Development of land to provide 450 student units with A Public Inquiry into the decision of the Borough of Poole to grant ancillary facilities and 3,500 sqm of academic floorspace (2.88 ha), 378 new housing units (11.42ha) public open space planning permission for development on land south of Wallisdown including a buffer strip, pedestrian and cycle links and vehicular access from Boundary Road, Gillett Road, Purchase Road, Talbot Village, will commence on 12th July 2011.

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Road and Cutler Close. Improvement works to heathland (15.64ha) including changing use of existing grazing areas (10.7 The policy relating to this development will be amended if/as necessary ha) for nature conservation purposes, creation of swales/reedbeds, installation of fire hydrants and creation of fire access to reflect the outcome of the Inquiry. to heath and erection of cat proof fence. To include associated infrastructure and landscaping". (Application 00/08824/084/P). This was against the advice of Natural England and in the face of significant local opposition. The application was "called in" on 27 September 2010, and will be heard at a public inquiry in July 2011. The allocation site lies within 400m of internationally important wildlife sites and in Natural England and RSPB's opinion, the current proposal (which policy SSA19 effectively reproduces) raises significant concerns over potential impacts on the integrity of those sites. Natural England's letter to the Council on 5th March 2010 sets out our objection, and the issues this proposal/allocation raises. Natural England and RSPB are presenting a joint case at the forthcoming Inquiry where issues will be debated. We consider that no decision to allocate this site should be made before the Secretary of State has determined the application as it would be difficult to deliver the proposed allocation in the face of a contradicting application decision. Given the policy constraints upon the site set out in the Council's own Core Strategy, we are extremely disappointed by the limited exploration of alternative uses of the site which have not been undertaken for this site. Alternative uses are mentioned within SSA19 but are not explored in supporting text in any meaningful way. Indeed Council officers working on the successor to the Dorset Heathlands Interim Planning Framework (IPF), the forthcoming Joint Dorset Heathlands Development Plan Document, have identified the site as a significant opportunity for promotion as a SANG. As is noted in paragraph 2.53 of the draft DPD, opportunities for new public open space are limited in the Borough. Natural England support the investigation of this site for alternative uses including as SANG. Representation ID 204: Mr Renny Henderson, Conservation Officer, RSPB South West Region. No. On 9 June 2010 the Council resolved to grant approval for the: “Development of land to provide 450 student units with A Public Inquiry into the decision of the Borough of Poole to grant ancillary facilities and 3,500 sq m of academic floorspace (2.88 ha), 378 new housing units (11.42 ha) public open space planning permission for development on land south of Wallisdown including a buffer strip, pedestrian and cycle links and vehicular access from Boundary Road, Gillett Road, Purchase Road, Talbot Village, will commence on 12th July 2011. Road and Cutler Close. Improvement works to heathland (15.64 ha) including changing use of existing grazing areas The policy relating to this development will be amended if/as necessary (10.7 ha) for nature conservation purposes, creation of swales/reedbeds, installation of fire hydrants and creation of fire to reflect the outcome of the Inquiry. access to heath and erection of cat proof fence. To include associated infrastructure and landscaping”. [Application Should this decision be refused by the Secretary of State, the uses 00/08824/084/P]. This was against the advice of Natural England and in the face of significant local opposition. The flagged up in this policy demonstrate the Council‟s approach to application was „called in‟ on 27 September 2010, and will be heard at a public inquiry in July 2011. The allocation site lies reasonable, deliverable, alternatives uses on the site. within 400m of internationally important wildlife sites and in our and Natural England‟s opinion, the current proposal (which policy SSA 19 effectively reproduces) raises significant concerns over potential impacts on the integrity of those sites. Our letter to the Council of 15 March 2010 sets out our objection, and the issues this proposal/allocation raises. The RSPB and Natural England are presenting a joint case at the forthcoming inquiry where the issues will be debated. We consider that no decision to allocate this site should be made before the Secretary of State has determined the application as it would be difficult to deliver the proposed allocation in the face of a contradicting application decision. Given the policy constraints upon the site set out in the Council‟s own Core Strategy, we are extremely disappointed by the limited exploration of alternative uses of the site which have been undertaken for this site. Alternative uses are mentioned within SSA 19 but are not explored in supporting text in any meaningful way. Indeed, Council officers working on the successor

69 to the Dorset Heathlands Interim Planning Framework (IPF), the forthcoming Joint Dorset Heathlands Development Plan Document, have identified the site as a significant opportunity for promotion as SANG. As is noted in paragraph 2.53 of the DPD, opportunities for new public open space are limited in the Borough. The RSPB support the investigation of this site for alternative uses including as SANG. Representation ID 215: Gareth Morgan, Director, Nathaniel Lichfield & Partners, on behalf of Talbot Village Trust. We support the principle and most of the detail of Policy SSA19 and the supporting text subject to the minor points made We welcome support for the policy. Changes suggested have been below. We consider that the policy does meet the test of soundness, is justified and effective and will make a significant made to the policy and map. contribution to meeting development needs in Poole. We have several points which relate to accuracy or drafting. These are as follows: 1. The location map on page 73 appears to omit a small area of land at the northern end of the site adjacent to the roundabout which lies within the planning application site and on which development has been supported by BoP. For ease of reference, we attach a copy of the application boundary in this part of the site (appendix 1) we suggest the location map is amended to accord with this. 2. In the third line of the section dealing with the infrastructure implications “supporting” has been typed twice. 3. In the bullet point to para 5.16 we suggest that “including” in the first line is substituted by “and”. This is because the treatment of the 10.7 hectares of the existing grazing area is additional to the improvement works to the existing 15.64 hectares of heathland. 4. In the first line of the second para of policy SSA19 replace “within” by “with”. 5. In the penultimate line of policy SSA19, the brackets should be closed after “Bournemouth”. Representation ID 247: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy SSA 19: Land south of Wallisdown Road, Talbot Village meets the PPS12 tests of A Public Inquiry into the decision of the Borough of Poole to grant soundness. We feel that this policy as it stands would be undeliverable, until the outcome of a Public Inquiry, which is planning permission for development on land south of Wallisdown anticipated to commence in mid-July 2011. Road, Talbot Village, will commence on the 12th July 2011. The policy relating to this development will be amended if/as necessary to reflect the outcome of the Inquiry. Representation ID 95: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. Policy SSA 18: We trust that the Secretary of State will reject the application for housing and student accommodation at Noted. Talbot Village since this is in breach of the European law and Dorset Heathland Regulations as also stated in Policy SSA 17. Question 30: Policy DM 8 – Accessibility and Safety Representation ID 19: Mr Peter Tanner, Tanner & Tilley, on behalf of Pennyfarthing Homes. It is considered that for the Infrastructure provisions of Policy DM 8 to be consistent with National policy, the text of the The „Delivering Poole‟s Infrastructure‟ DPD provides for funding of policy should include the following - "...Development will therefore be expected to contribute to offsetting the additional development to be delivered through CIL where it meets the tests

