schedule of responses - draft core strategy

6 JANUARY 2012 CITY COUNCIL RESPONSE TO REPRESENTATIONS RECEIVED ON THE DRAFT CORE STRATEGY This schedule provides details of all of the comments received during the Draft Core Strategy consultation period, together with a brief response from the city council A series of background reports to be published in February 2012 alongside the Publication Core Strategy will provide a much more detailed explanation of the reasoning behind the policies in the Publication Core Strategy and why other options have not been taken forward GENERAL COMMENTS GENERAL COMMENTS Ref From dcs11 Civil Aviation Authority dcs35 CABE Chapter/policy General comment Comment The Civil Aviation Authority not wish to make specific comments on the Draft Core Strategy but recommend that the Council considers the need of such aerodrome(s) within your development plan and consult with the aerodrome operator(s)/licencee(s) directly City council response Policy DEV7 of the Unitary Development Plan will continue to be saved after adoption of the Core Strategy, ensuring that aviation safety at Manchester Airport is protected A list of all general development/aviation related issues were also submitted Policy A14 of the Publication Core Strategy sets out the approach to be taken to Barton Aerodrome (City Airport) The spatial framework in Chapter of the Publication Core Strategy sets out a policy for each of 20 sub-areas in the city, providing clarity over their role and future direction This should enable local communities to better understand the plan and its implications, as well as helping to guide the production of any Thank you for consulting the Commission for Architecture and the Built Environment (CABE) Unfortunately, due to limited resources, we are unable to comment on this document However CABE would like to make some general comments for consideration A good spatial plan is essential to achieving high quality places JANUARY 2012 GENERAL COMMENTS Ref From Chapter/policy Comment and good design CABE believes that getting the local development framework core strategies right is one of the most important tasks planners are undertaking We have run workshops with over 50 local planning authorities to look at how well design is being embedded in core strategy documents, which form part of the local development framework The workshops offer local authorities independent informal advice from an expert panel and allowed us to identify the strengths and weaknesses of current approaches to spatial planning and how design, functionality and space are dealt with in core strategy documents There are three key messages for local planning authorities that have emerged from our workshops Tell the story A good core strategy needs to tell the story of the place, explain how it works and highlight its qualities and distinguishing features Telling the story helps everyone understand how the qualities of the place have shaped the strategy and its priorities for future quality Set the agenda Use the core strategy to say what is wanted for the area, express aspirations and be proactive and positive about the future of the place and say how this will be achieved Set out what is expected in terms of design quality and where necessary provide links to the relevant development plan documents or supplementary planning documents Say it clearly Make the core strategy relevant and understandable to a wide audience Use diagrams to inform the text and communicate the strategy and show what quality of place means It is also important that there is a clear priority for design quality and place-making objectives in the core strategy, setting out the key principles This needs to be explicit so that it cannot be City council response neighbourhood development plans The approach to design in the Publication Core Strategy has been significantly expanded, reflecting the importance of this issue in Salford The design chapter now incorporates a comprehensive suite of twelve policies that should help to ensure high quality design across the city Chapter of the Publication Core Strategy provides a locally distinctive vision based on Salford’s Sustainable Community Strategy The rest of the document sets out the policies and proposals for delivering that vision, with further details provided in the accompanying Implementation Plan JANUARY 2012 GENERAL COMMENTS Ref From Chapter/policy Comment challenged when applications are being determined We also have a new publication called Planning for places: delivering good design through core strategies This publication provides further detail on the three key messages above It is available to download from the CABE website http://www.cabe.org.uk/publications/planning-for-places The CABE website also has further information about the workshops and key findings www.cabe.org.uk/planning We have also attached some key questions that we use in the workshops for you to consider throughout the development of your Core Strategy document You might also find the following CABE Guidance helpful: · Making design policy work: How to deliver good design through your local development framework · Protecting Design Quality in Planning · Creating Successful Masterplans – a guide for clients and Design Reviewed Masterplans · By Design: urban design in the planning system towards better practice“ (published