Name:
Organisation (if applicable):
UKAEA Winfrith
Agent’s name (if applicable):
Terence O’Rourke
Contact: Martin Miller
Address C/O Agent
Telephone no: E-mail:
Agent’s address (if applicable):
Everdene House Wessex Fields Deansleigh Road Bournemouth BH7 7DU Telephone no: 01202 421142 E-mail: [email protected] Signature: Date: 10th November 2006
Respondent: Representation: Group ref:
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
The spatial vision is generic and although its intention is clear it does not necessarily provide a sense of how the ‘place’ will be in the future. Indeed, it constitutes a catch all statement that could be used for any Local Authority rather than being tailored to the area.
It is emphasised that the Purbeck Futures Conference workshops clearly identified the quality of the District’s environment as being its principal asset, rather than the quality of the towns, villages,
countryside and coast. Accordingly it would appear appropriate for the vision to refer to this specifically as it is the areas unique component that sets it apart from other authorities.
Given the significance of economic issues in facilitating desired sustainable development, it is
Q2. Spatial Planning Objectives
In your opinion, do the Spatial Planning Objectives set out in Section 3 correctly interpret the ‘Vision for Purbeck’?
No
The objectives do provide a reasonable interpretation of the Vision, although it is considered that there are areas that would benefit from clarification, namely objectives 3, 6, 7, 10, 11 and 12. When considering SO3 it is important to note that the housing needs of Purbeck District and the level of housing provision identified for Purbeck within the draft Regional Spatial Strategy (RSS) are two separate issues. The draft RSS deals with strategic housing targets rather than the localised requirements of Purbeck. This is evident relative to affordable housing, with Purbeck seeking 349 units per annum, whilst provision is only made for a total of 105 dwellings a year in the draft RSS. Much demand for housing in the area comes from outside of the District, with consequent
implications for prices. There is a need to seek to address this for if it continues unchecked the situation with regard to local needs will become worse. UKAEA Winfrith is concerned that the objective is too broad giving no clarity on the location of new housing or the range of factors that will be used to inform locational decisions.
It is a further concern to note that the objectives do not recognise the need to ensure that new employment development is located close to existing residential development and on sites that are, or have potential to be, well served by public transport. SO9 alludes to the importance of
accessibility and integrated transport, but with the exception of the A351 does not make it clear what this entails or how it will be secured.
The encouragement of increased employment opportunities at S07 is to be welcomed. The role of a high quality environment and sites well served by infrastructure should also be recognised,
particularly in the attraction of high-end employers.
It is encouraging to see that the key role that previously developed land can play in responding to the development needs of the District is recognised at SO12, although the objective would benefit from elaboration to emphasise that it does not just relate to employment, but also residential and mixed use developments. Linkage back to SO6 in this regard would be useful.
An objective which brings together the importance of linking employment development to residential development, aiding travel patterns and options, would be useful, rather than treating the two uses as being mutually exclusive.
As these objectives stand, we question whether they are compliant with the fourth, seventh and ninth tests of soundness set out in PPS12.
Q3. Preferred Option 1 - Sustainable Development
Do you support or object to Preferred Option 1?Support
UKAEA Winfrith considers that it is right that the value of the District’s environment, particularly its natural environment, is recognised and given protection. This of course means that new development needs to be focused on the areas of the District that are not constrained.
The economic well being of the District is an important consideration and appropriate employment provision in accessible locations, or areas that have the potential to be well served, can serve to prevent outward commuting.
Q4. Preferred Options 2-12 – Environment
Do you support or object to any or all of Preferred Options 2-12?Support
It is considered that energy efficiency can play a significant role in reducing emissions, something that PO7 does not recognise. Accordingly the policy should be broadened.
Q5. Preferred Options 13-28 – Thriving Communities
Do you support or object to any or all of Preferred Options 13-28?Object
With regard to P013, UKAEA Winfrith considers it important that new employment development takes place close to existing employment sites, existing and proposed residential areas, existing local facilities and existing or potential public transport corridors. Indeed such issues should be used to inform which settlements are to sustain development and where growth should take place. The extension of settlements will be required but dispersed growth across the across villages and towns may not deliver a sustainable form of development and may not deliver highway and public transport improvements where they are most needed and would bring the biggest benefits.
