Allocations Submission Document
Search representations
Results for Countryside Properties (Southern) Ltd search
New searchObject
Allocations Submission Document
Policy SER1 - North of London Road, Rayleigh
Representation ID: 28905
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Please see full submission
Object
Allocations Submission Document
Policy NEL1 - South of London Road, Rayleigh
Representation ID: 28906
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
NEL1 - Land south of Rayleigh Road
Of the proposed 5 ha site, some 2.5 ha of land is already occupied by long-established commercial uses. The site allocations DPD seeks the retention of these uses (para 5.14).
Of the undeveloped areas, the allocation includes a slither of land to the west of the existing businesses, of around 0.4 ha, which has no existing means of access, and which would be of limited use, given the shape of the land. To the east of the existing uses, there is a larger parcel of around 2 ha, with a frontage to London Road. However, the majority of this land is affected by the twin pylon lines that cross the site in a north/south direction. Although the pylons would not preclude commercial development as such, the lines themselves hang relatively low of the site, such that two storey development across the majority of the site would be difficult to achieve.
As far as we are aware, there have been no representations on the part of the landowner supporting the development of the site for commercial purposes, and no interest from any developer seeking to undertake a commercial development.
In the light of all of the above factors, we consider that the likelihood of any new commercial development occurring on NEL1 to be extremely limited, and therefore that the Site Allocations is not Justified/Effective since it will not deliver the high quality office development required by ED4.
By contrast, Countryside Properties have consistently argued that an element of commercial development can be developed as part of a mixed-use allocation north of London Road, where the costs of the servicing a commercial development (drainage, utilities, highways) can be shared with the development of the residential element.
Object
Allocations Submission Document
Policy NEL2 - West of the A1245, Rayleigh
Representation ID: 28907
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
NEL2 - West of the A1245
As set out elsewhere in our submissions, it seems highly unlikely that the Rawreth Lane Industrial Estate will be redeveloped, but in the event that this were to occur, our understanding is that this site is allocated in order to provide a suitable location for such uses to relocate.
What is unclear from the wording of the Site Allocations is whether or not this site is reserved solely for the relocation of uses from Rawreth Lane (aside from the proposed recycling centre). If the intention is that the land should be available such that an existing use from Rawreth Lane can relocate there, then the text to the Policy would need to make clear that the site is solely reserved for such uses, and that permission would not be granted for any development for commercial purposes unless it related to the relocation of an existing use.
If that is not the case, and the land is simply notionally available for relocation of existing uses, then there is of course no guarantee that even if an existing use from Rawreth Lane was able to afford the costs of relocation, that there would be space available for them on NEL2 to enable this to happen. If the land is not specifically reserved and left for relocating businesses, then the chances of Rawreth Lane ever being redeveloped are diminished even further, since existing business will stay.
We note that paragraph 5.31 lists one of the possible uses of the site as being for high quality office use". Given the relative remoteness of this site, we would suggest that the site is not appropriate for such high density business uses. Moreover, given that the site is also identified at paragraph 5.32 for 'heavy industry', it seems highly unlikely that it would attract a high quality office use anyway.
We would therefore consider that reference to high quality offices should be deleted from NEL2, since it is not Justified, and that to be Effective, NEL2 requires clarification as to whether or not the land is actually reserved for the relocation of existing business from Rawreth Lane, and not for general industrial use.
Object
Allocations Submission Document
Policy SER1 - North of London Road, Rayleigh
Representation ID: 28916
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Paragraph 3.27 - Access and traffic distribution (and Figure 7)
In advance of more detailed traffic modelling, it is inappropriate to be precise about the split of traffic between the northern and southern access points. Whilst there is no objection as such to the inclusion of the proportions suggested as a guide, there is no substantive evidence at the moment to justify a definitive approach (Justified), and the text should be caveated with the addition of "subject to more detailed testing through the site Masterplan and application stages".
In addition, we note that the first sentence of this paragraph is potentially confusing as to whether the Council is seeking two points of access from both London Road and Rawreth Lane, or two points of access overall (the latter is correct). Clarification of the text would assist successful delivery by avoiding confusion (Effective).
