Set out below is the Society’s response to the consultation on the proposed Modifications to the draft Core Strategy which submitted in January 2012 and was the subject of an Examination In Public (EIP) in May. There may be a further EIP on these Modifications and the responses received since the EIP in May If/when accepted the Purbeck Core Strategy will replace the Purbeck District Local Plan Final Edition (2004) as the strategic planning document.
The Society submitted its own response on the proposed Modifications to PDC on 25 July but before commenting specifically on them as set out in tabular form below, the Purbeck Society noted its concern at the length and complexity of the whole process. The proformas and the quasi-legal way in which the comments to the initial draft had to be made and, similarly comments on the current modifications, we considered to be very un-user friendly, which we are sure will have discouraged many from commenting. Hopefully these issues will not be a feature when developing and consulting upon the individual Local Plans. Furthermore, we noted that by the time the Core Strategy is finally adopted (presumably in 2013) it will be seven years into the plan period of 2006 – 2026/7!
We also felt the consultation period allowed little time to fully understand and hence comment intelligently on them. In the preparation of these comments, we have consulted with representatives from other local organisations and we believe their concerns are mirrored in those of the Society.
In summary we are of the view that the Core Strategy as modified was unsound as it
- did not prove the case for the amount of additional housing proposed
- did nothing to ensure the provision of affordable homes for local families
- ignored a prime site for sustainable development at Dorset Green (Winfrith)
- provided insufficient protection for the natural and built environments of Purbeck
- failed to prove that additional Supermarket floorspace was required in Swanage
- failed to provide sufficient protection for existing town centre retailers
- failed to properly address need for local employment
- failed to adequately address the transport needs of the area
- The detail is set out in tabular form, with the in the left hand column reference numbers in the Modification documentation.
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MM2 |
New Section Partial Review |
We believe this to be un sound. Although there is recognition that development in Purbeck is exceptionally constrained – it has identified areas for extension settlements e.g. Swanage, without ensuring there is adequate mitigation. As stressed at the EIP, there is still no evidence of housing need to justify the numbers proposed. There is still no mention of Dorset Green as a sustainable development site for housing and employment. Of all the sites in Purbeck, the Society believes this to be the most eco-friendly and sustainable site, self contained with good road connection and the potential for a direct rail link and with some existing employment already on site. We fail to understand why this is not included as a major strategic site for mixed use sustainable development. For this reason alone we find the Strategy and the Modifications unsound. A partial review of the CS does not appear strategic and could be market led and reactive. It could also be said that the current process being 6/7 years into the period is a review! In a PDC Statement on the Implications to the Core Strategy of the NPPF, we note that Natural England feels that extension settlements in Swanage into the AONB, are achievable but queries proposals for Dorset Green. We consider this to be completely illogical and thus unsound. Mitigation is just one element for sustainable development and it appears there has been scant regard for the other elements when determining housing allocation numbers in Swanage. Where are the policies to determine when housing allocation has achieved the optimum for certain areas?It seems Wool is the only place where PDC feels this is the case; this approach needs extension throughout Purbeck. There has been no Housing Needs Survey for Swanage and the need therefore has not been proven. (We refer to the discussions at the EIP as to the definition of need.) A housing strategy is needed that prioritises local allocations linked with jobs. There is no policy that ensures market housing will be predominantly family housing and not second homes or Executive luxury (as per Sandbanks and more recently Glebe Estate in Studland). The CS needs to find areas that can be developed sustainably and include the aspiration of achieving National Park Status |
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2.2 Section 1: Building a strong competitive economy |
“2.2.3 Ahead of the Site Allocations Plan and Swanage AAP the Council will consider preparing an economic strategy that is consistent with the emerging LEP strategy… “This wording does not seem to appear in the Main Modifications document, rather in a PDC statement on the implications to the Core Strategy of the Publication of the NPPF“.
