Core Strategy. Copies of Representations made for the Preferred Options Document. Part to November 2006

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1 Core Strategy Copies of Representations made for the Preferred Options Document Part to 2574 November 2006 Purbeck District Council Westport house Worgret Road WAREHAM, Dorset BH20 4PP Tel: (01929) Fax: (01929)

2 Contents: 2538 Scott Estate South West RSL Planning Consortium M N Hill, Moreton Association of Churches Together in Swanage and District Purbeck Housing Trust Purbeck Society Grainger Trust Dorset AONB English Partnerships C G Fry & Son UKAEA Winfrith Rempstone Estate Charborough Estate

3 2538 Scott Estate CORE STRATEGY PREFERRED OPTION CONSULTATION RESPONSE FORM Respondent: Representation: Group ref: Date Acknowledged: Response form for supporting or objecting to the Purbeck Local Development Framework CORE STRATEGY Preferred Options document Details Name: Organisation (if applicable): Address Telephone no: Agent s name (if applicable): Cliff Lane Acting on behalf of the Scott Estate Agent s address (if applicable): Wessex House Wimborne Dorset BH21 1PB Telephone no: clane@savills.com Signature: Date: 9 November

4 Aid to making representations: The test of a Development Plan Document is whether it is sound i.e. whether the content of the Plan is clear, robust, conforms to other plans and strategies and is capable of implementation. Comments should therefore be submitted on this basis rather than concentrating on individual words and their relevance. Q1. Spatial Vision for Purbeck In your opinion does the preferred option for a spatial vision provide a sense of what kind of place Purbeck will be in the future? No Please elaborate on your answer: In order to reflect the wider social, economic and environmental goals of sustainable development, the vision should include a reference to the needs of the economy. The vision should be amended to read:..supporting a strong and diverse economy, and improving the quality of life of the whole community. 4

5 Q2. Spatial Planning Objectives In your opinion, do the Spatial Planning Objectives set out in Section 3 correctly interpret the Vision for Purbeck? No Please elaborate on your answer: Whilst the overall intentions of the spatial objectives are supported, there are particular concerns over the wording of objectives SO3 and SO4. Objective SO3 implies that the housing needs of the area are identified in the RSS. This is not the case although the RSS identifies a level of future housing provision for the district, this is not the same as future housing need. For example the latest housing needs survey for Purbeck identifies a need of 349 affordable homes per annum, whilst the draft RSS only makes provision for 105 dwellings per annum. The draft RSS acknowledges that projections indicate that 25,000 new dwellings per annum are needed in the South West, but only about 23,000 dwellings per annum are provided for. The second part of SO3 should be deleted so that the objective is simply: To meet the housing needs of the area. Objective SO4 is unclear it refers to the provision of new market and affordable housing that meets local needs in terms of type and tenure, but does not refer to quantity, which is the most important aspect in terms of meeting community needs. A significant level of demand for housing in Purbeck comes from outside the district, this needs to be acknowledged and some form of provision made, otherwise the situation in relation to local needs will worsen significantly. SO4 should be amended to read: Support active communities through the provision of new market and affordable housing that meets local future needs, in terms of quantity, type and tenure. Do you have any views to add in response to the links with the Community Strategy for Purbeck? No 5

6 Q3. Preferred Option 1 - Sustainable Development Preferred Option 1: Support Q4. Preferred Options 2-12 Environment Do you support or object to any or all of Preferred Options 2-12? Preferred Options 2-6: Support. It is important that a positive planning framework is established that recognises the potential for new development to contribute to the protection and enhancement of nature conservation, landscape and the built environment. Preferred Option 7: Object Although the principle of renewable energy generation in new development is supported, the policy as currently worded fails to recognise the potential contribution of energy efficiency measures to reducing carbon dioxide emissions. For example, measures such as passive solar design, natural ventilation, district heating and combined heat and power generation offer significant energy efficiency improvements and reduced carbon dioxide emissions. The scope of the policy should therefore be widened and re-worded to encourage measures to improve energy efficiency and reduce carbon dioxide emissions (in addition to the minimum standards required by building regulations) alongside domestic scale renewable energy generation. The policy will need to define what is meant by small scale residential development. Preferred Options 8-12: Support. 6