by DETR) These, and other publications, are available from our website www.cabe.org.uk KEY QUESTIONS – CORE STRATEGY WORKSHOP Vision · Does it provide a locally distinct vision, setting out what the area will be like? · Is the vision communicated clearly and effectively? And in a way that others will understand? · Does the vision reflect the Sustainable Community Strategy? · Does the vision reflect the key characteristics and issues of the area? · Has the functionality of the place and its role within the surrounding context been considered? City council response JANUARY 2012 GENERAL COMMENTS Ref From Chapter/policy Comment Spatial Expression · Has a holistic approach to the function, role and key characteristics of place been adopted? · Has urban design evidence base and analysis informed the identification of issues and development of the options? · Does the Core Strategy reflect the Sustainable Community Strategy vision and objectives? · Has there been involvement and buy in from LSP’s, internal and external stakeholders? Is the plan realistic – has a delivery and implementation plan been set out? · Does the strategy understand, analyse and integrate transport, employment, residential, environmental and other spatial themes? Are these issues communicated spatially and effectively? · Does the document maximise the use of maps, diagrams, illustrations, photographs and examples to illustrate key points and characteristics? Are available mapping, layering and analysis technologies used? Design Quality · Has design been considered across all aspects of place? · How is design dealt with in the Core Strategy and has it been communicated clearly? Has a design ethos been embedded in the strategy? · What priority has been placed on design issues? Is there recognition of local design qualities? · Is the strategy robust? Will it help deliver the aspirations for the area? · Are there hooks in the core strategy to other LDF documents (AAP’s or SPD’s) that deal with strategic or detailed design issues? · How will the policy be implemented? Any quality monitoring or City council response JANUARY 2012 GENERAL COMMENTS Ref From dcs40 Graham Crook dcs58 dcs96 Ken Lee David Jones dcs108 Carole Bridge Chapter/policy Comment indicators required? Does it establish standards or assessment criteria for design quality? Does this extend to both urban design and building design standards? And how this will measured? The Core Strategy is a large document, which contains some of the most idealistic, visionary writing, I have ever read! It is unclear where the evidence has been derived, to make the claim that such widespread growth will be required over the next 20 years Certainly, current evidence shows that we cannot sell many existing new houses, and many recently developed shop units in Salford West, have either not been occupied, or been vacated People could be forgiven for thinking that the reasoning behind this proposal is the enormous revenue that would be generated by the Council, and the property developers Supports the Draft Core Strategy No comments made Need to be more specific as to development in Kersal in the Core Strategy There are no improvements to transport links, no metrolink available Bus services are chronic and unreliable and no rail link There is no provision in the area for the It's Your Salford exhibition bus There is no local library, no local shopping centre Is Kersal the forgotten area? I feel very neglected in these so called development Salford does need much redevelopemnt and investment to improve homes, social services and facilities However, I hope the same mistakes are not going to be made as in the 50's and 60's when Cross Lane, Ellor St was destroyed with all shops and local fcailities wiped out.Cross Lane is now desolate and the precinct, Broadwalk, Belvedere Rd is almost wiped out too City council response The scale of housing development proposed in the Core Strategy has been significantly reduced, from 33,750 over the period 2007-2027 at the Draft Core Strategy stage to 22,100 over the period 2011-2028 in the Publication Core Strategy The scale of housing proposed is based on household projections taken from the Greater Manchester Forecasting Model, with an additional allowance for the impacts of the extra office development proposed in the city It should therefore reflect a realistic assessment of likely demand Noted Policy SF2D of the Publication Core Strategy sets out the broad policy approach for Charlsetown and Lower Kersal Policy A5 supports improvements to public transport services, but as it is a strategic document it is unable to deal with very detailed issues relating to bus services to particular neighbourhoods Chapter 11 of the Publication Core Strategy seeks to maintain and enhance the existing network of town centres and local centres in across the city, so as to ensure that there are accessible shops, facilities and places to meet friends Policy JANUARY 2012 GENERAL COMMENTS Ref From dcs125 dcs126 dcs238 dcs239 G Platt G T West Government Office North West Government Office North West Chapter/policy Comment Nowhere to meet friends etc Support Sounds great Implementation There are a number of references to proposals in the Core Strategy being implemented via informal planning documents, e.g masterplans or informal development frameworks Such an approach is not appropriate