It is encouraging to see promotion of use of previously developed land as evident at PO14. However, the option does not make it clear whether it is concerned with employment and residential land, or is simply promoting use of previously developed land for housing development, as the latter part of the policy seems to imply. This uncertainty needs to be addressed and it should be made clear that it relates to all uses. PO14 would also benefit from using a more common interpretation of what is previously developed land, as contained in PPG3, being something that ‘may occur in both built-up and rural settings’. We suggest that PO13 and PO14 be clarified so that they reflect national planning policy guidance and the fourth test of soundness set out in PPS12.
With regard to PO13 and PO14, it should be recognised that some previously developed sites, even if not centrally located, have great potential to assist with accommodating the District’s identified growth if combined with infrastructure and access improvements.
One such area is the Winfrith Technology Centre (owned by English Partnerships) and the adjoining employment site owned by UKAEA Winfrith. Whilst we welcome Paragraph 6.3.8 of the draft Core Strategy which states that ‘The Council considers that Winfrith Technology Centre presents an opportunity to support and grow knowledge based industries’, UKAEA Winfrith wish to remind the Council of the contribution to employment provision that their adjoining land makes. UKAEA Winfrith therefore request that future drafts of the Core Strategy acknowledge their employment landholding alongside references to the Winfrith Technology Centre.
Q6. Preferred Options 29-35 – Economic Wellbeing
Do you support or object to any or all of Preferred Options 29-35?Support
UKAEA Winfrith has an extensive land interest at Winfrith and is encouraged by paragraph 7.2.1 which states that the area ‘is widely acknowledged to have further potential to promote employment uses that maintain its prestigious character’. In this regard it is highlighted that the land developed to date does not yet extend to the extent of policy allocation SS32 detailed in the Purbeck District Local Plan (November 2004). Given this and the site’s previously developed nature, the site could play a valuable part in accommodating new development.
Although not recognised at paragraphs 7.2.1, 7.2.9 or 7.2.10, it should be noted that the extent of employment land at Winfrith extends beyond the boundary of the Winfrith Technology Centre, and includes a significant amount of land owned by UKAEA Winfrith. UKAEA also controls additional land adjoining their current employment site which is being remediated, some of which will become available for additional employment during the timescale of the Purbeck Local Development
Framework. It is therefore necessary to ensure that the full potential of UKAEA’s landholding is assessed during the progression of the LDF.
PO30 is supported, although it is not clear whether or how the District’s employment expansion can be accommodated in line with the three scenarios given. As such, PO30 would benefit from
acknowledging that in some instances, extension to existing employment areas may also be appropriate, which may not be within the three main towns. As with the land at Winfrith, however, there is great potential to utilise previously developed land. This will enable the Policy to comply with the fourth test of soundness identified in PPS12.
UKAEA welcome the recognition given by PO31 to the potential of the Winfrith Technology Centre to support knowledge-based employment. However, in line with the views expressed above, UKAEA consider it important that PO31 be modified by the inclusion of the phrase “and adjoining employment land owned by UKAEA Winfrith” so that it reflects the contribution that their existing and future land could play in meeting the future employment needs of the District.
In assisting the economy of the District, responding to local needs through the provision of mixed size/ type employment units (PO33) is to be encouraged and can only help to make the District more attractive whilst retaining small/ starter businesses that originate from the area.
Q7. Preferred Options 36-40 – Accessibility and Transportation
Do you support or object to any or all of Preferred Options 36-40?Support
Generally UKAEA Winfrith is supportive of the options presented relative to accessibility and transportation and find the suggested approach most encouraging. One overarching concern is the feasibility of securing the necessary level of infrastructure desired given the relatively limited extent of development across the District, particularly with regard to the low level of new housing proposed. It would be useful to see more information on the level of funding required and how this will come forward. The release of some sites for development will only be appropriate where infrastructure developments occur. If it transpires that necessary funding for the infrastructure is not in place / achievable, the site may no longer be appropriate for development. There is a need to ensure that assumptions are not made about such sites coming forward, which could ultimately distort
development calculations.
PO36 seems entirely appropriate, although in some instances there may be cases where a development can reach a critical mass whereby it can make a better contribution towards sustainability. This fact should be recognised.
Q8. Preferred Options 37-47 – Swanage
Do you support or object to any or all of Preferred Options 37-47? UKAEA Winfrith has no comments to make.