7 Q5. Preferred Options Thriving Communities Do you support or object to any or all of Preferred Options 13-28? Preferred Option 13: Support The recognition that key villages play an important role in the settlement strategy for Purbeck is supported. The potential of many towns in Purbeck to accommodate new development is limited by environmental factors. Locations with fewer constraints where a range of services and facilities are present will therefore play an important role in accommodating development and enhancing self containment. Stoborough has potential to accommodate additional housing development and ancillary facilities in a manner which would enhance the self containment of the village. The identification of Stoborough as an area of search for new housing development on Key Diagram 2 is suggested in recognition of its potential to deliver sustainable growth. It should be identified as part of Wareham which is identified as a main settlement for growth or as key village. Preferred Option 14: Object The principle of re-development of previously developed land in sustainable locations is supported, however the preferred option should reflect the search sequence set out in paragraph 30 of PPG3, which specifies the re-use of previously developed land and buildings within urban areas followed by urban extensions. The policy should therefore be amended to read: Previously developed land and premises that are within or adjoining well related to existing settlements should be brought forward for re-use and / or redevelopment prior to the release of green field sites. Preferred Option 15: Object The housing requirement set out in the draft RSS does not provide for sufficient new homes to allow Purbeck to meet its housing needs. A higher level of housing provision is required to address the historic under-provision of housing in Purbeck, the high house price to income differential in the district, and the acknowledged shortfall in housing provision across the region. Paragraph suggests that the housing requirement proposed for Purbeck of 105 dwellings per annum is slightly lower than past completion trends which have on average totalled 137 net dwellings per annum It is in fact is 25% lower than past completions, and would result in the provision of 640 fewer homes over the RSS period. This potential decrease in housing provision is considered significant (rather than slight), and should be presented as such in the Core Strategy. Paragraph will need to clearly identify what the housing needs (both market and affordable) of the district are, and to what extent they will be met by the housing provision set out in the Core Strategy. Reference should be made to the Housing Needs Survey Update 2006 which suggests that 349 dwellings per year alone are needed to meet affordable needs. The overall need is higher still when account is taken of the need for market housing. Should the level of housing provision in the final RSS fall short of the actual housing needs of the district, it is important that the Core Strategy identifies the level of under provision and explains the reasons for it. Preferred Option 17: Object Stoborough should be seen as a key village or as part of Wareham in order for it to develop in a sustainable way. 7

8 Preferred Option 18: Support A broad area of search for housing around the major settlements of Swanage and Wareham is supported. Stoborough should be included in the search area around Wareham if it is not regarded as a key village in its own right. Preferred Option 19: Object The objective of ensuring that new housing developments achieve a balanced mix of dwelling size, types and tenures is fully supported. However, the focus should not be on the provision of smaller units at the expense of family homes. The need for a proper mix of housing including new homes for families was emphasised by Housing and Planning Minister Yvette Cooper in a recent speech and will feature in the forthcoming national policy guidance in PPS3. The last part of PO19 which states in particular through the provision of 1 and 2 bed units should be deleted from the policy, and paragraph amended to reflect a more balanced approach. 8

9 Preferred Option 20: Support Preferred Option 21: Object Whist the provision of affordable housing as part of new housing developments is supported, the last sentence of PO21, which states that a higher proportion of affordable housing may be sought on site specific housing allocations, is considered inappropriate. The possibility of an increase in affordable housing over the 40% level set out in policy will introduce significant uncertainty for developers, is likely to affect the viability of development, will restrict the potential to deliver other planning benefits, and does not support the delivery of a balanced mix of market and affordable housing provision. The most effective means of increasing the level of affordable housing provision is by increasing the overall level of housing provision in the plan. Preferred Options 22 23: Support Preferred Option 24: Support Preferred Option 25: Support Preferred Option 26: Object The intention of this policy to retain community facilities is fully supported. However, the policy and supporting text should acknowledge that new residential development can make an important contribution to securing the future of community facilities. Preferred Option 27-28: Support 9

10 Q6. Preferred Options Economic Wellbeing Do you support or object to any or all of Preferred Options 29-35? Preferred option 29: Support Preferred option 30: Support Preferred option 31: Support Preferred option 32: Support Preferred option 33: Support This section of the Core Strategy would also benefit from a section specifically relating to the rural economy and the challenges that face farming such as changes to the CAP, global warming, globalisation and the changing economics of food production, and the need for diversification. The core strategy should support farm diversification projects such as the growth of locally distinctive produce or produce grown for local markets which minimise food miles, on-farm or local processing which adds value to locally grown produce, including forest and woodland products, and alternative (non-food) crops for sustainable energy production or other purposes. Preferred option 34: Support Preferred option 35: Support 10

11 Q7. Preferred Options Accessibility and Transportation Do you support or object to any or all of Preferred Options 36-40? Preferred option 36-37: Support Preferred option 38: Object The aim of strengthening the A35 / C6 corridor is fully supported as one of the key components of the Purbeck Transport Strategy. The delivery of the Purbeck Transport Strategy is vital to the future economic performance of the district and the quality of life of its residents. Based on the anticipated level of grant funding from the Government, about two thirds of the total cost of the highways improvements will need to be met by contributions from developers. However, the amount and rate of growth planned for the district will not be sufficient to deliver the level of contributions needed to cover the anticipated private sector funding to allow for the construction of these important highway improvements. The current level of contribution per new dwelling is high, and any further increases are likely to be resisted by the house building industry, particularly given the likely costs associated with the proposed planning obligation framework, and the additional costs of incorporating renewable energy and sustainable drainage systems within new development. Furthermore, a levy on employment development is at variance with the Council s desire to regenerate the economy and revitalise WTC as a major knowledge-based employment centre. Whilst housing policy should not be driven by infrastructure needs alone, these needs are considerable and combine with other demographic and housing need factors to indicate that a higher rate of growth is justified. An increase in the housing requirement to at least 195 dwellings per annum could raise an additional 6.7m, sufficient to cover the shortfall in funding and allow for the removal of the levy on employment. Preferred option 39-40: Support Q8. Preferred Options Swanage Preferred Options Support PO47 particularly supported which would see small scale urban extensions to Swanage. Q9. Preferred Options Upton Preferred Options 48-52: Support The settlement strategy for Upton is supported as it recognises that the potential for development is constrained by Green Belt, floodplain and nature conservation sites, and states that no green field housing land releases are envisaged in this area. 11

