dcs647 NWDA Whilst our detailed comments are attached, we wish to highlight the following keyissues: Whilst we are generally supportive of the draft spatial vision and strategic objectiv
Trang 1CITY 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 Chapter/policy Comment City council response
dcs11 Civil Aviation
Authority General comment The Civil Aviation Authority do 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
is protected
Policy A14 of the Publication Core Strategy sets out the approach to be taken
to Barton Aerodrome (City Airport)
dcs35 CABE 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
The spatial framework in Chapter 6 of the Publication Core Strategy sets out a policyfor 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 planand its implications, as well as helping to guide the production of any
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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 necessaryprovide 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
neighbourhood development plans.The approach to design in the Publication Core Strategy has been significantly expanded, reflecting the importance of thisissue 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 3 of the Publication Core Strategyprovides 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
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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 throughyour 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 thearea?
· Has the functionality of the place and its role within the surrounding context been considered?
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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 thearea?
· 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
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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?
dcs40 Graham Crook 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 claimthat 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 reasoningbehind this proposal is the enormous revenue that would be generated by the Council, and the property developers
The scale of housing development proposed in the Core Strategy has been significantly reduced, from 33,750 over theperiod 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 isbased on household projections taken from the Greater Manchester Forecasting Model, with an additional allowance for theimpacts of the extra office development proposed in the city It should therefore reflect a realistic assessment of likely demand
dcs58 Ken Lee Supports the Draft Core Strategy No comments made Noted
dcs96 David Jones 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
to public transport services, but as it is a strategic document it is unable to deal withvery detailed issues relating to bus services to particular neighbourhoods.dcs108 Carole Bridge Salford does need much redevelopemnt and investment to
improve homes, social services and facilities However, I do hope the same mistakes are not going to be made as in the 50'sand 60's when Cross Lane, Ellor St was destroyed with all shopsand local fcailities wiped out.Cross Lane is now desolate and theprecinct, Broadwalk, Belvedere Rd is almost wiped out too
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
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Nowhere to meet friends etc 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
dcs125 G Platt Support Noted
dcs126 G T West Sounds great Noted
dcs238 Government
Office North
West
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 willneed 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
The Publication Core Strategy focuses on providing any additional guidance through Development Plan Documents and Supplementary Planning Documents Chapters 2 and 3 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
approach to affordable housing, renewable energy, employment land, retail need, sustainability assessments and other
Noted The relevant evidence is being published alongside the Publication Core
Strategy.
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appropriate assessments We are aware that a number of studies are being undertaken to put this evidence in place dcs175 Gary Sla Do not support the Draft Core Strategy Comments not entered Noted
dcs180 MOD The Ministry of Defence (MOD) can confirm they have no
safeguarding concerns as this falls outside the statutory safeguarding areas
Protection of biodiversity 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 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
Chapter 21 of the Publication Core Strategy seeks to secure an increase in the city’s biodiversity resources
Chapter 20 of the Publication Core Strategy seeks to protect, enhance and expand the Green Belt
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 thecity’s heritage
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
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The lack of specific indication of where industrial, warehousing, residential and other developments will be sited
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
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
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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 tothe environmental effects of the expansion
The Western Gateway Infrastructure would bring the traffic to anunbearable 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
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There is not clear indication about areas of low value/vacant and underused ‘industrial’ uses of apparent dubious existing andfuture employment generating capacity (without rationalisation ofland 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
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Planning and Compulsory Purchase Act 2004 to ‘exercise its [planning] function with the objective of contributing to the achievement of sustainable development.’
Finally the overall strategy is based on assumptions of relatively high growth rates These are unrealistic in the current economic climate and land should not be blighted now for a situation whichmay or may not exist in the very long term Any decision
regarding the Core Strategy must be delayed until the Employment Land Review and the Housing Land Review figuresare available
dcs342 T Booth Salford City Council is trying to run before it can walk Before it
indulges in such (Core Strategy) thinking it must earn the right tothink about such things by getting the basics right first Until then
it should just get, & keep, out of the way
It is important that Salford has an date spatial strategy and set of planning policies The Core Strategy will provide this
up-to-dcs353 Hani El Qasem A number of Salford residents have recently been made aware
of this consultation They were unaware it was occurring as they never received the LifeInSalford magazine advertising it
Unfortunately, this only gives them a week to respond and they are keen to respond Would it please be possible to extend the consultation period to allow them to provide input?
Late representations were accepted and taken into account
dcs400 Jodie Booth I would like to add some brief comment in response to the
consultation, particularly with regard to the proposals in Monton and Eccles A number of Salford residents have only very recently been made aware of this consultation at a residents meeting They were unaware it was occurring as they never received the LifeInSalford magazine advertising it Unfortunately,this only gives them a very short time to respond (less than a week) and I am aware of many who are keen to respond Would
it please be possible to extend the consultation period to allow them to provide input?
Late representations were accepted and taken into account
dcs401 Stephen
Ankers How can the council promote all the elements of this policy whilst considering building a ECO waste dump in an urban The city council refused the planning application for a waste management
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dcs409 Huw Buckley A number of Salford residents have recently been made aware
of this consultation They were unaware it was occurring as they never received the LifeInSalford magazine advertising it
Unfortunately, this only gives them a week to respond and they are keen to respond Woud it please be possible to extend the consultation period to allow them to provide input?