70 effects upon the transport infrastructure network having regard to the tests set out in S.122 of the Community according to the CIL Regulations 2010. Infrastructure Levy Regulations 2010, namely that the contribution is:- (a)necessary to make the development acceptable in planning terms; (b)directly related to the development; and (c)fairly and reasonably related in scale and kind to the development...."Without acknowledgement within the policy that those tests will be applied, it is considered that the application of the policy may not be justified or consistent with national policy. Representation ID 54: Ms Helen Jackson, Senior Transport Planner, Borough of Poole. p76 Section on LTP3 needs updating as this document has now been formally approved by all three local highway Noted. LTP3 was adopted during the consultation period. Long, authorities. This section should also mention the South East Dorset Transport Study (SEDTS) and how the Preferred medium and short term measures in LTP3 to reflect the adopted Strategy relates to the LTP. Should also check that the short, medium and long term measures are the measures quoted document, have been amended in the text, where necessary. in the LTP. Developer contributions are secured via s106 Agreements. The p80 Under Infrastructure heading - last sentence refers to CIL, but no mention of the South East Dorset Transport provisions of SEDTCS will be subsumed into CIL in due course where Contributions Scheme (SEDTCS). contributions meet the tests according to CIL Regulations 2010. Representation ID 64: Mr Harry Alexander, Open Spaces Society. Where it details cycling and walking, why is there no inclusion of Public Rights of Way? This should also encompass Public rights of way are comprised of cycle routes and footpath links, horse riders. The consultation that Borough of Poole has had with both the Ramblers Association and the British Horse The policy is clear in that new development would be expected to Society will be of much interest in this aspect. extend and link with existing routes. Representation ID 98: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. The Policy DM8 is UNSOUND in terms of deliverability since there is a delay in changing from S106 provision of funding The improvements set out in the policy reflect those in the adopted ALL infrastructure needs to the CIL, so many of these agreements are stalled. There needs to be an analysis of the CIL LTP3. Developer contributions are secured via s106 Agreements. The funds needed to meet the realistic transport infrastructure requirements. provisions of SEDTCS will be subsumed into CIL in due course. The „Delivering Poole‟s Infrastructure‟ DPD provides for funding of development to be delivered through CIL where contributions meet the tests according to the CIL Regulations 2010. Representation ID 131: Meghann Downing, Highways Agency. Yes. However the Agency has provided comments for the “Delivering Poole‟s Infrastructure DPD” to the effect that Noted. improvements to the SRN ought to be included as part of CIL funding. Representation ID 142: Meghann Downing, Highways Agency. We support the concentration of growth in the existing urban area and the emphasis upon sustainable transport options, Support noted. and in particular the importance placed upon pedestrian and cycle links and public transport improvements. Representation ID 153: Mr Graham Clarke, Strategic Planning Assistant, Dorset County Council. We are generally supportive of the content of this document and have identified no serious cross-boundary conflicts. We Noted.

71 are very pleased to see that due weight is given to the importance of sustainable transport in improving quality of life, Changes to the terminology have been made to the document to promoting healthy lifestyles, improving the quality of local environment and reducing carbon emissions. There are, reflect the provisions of the adopted LTP3. however, a number of inconsistencies between this DPD and the terminology, policies and timescales contained within LTP3 which should be resolved before the plan is adopted. These inconsistencies may have arisen because the List of schemes has been updated to be consistent with LTP3. documents were produced in parallel, during which time the policy landscape underwent considerable change. LTP3 has now been adopted and the following should be noted:- Support for the safeguarding of the Port Rail Link and Rail Freight The terms Bus Showcase Corridors and Urban Renewal Corridors are no longer in use and have been replaced by Facilities at Hamworthy is welcomed. Quality Bus Corridors and Prime Transport Corridors or Sustainable Transport Corridors respectively. References to the emerging status of LTP3 should be replaced by “adopted”. The phrase „demand management‟ (paragraphs 6.9-6.12) has caused some sensitivity at the consultation stage, and so care will be needed to ensure consistency with the wording in the final LTP. The policy document „Delivering a Sustainable Transport System‟ (7.12) no longer has the backing of Government, and references to it have been removed from the LTP. 1.4 Tables 7.3, 7.4 and 7.5 are contained neither within LTP3 itself nor within the Implementation Plan. Indeed they are quite contentious. There is debate about whether Cost Benefit Analysis (CBA) takes into account the wider economic, social and environmental benefits of sustainable transport interventions. As the tables stand, they convey the message that road schemes and junction improvements are better value than Sustainable Transport or Smarter Choices interventions. This contradicts the central thrust of LTP3. Therefore we suggest that the Cost Benefit columns be removed entirely. 1.5 The list of schemes and their timescales need to be made consistent with adopted LTP3. For example Table 7.4 states that Phase 2 Major Scheme bids are Medium term measures when in fact they have been deferred until after 2026. In Policy DM 8, there is also a need to ensure that the named schemes accord with the final LTP3/SEDMMTS programme. 1.6 With regard to specific schemes, we have some residual concerns over access to the Port and the Regeneration Area and about potential traffic impacts on the B3068 through Upton. It is to be hoped that the Poole Bridges Regeneration Initiative (PBRI) will lead to a reduction in through HGV movements on this route, and we look forward to working with BoP to ensure the installation of appropriate signage and Automatic Number Plate Recognition (ANPR) cameras to enforce the appropriate HGV route along Holes Bay Road. We therefore suggest that this DPD acknowledge these concerns and mitigation measures. 1.7 We are pleased to note the intention to safeguard the Port Rail Link and the Rail Freight facilities at Hamworthy. Representation ID 248: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy DM 8: Accessibility and Safety meets the PPS12 tests of soundness. The cumulative impact The improvements set out in the policy reflect those set out in the of forecast traffic growth from proposed housing and other developments require investment in new infrastructure, adopted LTP3. Developer contributions are currently secured via s106 including transport. Development will therefore be expected to contribute to offsetting the additional effects upon the Agreements. The „Delivering Poole‟s Infrastructure‟ DPD provides for transport infrastructure network. Initially this will be via s106 Agreements until as such time as this may be replaced by the funding of development to be delivered through CIL where introduction of the Community Infrastructure Levy in Poole. So many of these agreements are stalled or delayed. We contributions meet the tests according to the CIL Regulations 2010. would have to examine the actual amount of funds that will be available from the 106/CIL agreements. This would cause Policy DM 8 to be undeliverable.