12 Q10. Preferred Options Wareham Preferred Options 53-54: Support Preferred Option 55: Object If Stoborough is not seen as a key village in its own right it should be seen as an area to meet Wareham s expansion needs Preferred Option 56-57: Support Q11. Preferred Option 58 Wool, Winfrith & Bovington Preferred Option 58: Support Q12. Preferred Options South Purbeck Preferred Options 59-63: Support 12

13 Q13. Preferred Options Mid-North Purbeck Preferred option 64 68: Support Q14. Preferred Option 69 Planning Obligations Preferred Option 69: Support Please elaborate on your answer: Support, subject to the comments made in response to PO38 regarding the need to increase the level of housing provision in order to deliver level of developer contributions necessary to fund the delivery of the Purbeck Transport Strategy. Q15. Key Diagram What are your views on the Key Diagram? Is it clear? Is it helpful? If Stoborough is not regarded as a key village it should be included within the circle covering Wareham. 13

14 Q16. Draft Sustainability Appraisal The Core Strategy Preferred Options document is accompanied by a Draft Sustainability Appraisal. Please make your comments on the Draft Sustainability Appraisal in the space below (continue on a separate sheet if necessary). The summary of key sustainability issues facing Purbeck refers to housing being expensive in relation to salaries, and suggests that this is exacerbated by people form outside the area buying second homes or investment properties. This fails to acknowledge the link between housing supply and house prices, and the historic under provision of housing against strategic targets in Purbeck. The review of key documents in appendix 1 should be updated to include the Barker Review of housing supply, and commentary on the problem of housing affordability in Purbeck should recognise the link between house prices and the level of housing provision. Q17. Draft Proposals Map The Core Strategy Preferred Options document is accompanied by a Draft Proposals Map. Please make your comments on the Draft Proposals Map in the space below (continue on a separate sheet if necessary). Do you wish to be notified of when the Core Strategy has been submitted to the Secretary of State for Independent Examination? Do you wish to be informed of the publication of the Inspector s report following the Examination? Yes Yes Do you wish to be informed of the adoption of the Core Strategy? Yes Response forms must be retuned by 4pm Friday 10 th November 2006 to: Community Planning and Policy, Westport House, Worgret Road, Wareham, BH2 4PP Or attach as an ldf@purbeck-dc.gov.uk If you have any queries, please contact Brett Spiller (Tel ) 14

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46 2561 Grainger Trust From: Sent: 06 November :44 To: -ldf Subject: Web submission - LDF Form company = Purbeck District Council name = Allen Creedy organisation = Grainger Trust Plc postcode = NE3 1YL = allen.creedy@btclick.com telephone = question_one = no question_one_comments = Details are provided in the formal representations from the company. Certain of the prefered options may be sound but some are considered lacking in sufficient detail, are ambigiuous or are technically questionable to the point where they do not adequately demonstrate that that they are sound. question_two = object question_two_comments = Details are provided in the formal representations from the company. As above limited support and limited objections raised. question_four_comments = detailed comments are provided in the representations of the company question_six = yes question_seven = yes question_eight = yes 46