Late representations were accepted and taken into account
dcs647 NWDA Whilst our detailed comments are attached, we wish to highlight
the following keyissues:
Whilst we are generally supportive of the draft spatial vision and strategic objectives, we question whether the dwelling mix proposed will provide a sufficiently diverse range of high quality housing;
We question whether the high proportion of apartments is desirable and, in the current housing market, deliverable;
We have some concern over the proposed release of around
130 hectares of existing employment land to other uses such as housing, particularly if such sites are intended for more
apartments;
Where the Core Strategy refers to NWDA designated strategic regional sites, we suggest that some further changes are required; and
Whilst we see some potential synergy with the strategic regional site at Barton, a robust case will be needed to justify the release
of land adjacent to City Airport Manchester from the Green Belt
The dwelling mix has been updated in 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 proposed has been significantly reduced, with 13,550 proposed over the period 2011-2028 in thePublication Core Strategy, compared to 24,250 over the period 2010-2030 in the Draft Core Strategy
Around 405,000m2 of existing industrial and warehousing floorspace, equating to around 115 hectares of land, is proposed for redevelopment to other uses in Policy EC3 of the Publication Core Strategy Thisreflects the latest forecasts from the Greater Manchester Forecasting Model.The proposed release of 40 hectares of Green Belt at Barton for employment
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purposes has been deleted from the Core Strategy
dcs458 Zoe Price A number of Salford residents have recently been made aware
of this consultation They were unaware it was occurring as they never received the LifeInSalford magazine advertising it
Unfortunately, this only gives them a week to respond and they are keen to respond Woud it please be possible to extend the consultation period to allow them to provide input? I am a resident of Monton living on Canal Bank not 200 yards from the proposed site Here a link to Greenpeace’s alternatives to incineration for your consideration
to-sustainable-waste-management
http://www.greenpeace.org.uk/incineration/the-complete-guide-Late representations were accepted and taken into account
The city council refused the planning application for a waste management facility at Green Lane, which is being referred to
dcs463 Vicki Keogh A number of Salford residents have recently been made aware
of this consultation They were unaware it was occurring as they never received the LifeInSalford magazine advertising it
Unfortunately, this only gives them a week to respond and they are keen to respond Woud it please be possible to extend the consultation period to allow them to provide input?
Late representations were accepted and taken into account
dcs633 English Cities
Fund ECf broadly supports the spatial vision, framework and strategic objectives of the Core Strategy However, many aspects of the
recently adopted Salford Central Development Framework (2009) and the previous Planning Guidance (2008) is not sufficiently reflected in the emerging policies as it affects the area of Salford Central In particular, the vision for the western gateway into the Regional and City Centre has been obscured
by the policy sub-division for employment, housing, public space, etc.; and, the comprehensive regeneration necessary to deliver these segmented policy objectives has been lost in the more general vision presented here
Policy SF1B of the Publication Core Strategy now provides a clear vision and strategy for the Salford Central area, pulling together the various economic, housing, retail, and other proposals
dcs608 LPC Living Conclusion and Recommendations
It is important in preparing Local Development Frameworks that
The new retail facilities at Trafford Road are identified as a local centre in Policies TC1 and TC2 of the Publication Core
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any allocations stand a realistic prospect of being delivered
With this guidance in mind, and in the light of the above, LPC Living:
1 supports the overall message within the document to encourage future development in the existing and proposed centres;
2 recommends that a positive policy promoting regeneration across the City, including Ordsall, is included;
3 supports the identification of a new centre at Trafford Road, Ordsall (TC 3), but recommends the centres hierarchy should beamended to reflect the PPS 4 definitions to include district centres (TC 1, TC 3);
4 recommends the proposed centre at Trafford Road, Ordsall should be re-allocated as a district centre as defined in PPS 4, due to the nature of the approved development at the site (TC 3);
5 supports the approach to housing needs set out in H3 and H4,but recommends that the policy should acknowledge that flexibility will be required in certain circumstances; and
6 LPC Living supports the focus on expanding tourism, but recommends this be expanded to include district and town centre locations for hotels and other tourism uses (TO 1)
We trust that these representations will be considered as part of the Council’s ongoing process to develop the Core Strategy document We would be grateful if you can keep us informed of its progress and any additional stages of consultation that are
Strategy (Ordsall Local Centre) The scale
of the facilities, and their likely role, are notconsidered to constitute a district centre, and so the local centre designation is considered appropriate
Chapter 10 of the Publication Core Strategy sets out a clear policy approach
to housing, but the document is clear that policies will be applied flexibly where appropriate
Policy EC5 of the Publication Core Strategy includes town centres amongst the areas where hotel development should
be focused
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undertaken as part of the evolution of the document towards final adoption In the meantime, should you have any questions please do not hesitate to contact either Jeremy Hinds, Trevor Adey or James McAllister-Jones at these offices
dcs610 LPC Living LPC Living has a developer agreement with Salford City Council
to deliver regeneration across the Ordsall Estate Notable successes to date include:
1 Funding for Safer Schools linked to Primrose Hill Primary School as well as additional investment being injected into the new school
2 New infrastructure investment, including a new roundabout which limits traffic speeds through part of the estate linked to new highways across the estate
3 Full refurbishment of Monmouth Park in the south of the estate
4 Upgrade of infrastructure by Ordsall Hall to conservation kerbing, and the creation of a Pedestrian Priority Zone
5 Funding for the Ordsall litter-bug for three years
6 In excess of 335 new homes constructed and sold to owner occupiers and first time buyers
7 Working with the Council and the Primary Care Trust to deliver a new Health Centre within the centre of the estate to serve a wider community
LPC Living has recently been granted planning permission by Salford City Council for a mixed use redevelopment scheme at
Noted
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the former Radclyffe School (now demolished) and associated playing fields on Trafford Road, Ordsall (ref 08/56286/FUL) Theproposal comprises 153 houses and apartments as well as a 4,605 sq m foodstore, pre-let to WM Morrisons, and 2,347 sq m
of additional floorspace across 11 small units providing a mix of uses (Class A1, A2, A3 and D1)
Future priorities for LPC Living include:
1 Ensuring delivery of development of the former Radclyffe School site
2 Further development of new homes across the estate on a number of sites in partnership with Salford City Council
3 Securing a new Health Centre within the centre of the Ordsall Estate
4 Further infrastructure improvements across the estate to ensure that the estate becomes far more sustainable, and accessible to all
dcs619 Commercial
Estates Group We write on behalf of Commercial Estates Group (CEG) to makerepresentations in response to the Council’s current consultation
on the Draft Core Strategy (November 2009) These comments should be read further to those made to the Issues and Options (23 January 2009) and Alternative Options consultation (29 May 2009) CEG act for the owners of Barton Business Park on Cawdor Street, adjacent to which is the Americhem site CEG and Americhem have been considering a joint approach to the mixed-use redevelopment of these sites and the wider industrial area which also includes land owned by the Council (see enclosed plan) For the avoidance of doubt, the comments below relate only to those areas of the Strategy which are
Noted
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considered pertinent to CEG’s land interests
dcs602 Steve
Middleton The Draft Core Strategy feels very officer-led, I wonder what input councillors have had (if any) Councillors have been involved throughoutthe Core Strategy process All stages have
required approval either by the Lead Member for Planning or the full Council.dcs844 4NW (formally
NWRA) In terms of the RSS, the Core Strategy is in general conformity in relation to the spatial principles and framework within RSS,
particularly policies as follows: DP 1 – 9 and Policy RDF1 these polices set out the broad locations of development and the main development principles for the region however we do have the following comments to make
Noted
dcs898 Countryside
Properties See comment made to ref 900 (Chapter 6 Spatial Framework) Noted.