The further identification of sites will need to be done via a land allocations DPD SPD can provide greater detail on the policies in a DPD However, PPS12 at paragraph 6.4, says that councils should not produce guidance other than SPD where the guidance is intended to be used in decision making or the coordination of development as this could be construed as wishing to circumvent the provisions for consultation and sustainability appraisals Salford has produced a number of informal planning documents over recent years These are not in accord with national planning policy as set out above The Core Strategy should include trajectories in respect of previously-developed land and the rate of housing delivery in accordance with paragraphs 43 and 55 of PPS3 Evidence We will wish to see the evidence that supports the policies and proposals particularly in respect of the approach to floodrisk, the impact on the strategic road network, the viability of the approach to affordable housing, renewable energy, employment land, retail need, sustainability assessments and other City council response TC3 sets out the scale of new retail development proposed, based on a realistic assessment of likely spending patterns and competition from centres outside Salford Noted Noted The Publication Core Strategy focuses on providing any additional guidance through Development Plan Documents and Supplementary Planning Documents Chapters and of the Implementation Plan provide further information on this Policy H3 of the Publication Core Strategy provides a trajectory showing the anticipated rate of housing delivery and the likely proportion of dwellings on previously-developed land Noted The relevant evidence is being published alongside the Publication Core Strategy JANUARY 2012 GENERAL COMMENTS Ref From dcs175 dcs180 Gary Sla MOD dcs326 Mrs Jackie Anderson Chapter/policy Comment appropriate assessments We are aware that a number of studies are being undertaken to put this evidence in place Do not support the Draft Core Strategy Comments not entered The Ministry of Defence (MOD) can confirm they have no safeguarding concerns as this falls outside the statutory safeguarding areas My objections to the Strategy are as follows: the Strategy does not meet government requirements regarding sustainability in terms of: City council response Protection of biodiversity Chapter 20 of the Publication Core Strategy seeks to protect, enhance and expand the Green Belt The protection of the quality and nature of the landscape The preservation of the amenity value and heritage interest Maintaining a viable community and the vitality of the local community Protection of natural resources including soil quality Noted Noted Chapter 21 of the Publication Core Strategy seeks to secure an increase in the city’s biodiversity resources Policy D9 of the Publication Core Strategy provides strong protection for residential amenity Chapter 18 of the Publication Core Strategy seeks to protect and enhance the city’s heritage Protection of the land for agricultural use The loss of green land, habitats, landscape and wildlife and irreparable damage not deemed to be for “exceptional circumstances” required for release of Green Belt land The increase in traffic congestion and pollution especially noise, air and overall pollution Use of land in residential areas for inappropriate purposes such as incinerators The proposed scale and distribution of housing in Policy H2 of the Publication Core Strategy should help to maintain viable communities Policy GB5 of the Publication Core Strategy protects high grade agricultural land The proposed release of 40 hectares of Green Belt land at Barton for employment JANUARY 2012 GENERAL COMMENTS Ref From Chapter/policy Comment The lack of specific indication of where industrial, warehousing, residential and other developments will be sited Other objections: The plans not encourage and enable the active agricultural use of the high grade agricultural land for food production It does not recognise that an increase in recreation and leisure use is desirable It does not recognise that an expansion of public access to the Moss is desirable There is no indication that reasonable alternatives have been robustly tested The loss of value of residential homes that will be adjacent to heavy industrial areas such as the incinerator at Winton or the railway track at Barton The effect on air quality (already one of the poorest in the area because of the heavily congested major roads of M62, M60, A57and M602) The transport infrastructure will increase congestion and decrease public transport choices (Western Gateway Infrastructure Scheme is developing a junction on the Barton side of the flyover not in Irlam) that will have an impact on traffic in the rest of Salford as well as the rest of Manchester Indication is given regarding reducing risk of flooding to the River Irwell area but not regarding the impact of heavy industry City council response purposes has been deleted from the Core Strategy It is considered that there is insufficient evidence to justify the release of this land in the absence of a comprehensive assessment of need and supply at the Greater Manchester level Policy SF3F sets out a clear vision for Chat Moss, which includes promoting public access and increasing agricultural activity JANUARY 2012 GENERAL COMMENTS Ref From