47 SUBMISSION OF REPRESENTATIONS ON BEHALF OF GRAINGER TRUST PLC CONCERNING THE DRAFT CORE STRATEGY FOR PURBECK DISTRICT COUNCIL Introduction We are instructed by Grainger Trust plc with respect to the submission of consultation responses to the Core Strategy Preferred Options document published for public consultation on 29 September Grainger Trust plc is a substantial land owner in the immediate vicinity of Bere Regis. The company has a particular interest in providing affordable housing and rural workspace for this community within the context of establishing sustainable rural communities. Grainger Trust plc recognise that the community of Bere Regis is continuing to suffer de-population of the young, loss of shops and services and is increasingly simply fulfilling a dormitory function to larger settlements. Grainger Trust plc support the broad intentions of Purbeck District Council in seeking to address many of these issues as they pertain to settlements within the District, but overall believe that a more positive, proactive foundation to the Core Strategy will be necessary if tangible long term benefits are to be achieved in reality and for the strategy to demonstrate soundness. One of the necessary key issues for the final Core Strategy to demonstrate its soundness will be to include the measures required identify and deliver in policy terms, the means by which the Council s aspirations can actually be delivered on the ground. Many of the core strategy policies provide considerable detail on means of constraint, but offer little in the way of outlining mechanisms by which sought after developments can actually be brought to fruition. Simply allocating land and establishing developing control criteria is unsound and unlikely to be sufficient, particularly in more sensitive rural areas, where development issues are more complex. We would encourage Purbeck District Council to recognise that because of the high levels of environmental and other constraints that apply in particular to this District, the achievement of policy objectives will not be assisted without an imaginative and forward thinking approach to real delivery on the ground. Our Client s comments with regard to the Core Strategy are therefore founded with this overall objective in mind and to assist in now making the strategy sound.. Grainger Trust plc wishes to aid the council in understanding how development at Bere Regis would assist in meeting many of the spatial and policy objectives of the core strategy. A variety of development options in and around Bere Regis have been tested against known policy constraints. From this testing Grainger have prepared a 'diagrammatic illustration' showing one (of many) development options that is considered to meet the aspirations of the core strategy. This is enclosed with this submission. This 'diagrammatic illustration' is for illustrative purposes only and should not be taken as a definitive development proposal or a formal request for a site specific allocation at this stage in the adoption of the core strategy. The illustration does demonstrate a sound foundation for 47

48 a holistic approach to the various strategic issues outlined in the Core Strategy and how the aims of the council could be beneficially applied to this settlement. Granger Trust plc is concerned to protect and to enhance the natural environment in and around Bere Regis. To further this concern it has commissioned independent consultants to carry out detailed ecological research to inform its own future land management and the future site specific allocation work. Grainger Trust plc has met with the Environment Agency, Natural England, Dorset Wildlife Trust and other major stakeholders - to test its development ideas against their policies. It is considered that a development similar in nature and scale to that shown in the illustration is in accordance with the current polices of these stakeholders. Subject to the proposals being underpinned and substantiated by the necessary technical and supporting information no reason can be seen for the stakeholders to object.. Further information and supporting evidence will be provided in due course. We now set out below responses to individual elements of the Core Strategy Document:- CORE STRATEGY - REPRESENTATIONS Policy SO4 Support SO5 Qualified Support This spatial objective might be better phrased as follows:- To meet the needs of and address the impact resulting from an ageing population, SO6 Qualified Support It is not simply enough to identify and allocate employment land to meet the needs of local firms and inward investment. Over 80% of businesses in the UK are micro in nature; ie. with less than 10 employees. This sector is particularly characteristic of rural areas where large traditional employers are not found to the same extent and where there is a high preponderance of self-employed individuals. It is almost exclusively the case that such small businesses cannot and do not acquire land and build their own accommodation. They have neither the time nor financial capacity in most cases to do that. Such small businesses must rely on the provision of appropriate, flexible and well managed facilities but often find the traditional business park does not satisfy their requirements. Affordable workspace is just as important as affordable housing, particularly if the aspiration is to create mixed and vibrant communities where people can work closer to where they live. Accordingly, there is need for the polices of the core strategy to encourage, facilitate and positively provide for local, flexible, adaptable and affordable workspace. Policy SO6 should additionally seek to encourage the development of incubator facilities through partnerships with landowners and developers. The policy should be phrased to proactively commit the local authority and its partners to positively encourage the provision of workspace within Purbeck, both urban and rural. Policy SO7 Qualified Support Grainger Trust plc supports the ambition of this policy. However we do not believe that this Policy commitment to increasing employment opportunities, through encouraging innovation and business growth should be limited only to the established sectors of the knowledge based economy. Grainger Trust plc fully supports the thrust of the policy but consider that the policy should apply to all employment sectors, including the new sectors. 48

49 Whilst the aspiration to secure employment in higher wage sectors is admirable, this again does not necessarily place the wider requirement of providing a quantum of businesses that can meet a diverse range of employment needs across all wage sectors. With some 40% of the employable workforce in Purbeck commuting out of area every day for their employment, the principal strategic objective should be to claw back some of those employees into more localised employment; whether in the hi-tech industries or any other. It is the view of Grainger Trust plc that the core strategy should support innovation and business growth across all sectors, not just those which appear to be worthy at a point in time. They are often those which go by the wayside first in times of more challenging economic circumstances. Policy SO9 Qualified Support The phrasing of this spatial objective should recognise that any transport system will respond to the demand from users and that the transport patterns will arise from the spatial and development policies of the district council and others. It is necessary to include in the policy the word "sustainable", recognising that new employment; shopping and residential development should be provided in ways that supports sustainable mobility patterns. And those developer obligations, partnerships and the allocation of land for new development should be carried out in parallel to enhancing the sustainable mobility of settlements. Policy SO10 Qualified Support As a statement, this is an aspiration seemingly without foundation. What are the means of achieving such reinforcement? These should be spelt out. Grainger Trust plc supports the thrust of the policy and considers that its proposals for the development at Bere Regis will substantially assist in delivering this aspiration. Policy SO14 Qualified Support The core strategy recognises the difficulties that the council faces in reducing the emissions arising from existing and new development. However this spatial objective seems to again be merely seeking to encourage without significant commitment to proactive action to achieve targets. There is concern that the fragmented and isolated approach to meeting housing needs through small windfall sites will not allow the necessary additional renewable energy capacity to be afforded or provided. An alternative model for meeting housing needs through a small number of strategic housing sites with partners committed to providing renewable energy would allow the emission reduction strategy to be achieved. Grainger Trust plc supports the thrust of the policy and considers that its commitment to a low carbon development using ground source heat pumps, solar thermal and other renewable technologies at the development at Bere Regis will substantially assist in delivering this aspiration,. Policy PO1 PO4 Support Landscape Character Assessment of the District. With regard to paragraph 5.2.4, we would hope that there will be an opportunity for third parties to comment upon the methodology being used together with the conclusions of the 49