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Question 31: Policy DM 9 – Demand Management Representation ID 55: Ms Helen Jackson, Senior Transport Planner, Borough of Poole. p.81 Demand Management. Paras 6.10 - 6.12 - these need updating (see comments on LTP3 - should check that the Noted. Changes to the terminology have been made to the document short, medium and long term measures are the measures quoted in LTP. p.82 Policy DM8 Demand Management. Under to reflect the provisions of the adopted LTP3 and the name of the Travel Plans heading - i. refers to the "emerging Parking and Development Layout SPD" - the name may have since Parking & Highway Layout in Development SPD. changed. Representation ID 97: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. The forecast growth in car ownership with growing affluence and the average increase in the number of cars per National forecasting using TEMPRO software to predict growth in car household is very worrying for cross conurbation commuting, when taken with the statement that the 48,000 extra ownership levels sets the context for the Demand Management Policy dwellings in the conurbation will mean 60,000 extra cars by 2026. This is going to lead to severe traffic congestion and and its criteria based approach where new development to be growing air pollution as was originally stated by Poole & Bournemouth Council representations to the Regional permitted. Poole‟s Housing Trajectory 2006-2026 was prepared from a Government. This challenges and questions the reality and need for 10,000 extra dwellings in Poole. body of evidence which established the need to provide for a minimum of 10,000 new dwellings in Poole over the plan period. Poole Core Strategy 2009 provides the spatial approach for providing additional housing requirement and recognises the front loading of housing provision in the first half of the plan period to 2016. Where appropriate, additional information such as Travel Plan and/or Transport Assessments may help to influence travel behaviour of individuals and organisations, to move towards more sustainable travel choices.

Representation ID 132: Meghann Downing, Highways Agency. Yes. We are very supportive of the emphasis placed on demand management within the document. We would like to see Noted. additional commentary provided to the effect that the A31 is operating in excess of capacity and that therefore any developments which come forward must demonstrate no impact upon the operation of the SRN. Demand management can be one effective mechanism of ensuring this. Representation ID 188: Margaret Baddeley, Senior Associate Director, Nathaniel Lichfield & Partners, on behalf of Bourne Leisure Ltd. Whilst Bourne Leisure endorses the Council‟s recognition of the need to reduce dependency on the car and encourage DM9: Demand Management is fairly well defined in terms of its scope, more sustainable forms of transport including walking and cycling, the Company considers it to be important that the as detailed by the criteria its sets out. The policy aims to promote emerging DPD (e.g. in amended paras 6.9-6.12 supporting draft Policy DM 9) acknowledges that there is usually a reduced dependency on the car, in line with the government agenda to necessary reliance on the car for many leisure and holiday-related journeys, due to the often rural, more remote and promote a wider shift to sustainable travel. Policy DM4: Tourism and coastal nature of tourism facilities. The necessity of car travel in certain tourism-related circumstances is recognised at the Evening Economy sets out the Tourist Attractions and Tourism

73 paragraph 5.3 in the CLG Good Practice Guide on Planning for Tourism, which states that: “Planners will need to Zones on the Proposals Map, this recognises the unique qualities of recognise that the wide variety of developments that are inherent in the tourism industry means that there are some these places. Where any expansion results in additional parking developments…. that are car dependent”. Paragraph 5.4 of the Guide continues, “There will be some occasions where requirements, these will be considered with supporting evidence, development for tourism is sought at a location where it will be difficult to meet the objective of access by sustainable against relevant Core Strategy policies, Development Management modes of transport…. Developers and planners may find that in such cases there will be limited opportunities to make the Policies DM4 and DM9, together with (emerging) Parking & Highway development accessible by sustainable modes of transport or to reduce the number or proportion of visits by car”. Bourne Layout in Development SPD. Leisure therefore considers that draft Policy DM 9 should be revised, to promote the use of non-car modes where possible, and to recognise the reality of car-based accessibility, particularly for tourism uses in rural and more remote coastal areas. In response to Question 31, Bourne Leisure, considers draft policy DM 9 to be unsound as it is not consistent with national policy. In the light of the above, Bourne Leisure considers draft Policy DM9 should be amended to read: “Demand Management Reducing the need to travel is a key priority and this can be promoted in a number of ways. It is however recognised that in some circumstances, such as development for tourism, there will be limited opportunities to make the development accessible by sustainable modes of transport or to reduce the number or proportion of visits by car. Parking and Development Layout Where appropriate, development will be permitted where it can be demonstrated in a supporting Design & Access Statement that proposed parking provision:- ….” Representation ID 249: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy DM 9: Demand Management meets the PPS12 tests of soundness. Again developers have Noted. to be constrained and comply with the Core Strategy, all the Demand management details, footfall and vehicular movements have been calculated in accordance with the Core Strategy. Without these constraints being observed policy DM 9 is bound to fail and be undeliverable. Representation ID 260: Mr Jamie Sullivan, Tetlow King Planning, on behalf of South West Housing Association Registered Provider‟s Planning Consortium. Whilst we support this policy we consider it would benefit from indicating the thresholds or triggers at which point a travel The thresholds and instances where development proposals require a plan will be required in support of a planning application. This will ensure the policy is effective which at present we do not Travel Plan are set out in existing Supplementary Planning Guidance consider it to be. entitled „Travel Plans – Guidance for Developers (April 2003). Question 32: Policy SSA 21 – Facilities for Park & Ride Representation ID 31: Mrs Nicola Brunt, Urban & East Dorset Living Landscapes Manager, Dorset Wildlife Trust. We support the need to undertake a survey of wildlife interest on land at Yarrow Road as part of the proposals and to take Noted. Any proposal on this site would require a Wildlife Survey to measures to ensure the protection on site or relocation of protected species. We consider that where possible habitat ensure protected on site of protected species. Poole Core Strategy features/protected species should be retained and managed long term on site. We also support the retention of the copse Policies PCS28: Dorset Heath International Designations seeks to at Marshes End and recommend due consideration is given to incorporating an appropriate buffer to protect the copse mitigate any adverse effects upon protected sites by ensuring and protection given to tree roots during development works. heathland management measures and warden services are secured as part of any new development in Poole. DM10: Green Infrastructure supports the maintenance and enhancement of biodiversity in

