Town Council’s response to the Core Strategy Major Modifications document

This is the Town Council’s responses to the Core Strategy Major Modifications document

PONTELAND TOWN COUNCIL RESPONSE TO NCC CORE STRATEGY PRE-SUBMISSION DRAFT – PROPOSED MAJOR MODIFICATIONS – NOVEMBER 2016

Item 1 – Pages 8 & 9
Question 1
Which major modification does your response relate to?
FMAJ/03/01- Add symbol for Dissington Garden Village proposal and amend green belt boundary designation to reflect changes

Question 2
Do you consider that this proposed major modification meets the legal and procedural requirements?
No

Question 3
Do you consider that the proposed major modification has met these tests?
No

Question 4
Do you consider the proposed major modification to be unsound because it is not:
Positively prepared
Justified

Question 5
Please give details of why you consider this proposed major modification is not legally compliant or sound or if you wish to support the legal compliance or soundness of this proposed major modification please also use this box to set out your comments.
PTC can see no justification for the deletion of green belt in Ponteland.

Question 6
Have you raised this during previous consultation on the Core Strategy?
Yes in all previous consultations on the Core Strategy.

If you have answered ‘no’ please explain why this issue has not been raised before.

Question 7
Please set out what change(s) to the proposed major modification you consider necessary to make the Plan legally compliant or sound. You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text.
A re-consideration by NCC of the stance taken to build on the Green Belt.

Question 8
If you representation is seeking a change, do you consider it necessary to participate in the Independent Examination?
Yes the Town Council would be willing to participate.

Question 9
If you wish to participate in the Independent Examination, please outline why you consider it to be necessary?
To ensure the views of the Town Council and concerned residents are made known at the Examination stage.

Item 2– Page 14
Question 1
Which major modification does your response relate to?
FMAJ/05/02 – Additional land will be allocated adjacent to Prestwick Business Park to support additional high quality office development

Question 2
Do you consider that this proposed major modification meets the legal and procedural requirements?
Yes

Question 3
Do you consider that the proposed major modification has met these tests?
Yes

Question 4
Do you consider the proposed major modification to be unsound because it is not:
N/A

Question 5
Please give details of why you consider this proposed major modification is not legally compliant or sound or if you wish to support the legal compliance or soundness of this proposed major modification please also use this box to set out your comments.
PTC is not against additional land being allocated to Prestwick Business Park however, the Council is disappointed that the proposal for Prestwick Pit was removed as part of the previous consultation.

Question 6
Have you raised this during previous consultation on the Core Strategy?
N/A

If you have answered ‘no’ please explain why this issue has not been raised before.
N/A

Question 7
Please set out what change(s) to the proposed major modification you consider necessary to make the Plan legally compliant or sound. You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text.
N/A

Question 8
If you representation is seeking a change, do you consider it necessary to participate in the Independent Examination?
N/A

Question 9
If you wish to participate in the Independent Examination, please outline why you consider it to be necessary?
N/A

Item 3 – Page 16
Question 1
Which major modification does your response relate to?
FMAJ/07/02 – Green Belt. Remove area SE of Ponteland; N of Rotary Way, Former Police HQ. Identify land to W of Callerton Lane for housing, Remove existing housing on Cheviot View, Ridgley Drive from green belt, Remove an area in Prestwick for employment uses & remove an area of land N of Darras Hall to allow for development of a garden village.

Question 2
Do you consider that this proposed major modification meets the legal and procedural requirements?
No, in the majority of cases with the exception of land at the Police HQ and the removal of land at Prestwick for employment uses.

Question 3
Do you consider that the proposed major modification has met these tests?
No

Question 4
Do you consider the proposed major modification to be unsound because it is not:
Positively prepared
Justified
Effective
Consistent with national planning policy

Question 5
Please give details of why you consider this proposed major modification is not legally compliant or sound or if you wish to support the legal compliance or soundness of this proposed major modification please also use this box to set out your comments.
As stated in the response to FMA/03/01 the Town Council cannot see the justification to delete these areas of land (with the exceptions in brackets) from the Green Belt.
PTC feels the proposed Green Belt deletion is excessive in Ponteland with 228 hectares being proposed which is 51.7% of the total for the entire county of Northumberland.

Question 6
Have you raised this during previous consultation on the Core Strategy?
Yes on previous consultations

If you have answered ‘no’ please explain why this issue has not been raised before.
N/A

Question 7
Please set out what change(s) to the proposed major modification you consider necessary to make the Plan legally compliant or sound. You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text.
A re-consideration by NCC of the stance taken to build on the Green Belt.
Green Belt deletion should be based on Objectively Assess Need (OAN).
Question 8
If you representation is seeking a change, do you consider it necessary to participate in the Independent Examination?
Yes the Town Council would be willing to participate.