Chapter/policy Comment on the Moss with regard to flooding The unsuitability of heavy transport usage of the roads approaching the proposed incinerator in Winton The unsuitability of heavy or industrial buildings or a railway on peat bog and mossland: in Peel wording “The highest capacity intermodal rail terminal in Britain” ”(a 7-track rail reception yard capable of receiving the longest trains planned for the UK (775 metres), which in turn, will serve a 17 hectare integrated rail and port terminal” (http://www.oceangateway.co.uk/) which will be served by the industrial/warehousing site There is no evidence that the new job opportunities will benefit the local population There is no indication about the stated preservation and restoration of the important “heritage and environmental assets” mentioned in the Strategy There is no indication of brownfield sites or sites available for regeneration or redevelopment as suitable alternatives The Core Strategy fails to test "reasonable alternatives" to some of its proposals in terms inadequate consideration given to the environmental effects of the expansion The Western Gateway Infrastructure would bring the traffic to an unbearable level We have concerns regarding the evidence base which supports projections in the Employment Land Review and Housing Review provided by the Government that need to be revised City council response JANUARY 2012 GENERAL COMMENTS Ref From Chapter/policy Comment There is not clear indication about areas of low value/vacant and underused ‘industrial’ uses of apparent dubious existing and future employment generating capacity (without rationalisation of land use and infrastructure) and adverse environmental impact The requirements within the Regional Spatial Strategy to achieve at least 90% of development on previously developed land are paramount It is wholly unsustainable to depart significantly from national and regional policy and would reduce to a significant extent the volume of development within the regional centre, defined as a principle location for growth within the Regional Spatial Strategy There needs to be: Support for the sale of local produce to reduce food miles Home working and other ways of working which reduced the need to travel should be actively promoted including the re-use of redundant and underused buildings Support for retaining and enhancing existing facilities to help sustain rural communities including more farmers markets and community shops Support for the sale of local produce to reduce food miles Strong support for the protection and enhancement of Green Infrastructure and the biodiversity and open spaces While we recognise that the Council has a duty to ensure that the Core Strategy conforms to national and regional policies, it also has a higher statutory duty under Section 39(2) of the 10 City council response JANUARY 2012 WASTE Ref dcs1606 From Beryl Carroll Chapter/policy Policy WM1 Comment I wish to object to the proposal for a waste site at Green Lane dcs1609 E Barnes Policy WM1 dcs1610 Mr and Mrs C Talbot and Mr J Talbot Policy WM1 dcs1611 Evelyn Soanes Policy WM1 I wish to object in the strongest possible terms to the building of the Green Lane Incinerator, this village is not the place for this kind of industrial development; It will make life here quite intolerable, & the traffic chaos it will cause will be to say the least very dangerous Does the fact that Monton has pelican crossings on a small section of road not indicate that we already have too much traffic, due in part to our nearness to the M60 motorway, Morning & early evening sees Monton come to a veritable standstill, if this ridiculous idea goes a head, Salford council which receives a large amount in Council tax form this area could see that fall sharply as people move out of the area , & nobody else want to buy property here, it could also see a drop in the Labour party representation in the Eccles & surrounding areas We not want this Incinerator in Monton We are shocked to hear of the proposed Incinerator on Green Lane, and we trust that you will dismiss the planning application out of hand A waste site would be a disaster for Monton and Eccles Wish to put my NO NO NO to the proposed waste site at Green Lane Salford this will not only cause terrible blockages on the roads but is a health hazard dcs1617 Gillian Millett Policy WM1 I understand that Sky Properties are developing plans to build a waste transfer facility on Green Lane, Monton on the land where the Mitchell and Shackleton factory one stood, and I wish to formerly register my objection to this facility 792 City council response The city council refused the planning application for a waste management facility at Green Lane, which is being referred to The city council refused the planning application for a waste management facility at Green Lane, which is being referred to The city council refused the planning application for a waste management facility at Green Lane, which is being referred to The city council refused the planning application for a waste management facility at Green Lane, which is being referred to The city council refused the planning application for a waste management facility at Green Lane, which is being referred to JANUARY 2012 WASTE Ref From Chapter/policy Comment Although I understand there is a need to build waste transfer facilities I