dcs933 Trafford MBC Given that we are both moving towards Publication and
Submission of our respective Core Strategy’s in mid 2010 there
is clearly a need to expedite the conclusion of the outstanding joint GM Transport Modelling and Strategic Flood Risk Assessment level 2 work so that the conclusions of these studies can be thoroughly assessed and reflected in our respective documents
Both of these studies are now completed, and have informed the Publication Core Strategy
dcs922 Arndale
Properties Ltd Arndale Properties Limited is a private property company that owns a wide variety of largely industrial land throughout the UK
In particular, Arndale owns the former GUS Warehouse on Worsley Road Eccles, a site of some 4.64ha that was formerly used by GUS and thereafter Littlewoods/Shop Direct as a distribution warehouse, but which is presently vacant Arndale have been considering the future of the site, which adjoins residential properties and the Bridgewater Canal, for over three years, and presently has two interrelated planning applications with Salford Council for the part refurbishment and part redevelopment of the site for employment use
Given this context, Arndale are particularly familiar with the
Noted
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issues relating to regeneration of employment land in Salford
They also have considerable experience in respect of the application and interpretation of employment land policy and have successfully pursued planning applications and, where necessary, appeals, elsewhere in the UK, obtaining residential consent on vacant employment land
dcs746 NHS Salford How will the Core Strategy link into the development of the City
Region Governance? The timeframes of the Strategy do not match those of the Greater Manchester Strategy
The Association of Greater Manchester Authorities is continuing to consider the most appropriate way of tackling strategic planning issues A Greater Manchester Spatial Framework is likely to be produced, supporting the implementation
of the Greater Manchester Strategy.dcs756 NHS Salford The Strategy also notes a wider contribution to improving mental
health and wellbeing – reducing deprivation, affordable homes, access to nature and environmental quality All new
developments will be required to encourage healthy lifestyles
There is a commitment to increasing physical activity, provision
of open and green spaces, improving access to services, promoting and facilitation independence and self care and improving quality of life for older peoples These aims are welcomed by NHS Salford
Noted
dcs819 Christine A
Smith Alternative proposal: Build the eco village in the Regional Centre The city council refused the planning application for a waste management
facility at Green Lane, which is being referred to
dcs822 Christine A
Smith Alternative proposal: That national planning policy, specifically Planning Policy Statement 1, is changed to explicitly support
localised food systems, thereby encouraging the provision of food infrastructure including urban and peri-urban abattoirs, bakeries, dairies and food hubs
The Core Strategy has no control over national policy The Government has recently consulted on a draft National Planning Policy Framework, which would replace PPS1 The final version is due out before 31 March 2012
dcs916 Drivers Jonas Overall, we support the provision set out in the Salford Draft Chapter 11 of the Publication Core
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Core Strategy including both the Strategic Objectives of the planand the specific policies set out the achieve these objectives
We recognise the need for regeneration in areas of Salford and that the promotion of retail will play an important part in this We request however that Salford City Council ensure that the improvement of town centres and retailing within the Borough is
in accordance with the recently published PPS4 ‘Planning for Sustainable Economic Growth’
Strategy takes a positive approach to improving the city’s town centres, with Policy TC3 setting out the anticipated scale of additional retail floorspace for each centre
dcs789 Greater
Manchester
Ecological Unit
Climate Change GMEU supports objectives in the Strategy to reduce greenhousegas emissions and to mitigate the effects of climate change
Climate change is recognised as one of the most serious currentthreats to the conservation of biodiversity The Strategy makes important commitments to measures for reducing greenhouse gas emissions and to measures for mitigating the effects of climate change, including future restrictions of the extraction of peat from Chat Moss These measures will contribute to the effective conservation of biodiversity However, we note that the level of development proposed for the City in Strategy is significant and that meeting climate change objectives will therefore be challenging We would therefore support the preparation of a dedicated Climate Change Strategy as an addition/supplement to the Core Strategy
Noted The city council published a Climate Change Strategy in June 2010
dcs842 JASP Planning In general, it is considered that the policies are overly wordy
There are many elements of the policies that seek to influence matters which are unrelated to planning, such as building regulations, building management, dwelling emissions rates etc
The policies in the plan should not duplicate matters controlled
by other regulations or are not related to spatial planning matters
In addition the Core Strategy includes a significant amount of
The Publication Core Strategy continues
to include a significant number of detailed policies This is considered particularly important given the proposed loss of the Regional Strategy and a significant amount of detailed guidance at the national level, and will help to ensure that there is clarity for developers and decisionmakers The policies are not considered to
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detail, especially within the wording of actual policies, rather than seeking to establish a broad vision and strategy This will mean that elements of the policies will inevitably be out of date
or superseded by events before they are adopted In this respects the policy framework indicated appears neither robust
or sufficiently flexible to respond to changing market conditions
be unduly detailed or onerous All of the policies have been reviewed, and they no longer seek to control matters related to building regulations and dwelling emissions rates Policy DP7 does relate tomanagement and maintenance, as these are vitally important issues for the success
of development in Salford, and have created problems in the past
dcs843 JASP Planning The Core Strategy appears to be about fettering development
with complicated onerous policies that fail to provide a framework within which development can be delivered with a significant amount of pressure on developers of sites to deliver with conflicting aims and objectives and a reliance on high density development There seems to be little understanding of the impact these matters will have on the deliverability of schemes or the current state of the market and how that will evolve As a result there is some real doubt as to whether any ofthe objectives will be met