Question 9
If you wish to participate in the Independent Examination, please outline why you consider it to be necessary?
To ensure the views of the Town Council and concerned residents are made known at Examination,

Item 4 – Page 18
Question 1
Which major modification does your response relate to?
FMAJ/07/03 – Green belt boundary amended to incorporate proposed Garden Village

Question 2
Do you consider that this proposed major modification meets the legal and procedural requirements?
No

Question 3
Do you consider that the proposed major modification has met these tests?
No

Question 4
Do you consider the proposed major modification to be unsound because it is not:
Positively prepared
Justified
Effective
Consistent with national planning policy

Question 5
Please give details of why you consider this proposed major modification is not legally compliant or sound or if you wish to support the legal compliance or soundness of this proposed major modification please also use this box to set out your comments.
Please see reasons in PTC response to FMAJ/13/01

Question 6
Have you raised this during previous consultation on the Core Strategy?
No as this is a new major modification.
If you have answered ‘no’ please explain why this issue has not been raised before.
This is a new major modification.

Question 7
Please set out what change(s) to the proposed major modification you consider necessary to make the Plan legally compliant or sound. You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text.
See response to FMAJ/13/01

Question 8
If you representation is seeking a change, do you consider it necessary to participate in the Independent Examination?
Yes the Town Council would be willing to participate.

Question 9
If you wish to participate in the Independent Examination, please outline why you consider it to be necessary?
To ensure the views of the Town Council and concerned residents are made known at Examination.

Item 5 – Page 20
Question 1
Which major modification does your response relate to?
FMAJ/07/04 – Green Belt – Area North of Darras Hall is proposed to be developed for a Garden Village.

Question 2
Do you consider that this proposed major modification meets the legal and procedural requirements?
No

Question 3
Do you consider that the proposed major modification has met these tests?
No

Question 4
Do you consider the proposed major modification to be unsound because it is not:
Positively prepared
Justified
Effective
Consistent with national planning policy

Question 5
Please give details of why you consider this proposed major modification is not legally compliant or sound or if you wish to support the legal compliance or soundness of this proposed major modification please also use this box to set out your comments.
Please see reasons in PTC response to FMAJ/13/01

Question 6
Have you raised this during previous consultation on the Core Strategy?
No as this is a new major modification.

If you have answered ‘no’ please explain why this issue has not been raised before.
This is a new major modification.

Question 7
Please set out what change(s) to the proposed major modification you consider necessary to make the Plan legally compliant or sound. You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text.
See response to FMAJ/13/01

Question 8
If you representation is seeking a change, do you consider it necessary to participate in the Independent Examination?
Yes the Town Council would be willing to participate.

Question 9
If you wish to participate in the Independent Examination, please outline why you consider it to be necessary?
To ensure the views of the Town Council and concerned residents are made known at Examination.

Item 6 – Page 20
Question 1
Which major modification does your response relate to?
FMAJ/07/05 – Green Belt –Involvement of PTC and PNPSG in master planning of Garden Village
Question 2
Do you consider that this proposed major modification meets the legal and procedural requirements?
No

Question 3
Do you consider that the proposed major modification has met these tests?
No

Question 4
Do you consider the proposed major modification to be unsound because it is not:
Positively prepared
Justified
Effective

Question 5
Please give details of why you consider this proposed major modification is not legally compliant or sound or if you wish to support the legal compliance or soundness of this proposed major modification please also use this box to set out your comments.
PTC has not been directly approached at any time by NCC on this matter of huge importance to Ponteland.

Question 6
Have you raised this during previous consultation on the Core Strategy?
No as this is a new major modification.

If you have answered ‘no’ please explain why this issue has not been raised before.
This is a new major modification.

Question 7
Please set out what change(s) to the proposed major modification you consider necessary to make the Plan legally compliant or sound. You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text.
PTC would like to see the wording amended to “The Ponteland Town Council and Neighbourhood Plan Group will be invited to be involved in the development of the Supplementary Planning Documents/ etc”.

Question 8
If you representation is seeking a change, do you consider it necessary to participate in the Independent Examination?
Yes the Town Council would be willing to participate.

Question 9
If you wish to participate in the Independent Examination, please outline why you consider it to be necessary?
To ensure the views of the Town Council and concerned residents are made known at Examination.

Item 7 – Page 30
Question 1
Which major modification does your response relate to?
FMAJ/09/06 – Tyne & Wear Metro Links – reference to extension to Ponteland

Question 2
Do you consider that this proposed major modification meets the legal and procedural requirements?
Yes

Question 3
Do you consider that the proposed major modification has met these tests?
Yes

Question 4
Do you consider the proposed major modification to be unsound because it is not:
N/A

Question 5
Please give details of why you consider this proposed major modification is not legally compliant or sound or if you wish to support the legal compliance or soundness of this proposed major modification please also use this box to set out your comments.
N/A

Question 6
Have you raised this during previous consultation on the Core Strategy?
N/A

If you have answered ‘no’ please explain why this issue has not been raised before.
This is a new major modification.