cannot understand why it is being considered to allow such a facility within a residential area, especially when it will be close to children's nurseries and schools, surely such a facility should be developed within the confines of an established industrial park such as Trafford Park City council response From a health and safety point of view surely such a development would increase the volume of HGV vehicles delivering into and out of the plant, possible health risks from the process emissions and smells from the processes taking place There would literally be a rubbish tip in the middle of Monton, and wherever there is rubbish there is vermin, not the best thing to introduce to a residential area, is it? House prices are already at an all time low, for some people their equity is already less that the value of their house Introducing such a facility would further reduce the value of the homes within the area dcs1619 DA and NJ Grimshaw Policy WM1 I am sure that you have received many more letters similar to mine all with the same request, please not spoil Monton, leave it alone and build this facility in an industrial area that is equipped to handle the increased traffic flow and processes Don't ruin this area - who wants to live near a rubbish tip? Would you? We email to object to the proposed plan of using the former Mitchell and Shackleton factory site on Green Lane as an ‘eco park’ We feel that this would be detrimental to the area as one result would be a large increase in traffic in the already busy area, particularly HGVs In addition there are likely to be antisocial smells and noise due to the waste site This is a residential area and a further housing development would be a 793 The city council refused the planning application for a waste management facility at Green Lane, which is being referred to JANUARY 2012 WASTE Ref From Chapter/policy Comment much better use of this land located opposite a recently restored section of the canal 794 City council response JANUARY 2012 CHAPTER 22 – MINERALS MINERALS Ref From dcs192 Coal Authority Chapter/policy Policy MN Comment The Coal Authority is a Non-Departmental Public Body sponsored by the Department of Energy and Climate Change (DECC) The Coal Authority was established by Parliament in 1994 to: undertake specific statutory responsibilities associated with the licensing of coal mining operations in Britain; handle subsidence claims which are not the responsibility of licensed coalmine operators; deal with property and historic liability issues; and provide information on coal mining The Coal Authority set up a new Planning and Local Authority Liaison Department in 2008 to re-engage with the three planning systems across England, Scotland and Wales The main areas of planning interest to the Coal Authority in terms of policy making relate to: • the safeguarding of coal as a mineral in accordance with the advice contained in MPS1 and MPG3 in England; and • ensuring that future development is undertaken safely and reduces the future liability on the tax payer for subsidence and other mining related hazards claims arising from the legacy of coal mining in accordance with the advice in PPG14 and MPG3 in England Surface Coal Resources and Prior Extraction Although it is acknowledged that the Salford Core Strategy does not cover minerals issues in detail, as this will be contained within the emerging Greater Manchester Minerals Development Plan Document (GMJMDPD), you will be aware that the Salford area contains coal resources which are capable of extraction by 795 City council response Policy MN1 of the Publication Core Strategy includes a reference to avoiding sterilisation of known minerals resources JANUARY 2012 MINERALS Ref From Chapter/policy Comment surface mining operations Information on the extent of these resources is available to Mineral Planning Authorities free of charge from the Coal Authority and was provided to your Council in September 2008 The current Energy White Paper, published in May 2007, estimated that “by 2020 fossil fuels are expected to supply the great majority of UK energy needs and 14% of primary energy demand will be met by coal.” In March 2008, the Rt Hon John Hutton MP, Secretary of State for Business Enterprise and Regulatory Reform, stated that “… Fossil fuels will continue to play an important role in ensuring the flexibility of the electricity generation system as well Electricity demand fluctuates continually, but the fluctuations can be very pronounced during winter, requiring rapid short term increases in production Neither wind nor nuclear can fulfil that role We therefore will continue to need this back up from fossil fuels, with coal a key source of that flexibility ” The UK Low Carbon Transition Plan White Paper, which builds on the 2007 White Paper and was published in July 2009 to set out the national strategy for climate and energy, suggests that by 2020 clean coal will contribute 22% to the overall energy mix This is actually an increase on the level predicted in 2007 Energy White Paper The 2009 White Paper re-confirms that “coal and gas will remain important to ensure our electricity supply is reliable and secure as we move towards greater dependence on intermittent sources like wind…The UK needs to maintain security of supplies of fossil fuels, which will remain an essential input to our electricity supplies for many years to come Around a third of this is supplied by the UK coal industry.” 