GNLP0323

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Object

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22893

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Representation Summary:

The Part 1: Strategy document focusses very heavily on the growth of employment in high value, technical sectors. Policy 6 – The Economy states that sufficient land is allocated in accessible locations to meet need. The need arises from background evidence in an Employment Land Assessment, which does not consider the growth or support of low-tech business sectors, which have different needs and values. Policy 6 focusses allocations into strategic employment areas where new buildings are inappropriate and/or out of financial reach for the type of low-tech business attracted to locations such as Park Farm. This is contrary to the Plan’s objective of a broad-based economy, and to the reference in Policy 6 to the appropriate re-use of rural buildings.

We have therefore objected to Policy 6 and associated background documents and aspirations stated in the Plan, on the basis that the policy should include reference to the way that low value or low-tech business needs such as storage will be supported as part of the broad-based economy. Whilst this may well be served through criteria-based policies at the District Level, it is important to note that the lack of an allocation at Park Farm means that it may be difficult to rely on countryside-based policies for future consolidation of the uses, confidence from future occupiers, and confidence in related investment such as the access. Allocating the site in the Part 2 document will acknowledge its contribution to the range of businesses supported by the growth agenda. The plan acknowledges in the “alternative approaches” section of Policy 6 that detailed changes might be justified.

As noted elsewhere in this representation, Policy 6 should therefore include reference in section 2 to low-tech as well as smaller and start-up businesses, with additional or amended bullet points to refer to low-tech and low-value employment in appropriate locations such as Park Farm. On that basis, the formal allocation of Park Farm would be a natural conclusion.

Whilst the Part 2 assessment of the site suggests that there is simply no need for Park Farm to be allocated, as there is sufficient land already allocated, we object on the basis that the other land is high-value and not the right type of development for the type of user that is attracted to such locations as Park Farm.

Highway access is noted as a constraint. Please see the Transport Technical Note submitted with this representation, which includes visibility splays and swept path analysis and shows how accessibility is assured and safe.

Heritage is also noted as a constraint, associated with the setting of the Church of St Wandregelius. However, the site is proposed to utilise existing accesses and existing buildings, such that the setting of the listed church will remain largely unchanged in terms of character, and similar in appearance. Nevertheless, a heritage Statement will be provided in due course to support future stages of the GNLP preparation.

The site is within Flood Zone 1, low risk, for planning purposes and passes the sequential test. However, as it is greater than 1 ha, surface water is to be considered through a Flood Risk Assessment (FRA) as part of any future planning application. The FRA will demonstrate that the proposed development would be safe for the lifetime of the development without increasing flood risk elsewhere, and where possible, that the development will reduce flood risk overall.

The site should therefore be allocated for low-tech B1 development.

Full text:

For full representation, please refer to the attached documents.