A sound CS requires an economic vision and strategy which positively and proactively encourages sustainable growth together with local employment. A Core Strategy without such a strategy is unsound. The NPPF also states that planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.However, the C S allocates even more land at Prospect Farm in Swanage, where the existing site remains undeveloped. This is evidence of a lack of understanding or evidence to show what will boost sustainable economic growth in Swanage. An Economic Strategy needs to be produced as a companion to the Core Strategy not after and not “considering” preparing. |
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MM4 |
3.1 |
960 new dwellings are planned for SE Purbeck, of which a high percentage is expected to be second homes in order to achieve around 250 affordable homes. More creative ways of achieving affordable homes eg. Grant Shapps Housing Policy and the £30m fund for self-build housing must be included in the CS and the overall numbers of new homes in SE Purbeck must be reduced, as has been shown, this number cannot be justified or sustained. |
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MM3 |
1.5 Duty to co-operate |
Not sound. Working with Dorset Local Enterprise Partnership is a positive step. However with employment opportunities created in the Poole/Bournemouth conurbation increasing the amount of housing in SE Purbeck, as proposed, would add to the problems of commuting on the A351. The non recognition of traffic congestion that more commuting will cause is a serious omission, making this part of the CS unsound. |
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MM5 |
Chapter 5 |
Not sound. The statement on Sustainable Development does not reflect Purbeck’s unique landscape and habitats. The addition of one short paragraph about ensuring developers are to provide effective mitigation “if necessary” for European protected sites is clearly insufficient leading to un-sustainability. There appears to be only limited protection for AONB, with policies and guidelines still to be developed. These should be an essential companion to the Core Strategy if protect Purbeck’s unique landscape and character is to be retained for future generations. A more robust, proactive statement to protect Purbeck is essential. Whilst we recognise that it is not necessary to repeat policies that are in the NPPF we feel that Purbeck has such a unique geology, landscape and habitat that the CS should make additional policies in relation to protecting the AONB to ensure that it meets the soundness tests for sustainability. We believe that a commitment to obtain National Park status for the historic ÔIsle of Purbeck’ should be included to provide the protection needed. Omitting such a commitment is a serious flaw in the CS and the proposed Modifications. |
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MM7 |
LD |
Not sound, see MM10 below. |
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MM8 |
6.15 New Para |
Not sound. PDC seeking a Partial Review of Housing Need in 2015. With a limited evidence base and no Housing Strategy in place there can be no certainty that the proposed numbers and locations are correct. |
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MM10 |
6.7.3 |
“An update from the Council’s retail consultants (November 2011),É has identified a need for food floor space of around 1,250-1,300sqm for the plan period. Of this around 900-950sqm should be met in Swanage and around 50-60sqm in Wareham with the balance met in other town centres and local centres.” In the absence of an exclusive allocation policy to accommodate additional retail within the town centre, we are concerned that this leaves the door open for out of centre retail floorspace to be promoted. Furthermore the proposed threshold for a requirement for a retail impact assessment is far too high at 1,000 sqm, taking into account the type of retail provision that already exists within the town centres. If, as PDC is currently recommending 900-950sqm for Swanage, no retail impact assessment would be required. It takes no account for the fact that even a small amount of out of centre retail floorspace in Swanage has the potential to undermine the vitality and viability of the town centre. In applying national averages to take into account non store retail trade, we also suspect NLP has significantly underestimated the extent to which Purbeck residents undertake their main food shopping online, due to the limited number of medium to large food store provision within the District. In underestimating online expenditure, NLP will have overstated the requirement for additional retail floorspace within the District. Lastly, we note that there is insufficient provision within the proposed Core Strategy to prevent excessive non food provision coming forward as part of a proposal to extend the existing convenience goods retail floorspace. The proliferation of non food retail floorspace as part of an extension to the Co-op, for example, is likely to be to the detriment of independent non food shopping provision within the remainder of the town centre. |
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MM11 |
See MM10 |
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MM12 |
See MM10 Not legal or sound. A major change to retail allocation moving from Wareham to Swanage has been included without consultation. It is not clear what “majority” means. Remove statement that Swanage takes the majority of retail space. |
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MM36 |
SE |
Not legal or sound. See MM10. There has been no consultation or adequate evidence to support that Swanage takes the majority of retail space in Purbeck. |
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MM38 |
SE |
Not sound. The statement about extension settlements is not acceptable. There is no protection for playing fields at Swanage Middle School as there is for Wareham Middle School Playing fields. More stringent conditions need to be attached to any extension settlement to protect landscape and sustainability. A similar statement as Wareham Playing Fields should be included. |
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MM51 |
Not sound. No Gypsy and Traveller sites allocated. However it should be noted the opposition to such sites (three proposed) for Swanage. These would be illogical sited at the far end of a peninsular where access is poor and at times extremely congested and where there has been no demonstrated need for such sites. |
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MM56 |
8.8.7.7 |
Not sound. Do not seem to have recognised that “run off” flooding is not just a town centre probability but extends all along the valley to Herston. Neither does there appear to be any consideration of impact of development on the sea coast. |
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MM64 |
Design |
The Core Strategy should be more explicit on density as there is evidence that townscape character assessments are not currently working in Swanage. Design Guides are required to ensure that good design, appropriate to the context of the AONB and neighbouring built environment, is employed in all new developments. These should be produced not only for Conservation Areas but throughout the District. This is essential to maintain and enhance the quality of the built environment of Purbeck’s towns and villages, which has suffered in recent years due to the absence of such guidance. The example of the Cranborne Road area in Swanage was raised at the EIP. |
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MM72 |
IAT |
A PDC statement on the implications to the Core Strategy of the Publication of the NPPF states that “The Purbeck Transportation Strategy mitigates any adverse impact of growth on the constrained road network” therefore does not appear as a Main Modification. Unsound. We strongly refute that the Purbeck Transportation Strategy mitigates any adverse impact of this growth. We understand that the DCC budget for transport has substantially reduced. Therefore any substantial and effective management systems will not be put in place. Consequently, there will not be a better, or sufficient, public transport services linked to housing growth to help improve the self sufficiency of Swanage, or Purbeck’s other towns and villages. The planned rail services linking Swanage and Corfe Castle once again to the main line at Wareham (possible commencement of trial services in summer 2014) will be of marginal benefit to commuters with jobs in Holton Heath or Bournemouth /Poole and the rail link should be discounted as a justification for more housing. If/when these services can be projected to Bournemouth, there may be some greater justification. In the meantime, the rail link will improve access for visitors and tourists to the area and give choice for the existing residents at times of road congestion or when there is a serious accident closing the A351, or when the ferry is closed for maintenance. |
MAS
25 July 2012
Ends