GNLP2170

Object

Representation ID: 21801

Received: 16/03/2020

Respondent: Quantum Land

Please see attached for full submission
We object to the omission of the GNLP2170 and GNLP2171 sites from the Site Allocations, and the identification of these sites as being ‘Unreasonable Sites’ for the following reasons:
a. At Stage 2 of the HELAA, both sites were given ‘Green’ ratings in respect of site access, open space/GI, and transport and roads, and as a result of this and their other ratings they passed the Stage 2 assessment and were considered to be ‘reasonable alternatives’ and therefore ‘suitable sites’;
b. Stage 4 concluded that both sites were still considered to be ‘reasonable alternatives’. In relation to GNLP2170 (Langley North) it was noted that access to the site was to be via the adjacent Pinebanks site which already benefits from an outline planning approval, and that subject to overcoming the Sport England objection in relation to loss of playing fields (and a requirement for replacement before development commences) the site is considered to be a reasonable alternative.
At this point we should refer to the comments made above in relation to Appendix 1 of the Draft Strategy, and the absence of an up-to-date Sports Facilities Strategy for the area. In addition, it should be noted that the 2018 Draft Playing Pitch Strategy concluded that whilst there was a shortfall of 6 rugby pitches in the GNDP area, that the significant spare capacity of football pitches could be utilised to make up this shortfall. It is also interesting and important to note that, having reviewed the playing pitch audits undertaken as part of the preparation of the Strategy, the Former Langley School pitches were not recorded. It is therefore considered that their loss would not result in any additional deficiency over and above that already referred to.
c. At Stage 6 of the HELAA, detailed assessments of the reasonable alternative sites were undertaken. In respect of both GNLP2170 and GNLP2171, Highways commented that both sites were acceptable subject to an access strategy. In other words, Highways did not object to the inclusion of the two sites. Development Management commented that:
▪They were not convinced that estate-scale development could be delivered due tothe site constraints, although these constraints weren’t identified;
▪Queried whether the allocation should be open-ended in terms of housing numbers;and
▪Identified the need for a masterplan and/or a Design Code to be prepared;It is not clear what the site constraints were to which Development Management referred, as no significant constraints or ‘showstoppers’ were identified by other consultees; and
d.At Stage 7, the preferred sites were identified, and both GNLP2170 and GNLP2171 were dismissed on highways and ecological/landscape grounds, despite there being no objections from Officers on those grounds. This exclusion of the sites from being identified as being preferred sites and therefore becoming site allocations does not reflect the conclusions of the earlier stages of assessment, and on those grounds, we object to the exclusion of these two sites from the Site Allocations.We do not believe that there are sufficient grounds on which to exclude these sites from the Allocations, for the following reasons:
Both sites are previously developed,
These sites either have an existing access in place, or can be accessed via land within our Client's control and via a site already benefitting from outline planning approval for residential development;
There is no up-to-date evidence available at this stage to suggest that the development of GNLP2170 will result in a loss of playing pitches, or any further deficiency in playing pitches;