Preferred Options Site Allocations and Policies (incorporating IP-One Area Action Plan) DPD Review

Object

Representation ID: 25842

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

No credible consideration of the cumulative impacts of development at the six sites at Ravenswood on; traffic, residential amenity, various protected sites (including Nature Reserves and an SPA), air quality, noise and the environment. Such a large centre of development needs a clear policy environment relating to access. The plan fails to satisfy the requirements of paragraph 16d of the NPPF. The plan is not justified or positively prepared. It is not effective as there is no clarity as to what is expected of proposals. The plan is trying to allocate a large site via "stealth", without appropriate assessment.

Object

Representation ID: 25843

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

This site is allocated by SP3 but it doesn't particularly fall within that category. It's debatable whether this site can be delivered based on the 2007 Permission following the refusal of Reserved Matters Consent so long ago. Given that the Council's strategy for the site has been rejected by the Planning Inspectorate, it's essential that the Local Plan contains a criteria based policy saying in what circumstances a detained planning permission would be granted. The Local Plan gives decision makers no direction about the site's future. The SHELAA refers to this site as a brownfield site but is clearly greenfield.

Object

Representation ID: 25846

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The Plan does not qualify/ explain what the Sports Park is. The SA suggests this is just open green space that can sit comfortably with an adjacent Nature Reserve and SPA but it may be that built development, traffic, parking, lighting, evening activities and noisy activities. Plans should serve a clear purpose. If it's for predominantly open space then a Sports Park should be in Policy SP6. Residents are entitled to read the Local Plan and have certainty as to what is permissible here. The site is valued as a green space and for its ecological and visual value.

Object

Representation ID: 25847

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The Land Adjacent to Nacton Road does not appear in the SA and the site sheet for site IP150e suggests that this site should be masterplanned with IP150c but there is no policy to insist upon it. There should be a criteria based policy stating how the site can be delivered as part of a masterplan.

Object

Representation ID: 25849

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

This should be described as "land south of Alnesbourn Cresent". There is no justification for this allocation which is an odd shape to be developed effectively particularly as a neighbouring development to a sports park. The plan is vague about this site. Again, if it is to be proposed then it should be part of a wider allocation. The site has serious nature conservation issues. Unclear how the Sports Park would be integrated with such a strange shape of development. It looks like a frontage development with a Sports Park to the rear, contrary to Designing Out Crime principles.

Object

Representation ID: 25850

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

No justification for reverting from employment to housing. Traffic impact has not been assessed. Nothing to rule out piecemeal planning applications. The site is visually and ecologically connected to the adjacent nature reserve. Density at 35dph is higher than surroundings. Need for green infrastructure will increase this density. Vagueness about how it will come forward. Without a comprehensive and cumulative assessment of all proposals in this area the piecemeal developments would exacerbate bad planning impacts on biodiversity, green space, traffic, noise and air quality. A comprehensive proposal must be subject to EIA. Referred to as brownfield but clearly greenfield land.

Object

Representation ID: 25851

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

No justification for reverting from employment to housing. Traffic impact has not been assessed. Nothing to rule out piecemeal applications. It is visually and ecologically connected to the adjacent nature reserve. Density is higher than surroundings. Existing green infrastructure should be preserved. Need for green infrastructure will increase density. Vagueness about how it will come forward. Without a comprehensive and cumulative assessment of all proposals in this area the piecemeal developments would exacerbate bad planning impacts on biodiversity, green space, traffic, noise and air quality. A comprehensive proposal must be subject to EIA. Referred to as brownfield but clearly greenfield.

Object

Representation ID: 25853

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The plan hints that the site may allow the creation of a new access onto and improvements to the Nacton Road. The Site Sheet sets out a raft of constraints, yet the site continues to be allocated for development. Alarmingly, the only guidance is that the industry should be as far from the A14 as possible meaning closer to residential. The site has archaeological, ecology, surface water, noise and air quality issues which dictate that it shouldn't be allocated. No work has been carried out to prove that this is a developable without harmful impacts on protected areas.

Object

Representation ID: 25854

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

IP152: The plan hints that the site may allow the creation of a new access onto and improvements to the Nacton Road. The Site Sheet sets out a raft of constraints, yet the site continues to be allocated for development. Alarmingly, the only guidance is that the industry should be as far from the A14 as possible meaning closer to residential. The site has archaeological, ecology, surface water, noise and air quality issues which dictate that it shouldn't be allocated. No work has been carried out to prove that this is a developable without harmful impacts on protected areas.

Object

Representation ID: 25855

Received: 12/03/2019

Respondent: Ravenswood Environmental Group

The traffic impacts of this development must be assessed cumulatively along with the 24 hectares of development proposed at Ravenswood.