50 Landscape Character Assessment of the District currently being worked up by the Council in partnership with Dorset County Council and the Dorset AONB. We look forward to an early opportunity to participate in the separate public consultation mentioned as a precursor to approval as a supplementary planning document. Grainger Trust plc has commissioned independent detailed ecological, landscape and other surveys in the Bere Regis area to inform its views on the core strategy and in preparing its development proposals. Policy PO5 Object We consider that this Policy is unsound in defining its objective and unclear in the means proposed to achieve the objective. The wording is unclear, ambiguous and needs further clarification. It is suggested that the policy needs to distinguish two aspects to the policy, firstly the way in which new development should be sited to contribute and enhance the landscape through good design, through new planting schemes and through a commitment to its ongoing maintenance. And secondly there is a need to encourage and support landowners in their ongoing care and maintenance of the landscape, recognising the rapidly changing economic situation of farming and forestry and the need to diversify to provide rural enterprises that will generate the income needed to continue this work. Grainger Trust plc considers that its proposals for the development at Bere Regis will substantially assist in enhancing the local landscape character and will generate the necessary income for the management of the landscape in perpetuity. Grainger has prepared and enclosed supporting information to the illustrative diagram (referred to above). This demonstrates how on land under its control it would provide Suitable Alternative Natural Greenspace (SANGS) that would satisfy Natural England as part of any development option. Further details are enclosed as an Appendix 2 to this document. Policy PO7 Qualified Support Grainger Trust plc supports the objective of the policy. However the Council should note the omission of biomass in the list of opportunities, and this should be inserted as a bullet point. We would encourage the inclusion of biomass given the sizeable volume of biomass and wood waste that is available locally which could be used in both domestic and commercial biomass systems. Grainger Trust plc considers that its proposals for the development at Bere Regis will assist in meeting the targets referred to in para And are designed to meet the ambitions outlined in para to provide an exemplar low carbon development. Policy PO8 Support Policy PO9 Support Policy PO10 Object We consider that this Policy is unsound in its objective and unclear in the means proposed to achieve the objective. The wording is ambiguous and needs further clarification. There is concern that small scale developments will not be able to technically incorporate or afford to provide full "sustainable drainage systems"(suds). There is also concern that the need for 50

51 these systems should be decided on the merits of the allocation / application site and the ability of the allocation/ application site to assist in reducing local flood risks and improve water conservation. It is suggested that there are two aspects to the policy, firstly scale and extent to which new development incorporates sustainable urban drainage systems (SuDS) And secondly the way in which water efficiency in incorporated. Grainger Trust plc proposals for the development at Bere Regis are based on a commitment to provide full sustainable urban drainage systems (SuDS) and to assist in managing the flood existing and future flood risks through incorporating the latest technology and fixtures to improve water efficiency. Grainger has already met with the Environment Agency to discuss how a development at Bere Regis could assist in reducing the flood risk to the settlement and in protecting and enhancing the water catchment plan. Policy PO13 Support Policy PO14 No Comment Policy PO15 No Comment Policy PO16 No Comment Policy PO17 and Policy PO18 Qualified Support There may be merit in combining these preferred options as they effectively say the same thing. Para 6.3 Broad Location of New Housing. We are supportive of the need to reuse Brownfield land but remain concerned that relying on a large number of small windfall sites to meet the housing numbers will not allow the council to meet housing need, or to achieve the self containment of villages and towns. Based on existing housing allocation figures (para 6.3.1) it is the view of Grainger Trust plc that a significant proportion of the expected 350 new dwelling should be provided at a small number of strategic sites. And that at this site there should be agreements that provide for meeting the demonstrated housing needs of the district and provide for a "churn" in the housing market. Paragraph, It is not clear how allocation of housing sites as a measure will meet local needs and support the vitality and viability of shops, services etc. Land allocations alone will not achieve this and there is evidently no mechanism for supporting or delivering employment, services or other matters through this measure. Paragraph it is the view of Grainger Trust plc that the self containment of villages is inextricably linked to meeting the social, education and health needs of local people. Grainger Trust plc are concerned that there no land has been reserved for the new health centre, new community centre and possible need for a new school at Bere Regis. As these facilities are central to the health, vitality and self containment of Bere Regis, Grainger Trust wishes to provide land for these uses in its proposed development at the village. Paragraph The extent and scope of any potential extension to Bere Regis should be decided as a result of a comprehensive and transparent assessment. The relationship 51