Question 7
Please set out what change(s) to the proposed major modification you consider necessary to make the Plan legally compliant or sound. You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text.
PTC would welcome more information on this addition to the Core Strategy

Question 8
If you representation is seeking a change, do you consider it necessary to participate in the Independent Examination?
No PTC is only seeking additional information on this item.

Question 9
If you wish to participate in the Independent Examination, please outline why you consider it to be necessary?
N/A

Item 8 – Page 31
Question 1
Which major modification does your response relate to?
FMAJ/09/08 – Refers to former railway track bed between Newcastle Airport Metro Station and Ponteland

Question 2
Do you consider that this proposed major modification meets the legal and procedural requirements?
N/A

Question 3
Do you consider that the proposed major modification has met these tests?
N/A

Question 4
Do you consider the proposed major modification to be unsound because it is not:
N/A

Question 5
Please give details of why you consider this proposed major modification is not legally compliant or sound or if you wish to support the legal compliance or soundness of this proposed major modification please also use this box to set out your comments.
N/A

Question 6
Have you raised this during previous consultation on the Core Strategy?
N/A

If you have answered ‘no’ please explain why this issue has not been raised before.
N/A

Question 7
Please set out what change(s) to the proposed major modification you consider necessary to make the Plan legally compliant or sound. You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text.
PTC notes this addition and would welcome additional information on this issue.

Question 8
If you representation is seeking a change, do you consider it necessary to participate in the Independent Examination?
No as PTC is only seeking additional information on this addition.

Question 9
If you wish to participate in the Independent Examination, please outline why you consider it to be necessary?
N/A

Item 9 – Page 37 (Also annex 1, Chapter 13, pages 47- 68
Question 1
Which major modification does your response relate to?
FMAJ/13/01 – New chapter regarding the Dissington garden Village proposal

Question 2
Do you consider that this proposed major modification meets the legal and procedural requirements?
No

Question 3
Do you consider that the proposed major modification has met these tests?
No

Question 4
Do you consider the proposed major modification to be unsound because it is not:
Positively prepared
Justified
Effective
Consistent with national planning policy

Question 5
Please give details of why you consider this proposed major modification is not legally compliant or sound or if you wish to support the legal compliance or soundness of this proposed major modification please also use this box to set out your comments.
Ponteland Town Council believes that it is unsound and unjustified to include such a major modification in the Core Strategy at this late stage. The Council believes that there should have been a separate consultation on this topic alone.

It is a proposal that is unpopular with the majority of residents of Ponteland. Residents and consultees should have been given the opportunity to submit comments on the proposal as a whole rather than being restricted by the principles of ‘soundness’. There should have been a separate Supplementary Planning Document in view of the scale of the modification proposed.
The Town Council and residents have been given a 6 week period to respond to this as well as a revised SPD for the triangle area at Callerton Lane. The scale of this major modification should warrant a longer consultation period.

The eligibility criteria for garden villages state that they must be new, discrete settlements and not an extension of an existing village or town. However it appears that this is an extension of Ponteland as the proposed development will be accessed via Ponteland and will use its services.

The proposal does not have the support of the community, yet the eligibility criterion also refers to ‘a strong local commitment to delivery’.

The Government is also encouraging expressions of interest which make effective use of previously developed (Brownfield land) and/or public sector land however this proposal does not meet those criteria as it will mean significant Green Belt deletion.

The Town Council feels that this is inconsistent with the NPPF advice on Green Belt boundaries as outlined in paragraph 13.41. PTC continues to query whether ‘exceptional circumstances to build on Green Belt’ have been demonstrated.

Paragraph 13.49 states that this area is outside of the sensitive Green Belt corridors that separate Ponteland from the Airport and Newcastle upon Tyne. The proposal is still however on Green Belt land.

PTC also questions the use of the word ‘modest’ in relation to this proposed deletion. The area is a significant deletion to the Green Belt.

It is stated in several places in Chapter 13 that whilst the garden village must be discrete from existing settlements the area is close enough to Ponteland to take advantage of existing services and facilities. There is not the capacity in the small town of Ponteland to accommodate such a huge increase in demand for services particularly on top of additional housing numbers being proposed elsewhere in the area. All of this will be in addition to a figure of circa 600 new dwellings that have been built or approved to be built since April 2011.

In paragraph 13.31 it is stated that ‘the new village centre will align with and support the existing settlement hierarchy, both by increasing the population that will utilise the higher order services found in Ponteland and further afield”.
The Council repeats that there is not the capacity available for such a dramatic increase in population to take advantage of available services in Ponteland of either a higher or lower order.