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accordance with the Dorset Biodiversity Strategy, South West Nature Map, Heathlands DPD and South East Dorset Green Infrastructure Strategy. Representation ID 47: Mr S I Martin. No. Very deficient. Needs Noted. New proposals for Park & Ride Development would be a) pedestrian/cyclist access from Creekmoor Bridge roundabout to Holes Bay North roundabout; expected to be considered in line with relevant development b) pedestrian/cyclist crossing over bifurcated Upton by-pass at Holes Bay North roundabout (identical to the existing management policies, including DM 6: Accessibility and Safety and DM crossing at the Holes Bay South roundabout) 7: Demand Management. c) tarmac pedestrian/cyclist path in west verge from Holes Bay North roundabout south to existing bridge over Fleets stream. I shouldn't have to explain to you why the Creekmoor park and ride failed, but I'm going to anyway. The journey takes 5 minutes from the site to the Holes Bay North roundabout, another 5 to the station and another 5 to the set- down/pick up point. The consequences are:- 3 times as much fuel cost; two buses and drivers to pay for instead of only one (else passengers face a half hour wait). a journey time acceptably long for potential passengers as compared to the time taken to drive to the town centre. Drivers from the west (the natural users) are forced to continue past the western entrance and double-back - stupid! Half the drivers coming from the north are disreagarded because one of the two disjoint road networks (Broadstone Way) has no signage. No gate halfway along the northern fence, nor an all weather path from Roberts Lane through to Northmead Drive, so preventing pedestrian patronage from Creekmoor residents. Clearly what is essential is the removal of the ridiculous access obstructions I have mentioned, plus a single lane road for buses connecting the eastern end of the site to the Holes Bay North roundabout, plus moving the set-down/pick up to Vanguard Road. Then the fuel cost is cut by two thirds, bus hire and wages by half, the journey time to 5 minutes and the maximum wait to 10 (all with only one bus) reducing the total delay incurred by motorists to 15 minutes, which is competitive against the drive all the way alternative. Then it might make money. Its hard to avoid the conclusion that reactionary elements within the council deliberately sabotaged the scheme. Representation ID 99: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. Para 6.16 : We support the withdrawal of land at Marshes End, Creekmoor for Park & Ride since it is liable for flooding Noted. and should be protected as a green open space. We do however support SSA 19 Park & Ride for Mannings Heath as being a better car access site. Representation ID 133: Meghann Downing, Highways Agency. Yes. We support the part which park & rides can play in reducing congestion. We would like to highlight that for any new Noted. park & ride site evidence would need to be provided to show that there was no detrimental impact upon the SRN. Representation ID 177: Mr Nick Squirrell, Natural England. It is known that this site supports European Protected Species and as such the policy wording at point ii is not adequate. Appropriate wording requested from Natural England. My comments regarding DM4 above apply here. Natural England objects to the policy in its current form but advise that it should be possible to agree to rewording before the Consultation stage.

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Representation ID 196: Mr Michael Holm, Planning Liaison Officer, Environment Agency. Sound, although there is no reference to the flood risk that affects the site in the policy and the necessity for the Comment noted. development of park and ride on the remaining site to be in accordance with PCS34. Core Strategy policy PCS 34 –Flood Risk, sets out the need for development in areas at risk from flooding to be the subject of a detailed Flood Risk Assessment which identifies the adaptation and mitigation measures needed to avoid the risk of harm from flooding. Representation ID 250: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy SSA 20: Facilities for Park & Ride meets the PPS12 tests of soundness. There is some The policy sets out the requirements for the provision of a Park & Ride confusion to this policy, because the policy refers to Facilities for Park and Ride, and in the middle of the Policy there is site at Mannings Heath. Due to the size and topography of the site reference to Bus Maintenance Depot Relocation. We would support the aspects of Park and Ride, as this would be a way there is also the potential to accommodate the relocation of the Wilts of reducing congestion in the town. Perhaps as part of the policy the relocation of the bus maintenance depot should be to and Dorset bus mainteneance depot from its town centre location, the Yarrow Road site, but there would have to be further policies to cover this aspect. Therefore we feel that Policy SSA although the supporting text points to the fact that there are a number 20 would be undeliverable. As part of the park and ride proposal for the Creekmoor site. Could a water taxi service be of sites in the Mannings Heath area that also have the potential to introduced to tranport users to the Quayside? Especially as a water taxi service is due to start from the new Marina Ro Ro meet this requirement. 1 to Dolphin Quays Marina. Representation ID 184: Mr Nigel Pugsley, Senior Planning Consultant BNP Paribas Real Estate, on behalf of Royal Mail and Parcelforce. Policy relates (in-part) to the allocation of land at Marshes End, Creekmoor for Park and Ride facilities. The Council may Noted. be aware that Royal Mail occupies premises close by at Upton Road. My client is supportive of policy which proposes the „de-allocation‟ of the eastern part of land set-a-side for Park and Ride facilities. Should the remaining land come forward for this purpose in the future, it is imperative that site operations do not impact adversely on Royal Mail operations in the area. Question 33: Policy SSA 21 – Local Centres – Priorities for Investment Representation ID 48: Mr S I Martin. Yes, but a pedestrian/cyclist link is needed between the Petersham Road cul-de-sac and the service road between the Comments noted. food store and the Creekmoor community centre. The potential for a pedestrian/cycle link between Petersham Road and the local centre service road could be explored through stakeholder engagement as part of the Development Brief process. Representation ID 100: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. The Policy is UNSOUND since there is a critical need for upgrading the Lower High Street and Lagland Street areas. The Lower High Street is the subject of Core Strategy policy PCS14 These must be added to the list. which sets out the future role and function for this area. Representation ID 134: Meghann Downing, Highways Agency.