The Publication Core Strategy provides a clear framework within which significant levels of development can be delivered However, it is important that detailed policies provide clarity over the type of development that will or will not be acceptable
dcs887 John Cook To achieve anything like the vision portrayed, you must
approach each area with some degree of sensitivity for the weel being of its residents, by this I mean giving them the opportunity
to respect their surroundings and contribute to their upkeep
I have always maintained that each district or community should have access to a community centre in the hope they will all feel something is being done on their behalf The climate does not bold well for young people in the next ten years, so any development must include jobs to give them self respect and a chance to earn a living Industry must be encouraged to come into the city and this must not all be service sector A solid manufacturing sector is essential to create the right sort of skills for growth There must be no more bad planning decisions by allowing the building of apartments or offices directly up to the
The spatial framework in chapter 6 of the Publication Core Strategy sets out a visionfor each part of the city The Localism Act
2011 provides new powers for local communities to produce their own neighbourhood development plans, which will enable communities to identify local priorities
Chapter 9 of the Publication Core Strategysets out a range of policies designed to ensure that there is good access to employment opportunities for all Salford residents
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pavement You mention the development of Chapel Street when
it already has new buildings, built on the edges of roads frustrating this vision It is doubtful a one way system would workwithout opening up other roads to take the ineviatable increase
in traffic over the next decade
Dare I be so bold to suggest that in our land locked city, to open space for roads green spaces, community centres etc that in certain CPO's would be deemed necessary, radical,
controversial, yes but without this kind of thinking and supported
by adequate finance from whatever quarter, afailur this will be
Without such radical thoughts your visions for the future in 2027 would remain just dreams
The Implementation Plan explains in moredetail how the policies and proposals of the Publication Core Strategy will be delivered
dcs1034 GMPTE Mention is made in the introduction that the main infrastructure
proposals are contained in the Core Strategy but an Infrastructure Plan will be produced providing more detailed information on infrastructure needs/requirements It is important that GMPTE is involved in the preparation of this document at anearly stage to ensure that the public transport infrastructure proposals are consistent with that we are proposing and that they are properly integrate with new development schemes
GMPTE has been consulted on the relevant parts of the Infrastructure DeliveryPlan, including the chapters on buses and light rail
dcs1024 Highways
Agency The Core Strategy will replace large parts of the City of Salford Unitary Development Plan (UDP), although some policies in the
UDP together with the Proposals Map will remain in force It is intended that the Core Strategy will not make any amendments
to the Proposals Map, with all proposals being shown diagrammatically Where precise boundaries need to be identified then this will be done through the production of Salford’s Allocations Development Plan Document, which is due
to be adopted in 2013
This is a review of the draft version of the Core Strategy It is anticipated that the final version will be adopted by the city council in September 2011
The approach taken provides an appropriate level of flexibility and it is not envisaged that this will prevent the Core Strategy being implemented It is still intended to produce an Allocations Development Plan Document following on from the Core Strategy
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The Agency is concerned that it is not proposed to alter the Proposals Map, in line with the emergence of the Core Strategy,
as the consultation periods and accompanying evidence preparation may result in sites being no longer suitable for promotion through the LDF, as well as the possibility of new sitesemerging As such, the Agency requires some clarity as to why this approach has been adopted, and how flexible it will be if the proposed aspirations contained within the Core Strategy cannot
be delivered, and therefore not promoted further
dcs934 Trafford MBC In general, we are supportive of the approach set out within the
document and consider that it, for the most part, complements the work being progressed within Trafford on our own Local Development Framework and Core Strategy We do however have the following detailed comments to make: see comment references dcs925-dcs930, dcs932 and dcs933
Noted
dcs972 Central Salford
URC The Council’s draft Core Strategy presents the opportunity to translate the shared aspiration for the City of Salford’s future
prosperity into prescriptive targets for housing units and employment floorspace In this case, Central Salford URC are focusing upon the proposed future outputs for these two key areas which are vital to the City and Region’s continued economic growth, in particular how proposals within the draft Core Strategy link with Central Salford’s programme of transformational change which is focused around the Ordsall and Irwell Riverside wards The remit of the Urban RegenerationCompany is to act as a facilitator between the public and private sectors and work with partners to deliver longlasting and
transformational change to the city
Central Salford endorses, supports and is committed to realisingambitious targets for the city’s growth within the next 17 years
Aspirations set out within the Spatial Vision and Strategic
Noted
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Objectives sections are agreed as the core principles upon which to build Salford’s future, and their ability to guide the city towards becoming more economically prosperous,
environmentally conscious and a place where people choose to live and enjoy doing so are commended The Spatial Frameworkeffectively communicates the type and nature of future
development in a number of the URC’s key project areas, and lends a narrative to underpin delivery figures outlined in the Housing and Employment sections later in the document
Further detail on how these areas should be developed is provided in number of policy documents; most of the key project areas (Greengate, Salford Central, Irwell City Park, MCUK, Ordsall Waterfront) have dedicated adopted Planning Guidance documents n the case of the Salford Central area, the adopted Salford Central Development Framework takes forward key polices of the parallel Planning Guidance to provide additional detail around preferred land uses, scale and height, routes and connections and layout The draft Core Strategy’s projections forthe delivery of new employment floorspace to encourage and secure economic investment within the city and anticipated delivery in housing units to retain and expand Salford’s population are already being implemented at key sites within theCentral Salford area