52 between any new settlement extension and the development of the existing employment allocation is ambiguous in this paragraph. The explanation of the inspector's decision as given in this paragraph is incomplete. Any reference to the inspector's decisions should be given in full and cross referenced to the relevant sites or deleted. Para Grainger Trust plc consider that the housing needs of the district can be met more readily if the council adopts a more creative mix of policies and is committed to these being delivered in partnership with RSL and private sector partners providing More flexible approach to affordable housing definition that recognises the wider range of shared equity options, and "flexible tenure" options (Grainger Trust plc is willing to share its knowledge on this aspect) the positive encouragement of new retirement villages and new wardened accommodation with planning obligations over the release of subsequently vacated housing so that this remains as affordable housing Policy PO19 Qualified Support It is to be recognised however that in order to achieve this objective, housing developments will need to be of some size. Clearly this will not be achievable in a small affordable housing schemes or infill developments. Grainger Trust plc considers that its proposals for the development at Bere Regis will assist in meeting the housing needs referred to in para Policy PO20 No Comment Policy PO21 Qualified Support The definition of affordable housing is too narrow and the Council should consider a broader definition as outlined above that will stimulate movement in the housing market and the provision of an even broader mix of housing opportunity within the District. Policy PO22 No Comment Policy PO23 No Comment Policy PO24 No Comment Policy PO25 Support Policy PO26 Qualified Support The addition of "and new development" at the end of the policy would make this more comprehensive. Policy PO27 Support Policy PO28 Support Policy PO29 No Comment Policy PO30 Qualified Support 52

53 This should be couched in much broader terms and perhaps it may be helpful to omit the word new. Although there is an encouragement to mixed and sustainable development in the key villages, these are not referred to within PO30. In other locations, it may be appropriate to introduce a reference to the Government Guidance Note PPS7 as a means to determining what is and what is not appropriate in rural proposals. Policy PO31 No Comment Policy PO32 No Comment Policy PO33 Qualified Support This Policy is currently couched in too narrow a form and it may be better worded as follows:- Encourage the provision of "live-work" and "start-up units, incubator and/or serviced employment accommodation. From our experience it is virtually impossible to identify local areas in which a need for business start-up can be demonstrated. The latent demand for workspace, particularly in rural areas, is often only demonstrated by positively providing start-up and incubator units within an environment that encourages those latent and hidden businesses to emerge to occupy it. Given that Purbeck has a requirement throughout the District to provide new employment opportunities so as to retain its employable workforce more closely, there is effectively a need throughout the District and therefore it cannot be qualified at a more localised level. There is a need for the addition of "live work units" to reflect the growing popularity of these units for start-ups in the knowledge economy Policy PO34 No Comment Policy PO35 Qualified Support The preferred option is couched in too narrow terms. Simply retaining and enhancing existing holiday accommodation (or providing some additional holiday accommodation in Swanage and Wareham) will not in itself promote Purbeck as a year round tourist destination. There are many other aspects to tourism which require entirely distinct encouragement and support. Accommodation is but one measure. The policy needs to be expanded and reworded. Policy PO36 40 Support Chapter 14 Mid-North Purbeck It is not made clear in the Core Strategy why Bere Regis does not benefit from the creation of an Area Action Plan as proposed for other large villages within the District. If there are criteria against which such initiatives are judged then it would be helpful for these to be explained. Policy PO64 Object and Re-Word Policy PO64 could be re-worded as follows:- "Enhance existing shops, services, community facilities and employment opportunities 53

54 provided in Bere Regis; support new development within and as an extension to the built up area; support the development of an employment allocation, thereby helping to reduce the need to travel and increasing the self-containment. The extension of the built up area along the eastern edge of the built up area of the settlement is constrained by the extent of the South East Dorset green belt". Policy PO66 Object. Grainger Trust plc is concerned that the proposed approach in the core strategy to revising the green belt boundaries to accommodate development is unsound. Grainger Trust Plc support the retention of the existing green belt boundaries as defined and is concerned to ensure that these boundaries should be altered "only exceptionally" (PPG2 para 2.6) circumstances. Grainger Trust plc considers that the original purpose for the designation has not changed. And it is neither necessary nor desirable to review these boundaries because suitable sites for development exist elsewhere around Bere Regis that can be developed in accordance with the policies of the Core strategy and that such development will meet the aspirations of the Core strategy. Exceptional circumstances justifying the changes to the boundary do not prevail. (Note: there is an incorrect reference to a non existent paragraph ) Policy PO67 68 Support Policy PO69 No Comment Key Diagram Support Grainger Trust plc 1 st November 2006 Allen Creedy MRTPI Consultant to Grainger Trust plc. 28 Windsor terrace South Gosforth Newcastle upon tyne NE3 1YL tel & fax mobile allen.creedy@btclick.com 54