796 City council response JANUARY 2012 MINERALS Ref From Chapter/policy Comment The Coal Authority is keen to ensure that coal resources are not unduly sterilised by new development In instances where this may be the case, the Coal Authority would be seeking prior extraction of the coal Prior extraction of coal also has the benefit of removing any potential land instability problems in the process Contact details for individual operators that may be able to assist with coal extraction in advance of development can be obtained from the Confederation of Coal Producers’ website at www.coalpro.co.uk/members.shtml As the Coal Authority owns the coal on behalf of the state, if a development is to intersect the ground then specific written permission of the Coal Authority may be required The comments which the Coal Authority would like to make in relation to mineral safeguarding are: Test of Soundness Justified Effective Consistency With National Policy-X In order to ensure that mineral resources are not unnecessarily sterilised, MPS1 requires Minerals Planning Authorities to define Mineral Safeguarding Areas (MSAs) and to encourage the prior extraction of minerals, where practicable, if it is necessary for non-mineral development to take place in MSAs The Coal Authority notes that detailed mineral planning issues will be addressed through the production of the Greater 797 City council response JANUARY 2012 MINERALS Ref From Chapter/policy Comment Manchester Joint Minerals Development Plan Document (GMJMDPD), and welcomes this approach to developing a consistent mineral planning framework for the Greater Manchester area City council response The specific reference within Policy MN1 (Minerals) of the Draft Core Strategy to the identification of MSAs through the subsequent GMJMDPD is therefore supported This will ensure that an appropriate strategic policy ‘hook’ is provided to allow this important issue to be addressed through the GMJMDPD at a later date The specific reference within the reasoned justification to the presence of surface coal resources within Salford is also supported However, in order to fully address the requirements of MPS1, it is considered that a positive reference should be made within Policy MN1 to the potential for prior extraction of mineral resources where practicable It is recommended that such a reference be included within the third bullet point under Policy MN1, which could be reworded as follows: • “Avoiding sterilisation of known mineral resources INCLUDING, WHERE PRACTICABLE, BY SUPPORTING THEIR EXTRACTION IN ADVANCE OF DEVELOPMENTS THAT WOULD OTHERWISE LEAD TO STERILISATION.” dcs441 Lancashire Wildlife Trust Policy MN Reason – To ensure that the requirements of paragraph 13 in MPS1 (Planning & Minerals) are fully addressed Policy MN1 - It is essential that further peat extraction within Chat Moss should not be permitted, but it isn’t clear from this policy statement when this is likely to come into effect As indicated under our comments on Policy GB 3, it will not be sufficient for this to take effect from the date of the introduction 798 Policy MN1 of the Publication Core Strategy states that applications for peat extraction will not be permitted, except where they are the minimum required to secure lowland raised bog restoration It is JANUARY 2012 MINERALS Ref From Chapter/policy Comment of the Core Strategy It must be anticipated that a great deal of extra damage will be done to the mossland and to its potential for the restoration of biodiversity between now and when the Core Strategy comes into effect, For such a policy to be meaningful, it should apply with immediate effect, otherwise irreparable damage may be done before the Core Strategy is introduced Paragraph 22.5 refers to the role of The Greater Manchester Geological Unit in the production of a Greater Manchester Joint Minerals Development Plan It will be important, in the preparation of this plan that the effects on biodiversity and wildlife interests are taken into account 799 City council response considered that some weight can be given to the policy immediately, but it will only have full weight once the Core Strategy has been adopted JANUARY 2012 CHAPTER 23 – DEVELOPMENT MANAGEMENT DEVELOPMENT MANAGEMENT Ref From Chapter/policy dcs957 Arnold Laver Policy DM Comment Similarly to the emerging design policies, requirements and development management criteria should not be rigid and onerous Flexibility should be incorporated into these policies that allow sites and schemes to be considered on their own merits taking into account site specific circumstances City council response The application of all policies will take into account site-specific circumstances It is unnecessary to repeat legal tests or national guidance for planning obligations in the Core Strategy In terms of developer contributions, it is recommended that any future policies requiring contributions are in line with guidance outlined in circular 05/2005 The Circular states that policies should be mindful of the five key tests; all of which must be met in order for a planning obligation to be sought In short, a planning obligation must be: Relevant to planning; Necessary to make the proposed development acceptable in planning terms; Directly related to