However, the anticipated outputs in terms employment floorspace and housing units require further refinement in order
to accord with projections generated by Central Salford URC considering projects which possess planning permissions, expected reductions in these following the economic downturn and anticipated future developments on key sites within Central Salford Comments on the draft Core Strategy’s projected employment floorspace and developable dwellings are explored
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separately and in detail below (See comment references dcs973(Employment) and dcs974 (Housing))
dcs981 Central Salford
URC
Central Salford Urban Regeneration Company welcomes the opportunity to respond to this consultation The URC fully supports the City Council’s approach in carrying out robust and meaningful consultation at all stages of the Core Strategy’s development Through a strong partnership with the Council, much has been done to realise the Central Salford Vision and Regeneration Framework to transform Central Salford into a place that is beautiful, vibrant and prosperous The URC’s response has been formed through the consideration of the draftCore Strategy’s general and specific proposals, and the URC will continue to work with Salford City Council in the
development of the draft Core Strategy to ensure that figures within Central Salford’s approved Business Plan and those generated by the Salford Housing Land Availability Assessment (SHLAA) are related
PAC and CSC welcome the opportunity for involvement in the LDF process and are keen to work closely with all Authorities including Salford City Council in their long term vision to enhance the City and further strengthen its economic base
Policy TC1 of the Publication Core Strategy explicitly recognises the very important role that the primary shopping area of the Manchester/Salford City Centre will continue to have throughout the Core Strategy period The
assumptions underpinning the scale of retail development proposed for Salford’s centres in Policy TC3 continue to assume
a very large outflow of expenditure from the city into Manchester
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The importance of the continued health of the Regional Centre
to the future strength of the economic base of the City of Salford and its residents, the wider City-region and the North-West as a whole is clear and the Core Strategy, being the central Planning Policy Document for the City of Salford up until 2027,should naturally reflect the importance of the Regional Centre and seek
to substantiate and enhance the role it serves as a destination for people to live, work, shop and as a tourist and leisure attraction in its own right
In respect of the retail role and function of the Regional Centre, Manchester/Salford is one of the UK’s leading retail destinations and the retail attractions within the Regional Centre draw shoppers and expenditure from a wide catchment area PAC and CSC believe that the City Council, through the Core Strategy should seek to protect and enhance the health and vitality of the Primary Shopping Area (PSA) of the Regional Centre, especially during the current economic climate, to ensure it continues to fulfil its important retail and economic role for the City of Salford and its residents through its consolidation and enhancement
dcs1049 Brian Downes The areas of Claremont and Weaste are under-represented in
the strategy as it currently exists The area needs Community and Leisure facilities which are within wlaking distance of the majority of the population The area at the south of Buile Hill Park/ Seedley Park could be used to create a new facility within the area
There are a few facilities for the young people in the area and the Height Youth Club is in urgent need of refurbishment The people whu run the Youth Club do an exceedingly good job within the restrictions imposed on them but would do so much better with a refurbished or purpose built place The young
Policy SF2F of the Publication Core Strategy provides a broad vision and policy framework for the Claremont and Weaste area Many of the issues referred
to are too detailed for the Core Strategy
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people in the area would also like more recreational facilities andfeel that improved lighting in the parks would create space for them to undertake their activities
The Eccles New Road area is particularly run down and could benefit from improved facilities, especially as it is close proximity
to the development at Salford Quays In particular the area needs schools, leisure facilities and a Community Centre to improve the condition of the area
Within the Claremont area there are a number of areas which should be helped before they descend into much worse areas (Stapleton Street, Fairhope Avenue, etc) and as before the provision of much needed facilities would enhance the area
The city council considers that the Core Strategy is sound, and responds to identified development needs
The level of policy detail is considered to
be appropriate, particularly given the proposed loss of the Regional Strategy and much of the detailed national guidance The detailed policies in the Publication Core Strategy will help to provide more certainty for developers and decision-makers, without adversely impacting on the implementation of the overall strategy for the city
dcs1167 Peel Holdings PPS12 (paragraphs 4.1 to 4.4) sets out the nature of core The city council considers that the Core
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(Management)
Ltd strategies It confirms that:
- A core strategy should include an overall vision for the area;
strategic objectives to address the key issues facing the area; a delivery strategy for achieving these objectives and clear monitoring arrangements;
- The vision should be informed by an analysis of the area and the key issues it faces;
- The strategic objectives are to form the link between the high level vision and the detailed strategy and identify the key specificissues that need to be addressed; and
- The delivery strategy needs to show how the objectives will be delivered Particular attention is to be given to the co-ordination
of actions and resources to ensure that there is a realistic prospect of the strategy being delivered
Paragraph 4.50 of PPS12 confirms that core strategies must conform generally to RSS Paragraph 4.52 provides that a core strategy must be sound In order to be sound it must be:
- Justified (founded on a robust and credible evidence base and the most appropriate strategy when considered against
reasonable alternatives);
- Effective (deliverable, flexible and able to be monitored); and
- Consistent with national policy
Having reviewed the Salford DCS, Peel considers that it does not satisfy these requirements Peel considers that the policies
Strategy is sound, and responds to identified development needs
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are not sufficient to ensure that the Strategic Objectives and Vision of the DCS will be delivered; that the DCS fails to make adequate provision for the spatial development needs of the city and as such is neither effective, justified nor in conformity with the RSS It is therefore fundamentally unsound