55 Appendix 1 Table showing the representations of Grainger trust Plc Policy Number Support (S) Qualified Support (QS) No Comment (NC) Object (O) SO4 S SO5 QS SO6 QS SO7 QS SO10 QS PO1 PO4 S PO5 O PO7 S PO8 S PO9 S PO10 O PO13 S PO14 NC PO15 NC PO16 NC PO17 AND PO18 QS PO19 QS PO20 NC PO21 QS PO22 NC PO23 NC PO24 NC PO25 S PO26 S PO27 S 55

56 Policy Number Support (S) Qualified Support (QS) No Comment (NC) Object (O) PO28 S PO29 NC PO30 QS PO31 NC PO32 NC PO33 S PO34 NC PO35 QS PO36 PO40 S PO64 O PO66 O PO67 PO68 S PO69 NC KEY DIAGRAM S 56

57 Appendix 2 Bere Regis - Provision of SANGS and Access Management Purpose Natural England are developing a strategy to mitigate potential in combination impacts on the Dorset Heathlands Special Protection Area (SPA), predicted to occur due to increased access for recreation as a result of an increase in residential properties within 5 km of the SPA. The strategy of mitigation measures is likely to include provision of SANGS, access and visitor management, and developer contributions towards managing SPA habitats and visitors. However, there has been a recent announcement concerning an interim arrangement of no objection from Natural England in relation to SPA issues for residential development within the 400m to 5km zone in return for a contribution of 1500 per dwelling. The provision of SANGS may still be required in the future. The proposal at Bere Regis has been developed in the expectation that SANGS will be required. SANGS Natural England has provided guidance on SANGS standards they expect to be provided. SANGS should be sufficient areas of land within a suitable location that can be provide an adequate alternative greenspace experience for the user to carry out recreation activities, such as walking and exercising their dog, in preference to visiting the SPA. For the Thames Basin Heaths SPA, the area of SANGS that Natural England consider suitable for new residential developments within zone B, between 400 m and 2 km from the SPA boundary, is 16 ha per 1000 new residents, using the national average of 2.4 people per household. If 350 dwellings were proposed at Bere Regis this equates to 840 people and hence an area of approximately 13.5 ha, which is over the minimum requirement of 12 ha for this zone. The SANGS should provide an informal and functional recreation area, safe pleasant walking opportunities, easy and clear access with good signage, non-restrictive entry points (i.e. gates rather than stiles), good but natural path surfaces, open space where dogs can safely run off the lead, a choice of lengths of walks, alternative routes, a variety of habitat types, and varied topography to provide a suitable alternative to the heathland SPA. There is opportunity as part of the Bere Regis proposal to provide SANGS on adjacent areas of land and improve existing open access land (i.e. Souls Moor Common). The existing land use of the proposed SANGS land is arable and so will need to made suitable by creating new habitat and paths which will need to be suitably managed in perpetuity. The illustrative plans accompanying these representations shows the location of existing public rights of way and open access land (identified under the provisions of CRoW), together with the location of proposed paths and SANGS open access land. Open access land There is scope to provide approximately 22.5 ha of new open access land on the arable fields between the proposed development and Black Hill Heath SSSI by creating new habitats. There is good structure around the edge of the fields in terms of natural woodland, mature hedges and boundary banks. The proposed habitat types are shown on the accompanying plan, and an overview of these and their management are as follows: 57

58 Herb-rich grassland these areas will be sown with an appropriate seed mix to create herbrich grassland that will be managed by grazing with cattle in autumn and winter to provide flower-rich grassland in the spring and summer. The vegetation type created will depend on further analysis of soils, but it is certain that it is more likely to support calcareous communities rather than acid (heath) vegetation. One field will be planted with a scattering of trees to add variety to the otherwise open field. Pasture woodland the northern boundary of the SSSI is secondary woodland and scrub and this habitat can be graded into the open herb-rich grassland by planting groups of trees in the grassland. This area will also be grazed and so can then become part of a pasture woodland habitat. Common Souls Moor Common is existing open access land which is in need of management and can then provide further recreation space. Again this area should be grazed, preferably by cattle, in order to provide a sustainable means of management. Furthermore, the area of common will need to be extended to compensate for loss of a small part to accommodate the access road. To ensure there is no conflict with dog walkers, people will be made aware of their responsibilities when using open access land through signage and new residents will be provided with an information pack which will highlight SPA issues and provide details of alternative areas and promote their use. Routes The proposed walking routes are linked to existing rights of way to promote access to the proposed SANGS open access land. A combination of use of existing and proposed paths will provide a range of walk lengths and alternative routes, taking the user through a variety of habitat types. Ends 58

