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Charnwood Local Plan 2006-2028 Core Strategy

Proposed Modifications

The Council has now published its proposed Modifications following a letter from the Inspector Mr Kevin Ward BA(Hons)MRTPI

The proposed modifications can be viewed on the Councils dedicated Local Plan Website or by the link (click here)

The Council have made the format for replies very narrow and very concise which does not make the task easy or simple.

The objections are confined to the amendment or deletion of any elements of the proposed modifications that are viewed as being unacceptable.

If the words are unacceptable a brief reason for the unacceptability and some alternative words and if they are totally unacceptable then a deletion note again with a brief explanation as to why they are unacceptable.

The format requires three elements to each response the first is the Modification reference which is two letters and a number example MM1 The second is the policy reference example CS1 and the third is the paragraph reference/references 4.2-4.10.

This has not been designed to be user friendly and it makes life very difficult for members of the community whose future it affects.

It is unsatisfactory but in order to assist. Attached are format and examples of the sort of comments that may assist you in any objections you may have.

You may wish to object using the attached framework by either adding further points or changing some words that have been used.

Despite the format chosen by the Council we need to show our commitment to generating a development plan that works for us the community.

Your support and endeavour is appreciated we are people that care about what happens to our community.

click on image for larger scale

GPCPG Comments on the Charnwood Local Plan 2006-2028 Core Strategy Proposed Main Modifications

Mod Ref

Policy

Ref

 

MM1

CS1

19-33

Delete the words "at least" Before 13940

 

 

 

Reason:- The need is a quantified and definitive amount at least opens the total up to challenges which are unwarranted and not necessary

 

 

4.2-4.10

Delete "At least" throughout the document to totals are either defined and agreed or the whole question of need is still not resolved contrary to the plans purpose

 

 

 

Reason:- The use of the word throws into doubt the integrity of the numbers throughout the Document thereby generating uncertainty which is contrary to the objectives of the plan.

 

 

4.23-4.63

The use of the word ‘approximately’ in regards to the number of homes for Shepshed given as 1200 should be replaced with the known actual total of 1375.

 

 

 

Reason:- There is no need to use such inaccurate number when the actual number is known and therefore affords the plan more integrity

 

 

 

Insert the words ‘up to’ and delete the words ‘approximately’ before 7 hectares of employment land.

 

 

 

Reason:- Makes the number definitive as currently drafted it affords uncertainty

 

 

 

Remove at least before 3000 homes

 

 

 

Reason:- Introduces uncertainty contrary to the purpose of a plan

 

 

4.25

Given the scale of development on the eastern side of Shepshed it constitutes an extension of the settlement and should be recognised as such.

 

 

 

Reason: - Introduces uncertainty contrary to the purpose of a plan. 

 

 

 

The majority of the Loughborough SUE is not within the Ward of Loughborough at 30 to the hectare the truth is 1284 homes are in Shepshed part of the Garendon proposal and 1172 are in Hathern; only 630 are actually in Loughborough

 

 

 

 

 

 

 

Reinstate the words ‘and Shepshed’ to more accurately reflect the facts.

 

 

4.46

There are commitments for 1375 homes at Shepshed and given the ceiling of 1200 the 2028 number is already blown notwithstanding the Garendon element

 

 

 

Reason:- Fact that has a bearing and should not therefore be missed

 

 

4.50

The reference to 1800 homes between Loughborough and Shepshed needs to define how many for each ward

 

 

 

Reason:-There is no need at all to use the approach being taken when the numbers are known it is simply lazy and only serves to fog the matter up

MM2

CS3

37-42

Remove the words "at least" before 13940

 

 

 

Reason :- It is either a defined total or the whole question of need is thrown open for debate which defeats the objective of the plan to afford clarity and certainty

 

 

5.18

Its either ambitous or realistic it cannot be both so delete realistic

 

 

 

Reason ;- As drawn its nonsense

MM4

CS5

5.36-5.37

‘Significant detrimental impact’ needs to be expanded to set out what this means

 

 

 

Reason:- as drawn it has little by way of meaning

 

 

45-46

Policy does not accord with National Guidelines in regard to location certainly with the Loughborough SUE. Location on Garendon is unrealistic and contrary to guidance

 