Policy RDF1 provides that the Regional Centre should be the first priority for growth and development, with the surrounding inner areas the second priority Policy MCR2 qualifies this by providing that the Regional Centre should continue to develop
as the prime economic driver with housing coming forward as part of mixed use schemes where they contribute to the vitality and viability of the Regional Centre MCR5 relates to the northern part of the City Region which includes Salford West and specifically seeks to expand the quality and choice of housing (in terms of size, type, tenure and affordability) Peel considers that the DCS places too much reliance on housing in the Regional Centre and fails to adequately deliver the objective
of Policy MCR5
26% of the housing proposed for the city will be in Salford West This reflects a significant level of investment in that part
of the city, and would equate to an average of around 330 dwellings per annum Policy H1 of the Publication Core Strategy specifically proposes the release
of greenfield land in two locations in Salford West to ensure that there is a good mix of housing coming forward in thecity
As set out in paragraph 2.4 of the DCS, Salford is an outward looking city which is a net importer of labour at present As a significant part of the Manchester City Region, Salford is committed to accelerated economic growth over the next few decades so that it can become a key part of a world class city region with productivity levels matching those of London and the
The scale of housing proposed in the Publication Core Strategy is considered to reflect an objective assessment of housingneed, based on the Greater Manchester Forecasting Model
The dwelling mix has been updated in Policy H4 of the Publication Core Strategy (providing 39% houses, rather than 28%
at the Draft Core Strategy stage) The mix
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South East (paragraph 2.30) Alongside this, RSS plans for a high level of housing growth between 2003 and 2021 (well above the local household formation rate) in order to attract significant new resident population and deliver a more sustainable pattern of development Improving the balance between economic development and the amount and type of housing provision is key to achieving RSS’s objectives for the City Region and achieving sustainable patterns of development
Peel agrees with the statement at paragraph 2.33 of the DCS which confirms that the scale of economic and housing growth required to achieve this is very significant It agrees with the summary of the following key challenges as set out in paragraph2.39:
- “How can the economic growth ambitions for the Manchester City Region be fully supported in a way that maximises the benefits for local residents in terms of reducing worklessness and improving average household incomes, whilst minimising potential negative impacts?”; and
- “How can the high dwelling requirement be met in a way that provides a diverse mix of affordable housing in attractive neighbourhoods of choice with accessible, high quality facilities?”
In addressing these challenges it is clear that Salford is to play asignificant role in accommodating regional growth aspirations by providing for a high proportion of the City Region’s housing requirements and in particular expanding the quality and choice
of housing The achievement of this objective is central to the achievement of RSS for the Manchester City Region Failure to make appropriate provision to ensure that this can happen will
of dwellings reflects the forecast mix of household sizes
Policy H1 of the Publication Core Strategy specifically proposes the release of greenfield land in two locations in Salford West to ensure that there is a good mix of housing coming forward in the city, including higher value ‘aspirational’ housing
The scale of industrial and warehousing proposed reflects past trends and forecastemployment levels, and is therefore considered appropriate
The Publication Core Strategy proposes some limited additional greenfield land release for housing compared to the Draft Core Strategy, sufficient to accommodate around 300 dwellings in Worsley and Boothstown
The proposed release of 40 hectares of Green Belt land at Barton for employment 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 The same applies to Green Belt release more generally for housing and
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render the DCS in clear non-conformity with RSS and therefore unsound
The role established in RSS has key links to the achievement of the City’s economic aspirations This is a particular priority in thewestern parts of the City that fall within Policy MCR5 of the RSS,which provides for a considerable amount of residential and economic development This is spelt out more locally in the Salford West Strategic Regeneration Framework, a document which the Council has published as a guiding vision and framework for the whole of the west of Salford (but is not referred to in the DCS) It states:
“There is a clear role for Salford West to provide an increasing supply of the quality residential developments needed to retain and attract a skilled and aspirational workforce This includes providing high quality, aspirational housing that attracts and retains higher income earners and families”
Although the DCS correctly identifies the key challenges associated with achieving these objectives, it fails to make adequate provision to ensure delivery of the CS’s vision or of RSS’s provisions for the City Region Peel’s overall case is therefore summarised as follows:
i) Amount of housing: the DCS significantly under-estimates the housing requirements of Salford as set out in RSS (and the Greater Manchester Growth Point) and over-estimates the current supply of housing in the city The net effect is that the DCS makes provision for substantially fewer homes overall than are required to meet strategic objectives and to conform with RSS;
employment purposes
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ii) Type of housing: there is a pressing need in Salford to diversify the type and quality of housing available in the City in order to deliver the objective of accelerated economic growth and attracting significant new resident population The current land supply is dominated by small apartments in the central areas and the range of sites available for houses (as opposed toapartments) does not provide sufficient land in the right locations
to ensure sustainable delivery of the required quantity of high quality family and aspirational housing;
iii) Distribution of housing: there is a need to provide more land for more and better quality housing than the DCS plans for
Central Salford cannot meet the scale and nature of these needs; hence there is a need for additional housing land in Salford West;
iv) Amount and type of employment land: there is insufficient land identified for new industrial and warehousing development
to deliver the City’s economic growth aspirations This requirement cannot be met in Central Salford and should be located in Salford West;
v) Implications in Salford West: owing to the insufficient quantity and quality of housing and employment land provided for in the DCS, significant additional land must be released in Salford