the proposed development; Fairly and reasonable related in scale and kind to the proposed development; and Reasonable in all other aspects In addition, the policies and mechanisms for developer contributions should be flexible to ensure that any requirements not hinder the viability of a scheme and ultimately prevent development from coming forward dcs198 Coal Authority Policy DM Test of Soundness A new Policy PH3 has been included in 800 JANUARY 2012 DEVELOPMENT MANAGEMENT Ref From Chapter/policy Comment Justified Effective Consistency With National Policy-X The reference within Policy DM1 to land stability issues is supported However, as currently worded, the policy criterion is focussed on ensuring that new development does not detrimentally impact on the stability of surrounding land or buildings Whilst welcomed, this does not provide a policy mechanism for ensuring that new developments are not themselves subject to any risks associated with land stability For the reasons set out above, and in line with the guidance in PPG14, it is therefore considered that criterion xxi of Policy DM1 should be reworded as follows: • “Not BE SUBJECT TO RISK FROM LAND STABILITY OR have an unacceptable impact on the stability of surrounding land or the structural integrity of buildings or other structures; and” Reason – To comply with the guidance in PPG14 CONCLUSION The Coal Authority welcomes the opportunity to make these comments We are, of course, willing to discuss the comments made above in further detail if desired and would be happy to negotiate alternative suitable wording to address any of our concerns The Coal Authority also wishes to continue to be consulted both informally if required and formally on future 801 City council response the Publication Core Strategy This addresses the impact of existing land instability on proposed developments as well as the impact of development on land stability The reasoned justification refers to the Coal Authority’s Coal Mining Development Areas JANUARY 2012 DEVELOPMENT MANAGEMENT Ref From Chapter/policy dcs313 dcs438 dcs470 dcs711 Natural England Dandara Ltd The Theatres Trust Environment Agency Policy DM Policy DM Policy DM Policy DM Comment stages City council response Thank you for your attention We welcome the inclusion of an overarching development management policy (DM1) to set out requirements for development within Salford In particular we welcome the requirement for developments to minimise greenhouse gas emissions, although we would welcome the expansion of this point to require developments to maximise opportunities for the incorporation of renewable energy generation Within the section covering impacts, we consider that the wording ‘not have an unacceptable impact on…’ is somewhat ambiguous and implies that some level of detrimental impact will be acceptable We would prefer to see the policy requiring development to ‘have no adverse impact upon and where possible enhance…’ these features Support the general approach to develoment management As suggested in our previous representation (see reference 369 - Policy TC4), the Core Strategy should include a policy to establish a general approach to Planning Obligations with appropriate references to strategic sites and clear links to the details set out in the supplementary planning document Paragraph 23.3 on page 211 states that It is therefore essential that all relevant policies are considered when putting together and determining planning applications but does not include guidelines for the Council’s approach to planning obligations and CIL relevant to Policy DM1 Development Management We would suggest that the wording of this policy needs strengthening as the use of the word ‘unacceptable’ would be open to varying interpretation We would therefore recommend this policy is worded to ensure there is no overall detrimental 802 The policy has been subdivided in the Publication Core Strategy In terms of greenhouse gas emissions and renewable energy generation, the Publication Core Strategy does not require developments to exceed national requirements In terms of biodiversity, Policy BG2 clearly sets out what will be required from new developments, and how the acceptability of any impacts will be determined Noted Policy DP6 of the Publication Core Strategy sets out the overall approach to mitigating the impacts of development, which includes the use of planning obligations More detailed guidance on planning obligations will be provided in a separate supplementary planning document The policies of the Publication Core Strategy are clear as to how the acceptability or otherwise of any impact will be determined, and provide more JANUARY 2012 DEVELOPMENT MANAGEMENT Ref From Chapter/policy dcs767 dcs1128 Worsley and Boothstown CC Highways Agency Comment effect on the boroughs natural resources Policy DM We agree with this policy Policy DM The Agency welcome and encourage the areas identified within this Policy, especially those that look to improve accessibility to key services and development, as well as improving accessibility to public transport, cycling and walking routes The Agency also supports the aspiration to minimise the need to travel, as this should reduce any adverse impacts of the proposed development quantum on the SRN 803 City council response detail than Policy DM1 of the Draft Core Strategy Noted