Site Allocations and Policies (Incorporating IP-One Area Action Plan) Development Plan Document (DPD) Main Modifications

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Site Allocations and Policies (Incorporating IP-One Area Action Plan) Development Plan Document (DPD) Main Modifications

MM199 - Page N/A, New Policy

Representation ID: 26722

Received: 20/09/2021

Respondent: Ravenswood Environmental Group

Legally compliant? No

Sound? No

Representation Summary:

Concerns raised regarding amount and significance of re-drafting at Main Modifications stage. In effect a new Local Plan has been prepared. The amount of change for the Ravenswood sites is confusing. The suggested necessary changes required to the Local Plan to make it “sound” are so significant that the plan requires proper re-assessment through the formal Local Plan process. The consultation web page seeks to influence consultees through introductory remarks. Concerns regarding consultation process at earlier stages in terms of multiple site notices. This new policy has not been subject to proper SA or HRA. Fails to establish an access regime. Type and tenure of housing needs to be balanced. The type and tenure of housing is also a key concern here given that the Borough Council is committed to proposing a development consisting solely of Social Housing at sites UVW to the north in breach of a previously dismissed appeal. It is vital that any new residential development reflects the existing mix within Ravenswood to ensure that a balanced community is created to integrate within the locality. The S106 list at paragraph xv needs to be open. Our primary concerns remain. This is not a collection of small sites; it is a large mixed use allocation which will have serious environmental and social impacts. Further hearing sessions are necessary as per the March 2021 procedure guide for local plan examinations. The new plan is so different to the submission plan that it can't be considered a "modification" and is therefore not sound or legally compliant.

Change suggested by respondent:

At sub paragraph iii the New Policy should be clear that the mix of housing should be balanced with market housing and that a 15% quota (or other specified %) should be applied to the proportion of Affordable Housing proposed. Additionally, the affordable housing should include First Homes. At sub paragraph xv the S106 list is closed and needs to be open to mitigating the impact of the development. The list should be an open list stating that S106 Planning Obligations will be required to help to mitigate the environmental and infrastructure impacts of development. Financial contributions should include funding for a Recreation Avoidance Mitigation Strategy in the event that the New Plan is found sound. This would assist with mitigating the impact of industrial development and population growth upon the Orwell Estuary SPA, SSSI, RAMSAR site, Bridge Wood Local Wildlife Site and County Wildlife Site.

Full text:

See scanned representation.

Object

Site Allocations and Policies (Incorporating IP-One Area Action Plan) Development Plan Document (DPD) Main Modifications

MM200 - Page N/A, New Paragraphs

Representation ID: 26723

Received: 20/09/2021

Respondent: Ravenswood Environmental Group

Legally compliant? No

Sound? No

Representation Summary:

Concerns raised regarding amount and significance of re-drafting at Main Modifications stage. In effect a new Local Plan has been prepared. The amount of change for the Ravenswood sites is confusing. The suggested necessary changes required to the Local Plan to make it “sound” are so significant that the plan requires proper re-assessment through the formal Local Plan process. The consultation web page seeks to influence consultees through introductory remarks. Concerns regarding consultation process at earlier stages in terms of multiple site notices. This new policy has not been subject to proper SA or HRA. Fails to establish an access regime. Type and tenure of housing needs to be balanced. The type and tenure of housing is also a key concern here given that the Borough Council is committed to proposing a development consisting solely of Social Housing at sites UVW to the north in breach of a previously dismissed appeal. It is vital that any new residential development reflects the existing mix within Ravenswood to ensure that a balanced community is created to integrate within the locality. The S106 list at paragraph xv needs to be open. Our primary concerns remain. This is not a collection of small sites; it is a large mixed use allocation which will have serious environmental and social impacts. Further hearing sessions are necessary as per the March 2021 procedure guide for local plan examinations. The new plan is so different to the submission plan that it can't be considered a "modification" and is therefore not sound or legally compliant.

Change suggested by respondent:

At sub paragraph iii the New Policy should be clear that the mix of housing should be balanced with market housing and that a 15% quota (or other specified %) should be applied to the proportion of Affordable Housing proposed. Additionally, the affordable housing should include First Homes. At sub paragraph xv the S106 list is closed and needs to be open to mitigating the impact of the development. The list should be an open list stating that S106 Planning Obligations will be required to help to mitigate the environmental and infrastructure impacts of development. Financial contributions should include funding for a Recreation Avoidance Mitigation Strategy in the event that the New Plan is found sound. This would assist with mitigating the impact of industrial development and population growth upon the Orwell Estuary SPA, SSSI, RAMSAR site, Bridge Wood Local Wildlife Site and County Wildlife Site.

Full text:

See scanned representation.

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