There is a constrained supply and lack of suitable sites in Central Salford to achieve the quality and quantity of both housing and employment (industrial and warehousing) development required Additional land is therefore required in Salford West to meet these needs;
vi) Greenfield land: as a result of the above, there is a need to release greenfield land in sustainable locations for housing, over
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and above that proposed in the DCS; and vii) Green Belt land: in addition, there is a need to release GreenBelt land, also over and above that proposed by the DCS, for both housing and employment purposes This is justified on the basis of the exceptional circumstances arising from the need to meet housing and employment land requirements, which cannot
be met within the urban area or on other (non Green Belt) greenfield land This would be in addition to the allocation of the Burgess Farm
These representations explain Peel’s position in more detail, including commenting on the flawed methodologies that the Council has employed and the evidence that underpins our analysis We then set out in broad terms suggested changes to the DCS to ensure that it is capable of realising the vision for Salford, conforming with RSS and being found sound at examination
dcs1272 BT The Draft Core Strategy as presented is not considered to
accord with the tests of soundness outlined in PPS12 In particular:
The Core Strategy is not in accordance with Regional Policy;
There is an inflexible interpretation of the evidence base which may prejudice the medium to long term development potential ofsustainable brownfield sites, such as this;
The most appropriate strategy when considered against all reasonable alternatives has not been chosen in respect of the Regional Centre and Salford Central; and
The deliverability of sites within the Regional Centre and Salford
The city council considers that the Publication Core Strategy will support the development of previously-developed landwithin the Regional Centre
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Central may be compromised as a result of the lack of flexibility presented in the Draft Core Strategy;
dcs1341 Matthew
Morrison
General comments - To answer yes or no is quite a general answer for such a big plan I agree with parts and not with other parts
It would welcome the opportunity to be more actively involved in the progression of the Core Strategy and the rest of the LDF
As you know, we support much of the vision and most of the strategic objectives set out within the document and we believe that Peel and Council have a number of common interests in thefuture growth and regeneration of the Borough
We are, however, very concerned that the spatial framework anddraft policies set out within the Draft Core Strategy simply will not achieve what the Council is seeking to do We have taken Counsel and consultancy advice and believe there are fundamental shortcomings in key aspects of the evidence on which the Preferred Options are based and flaws in the methodologies for arriving at critical spatial policies and land requirements In particular, we consider that the plan does not make provision for enough high quality housing or employment land (particularly houses for families and aspirational
households and sustainable sites for larger scale industrial and warehousing users) and does not achieve a deliverable
The city council considers that the Core Strategy is sound, and responds to identified development needs
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distribution of development around the City
In short there is a mismatch between the ambitions for the City and the delivery mechanisms contained within the draft document
In the light of this we are very concerned that the Preferred Options do not conform to RSS and Growth point and will not deliver the wider vision for the City Region There is a clear risk that if an Inspector agrees with this assessment the Core Strategy will be found unsound and the timescale for advancing many key development and regeneration projects would be jeopardised This would significantly frustrate our common interests
Peel clearly wishes to avoid unnecessary delay in the adoption
of the Core Strategy and has put forward measures it believes will help to rectify the identified shortcomings including the release of additional land for development We believe our land
is appropriate for development and capable of meeting some of the key aspects of the City's vision We will be providing more information on the sites in due course We would welcome a discussion about these representations at the highest level
dcs1432 T A Fanning Concerns about lack of disabled facilities for people living in the
Salford area Issues of disabled access are addressed through Building Regulations, However,
the Publication Core Strategy does include
a number of measures that should assist people with disabilities, including a requirement that all new dwellings are built
to the Lifetime Homes standard, policies toimprove accessibility, and a
comprehensive set of minimum car parking standards for disabled people
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dcs1434 Roy Speakman Does not support the Draft Core Strategy Noted
dcs1457 Susan Wright See comments to reference 355 (Policy E1 New Employment
dcs1464 Susan Wright There must be more intensive use of brown field sites and
existing buildings before allocating new land Policy DP1 of the Publication Core Strategy seeks to maximise the use of
previously-developed land in meeting development needs
dcs1465 Susan Wright Well integrated mixed use would actively assist in creating self
contained sustainable communities The Publication Core Strategy supports mixed-use development in appropriate
locations, particularly the Regional Centre.dcs1466 Susan Wright Provision of local facilities is key to creating cohesive
Policy DP1 of the Publication Core Strategy prioritises the reuse of previously-developed land over greenfield sites
dcs1480 Susan Wright To implement a comprehensive package of neighbourhood
support, engagement and training opportunities to improve and sustain life chances of local communities
The Core Strategy can only be one small element of this
dcs1482 Susan Wright Introduce a permissive regime that enables local authorities to
prioritise permaculture design principles in local planning policy Policy SF3F of the Publication Core Strategy supports greater agricultural
activity in Chat Moss, and Policy R2 includes a stricter standard for the provision of allotments (increased from 10
to 20 plots per 1,000 households since theDraft Core Strategy)
dcs1487 Susan Wright Adapt legislation to make it easier to take control of abandoned The Core Strategy has no control over
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patches of land legislation
Policy DP1 of the Publication Core Strategy prioritises the reuse of previously-developed land over greenfield sites
The Core Strategy can only be one small element of this
dcs1556 Barton Moss
Green Belt Introduce a permissive regime that enables local authorities to prioritise permaculture design principles in local planning policy Policy SF3F of the Publication Core Strategy supports greater agricultural
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Protest Group activity in Chat Moss, and Policy R2