Finally, we are not aware that there is any substantive evidence underpinning the suggestion of two points of access to London Road. It is unclear as to what the function of a 'circular link' might be. This text should be deleted if it is not Justified.
Object
Allocations Submission Document
Policy SER1 - North of London Road, Rayleigh
Representation ID: 28917
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Paragraph 3.35 - Green Buffer and Allotments
Whilst understanding that the Council desire for the Green Belt beyond the development to be protected, there is no justification that we are aware of as to why such greenspace should be publically accessible or form parkland.
The preceding paragraphs establish the quantum of formal/informal open space necessary to meet the needs of residents from the development, and therefore there is no quantitative need for additional publically accessible greenspace above and beyond that provided within the site.
If the objective is to maintain a green buffer, then the retention of land in agricultural use would be equally effective.
Whilst no objection is therefore raised to the provision of a 'green buffer' to the west of the development, which would be provided by the Green Belt, we do not consider that a requirement for additional publically accessible greenspace has been Justified.
Finally, we note that the end of this paragraph refers to the fact that allotments 'may' be provided within this buffer. In our view, there may be more appropriate locations for the provision of allotments (for example, within the buffer that will be needed between the new development and Rawreth Industrial Estate, where it would be accessible to new and existing residents), and we would question whether such a use would actually be desirable in landscape terms on the western fringe of the development. Whilst accepting that this paragraph says 'may' only, it would be more appropriate (i.e. Justified) to split the reference to allotments in to a new paragraph, and make clear that there are other locations within the site where the allotments may be provided.
Object
Allocations Submission Document
Policy SER1 - North of London Road, Rayleigh
Representation ID: 28918
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Paragraph 3.37 - Relocation and replacement of existing playing fields
We note that this paragraph states that the existing playing fields "should" be relocated, and that the revised facility should be within 340 metres of the existing site.
Taking the latter point first, a radius of 340 metres from the existing site, even taking the central point from the north-western tip of the existing site, results in an extremely limited search area for a replacement facility. The options are essentially limited to putting the replacement facility either:
(a) On the adjoining land to the north, which would seem a little pointless;
(b) Under the pylon lines immediately to the west; or
(c) Partially in the floodplain of the brook.
In addition to the above, any replacement facility within that radius will be on land that would require reprofiling to make it level, whereas the existing site is already flat.
In the light of the above, we would suggest that the 340 metre limitation is not appropriate. We understand that it is based on not wishing to locate the facility substantially further away from those who currently walk to the site, but in practice the alternative siting options within that radius are all constrained, and will require extensive works.
Moreover, given the limitations on the alternative siting options, the cost of replacement, and the desire of the Council not to move the pitches further away from existing residents, it seems the most appropriate option may well be to leave the pitches in their current location.
It will also be important to ensure that any decision to relocate the pitches does not result in the unnecessary delay of the development itself, given the limited time available for the commencement and completion of the 550 units by 2021.
Whilst recognising that a replacement structure built to BREEAM Very Good criteria would be a benefit to the Sports and Social Club, we query whether this should be a requirement of the development, as opposed to an objective that the land owner (i.e. Rochford District Council) and the developer might seek to achieve.
In the light of the above, we consider the following amendments necessary to ensure this paragraph meets the Justified and Effective tests (alterations in italics):
"The playing fields to the south of the site along London Road may be relocated as part of the development. A replacement sports field with new ancillary facilities together with a new club house would be required to be provided ahead of any removal of the existing facility so as to ensure the continued and uninterrupted operation of this valuable community facility. It will be necessary to ensure however that any relocation does not delay or prejudice the implementation of the development in accordance with the timescale set out in the adopted Core Strategy. The Council will encourage any new structure to be built to the BREEAM (Very good) standard thus providing a new, efficient and environmentally friendly establishment which will be of great advantage to the community as a whole and to the operators of the Sports and Social club. The location of any replacement facility should be established within the Masterplan to be prepared for the site, and should be informed by consultation with the existing users. Additionally any new facility should be well connected to the pedestrian and cycling network.