In the Preferred options stage 2 Para 5.11 page 36 it is stated:
“As part of this assessment consideration has been given to a number of issues, including….. Projected population change – as a guide, it has been considered that on average an acceptable increase in population for Main Towns is between 10% and 19%, 4% and 8% for Service Centres and around 4% in the rest of the County.”
850 houses would deliver a population increase at 14.7% for Ponteland.
The housing numbers suggested to be developed in Ponteland would increase the population by over 50%.

Ponteland was identified as a smaller town in the last core strategy major modifications in June 2016. There are inconsistencies in several places in the document where Ponteland is referred to as a main town. For example, in earlier versions of the Core Strategy Ponteland has been described as a tier 1 settlement, then a service centre, then a main town and then a smaller town centre. Ponteland was changed to a smaller town in the Proposed Major modifications consultation carried out in June 2016 which was welcomed by the Town Council (MAJ/05/42 refers).PTC disagrees with various statements made in Chapter 13 in relation to the designation of Ponteland, for example paragraph 13.21 which refer to Ponteland as a main town and a key hub for various services. Ponteland is not a key hub for retail, transport and healthcare.

It is unfair and unjustified to have this huge addition to housing numbers in Ponteland that do not count against the objectively assessed housing need (OAN) numbers identified for Ponteland.If the DCLG application for Garden Village status is not approved and NCC progress the scheme through the Core Strategy, PTC seeks confirmation that the additional houses would then count against the OAN.

PTC questions the statement in paragraph 13.23 of chapter 13 that refers to “much needed housing”. The Town Council do not believe there is such a need in Ponteland and know of no such evidence to support this statement.

The statement in paragraph 13.25 regarding the creation of jobs has also been consistently questioned by the Town Council and it has not yet been explained satisfactorily. PTC has received no explanation that 24000 new dwellings are needed in Northumberland to create 10000 jobs. Nor do we understand why the 2014 ONS data has not been used as this suggests a DCLG starting point of around 11000 new dwellings.

There are comments made within chapter 13 that are not accurate, for example, in paragraph 13.8 it is stated that “DGV will be planned to embody all of these objectives in order to create a genuinely sustainable and exemplar new community within the heart of Northumberland. The area is not in the ‘heart of Northumberland’ but on the southern tip. Most residents in Ponteland do not work in Northumberland as they travel out of the county to Tyneside.

In relation to the proposed relief road, the route is causing concern about possible flood risks to those living near the inner route. PTC questions the value of the relief road to the community if it comes at the price of a further 2000 properties being imposed on Ponteland. A comment made in paragraph 13.20 of chapter 13 proves that access is proposed to the airport via the A696, the main route through Ponteland.

It is noted that if approval is given there would be a range of house builders and developers working in the area at the same time in order to accelerate housing delivery. The last sentence of paragraph 13.38 suggests that some building may be capable of being carried out prior to the building of the relief road and this is confirmed in paragraph 13.86 that states that housing supply can be delivered over a 12 year period with a potential start on site as early as 2018. The resulting impact on the road infrastructure in Ponteland is unimaginable. It was the Town Council’s understanding that the relief road would come before development – clarification as to the sequence of events is required.

The Town Council disputes all of the wording in paragraph 13.77. This proposal is not ‘complementary’ as suggested but a total new addition to the Core Strategy and the NCC over projection of housing numbers.

Paragraph 13.79 confirms that the Dissington proposal has been confirmed as the only location that can deliver the objectives of a garden village. PTC challenges that assumption. In an area the size of Northumberland there must be other areas that meet the criteria (Brownfield sites, discrete settlement and community led).

Item 8 of the strategic principles listed on page 64 refer to the prevention of incremental development where it is likely to prejudice the comprehensive development of the garden village. It should be noted that Ponteland has had massive incremental development over the years and Ponteland has grown through this. For example, since April 2011, the start date of the Core Strategy, around 600 extra dwellings have been built or approved to be built in Ponteland.

Question 6
Have you raised this during previous consultation on the Core Strategy?
No as this is a new major modification.

If you have answered ‘no’ please explain why this issue has not been raised before.
This is a new major modification.

Question 7
Please set out what change(s) to the proposed major modification you consider necessary to make the Plan legally compliant or sound. You will need to say why this change will make the Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording for any policy or text.
1. Housing need should be based on OAN. Housing and population growth for the small town of Ponteland should be proportionate. PTC request that housing numbers should be reduced to a more realistic level that would not compromise the special character of Ponteland.
2. This hugely significant major modification should have been subject to a separate consultation and not introduced at the very last stage of the consultation process where residents feedback is restricted to soundness.

Question 8
If you representation is seeking a change, do you consider it necessary to participate in the Independent Examination?
Yes the Town Council would be willing to participate.

Question 9
If you wish to participate in the Independent Examination, please outline why you consider it to be necessary?
To ensure that the views of the Town Council and concerned residents are made known at Examination.

 
 

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