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60 2562 Dorset AONB CORE STRATEGY PREFERRED OPTION CONSULTATION RESPONSE FORM Respondent: Representation: Group ref: Date Acknowledged: Response form for supporting or objecting to the Purbeck Local Development Framework CORE STRATEGY Preferred Options document Details Name: Doug Harman Agent s name (if applicable): Organisation (if applicable): Dorset AONB Team Address: The Barracks, Bridport Road, Dorchester. DT1 1RN Agent s address (if applicable): Telephone no: d.harman@dorsetcc.gov.uk Telephone no: Signature: D. A. Harman Date: 10/11/06 60

61 Aid to making representations: The test of a Development Plan Document is whether it is sound i.e. whether the content of the Plan is clear, robust, conforms to other plans and strategies and is capable of implementation. Comments should therefore be submitted on this basis rather than concentrating on individual words and their relevance. Q1. Spatial Vision for Purbeck In your opinion does the preferred option for a spatial vision provide a sense of what kind of place Purbeck will be in the future? Yes/No Please elaborate on your answer: This presents a sustainable and integrated vision for the future of Purbeck. The emphasis on environmental assets is welcomed in terms of protecting the high environmental value that the wider community and legislation places on the District. Q2. Spatial Planning Objectives In your opinion, do the Spatial Planning Objectives set out in Section 3 correctly interpret the Vision for Purbeck? Yes/No Please elaborate on your answer: Although many of the objectives are geared towards delivering sustainable development in context of Purbeck s unique environment, greater support for rural based economies and associated diversification are required. In fulfilling the environmental protection objectives within the plan, it is considered essential that recognition is given to supporting rural activity that in turn, provides for continued and enhanced management of the surrounding countryside. Do you have any views to add in response to the links with the Community Strategy for Purbeck? No Q3. Preferred Option 1 - Sustainable Development Do you support or object to Preferred Option 1? Support/Object Please elaborate on your answer: The recognition of environmental protection and local distinctiveness are welcomed. However, it should be noted that sustaining the environment should be delivered through the creation of thriving communities, economic well being and appropriate accessibility. This conforms to the approach of ecological thresholds within the emerging Regional Spatial Strategy. 61

62 Q4. Preferred Options 2-12 Environment Do you support or object to any or all of Preferred Options 2-12? Support/Object Please elaborate on your answer: PO 4 is considered too weak. Policy should go beyond encouraging enhancing character and should state that development will only be permitted if character is conserved or enhanced. Further reference is also required on local distinctiveness, sensitivity and tranquillity as key aspects of landscape character. DPOP are currently looking into a consistent countywide landscape policy which may provide an alternative to the suggested policy. P0 7 Although the renewable energy targets and policy are welcomed, policy on domestic wind turbines is currently being reviewed centrally. It should be noted that this policy may not apply to conservation areas. Q5. Preferred Options Thriving Communities Do you support or object to any or all of Preferred Options 13-28? Support/Object Please elaborate on your answer: PO 13 The promotion of development that addresses the functionality and self containment of market/coastal towns and villages is supported. This will help in achieving sustainable communities, and help to reduce the need to travel within a sensitive environment. 6.65/6 Use of the extensive Rights of Way (ROW) network and South West Coast Path has been omitted. Both provide opportunities for open air enjoyment and recreational activities as well as physical and mental health benefits to all age groups. Support for ROW and links to them can provide additional open space opportunities where new or existing residential developments may be limited in open space provision. 62

63 Q6. Preferred Options Economic Wellbeing Do you support or object to any or all of Preferred Options 29-35? Support/Object Please elaborate on your answer: As stated within the response on the Spatial objectives, a stronger policy on appropriate rural development is required in helping to sustain the wider landscape. Although South Purbeck and Mid Purbeck do contain polices on local economy, these should be strengthened in this section. E.g. Development will be permitted in the countryside where it supports the rural economy and communities and helps to conserve the countryside and where either it is: Necessary for the purposes of agriculture, farm diversification, forestry, recreation, tourism and other enterprises with an essential requirement to locate in the countryside, or For facilities which are essential to meet the needs of local communities which cannot be accommodated satisfactorily within built up areas, or For new uses in existing rural buildings consistent with the building s scale, massing, character and location, or For the extraction of minerals or the disposal of waste. In particular, isolated new houses and conversions in the countryside will require special justification. PO31 could be strengthened to include rural skills in support of the above objection. PO34 The requirement of travel plan is welcomed in helping to address the wider impact on the sensitive environment. Active promotion of Purbeck as a green tourism destination where visitors are positively encouraged to use public transport, rather than their cars, for their stay would be a positive step. Q7. Preferred Options Accessibility and Transportation Do you support or object to any or all of Preferred Options 36-40? Support/Object Please elaborate on your answer: PO 38 requires additional strength by the addition of in ways that respond to the local context and create or re-enforce local distinctiveness. Traditional approaches to highway design create intrusive engineered impact on the landscape/villagescape and it is essential that we not only ensure the safety of all highway users but achieve it in a way that minimises the impact on the surrounding environment and responds to local distinctiveness. 63