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Yes. Noted. Representation ID 267: Mrs Ann Smeaton, Hamside Residents Association. We do not feel that the Policy SSA 21: Local Centres - Priorities for Investment meets the PPS12 tests of soundness. Comment noted. Hamworthy residents are disappointed that the main contributor to the Hamworthy Local centre has been allowed to trade The Development Brief approach proposed by the policy will provide a on a temporary planning permission (for nearly four years) providing a store that is totally inadequate to meet the needs of mechanism that will encourage key stakeholders to work in partnership such a large isolated community. with the local community to deliver improvements to Hamworthy Local Centre. Representation ID 251: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 21: Local Centres - Priorities for Investment meets the PPS12 tests of soundness. Noted. We would support these areas as priorities for Investment, which should be deliverable. Question 34: Policy SSA 22 – Hamworthy – Redevelopment Site Representation ID 135: Noted. Meghann Downing, Highways Agency. Yes. Representation ID 252: Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 22: Hamworthy - Redevelopment Site meets the PPS12 tests of soundness. We would Noted. support this policy, but we are well aware that the residents close to this site do not want any more affordable housing. They feel that they already have more that their fair share of affordable housing in the area. We believe that this Policy is deliverable. Question 35: Policy SSA 23 – Ashley Road Local Centre Representation ID 136: Meghann Downing, Highways Agency. Yes. Noted. Representation ID 253: Noted. Mr Christopher Allenby, Poole Old Town Conservation Group. We do feel that the Policy SSA 23: Ashley Road Local Centre meets the PPS12 tests of soundness and therefore should be deliverable. Question 36: Policy DM 10 – Green Infrastructure and Biodiversity Representation ID 34: Mr Justin Milward, Regional & Local Government Officer, Woodland Trust. Objection 1 Whilst we are pleased to see the opening statement in Policy DM 10 that: “Existing Green Infrastructure and biodiversity Comments noted. assets will be protected, maintained and enhanced in accordance with objectives set out in the Dorset Biodiversity Green Infrastructure and Biodiversity policy amended to incorporate Strategy, South West Nature Map, Heathlands DPD and South East Dorset Green Infrastructure Strategy‟, we would like suggested amendments.

77 to see this statement clearly include the expansion of priority UK BAP habitats like Native Woodland in accordance with national policy. Otherwise we consider that this Policy DM 10 is not sound. Reasons We would like to see clear and unequivocal support for a significant increase in native tree cover in Poole as a key element of green infrastructure, for all the benefits that native woodland can deliver. The UK is one of the least wooded areas of Europe, with just 11.8% woodland cover compared to around 44% for Europe as a whole, and Cornwall is one of our least wooded counties. The Woodland Trust is therefore working to achieve its ambitious aim of doubling native woodland cover over the next 50 years. Woodland creation is a key delivery component of Government policy to improve peoples‟ quality of life. Caroline Spelman, Environment Minister has set this out: “Now let me turn to our environment and, specifically, to our trees. Because if ever organisms demonstrated their ability to multi-task, it‟s trees. They capture carbon and hold soils together, prevent flooding and help control our climate”. (Speech at Angela Marmont Centre for Biodiversity, 20 May 2010). The Woodland Trust believes that woodland creation is especially important because of the unique ability of woodland to deliver across a wide range of benefits - see our publication Woodland Creation - why it matters (http://www.woodlandtrust.org.uk/en/about-us/publications/Pages/ours.aspx). These include for both landscape and biodiversity (helping habitats become more robust to adapt to climate change, buffering and extending fragmented ancient woodland), for quality of life and climate change (amenity & recreation, public health, flood amelioration, urban cooling) and for the local economy (timber and woodfuel markets). The UK Biodiversity Action Plan (http://www.ukbap.org.uk/default.aspx) makes it clear that expansion of priority habitats like native woodland is a key aim. Under section 40 of the Natural Environment and Rural Communities Act 2006, all public authorities now have a statutory duty to conserve biodiversity under the definition of „Conserving biodiversity includes, in relation to a living organism or type of habitat, restoring or enhancing a population or habitat‟. It therefore follows that public bodies such as Local Authorities should support the creation of more native woodland. In a letter to all Local Authorities calling for support for the Government‟s National Tree Planting Campaign („The Big Tree Plant‟), the Environment Minister Caroline Spelman has extolled the many virtues of trees: „Trees offer so many benefits to our citizens. They capture carbon and hold soils together, prevent flooding and help control our climate. They also add immeasurably to our quality of life by making areas more attractive and healthier places to live. In recent years the number of trees being planted annually across the country has declined, and could decrease further, unless action is taken to reverse this trend‟ (letter to all Local Authorities, 12th November 2010). An important publication from the Forestry Commission, The Case for Trees in development and the urban environment (Forestry Commission, July 2010), sets out „The multiple value of trees for people and places - increasing greenspace and tree numbers is likely to remain one of the most effective tools for making urban areas more convivial‟, and lists (on p.10) the benefits as- - Climate change contributions - Environment advantages - Economic dividends - Social benefits.

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The South West Forestry Framework Implementation Plan 2009-2012 (Forestry Commission, 2009, Action 2.3) highlights the need to “Encourage tree planting and woodland establishment”, and this is repeated in Action 3.6 – “Develop spatial framework for targeting tree planting and woodland creation”. Support for woodland creation is becoming widely embodied in the Local Development Plans process across the country and this is reflected in the draft South East Dorset Green Infrastructure Strategy referenced in this Policy. It states that: “Woodlands have suffered severe loss of area and are generally highly fragmented, albeit with some concentrated expanses on river valley sides and scarp slopes. Despite past losses woodland contributes substantially to landscape identity. Woodlands offer great scope for expansion, and can be restored or recreated on a wide range of soils and landforms”. Changes We would like to see the opening sentence of Policy DM 10 amended to (italics) – “Existing Green Infrastructure and biodiversity assets will be protected, maintained, (and) enhanced and expanded in accordance with objectives set out in the Dorset Biodiversity Strategy....”. Objection 2 We are objecting to the reference under the „Biodiversity Heading of DM 10/sub-heading „Local Sites of Biodiversity‟ to ancient woodland, specifically sub-paras iii & iv which weaken the protection offered. This is contrary to national policy, and is therefore unsound. In terms of compensatory measures, it is impossible to replace ancient woodland as this habitat has evolved over centuries and it is impossible to replace hundreds of years of ecological evolution by planting a new site or attempting translocation. Reason As mentioned above, ancient woodland represents an irreplaceable semi natural habitat that still does not benefit from full statutory protection: for instance 86% of ancient woodland in the South West has no statutory protection. This is particularly relevant as ancient woodland is still facing considerable threats - research from the Woodland Trust shows that in the last decade 100 square miles (26,000 hectares or 5% of the total amount of ancient woodland remaining in the UK) of ancient woodland in the UK has come under threat from destruction or degradation. Development threats associated with transport and infrastructure appeared to be the most significant (31% of cases), followed by amenity and leisure developments (14%), housing (10%), and quarrying and mineral extraction (6%). Although Poole contains only 0.24% ancient woodland cover compared to 2% for the whole of Great Britain, ancient woodland is our richest habitat for wildlife conserving more species of conservation concern than any other habitat (232 species as outlined in the UK Biodiversity Action Plan, 1994). The Coalition Government has signalled its intention to protect biodiversity: „We will introduce measures to protect wildlife and promote green spaces and wildlife corridors in order to halt the loss of habitats and restore biodiversity‟ („The Coalition - Our programme for government‟, May 2010). The „UK Forestry Standard‟ sets out the UK Government‟s approach to sustainable forestry. It states: “ancient semi- natural woods...are of special value.” The Standard has a series of UK-wide aims for semi-natural woodland and clearly states: “the area occupied by semi-natural woodland should not be reduced.” (Forestry Authority, 1998, UK Forestry Standard: Standard Note 5, pp.41-43).