includes a stricter standard for the provision of allotments (increased from 10
to 20 plots per 1,000 households since theDraft Core Strategy)
In 2008, a number of consultation events were undertaken with
a range of disabled people including those with a physical disability, hearing or visual and dual sensory impairments The aim of the consultation was to find out what kind of things organisations need to put in place to improve the health and wellbeing of disable people living in Salford
This resulted in the production of a strategy document and action plan called Improving the Life Chances of Disabled People, which outlines clearly what disabled people told us, which I enclose
I know Graham Gentry is aware of these documents as there are some specific actions highlighted for Sustainable
Regeneration
The Partnership Board are keen to ensure this strategy is taken into account when looking at the relevant sections of the core strategy
Also, what has become evident to the Partnership Board and reiterated by disabled communities is that senior managers and
Regard has been had to these documents
in developing the Core Strategy
A Community Impact Assessment assesses the likely impacts of the Publication Core Strategy on different groups, including disabled people
The inclusion of a requirement that all newdwellings be built to the Lifetime Homes standard is considered to be particularly positive in this regard
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officers and others that are involved in designing new services and facilities across the city are not always involving disabled people fully in the process which potentially leads to costly mistakes being made whereby the facility or service does not meet the needs of disabled people and so they are not able to access or communicate effectively with people The view of the Partnership Board is that if we get it right for disabled people then able bodied people generally will have no difficulties
Therefore we would urge that having a range of people with disabilities when designing services/ facilities should be automatically built into the planning agendas, and would like to see this included in the core strategy
Also, awareness raising and training in understanding the needs
of disabled people is also recognised as an area that needs further development and improvement and features in the Improving Life Chances strategy
*A copy of “Improving the life chances of disabled people in Salford – a summary of our well being strategy for people with physical and/or sensory impairments 2009-2013” was also included with the comments
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dcs708 Worsley and
Boothstown CC 1 There are other developing documents and strategies that may have a bearing on the final core strategy and some that may be
more developed before the proposed examination in public (in early 2011) Three documents to note are:
Regional Strategy 2010 (current working title) (4NW) Transport Strategy for Manchester City Centre (consultation draft)(MCC and GMPTE)
Bridgewater Canal Corridor Study (SCC) Bridgwater Way (canal side renewal programme) (Bridgwater Canal Company and partners)
We consider that section 1.20 covers this point but it may be appropriate to add into 1.20 section of the publication of the eventual Core Strategy (due August/October 2010) a note of these developing studies and strategies and others as they haverelevance to the final development of the eventual Statutory Core Strategy
The city council has taken into account all relevant documents in producing the Publication Core Strategy It is not considered appropriate to list them all in the document given the number involved The background evidence identifies key documents where appropriate
dcs2 Dr
Steven
Millington
1.1 The evidence at best is that housing demand will remain stable
Nationally there maybe ever increasing demand, that's unless the human race dies out, but locally the population of Salford is significantly lower than it was 20 years ago The problem is that enough of the right sort of housing is being constructed in the right place, with a lack of family housing in the urban core, but too much sprawl in the suburbs and not enough entry level properties
The evidence from both the Greater Manchester Forecasting Model and the Department for Communities and Local Government is that there will be a significant increase in the number of households in Salford over the Core Strategy period, and so it will be necessary to plan for additional housing tomeet those needs The Core Strategy seeks to increase the supply of family
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housing in the urban core, with 4,200 houses proposed in Central Salford A significant proportion of the housing supply will be in lower price areas, and should therefore be affordable
dcs36 Robert Tynan 1.2 Why does salford need more new residents? Isn't it big enough? It is important that the Core Strategy plans
for the forecast scale of household growth,
so as to ensure that everyone can meet their housing needs
dcs1230 Peel Holdings
(Management)
Ltd
1.4 Reference to Strategic Sites should be added, relating to the
proposals map It is not considered necessary to identify any strategic sites in the Core Strategy
Key locations have been identified where appropriate
dcs1203 Peel Holdings
(Management)
Ltd
1.4 In paragraph 1.4, the Proposals Map would need to be amended
to identify ‘Strategic Sites’ such as Burgess Farm and the additional strategic sites that Peel wishes to be identified as listed in Appendix 1 (ie Housing land in Worsley and Boothstown sub-artea, High Clove Lane, Broadoak Park North and South, Crossfield Drive and Beesley Green, Hazlehurst Farm, land east of Irlam, and Land North and West of City Airport)
It is not considered necessary to identify any strategic sites in the Core Strategy Key locations have been identified where appropriate The locations are identified
on maps and diagrams in the Publication Core Strategy rather than on the
Proposals Map
dcs527 Sport England 1.8 Whilst it is necessary to ensure that the core strategy does not
repeat national and / or regional planning policy, it would be useful if the issues considered to be of major importance to the city that are covered by higher level policies are made explicit
As well as providing clarity for the reader, it should also result in the core strategy being a more usable document once adopted
Additional detailed policies have been included in the Publication Core Strategy given the proposed reduction in guidance
at the national level, including a new policy
on the protection of existing recreation facilities (Policy R4)
dcs528 Sport England 1.19 From the list of documents set out in this paragraph, it does not
appear that the evidence base includes an audit / needs assessment of open spaces, sport and recreation facilities across all of the typologies set out in PPG17 Sport England considers an up to date PPG17 compliant audit / needs assessment an essential component of the evidence base It is
The playing pitch assessment is considered to provide a reasonable indication of likely demand, and the suggestion that it should be updated everytwo years is unrealistic The standard for playing pitches in Policy R2 of the