THE DRAFT LOCAL PLAN This is my submission to the Draft Local Plan I very strongly believe that greenbelt should be protected unless exceptional circumstances can be demonstrated. I am an elected member of Cheshire West and Chester Council, I represent the Handbridge Park Ward in Chester I do not consider the Plan sound for the following reasons:- JUSTIFIED - The Plan is not the most appropriate strategy as housing requirements are much too high compared to Government household projections. Furthermore, even with this high level of housing there are no exceptional circumstances to release Green Belt in Chester as the need can be met on brownfield sites in Chester or other areas of the Borough. EFFECTIVE - There is inadequate infrastructure to support 1,300 houses at the Wrexham Road. To make the Plan sound policy STRAT3 should be amended to remove the housing allocation at Wrexham Road and the greenbelt designation retained. JUSTIFICATION The proposal is to remove land from the Greenbelt on the Wrexham Road Site in Chester and to build 1300 houses. This in my opinion would greatly affect residents in a number of ways who live in my ward in the Westminster Park area, which is situated directly next to the Wrexham Road site. We held an Area Forum meeting on 24th October 2012 and a drop in session on 26th September 2013 about the Draft Local Plan and the overwhelming majority of residents were against the release of the green belt. I understand the need for housing and also the reasoning behind this suggestion, however, I am very concerned about the proposals to remove land from the Greenbelt on the Wrexham Road Site as I believe that exceptional circumstances have not been demonstrated, as per paragraph 83 of the NPPF. I agree that we need more family homes and affordable homes. I believe that there is a need for housing but the requirement is different. There are different types of growth to consider. Younger generation and older generation requiring different needs. Careful consideration is required when designing homes for the future as demographics are changing, thanks to advances in medical sciences we are all living longer, which means that there is a need for different type of housing for the older population and if we have to provide homes for our older population then Wrexham road site may not necessarily be ideal as it is further away from the city centre. An older person may feel isolated and it would be better to have housing for older people nearer to the city centre which gives them access to all the facilities they need like medical centre, banks, post office and shops thereby promoting independence. In doing so it would use up some of the brownfield sites identified in the city and not our precious greenbelt. The National Policy Framework states that plans should be aspirational but realistic. To introduce 1300 houses on the Wrexham Road site is my opinion not realistic as there is no infrastructure in place to cope with 1300 new homes. It is very easy to say that matters such as flooding, drainage and traffic will be addressed at the planning stage. I very strongly believe that it is vital to have solid infrastructure in place and I query whether the Plan has been ‘positively prepared’ as the Council has not objectively assessed infrastructure requirements particularly in relation to transport, flooding and drainage. TRAFFIC One of the major concerns residents have is that there will be traffic gridlock particularly during peak times as at the moment they already experience huge traffic problems. If the proposal to build 1300 houses goes ahead this would only exacerbate the situation . There will be at least approximately 2000 additional cars trying to get into the City and only two bridges which in my opinion will not be able to cope with the additional traffic. I believe in order to address the traffic issues one of the solution would be to have a Western Relief Road. It has been highlighted in the Chester Transport Strategy. This solution has been talked about for many years and nothing is ever done and it remains an aspiration because of lack of funding. The reality is that chances of acquiring any funding for the Western Relief Road is very low. I understand that there has been some discussion but not with local Councillors. In my opinion it is fundamentally important to have proper infrastructure to support any housing development. Exceptional circumstances to remove the greenbelt on Wrexham Road has not been demonstrated for the following reason 1. Localism means listening to people. Residents of Westminster Park are very strongly objecting to this proposal as it will have detrimental impact to their quality of life. Their concerns are a) Lack of investment in the Infrastructure b) Lack of funding to improve infrastructure c)Traffic and highways issue - (full details of the issues are described in the submission made by Westminster Residents Association). d) Flooding/Drainage e) Overdevelopment SO 11 - Strategic Objectives 11 - states that we must ensure new development does not create an unacceptable impact either individually or cumulatively, on the amenity and health of residents. 2. There are huge concerns about the assumptions made with regards to numbers of houses required. The concerns are shared by our member of Parliament, Mr Stephen Mosley MP, fellow Councillors and local residents. The plan is not ‘justified’ because the need for houses has been exaggerated by a significant number (contingency on contingency). • Employment peaked around 2007 but houses were built between 2007 and 2010 (start of the local plan) = estimated at approx. 1500–2000 (actual numbers not given in plan documentation) • Structural over-supply of labour in the models results in 2130 additional houses in the 0.4% growth scenario. This scenario is the closest to the 1100p.a. dwelling led plan chosen. • The additional allowance for managed delivery is ~1600 houses added to the first five years • Windfall sites could be included after year 3 of the plan, but have not been included at all. This would amount to 5321 dwellings in the plan period, based on the 2009-2012 average windfall and garden site delivery of 313 houses per annum. The main concern is that the numbers of houses required are based on scenarios which are not supported by evidence. Government projections have been reduced from 800 homes per annum to 495. This new forecast reduces the household growth numbers from 16,000 to just 9,900 new households over twenty years. Recently planning application has been granted to Saighton Camp, for 295 houses, this may reduce the numbers of houses required. Given the increase in sites which are coming forward like Saighton camp which I understand was not in the SHLAA and there may be more. This in my opinion weakens the case for the release of greenbelt. We can still have economic growth with a lower number of housing as Chester is a traditional centre for employment and has a good public transport and within easy driving distance of many nearby towns FLOODING/DRAINAGE Any above average rainfall leads to flooding in Westminster Park and the surrounding fields are also covered in surface water. The drainage is less than adequate for the current number of houses in Westminster Park, never mind additional problems brought by a new development. I note that there was a planning application in the late 1980s in this area which was refused planning permission. EDUCATION The only provision mentioned in the draft local Plan is a school. This is not adequate to accommodate the increased numbers expected. CONSULTATION Although consultation period was extended by two weeks more than legally required. I feel that this was not adequate from the feedback I have received from residents in my ward. There was one Area Forum and a drop in session. I requested another meeting but unfortunately this was not possible. However, All the members of the Spatial Plannning team have been very helpful in providing guidance and information. Web access issues and all other enquires were dealt with promptly. The Representation Form was very difficult to use and not user friendly. I don’t think it is appropriate to ask an ordinary member of public to quote national policies. Residents simply wanted to give their views in the strongest possible way and that is to protect our green belt. I believe that the consultation on the plan has not been carried out in accordance with the Statement of Community Involvement (SCI) and therefore not legally compliant CONCLUSION A proposal to build 1300 homes should have solid infrastructure in place. There is clearly no evidence to suggest that this is in place for the Wrexham Road site and this will have a detrimental effect to the quality of life of residents in my ward particularly residents of Westminster Park. There is no evidence in the plan that the Council has engaged constructively and on an on-going basis with all the neighbouring authorities as required by the Localism Act ‘Duty to Cooperate’ therefore the Plan is not legally compliant. The Plan is not legally compliant as it disregards National Policy for Greenbelt I would be happy to participate at the oral examination.
Posted on: Fri, 01 Nov 2013 15:04:02 +0000
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