 

 

Amend policy to reflect guidance which is based on hard information gained by central Government

MM14

CS22

118-128

First Line should read:- We will allocate land to the west of Loughborough and the south of Hathern together with land to the east of Shepshed for an extension to those communities

 

 

 

Reason:- The Current plan means that the vast majority of the proposed SUE will have its residents voting in Hathern and Shepshed Council elections not Loughborough

 

 

 

Any Boundary Change would be a matter for the Boundary Commission So for the sake of truth, accuracy and fact the Inspector is saying 1200 for Shepshed is enough when 1375 have been granted and in the event that the Garendon scheme were to be granted or indeed supported by the inspector then the Total for Shepshed becomes 2659 which makes joke of the whole process

 

 

 

Gypsy Policy does not conform to Best Practice Guidelines and in reality will result in no commercial investment being made as evidenced in the guidelines.

The plan makes much of regeneration and the need for jobs. 

 

 

 

 

Bullet point four Reinstate Historic it affords the clarity that registered does not. Alternatively use the term "Historic Registered park".

 

 

 

Bullet point four Reinstate Historic it affords the clarity that registered does not.

 

 

 

Delete "consistent with their significance" it has no meaning without the New Bullet or expand the definition of significance

 

 

 

2nd line delete "by delivering" and replace with "by providing" for

 

 

 

Reason:- A plan cannot deliver it can only enable

 

 

10.12

Replace ‘delivering’ with ‘target of delivering 2440’.

 

 

 

Reason:- Delivering is not within the Councils gift it can only enable

 

 

10.20

Remove "whilst also responding to the lack of provision for food shopping in the west of Loughborough"

 

 

 

Reason:- Misleading as the connection with Loughborough is minimal

 

 

10.24

Should read it will have the ‘character of an estate road incorporating design standards that avoid lengthy straights and should include islands to reduce speeds’.

 

 

 

Reason: - ‘Character of an estate road’ means absolutely nothing unless it is expanded.

 

 

10.28

Remove the word ‘appropriate’ before public access.

 

 

 

Reason:-The former statement clearly states it is a public park and therefore the use of the word ‘appropriate’ is not necessary and implies a limitation which is not what was advertised to the public at the outset.

 

 

10.35

Remove ‘appropriate’ and reinstate ‘Historic’; reasons already given.

MM16

CS24

10.40

Refers to the need to amend the settlement boundary. This should be detailed, given the fact that a significant proportion of the SUE is in the Ward of Shepshed.

The Council can only amend the western boundary of the settlement; the Section of the SUE in Shepshed has to either be acknowledged as being in Shepshed, as would the Hathern section, or the Boundary Commission will need to be asked to address the issue.

The former renders the Shepshed element untenable because the Council and the Inspector acknowledge that 1200(1375) is the limit for Shepshed.

The latter needs the Boundary Commission to determine the position prior to the headlong rush into resolving a numbers game

 

MM17

CS25

11.10-11.15

CIL implementation to be the subject of viability testing.

This commitment should also clarify the positon in regard to establishing the viability of the SUE proposals as Section 106 burdens cannot be raised post consent and new conditions cannot be introduced at the reserved matters stage. Given the positon of some of the SUE proposals in terms of determination the viability element should be applied to those sites immediately.

 

Annex C

 

CS11-CS13

Key Policy Aim - To Protect Settlement Identity - Baseline N/A - 100% of decisions taken in accordance with the policy.

 

 

 

Comment:- Except coalescence of Shepshed and Hathern as evidenced by the ward boundaries so policy untenable.

 

 

CS5

Policy does not accord with Best Practice Guidelines.

 

 

CS14

Acknowledges Garendon as ‘Historic’ yet the balance of the strategy changes its status to ‘Registered’. Needs to be consistent.  ‘Historic’ should be applied.

Within the Core Strategy there is no acknowledgement as to where the funding for the restoration of Garendon Park will come from. It is silent in the schedules as to funding but annotated as essential with the need generated by the current proposal. It must raise the question as to viability and therefore sustainability and soundness of any decision.

 

 

 

CS22

Demonstrates the lack of faith in the employment land take-up by setting a target of half an acre a year up to 2028. So much for the regeneration sophistry woven into the story.