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The Biodiversity Strategy for England clearly states that the Government will “take measures to prevent loss or damage to ancient woodland and trees, and their uniquely rich biodiversity, from development.” (DEFRA, 2002, Working with the grain of nature. A biodiversity strategy for England , para 6.9). Under section 74 of the Countryside and Rights of Way Act 2000, the Government has a statutory duty to publish lists of priority conservation habitats. Under section 40 of the Natural Environment and Rural Communities Act 2006, all public authorities now have a statutory duty to conserve biodiversity. The UK BAP targets includes a new Habitat Action Plan for Native Woodland which specifies a clear „maintenance‟ target of no more loss of ancient woodland - http://www.ukbap.org.uk/BAPGroupPage.aspx?id=98. It is therefore axiomatic that Poole Council has a statutory obligation to protect ancient woodland. The SW Forestry Framework (Forestry Commission, 2005) contains a key objective to „Protect, improve and manage Ancient Semi-Natural Woodland...”. As an example of policy used by other local authorities, the Sheffield City Policies and Sites Consultation draft (http://www.sheffield.gov.uk/planning-and-city-development/planning-documents/sdf/city-policies-and-sites) states in Policy G3: „New developments will be required to include appropriate tree planting, to retain and integrate healthy, mature trees and hedgerows and replace any trees that need to be removed. Development will not be permitted that would directly or indirectly damage existing mature or ancient woodland, veteran trees or ancient or species-rich hedgerows‟. Changes We would like to see ancient woodland given a separate sentence indicating that it will receive absolute protection from development. Representation ID 35: Mrs Nicola Brunt, Urban & East Dorset Living Landscapes Manager, Dorset Wildlife Trust. This section is broadly supported with the following points of objection: Broad support for policy welcomed. 8.16 The consider that reference should be made to the Dorset Nature Map, which identifies Strategic Nature Areas, Supporting text amended to include reference to Dorset Nature Map. including an area that extends from Canford Heath to north of Broadstone. Policy sections relating to SSSI‟s and Local Sites of Biodiversity – SSSIs - We consider that this policy should reflect PPS9 more closely. Reference should be included to the need to Should not repeat national policy. mitigate the harmful aspects of the development and where possible, to ensure the conservation and enhancement of the Policy text in respect of Local Sites of Biodiversity amended to reflect site‟s biodiversity or geological interest where development is permitted. suggested changes. Local Sites of Biodiversity - We consider this should more closely reflect PPS9. PPS9 Paragraph 11 indicates that policies Policy DM1 references role of new planting in development supporting and plan should include important natural habitat types that have been identified in the Countryside and Rights of Way Act wildlife thereby contributing to wildlife. Emerging Design SPD will 2000 section 74 list, (superceded by Section 41 of the Natural Environment and Rural Communities Act 2006) as being of provide further guidance on promoting opportunities to incorporate principle importance in the conservation of biodiversity in England and identify opportunities to enhance and add to them. biodiversity within the design of the development. These therefore need to be included alongside ancient woodland and trees. We recommend that development that could adversely affect Sites of Nature Conservation Interest (SNCI), Local Nature Reserves (LNR), Ancient Woodland and other habitats of principal importance for biodiversity should be resisted. We would suggest adding clearly outweighs to point (iii) We consider then that in (iv) the second proviso should be worded such that that where harm is likely to result developments will be expected to provide measures to avoid or mitigate that harm or, if significant harm cannot be prevented or adequately mitigated against, appropriate compensation

80 measures should be sought. If that significant harm cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused (PPS9( 1 iv)). We also consider that in this section should be policy to promote opportunities for the incorporation of beneficial biodiversity and geological features within the design of the development and reference to strategic approaches to conservation, enhancement and restoration of biodiversity. DWT would be pleased to discuss this policy further. Representation ID 101: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. Policy DM10 is UNSOUND since it is essential to insist that any land taken for development from Public Open Space and Policy wording amended to delete word „normally‟ so that text under Urban Greenspace must be replaced by an equal amount of land of equal quality. Public open Space and Urban Greenspace now reads “Proposals for development that would result in the loss of public open space and urban greenspace, as shown on the Proposals Map, will not be permitted except:-“ Criteria i and ii then require replacement by land of an equivalent or greater area and value to be provided in the same locality. Representation ID 137: Meghann Downing, Highways Agency. Yes. Noted. Representation ID 179: Mr Nick Squirrell, Natural England. Yes. Natural England welcomes the emphasis on green infrastructure (GI) in this chapter. It is important to recognise that We welcome support for this policy. different elements of GI will have different objectives and outcomes depending on their purpose, and with respect to Amendments, agreed with Natural England, made to supporting text initiatives such as SANGs, will have to meet strict regulatory requirements, in connection with mitigating potential harm to and policy that address comments. designated wildlife sites. Within Policy DM 10 we support the explicit highlighting of biodiversity. We would however comment that biodiversity should be protected and enhanced for more than just its own sake, but additionally for the social, economic and environmental benefits it brings. Natural England is pleased to note the comment on the ecological variety and value of biodiversity within the „surrounding environment‟. However we consider that development should also seek to enhance biodiversity within the built environment and this should extend beyond tree planting and landscaping eg multifunctional green roofs and SuDs. In paragraph 8.15, the text somewhat confuses habitat types and formal designations, this could be reworded to improve clarity by separating habitats (e.g. heathlands, wetlands etc.) from their designations (SPA, SAC etc.). Natural England would welcome the opportunity to meet with your officers to advise on re-wording. Representation ID 205: Mr Renny Henderson, Conservation Officer, RSPB South West Region. Yes. We welcome the emphasis on green infrastructure (GI) in this chapter. It is important to recognise that different We welcome support for this policy. elements of GI will have different objectives and outcomes depending on their purpose, and with respect to initiatives such Amendments, agreed with RSPB, made to supporting text and policy as SANGs, will have to meet strict regulatory requirements, in connection with mitigating potential harm to designated that address comments. wildlife sites. Within Policy DM 10 we support the explicit highlighting of biodiversity. We would however comment that

