Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 385

Received: 05/02/2019

Respondent: Mr Pieter Montyn

Representation Summary:

AL 6 gives rise to serious questions around need for link road, river bridge, and housing in this location: situated in coastal and fluvial risk Flood Zones 2 and 3; road height, views of Cathedral and Downs, low public acceptance for Option 2; major development adjacent to AONB; employment land allocation three times what is required in HEDNA identified need;
no Sustainability Assessment.

Full text:

-no mention of Flood zones 2 and 3 with significant risk of flooding; see Policy S27, sequential test, exception test, DM18, 8 and 16 metres fluvial and coastal flood risk setback distances, etc;
no mention of Flood Risk Assessment and EA requirements.
-Para 5.54 in Flood Risk and Water Management section referring to coastal and fluvial flood risk states .'.. development needs must be strongly resisted in areas at risk of flooding.'
-no detail provided of Stockbridge link road and river bridge
-need to raise previously proposed link road estimate by 1 metre; after imminent publication by EA of revised 100 year sea level rise forecast, further raise will likely be required
- link road interference with views to Cathedral and Downs
-no mention of AONB buffer zone as previously required
-works are a major development within impact area of AONB and its SSSI and designated sites: raises obligations under NPPF and Rural Communities Act 2006 coupled with requirement to consult with Harbour Conservancy
-no evidence that CDC is having 'regard to the purpose of the AONB' as required under the PROW Act 2000 Section 85
-link road is part of earlier Option 2 which received very low acceptance
-why is there a requirement for a 'strategic open space and a managed country park' -these are not defined in the Glossary.
-33 hectares of employment land is postulated in this Policy; three times what is required to satisfy the 2035 HEDNA estimate in Policy S8 for 231,835 sq.m (or 23.2 ha) of additional floor space for employment: taking into account Para 4.52: 6 ha in AL1; 4 ha in AL 2, and 2.4 ha in AL 15, i.e. total of 12.4 ha, leaving 11 ha to be identified-not 33 ha; additional 11 ha can be distributed over other sites with better connections not requiring new road-see also entry under Meeting Business and Employment Needs paras 4.56 and 4.57
100 homes can also be redistributed elsewhere;
Stockbridge link road, introduced at late stage of PBA work,and justified by introduction of excess employment space and housing, should be removed from :Local Plan Review.
AL 6 is one of several strategic sites missing from the development location assessments in the Appendix of the Sustainability Appraisal document.