Q9. Preferred Options 48-52 – Upton
Do you support or object to any or all of Preferred Options 48-52? UKAEA Winfrith has no comments to make.
Q10. Preferred Options 53-57 – Wareham
Do you support or object to any or all of Preferred Options 53-57? UKAEA Winfrith has no comments to make.
Q11. Preferred Option 58 – Wool, Winfrith & Bovington
Do you support or object to Preferred Option 58?Support
UKAEA Winfrith welcomes the recognition that the Winfrith Technology Centre receives at paragraph 12.1.3 of the draft Core Strategy, and the acknowledgement that it fulfils a sub-regional employment role. However, in line with other representations set out above, UKAEA Winfrith considers it important that future draft Core Strategies recognise the contribution that their employment site adjoining the Technology Centre makes to the provision of employment opportunities within Purbeck, and requests that the phrase “and adjoining employment land owned by UKAEA Winfrith” be included within the opening sentence of this paragraph accordingly.
With regard to the poor linkages and levels of high in-commuting referred to in paragraph 12.13, it should be recognised that additional employment development at the site perhaps in combination with residential close by could actually assist with generating funding for infrastructure initiatives, which overall could improve these linkages and increase levels of self containment in the area. UKAEA Winfrith welcomes the preparation of an Area Action Plan (PO58) for Wool, Winfith and Bovington and looks forward to being consulted at an early stage of its preparation. However, there is concern that without sufficient new development within the immediate area there will be limited opportunity to secure necessary funding. Any AAP may also care to continue to explore how to take ‘greater advantage of the location to the railway line’ as is suggested in the Final Edition Local Plan.
Q12. Preferred Options 59-63 – South Purbeck
Do you support or object to any or all of Preferred Options 59-63? UKAEA Winfrith has no comments to make.Q13. Preferred Options 64-68 – Mid-North Purbeck
Do you support or object to any or all of Preferred Options 64-68? UKAEA Winfrith has no comments to make.Q14. Preferred Option 69 – Planning Obligations
Do you support or object to Preferred Option 69?UKAEA Winfrith has no objection to the principal of developing a planning obligations framework under PO69. However, in order to comply with Government Policy set out in Circular 05/2005 and therefore for the Core Strategy to comply with the fourth test of soundness, the preferred option must make references to the tests for planning obligations specified in the Circular and to make it clear that all planning obligations need to be negotiated.
In order to ensure that the seventh and eighth tests of soundness specified in PPS12 are also complied with, it is considered inappropriate for any framework to be definitive in respect of the matters for which planning obligations will be sought. This must remain flexible and must not prejudge the impacts associated with (as yet) unknown development proposals.
Consequently, we consider that PO69 should be rewritten accordingly:
“Purbeck District Council will seek to develop a planning obligations framework through which
appropriate, fair and reasonable contributions may be negotiated with developers towards some or all of the following objectives:
• mitigating any adverse impacts of development • contributing towards off-site highways works • the delivery of affordable housing
• the provision and future maintenance of open space and recreational facilities • the provision of other community facilities for which there is an identifiable need.”
Q15. Key Diagram
What are your views on the Key Diagram? Is it clear? Is it helpful?
UKAEA Winfrith considers the key Diagram to be very useful in giving an indication of context and constraints across the District as well as some of the more strategic intentions. However, UKAEA considers that three amendments should be made, namely:
• the area shown on the Key Diagram covered by the Area Action Plan for Bovington, Wool and Winfrith needs to be extended to include the Winfrith Technology Centre and adjoining land owned by UKAEA
• the Winfrith Technology Centre and adjoining land owned by UKAEA should be recognised as a ‘sub-regionally significant employment area’ to better reflect the employment value of this important area, and
• the information concerning the nature map should be removed in order to facilitate easier interpretation of the Key Diagram.
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).
UKAEA Winfrith has no comments to make.
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).
UKAEA Winfrith has no comments to make.
Do you wish to be notified of when the Core Strategy has been submitted to the Secretary of State for Independent Examination?
Yes
Do you wish to be informed of the publication of the Inspector’s report following the
Examination?
Yes
Do you wish to be informed of the adoption of the Core Strategy?
Yes
Response forms must be retuned by 4pm Friday 10th November 2006 to:
Community Planning and Policy, Westport House, Worgret Road, Wareham, BH2 4PP Or attach as an e-mail: [email protected]