81 biodiversity should be protected and enhanced for more than just its own sake, but additionally for the social, economic and environmental benefits it brings. We were pleased to note the comment on the ecological variety and value of biodiversity within the „surrounding environment‟. However we consider that development should also seek to enhance biodiversity within the built environment and this should extend beyond tree planting and landscaping. In paragraph 8.15, the text somewhat confuses habitat types and formal designations, this could be reworded to improve clarity by separating habitats (e.g. heathlands, wetlands etc.) from their designations (SPA, SAC etc.). Representation ID 254: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy DM 10: Green Infrastructure and Biodiversity meets the PPS12 tests of soundness. The Dorset Heathlands contribution cannot be set aside otherwise Following on from our response the Question 16 last paragraph. We would support that a caveat is introduced whereby residential development would fall foul of the Habitats Regulations. this financial contribution can be lifted in the regeneration area due to need for increased S.106 funds in this area to be spent on town centre infrastructure rather than Heath land. Representation ID 261: Mr Jamie Sullivan, Tetlow King Planning, on behalf of South West Housing Association Registered Provider‟s Planning Consortium. We support the exception to the requirement to provide open space where the development is for „essential community Not considered necessary to specify forms of development that would purposes‟. We suggest this would include affordable housing developments as these provide an intrinsic benefit to the constitute „essential community facilities‟ as each proposed exception local community. To ensure the document provides clarity to developers and is thus effective, we recommend indicating would need to be considered on its merits and weighed against the the types of developments likely to be considered „essential‟, including affordable housing. loss of open space. Affordable housing would not be considered an essential community facility. Housing creates a need for open space whether affordable or not. Representation ID 189: Margaret Baddeley, Senior Associate Director, Nathaniel Lichfield & Partners, on behalf of Bourne Leisure Ltd. Development Management Policy 10: Green Infrastructure and Biodiversity – Support, with observations Bourne Leisure considers that the principle of the policy approach set out in draft Policy DM 10 in relation to the Policy DM5 specifically identifies Rockley Park as a tourist attraction consideration of development proposals on, or within proximity to nature conservation interests is broadly appropriate. and supports the redevelopment and upgrade of existing facilities With specific reference to Rockley Park however, the Holiday Park is abutted to the south and east by the Dorset Heaths subject to the safeguards specified in respect of identified and Poole Harbour Spa SSSI designations. As Rockley Park is allocated as a tourist attraction under draft Policy DM 5, environmental and visual assets. The proposed amendment is not Bourne Leisure considers that the text explaining draft Policy DM 10 should specifically recognise and confirm that there considered necessary as any development proposal would be is scope for appropriate development in and adjacent to SSSIs, provided that careful consideration is given to the detailed considered on its merits and would include a balanced assessment of design and layout of any proposed development, and that commensurate mitigation measures are implemented where all material considerations. necessary, to minimise both direct and indirect impacts. In relation to Question 36 therefore, Bourne Leisure considers draft Policy DP 10 to be sound, but requests that the following additional clarification is set out under the heading of Biodiversity in draft Policy DM 10, to ensure consistency across the emerging DPD with specific reference to promoting tourism development at Rockley Park: “… Biodiversity Natural features and processes distinctive to Poole‟s environment will be protected in the interests of supporting biodiversity. It is recognised that in some cases, allocations for potential development are located within proximity to

82 recognised biodiversity assets and the consideration of development proposals on these sites will adopt a comprehensive and balanced approach with specific regard to economic, social and environmental considerations. Sites of Special Scientific Interest (SSSIs)…” Question 37: Policy SSA 37 – Upton Country Park Representation ID 36: Noted. Mrs Nicola Brunt, Urban & East Dorset Living Landscapes Manager, Dorset Wildlife Trust. The provision of SANG and biodiversity enhancement is supported. Representation ID 49: Mr S I Martin. No. Why not use the extreme north-eastern field of Upton Park Farm to complete the development ring of Creekmoor, by The north-eastern field of Upton Park Farm lies within the South East allowing on this field, which lies between the Millfield sheltered housing and Nuthatch Close. Dorset Green Belt and part is covered by a „saved‟ Poole Local Plan First Alteration policy which reserves land for Educational Use. Representation ID 138: Noted. Meghann Downing, Highways Agency. Yes. Applications at this site could meet the criteria for a „major planning application‟, in which case the Agency will need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 180: Noted. Mr Nick Squirrell, Natural England. Yes. Natural England comments Natural England supports the identification of Upton Country Park and Upton Park Farm as having a potential for SANG. There is a potential role for the sites to contribute to mitigating pressures from residential development on protected heathlands, subject to further evaluation as well as the effects of climate change on Poole Harbour SPA and Ramsar. There is a need, as is recognised in SSA 24, to avoid harm to Poole Harbour SPA and Ramsar. Representation ID 206: Noted. Mr Renny Henderson, Conservation Officer, RSPB South West Region. Yes. We support the identification of Upton Country Park and Upton Park Farm as having a potential for SANG. There is a potential role for the sites to contribute to mitigating pressures from residential development on protected heathlands, subject to further evaluation. There is a need, as is recognised in SSA 24, to avoid harm to Poole Harbour SPA. Representation ID 255: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy SSA 24: Upton Country Park meets the PPS12 tests of soundness. We believe that Upton Comment noted. Country Park is kept open and run with the assistance of Volunteers, without the co-operation of these helpers the Policy Reliance of volunteers in the running of the Country Park is not an would be undeliverable. issue that can be addressed through planning policy, this being an operational matter. The proposed creation of SANG on the adjoining Upton Park Farm is essential to the delivery of development on the Regeneration Area sites. Question 38: Policy SSA 38 – Major Developed Sites in the Green Belt