Noted JANUARY 2012 CHAPTER 25 – RISK MANAGEMENT RISK MANAGEMENT Ref From dcs1374 Peel Holdings (Management) Ltd Chapter/policy 25 Comment The risk management table does not adequately reflected the major challenges faces Salford in respect of the following risk: "Suitable sites are not available to deliver the scale of development proposed." The impact of the risk is assessed as ‘serious’ Peel considers that this is a ‘major’ issue The likelihood of the risk is classed as ‘remote’, but, based on the analysis set out in section above, it is considered by Peel to be ‘very likely’ The DCS has under-calculated the housing provision, underprovided for high quality family housing, overloaded phasing later in the plan, under-estimated the effects of the recession on the housing market, under-calculated the need for new industrial and warehousing land and over-calculated the amount of employment land to be released This creates a major policy tension in Salford West which can only be overcome by releasing additional land for housing and employment If the City does not plan for the need to release additional greenfield and/or Green Belt land, it is likely that individual projects will progressed through the development management system, relying on national policy to ensure that the housing and economic needs of Salford are catered for The City will effectively be planned by the latest appeal decision This represents the most significant risk to the Salford DCS 804 City council response The various assessments and analyses of land availability have been updated, and are considered to be realistic The assessment of this risk is therefore considered to be accurate, but it will be important to monitor it to ensure that it continues to be minimised The risk assessment is now contained in the Implementation Plan rather than the Core Strategy, so that it can be updated regularly JANUARY 2012 CHAPTER 26 – REPLACEMENT OF UDP POLICIES REPLACEMENT OF UDP POLICIES Ref From Chapter/policy dcs561 Sport England Table 26.1 Comment The inclusion of this section is valuable to the document However, there are some queries Firstly, the table following para 26.2 shows policy R6 of the UDP as being replaced by the Allocations DPD Policy R6 allocates a number of sites for new or improved recreation use Amongst these sites is the Duncan Mathieson Playing Field (R6/3) The UDP states that this allocated site comprises of an underused, private playing field in need of improvement and adjacent land which provide the opportunity to concentrate a large number of high quality sports pitches in a single location Salford’s Playing Pitch Strategy also identifies the site and identifies actions including enhancing the sports pitch provision and ancillary facilities dcs562 Sport England Table 26.1 Whilst the Allocations DPD will replace policy R6, it is unclear whether the actual sites identified by policy R6 will actually be allocated in the Allocations DPD Further clarity would be beneficial here It also raises a question about the time lag between adoption of the core strategy and the allocations DPD Specifically, policy R6 is currently saved but is not being replaced by a policy in the core strategy However, some of the policies which R6 supports are being replaced by the core strategy Does this then mean that the sites allocated by R6 will remain as allocations until the Allocations DPD is adopted? Secondly, the same table shows policy R1 Protection of Recreation Land as being replaced by policies GI1 and TO2 However, neither policy GI1 or TO2 appear to offer a safeguarding role and instead focus on new developments In addition, the scope of policy R1 is more wide ranging in scope than either GI1 and TO2, eg it includes indoor sports facilities 805 City council response The sites allocated in saved UDP Policy R6 will remain allocated until that policy is replaced by the Allocations Development Plan Document It would be inappropriate to speculate as to what sites may or may not be allocated in the Allocations Development Plan Document, as that would pre-empt the whole process A new Policy R4 has been included in the Publication Core Strategy, which specifically relates to these issues JANUARY 2012 REPLACEMENT OF UDP POLICIES Ref From Chapter/policy dcs563 Sport England Table 26.1 Comment Thirdly, the table shows policy R2 Provision of Recreation Land and Facilities as being replaced by policies TO2 and TO3 respectively However, policy R2 is much wider in scope than polices TO2 and TO3 For example, policy R2 includes indoor sports facilities within its scope 806 City council response Policy R2 of the Publication Core Strategy provides a comprehensive approach to recreation provision, and includes reference to indoor facilities ... 1,000 households since the Draft Core Strategy) The Core Strategy has no control over 35 Policy DP1 of the Publication Core Strategy seeks to maximise the use of previously-developed land in meeting... Policy H4 of the Publication Core Strategy (providing 39% houses, rather than 28% at the Draft Core Strategy stage) The mix of dwellings reflects the forecast mix of household sizes The number of apartments... 13,550 proposed over the period 201 1-2 028 in the Publication Core Strategy, compared to 24,250 over the period 201 0-2 030 in the Draft Core Strategy Around 405,000m2 of existing industrial and warehousing