Object
Allocations Submission Document
Policy SER1 - North of London Road, Rayleigh
Representation ID: 28919
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Paragraph 3.45 - Retail/Neighbourhood centre, and commercial uses.
Given the existence of a neighbourhood parade to the south, a local petrol filling station shop, a local Tesco extra, and most significantly Asda to the east, it is unlikely that a neighbourhood parade of shops within this development would be viable. In order to be Justified, reference to such a facility should be change to "could be integrated" rather than "should be integrated".
However, it would be appropriate to include within the mix of uses an allowance for some small-scale business use, particularly in the light of the lack of deliverability of the proposed commercial allocation south of London Road (see our separate representations to NEL1). An element of commercial/business use within this broad location would help achieve a sustainable mix of uses, help to create vitality across the whole of the Masterplan area, and allow full use of land within the allocated area in locations that might be unsuitable for other reasons for residential use.
Object
Allocations Submission Document
Policy SER1 - North of London Road, Rayleigh
Representation ID: 28920
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
Paragraphs 3.24-3.25 - Open Space Requirements
We do not disagree with the need for appropriate open space provision, or for open space suitable for the various uses set out. However, the level of prescription set out in these two paragraphs is excessive, and unnecessarily curtailing on the design solution. It would be more appropriate (i.e. Justified) to aggregate the open space areas together in to a general quantum to be provided to meet the end users suggested, and then allow the Masterplan to determine the best configuration for the site.
Object
Allocations Submission Document
Settlement Extension Residential Land Allocations
Representation ID: 28921
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Representations
Paragraph 3.7 and Table 2
The statement in paragraph 3.7 as drafted that the Core Strategy identified the "approximate" number of dwellings at the locations set out in Table 2 is not quite correct. The quantums set out in Table H3 of the Core Strategy (post 2021) were expressed as approximate figures, the quantums set out in Table H2 (2015-2021) were not, and were expressed as the number of homes to be achieved within that time period. In order to maintain consistency with the Core Strategy, the text should be amended to reflect the actual position.
Object
Allocations Submission Document
Settlement Extension Residential Land Allocations
Representation ID: 28922
Received: 22/01/2013
Respondent: Countryside Properties (Southern) Ltd
Agent: Phase 2 Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Paragraph 3.10 (5% cap on flexibility)
As set out above, the Core Strategy Inspector accepted the Council's land supply position only on the basis that the strategic growth locations had flexibility to accommodate shortfalls arising elsewhere (and on the basis of a promised early review, arising from the shortfall in the length of the Plan period itself).
Paragraph 3.10 introduces a flexibility cap of 5%. There is no such 5% limit in the CS, and given the reason why the CS Inspector considered flexibility was needed, it is evident that a 5% flexibility cap is inadequate and inappropriate.
Our comments here apply equally to all settlements, but taking Rayleigh as an example, the strategic growth area allocation is 550 units (all to be delivered between 2015 and 2021). The 5% flexibility allowance equates to 27 houses. The Rawreth Lane Industrial Estate is supposedly capable of delivering 222 homes, but as per our representations elsewhere, it is highly unlikely to be delivered. How would a flexibility allowance of 27 units provide flexibility for the lack of delivery of 222 units? Even if the site were developed, but at the more realistic level of circa 140 units, how would the 5% cap cater for the shortfall in the 60-70 units that would arise?
Elsewhere, the Concept Statement for the west of Rayleigh growth location explains the need for a comprehensive approach, and as indicated above, the development is due to be completed by 2021 - how would the additional development required to meet any shortfall arising elsewhere later in the Plan period (i.e. post 2021) be factored in, if the Masterplan for the comprehensive development of the land did not at this stage include sufficient flexibility for what is a likely eventuality?
For the above reasons, we consider that the introduction of the 5% cap fails the test of soundness for all four reasons i.e. this aspect of the Plan is not Positively Prepared, Justified, Effective or consistent with National Policy.