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Representation ID 50: Mr S I Martin. Yes. But the dead-end pedestrian/cyclist route (Longfleet Drive) needs to be continued around this site to join up with the Noted. Canford Park area and sports ground. The issue of the pedestrian/cycle route does not impact on the purpose of the policy to allow for limited infilling/redevelopment within the Site Control Centre. Representation ID 102: Mr Terry Stewart on behalf of CPRE - Dorset Branch; Branksome Park, Canford Cliffs & Sandbanks Neighbourhood Watch and of the Southern Poole Chairmens' Group. The Policy on the Site Control Centre is UNSOUND in that it does not lay down restrictions on the site in case of request The „Major Developed Sites in the Green Belt‟ boundary defines that for expansion. Development must not result in any direct or indirect, individual or cumulative adverse affect upon the area of the Site Control Centre covered by the Minerals & Waste Local integrity of the adjacent Dorset Heathlands. Proposals that would result in additional trip generation associated with the Plan policy boundary, together with the adjoining area to the south- development/operation of the site, must be subject to a transport assessment to determine any impacts on the operation west, allowed on appeal for the expansion of the existing composting of the Strategic Road Network and identify the measures required to mitigate adverse impacts. facility. The supporting text clearly states that the future operation of the site will be the subject of review as part of the Bournemouth, Dorset & Poole Waste Core Strategy process. Representation ID 139: Meghann Downing, Highways Agency. Yes. As above, applications at these sites could meet the criteria for a „major planning application‟, in which case the Support for policy noted. Agency will need to assess the applications in accordance with the protocol as agreed in the MOU. Representation ID 150: Mr Robert Asquith, Planning Director, New Earth Solutions Ltd. I support the objectives of Policy SSA25: Major Developed Sites in the Green Belt, which proposes the 7.65ha Site Support for policy noted. Control Centre South of Magna Road site as such a major developed site, whereby limited infilling or redevelopment, in accordance with PPG2: Green Belts and ancillary to the composting and recycling facilities, will be permitted, subject to satisfying the two criteria set out in the Policy. Representation ID 256: Mr Christopher Allenby, Poole Old Town Conservation Group. We do not feel that the Policy SSA 25: Major Developed Sites in the Green Belt meets the PPS12 tests of soundness. We Representation refers to support for the proposals contained in the would support proposals for limited infilling or redevelopment that will be permitted within the boundaries of „Major policy, but does not provide reasons or evidence to support view that Developed Sites in the Green Belt‟, identified on the Proposals Map, as follows:- Canford School, Canford Magna the policy would not be deliverable. Facilities that support and enhance the educational functions of the school, provided that: development does not affect the setting of listed buildings or the distant views of them. Corfe Hills School, Broadstone Facilities that support and enhance the educational functions of the school that: Do not exceed the height of the main school building. Site Control Centre south of Magna Road Development that is ancillary to the composting and recycling facilities on the site, provided that:- Development does not result in any direct or indirect, individual or cumulative adverse effect upon the integrity of the adjacent Dorset Heaths International designated habitat. Proposals that would result in additional trip generation associated with the development /operation of the site, will be subject to a transport assessment to determine any adverse impacts on the operation of the Strategic Road Network and identify the measures required to mitigate adverse impacts.

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Our concerns would be that the above policy would not be deliverable. Question 39: Monitoring Framework Representation ID 141: Meghann Downing, Highways Agency. Yes. Support noted. Representation ID 257: Mr Christopher Allenby, Poole Old Town Conservation Group. We believe that the whole monitoring process and observation process that is being carried out by local associations is The monitoring framework set out in the Monitoring and being encouraged by the Borough. This stretches the association‟s resources far in excess that might have been Implementation section will be the responsibility of Planning & considered by the Authority. It is excellent that consultation is occurring, but until the process is streamlined from Regeneration Services to administer and, as appropriate, provide experience obtained, the monitoring process is still too top heavy and therefore the framework will become ineffective. analysis and progress against targets through the Annual Monitoring Report (AMR). Appendix 1: Schedule of Saved Policies Representation ID 3: Mr John Sprackling, on behalf of Branksome Park, Canford Cliffs & District Residents Association Replacing H10, BE23 and BE24 with PCS 23 will deprive us of some clear statements which have repeatedly over the last Character issues are dealt with by policies in the Core Strategy and 6 years prevented the overdevelopment of The Avenue Conservation Area. We would like the following statements to Development Management Policies. remain in policy: I do not consider that PCS 23 adequately replaces H10, BE23 and BE24 It should be made clear that in For conservation areas there is an additional layer of control through Conservation Areas of Low density development, their designation and the Management Plans for them. Plot severance or the combination of plots will be unacceptable, as will the erection of blocks of flats, terraced The emerging Design Supplementary Planning Document could housing or the conversion of properties into flats include further guidance in respect to this issue. Residential development should be single household detached dwellings (please do not reuse the words „take the form of‟ which have caused confusion). Representation ID 17: See Representation ID 3 above. Dr Alan Fisher If we accept that inspector Robert Mellor was correct when he made clear the importance of the supporting text when considering the policies in The Poole Local Plan First Alteration*, we fear that replacing H10, BE23 and BE24 with PCS 23 will deprive us of some clear statements which have repeatedly over the last 6 years prevented the overdevelopment of The Avenue Conservation Area. We would like the following statements to remain in policy: Plot severance or the combination of plots would be considered unacceptable, as would the erection of blocks of flats, terraced housing or the conversion of properties into flats Residential development should be single household detached dwellings (please do not reuse the words „take the form of‟ which have caused confusion). Much time, effort and rate payer‟s money has been expended restraining overdevelopment. Some of this might have been avoided by clear and unambiguous policy. PCS 23 is well written but we fear it might be even more open than previous policies to disputed interpretation. We are keen to avoid that if possible. *Appeal 2 Tower Rd., August 2006. APP/Q1255/E/05/1180556

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Representation ID 66: Ms Rose Freeman , on behalf of The Theatres Trust Appendix 1 on saved policies states at the top of page 153 that “national policy guidance is considered to provide National policy guidance identifies arts and cultural facilities as main appropriate guidance in respect of art and cultural facilities”. town centre uses. Core Strategy policy PCS 10 and DM 4 provide However, there is no national guidance on this matter - this statement is incorrect and we recommend a more robust additional support in respect of arts and cultural facilities. Poole Local Policy DN3 to be re-titled Town Centres and to include effective guidance for existing and future „other town centre uses‟ Plan policy L16 in Appendix 1: Schedule of „Saved‟ olicies amended to as well as shopping. reflect this. Whilst titled „Shopping‟, policy DM3 sets out the Key Principles for shopping and other town centre uses which includes arts and cultural facilities – no change to the policy is therefore proposed.

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