The Commentary on the pre-Submission Draft published here on 10th July was handed to the Town Council Officers, who responded to explain their viewpoint. The Commentary, which tried to include all the points raised in Public Meetings concerning the Charter was then adapted and the principal points were submitted as a Representation in the form of a number of Recommendations for Policies, backed up by the commentary. The document is lower down this page in the form of a (large and long) webpage. The PDF Version (link below) is probably easier to read and print.
Use this link to view or download as an Adobe Acrobat PDF file > Click Here
The Original Commentary can be viewed / downloaded
as an Adobe Acrobat PDF file > Click Here
Full record of all Representations received by LTC > Click here to View / Download
Submission of Recommendations on the Littlehampton Neighbourhood
Plan by the Charter Working Group, |
(Sponsored by the Civic Society), |
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This submission arises out of points identified and
discussed in Commentary already submitted for information at the 10th July drop-in
event. RECOMMENDATIONS
SUMMARY: |
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Additional Policies |
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A: A Holiday Trade Policy to include
Holiday Accommodation and various smaller-scale Facilities and Provision as well as
the larger Leisure Industry, recognising the continuing importance of this core area. |
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B: An evaluation of the Visual
qualities of the parts of the Town to include the qualities of the townscape and of
views and outlooks from specific locations, and a statement of what is
essential, what is desirable what improvements would be
encouraged. The evaluation should include surrounding green areas outside the
built-up townscape with statements of their value. The Value Statements
are to inform decisions on proposals which would have an effect
on anything identified in this study, and a suitable Policy clause
(possibly as part of the Design Review Panel procedure) requiring new
development of buildings and infrastructure to take full account of the values
ascribed and to do nothing to diminish them, and where
appropriate, to enhance them. (The document can be in the form of an appendix
which can be expanded by due process). |
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C: A schedule of all open spaces and associated infrastructure of
significance, not simply a few selected Green Spaces, with a statement
expressing their importance and the Town’s determination to add to and
enlarge the provision as the population grows. (The schedule listing can
be in the form of an appendix which can be expanded by due process).
It is appreciated that some of these spaces will not satisfy the
requirements of NPPF para 77, but nevertheless several that are not
listed appear to meet the requirements, and all have vital community
value and should not be degraded as the result of development unless a
generally acceptable improvement results. |
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D: A schedule of Assets of Community Value as a formal statement
expressing and recognising their importance to the Community
(The schedule listing can be in the form of an appendix which can be
expanded by due process). |
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E: A Health Facilities Policy that
expresses what the community judges is needed and reasonably aspires to, rather
than what is on offer. |
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Expanded Policies |
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4.3 Housing Policies |
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An expanded Housing Land Policy that
allows for development of more creative ways of providing Affordable Homes
and Homeless Accommodation, other than simply relying on Housing
Associations. If this is truly beyond the expertise of the |
Neighbourhood Plan then at least a statement of presumption in favour of providing opportunities for these more direct
approaches instead of the more common commuted approach. |
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Policy 5: |
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A far more assertive West Bank Policy
that actually reflects and expresses the view of the townspeople and
community, and seeks to preserve what we consider of great value, and limits
adverse effects. To include an embargo on new housing or hotel development
further south than the end of the Rope Walk wharves (meaning a line extending
from the river westwards towards Climping) with the
Neighbourhood Plan Key Diagram revised to take
account of this geographic limitation, and a requirement to provide for a substantial
Publicly Accessible wetland / wild area. To take account of
flooding and groundwater risks and to limit obstruction of views by setting a
strict limit on overall heights of buildings. |
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Policy 7: |
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A fuller approach to
Employment premises and Land, to include consideration of a wider range of
trades and occupations. The town is in need of places and facilities for carrying out
trades and occupations of all kinds, not just residential-area-friendly B1
uses. If part of the new Health Facility in north Littlehampton
is to be built on land allocated for business or industrial use, then an
equivalent additional amount of industrial land should be provided in the
Plan. |
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Policies that should be amended |
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Policy 11: Littlehampton
Leisure Centre |
- by
deletion of
explicit support for Housing at the Swimming and Sports Leisure Centre site |
- by removal of reference to relocation to
north of the Academy, as - if this relocation is unavoidable -
this not the only site option, and the point about access from |
Instead, the Policy should say that if
it becomes impossible to resist relocation of the leisure centre then it
should be relocated to a position conveniently accessible to the most users,
where it does not have an adverse effect on residents nearby, that the
facility shall operate separately from the Littlehampton
Academy or other similar establishments, and the replacement leisure facility
is to be consented and implemented before use of the existing Swimming and
Sports Leisure Centre is discontinued. Additionally the Arun
Aqua Centre must be properly protected and supported so it can continue with
access to the seafront. |
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Policy 12: The Windmill Theatre |
- by deletion of explicit support for
Hotel at Windmill Theatre site. |
- by rewording the present policy to make
it definite that permission to redevelop the Windmill site is conditional on
provision of an equivalent cultural facility to be consented and implemented
before development commences.
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Aspects
of the Plan which seem particularly commendable |
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Policy
2: The Spatial Plan |
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Policy
6: Other Housing
Sites |
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Allows for adjustment of uses as the
area changes, and includes some safeguards for community facilities. This is
a sensible provident policy attempt to reserve some control. |
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Policy
8: Business Incubator
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The location of the proposal near the
centre of town lends itself to B1 uses, and is particularly accessible. |
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Policy
9: Local Centres and 10 Convenience Stores |
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The Community is bound to applaud and
support these proposals as a principle, however this
must be matched by support for the neighbourhood
traders who face strong competition from the out-of-town supermarkets. |
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Policy
18: |
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The detailed outcome of the proposal
is probably better on balance than would have been the result of the original
scheme, with its overpass and interchange – but then if that had been less
ambitious it probably would have been implemented. |
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Policy
19: Lyminster Bypass & A27 Bypass |
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The regrettable loss of open farmland
has to be balanced against the severe problems to both residents of Lyminster and travellers on the
existing dangerous road. |
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Policy
20: Arundel Chord
Railway Improvement |
(except it
seems to be an arc rather than a chord!) |
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About a century and
a half over-due.
This seems to be the only place where taking account of flooding is
specifically mentioned, where presumably blockage of existing water courses
is the concern rather than tidal inundation as in the housing land locations
–where no specific mention is made. |
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Policy
21: Arun Canal - This may be a slow-burn policy. |
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There is probably near-universal
support for completion of this long-term project, although there is always
the possibility of local problems being encountered in view of the great
changes since the navigation was abandoned. |
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Policy
22: Design of New
Housing Development - Reflects local concerns. |
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Policy
23: Community Right
to Build Orders |
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As with Assets of
Community Value, there is agreement between Town Council and Community on
these deemed Planning Approvals. |
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Commentary
in Support of the Representation |
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This commentary follows the content of the Littlehampton Neighbourhood
Plan and where possible page numbers have been given corresponding to the
Plan. |
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Index of Content Page No |
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1. Introduction, 1.4 Consultation 4 |
2. State of the Town |
2.3 Community Views 5 |
2.5 Submission Arun
Local Plan 6 |
3. Vision and Objectives 7
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Policy 1: The Presumption in Favour of Sustainable Development 7 |
Policy 2: A Spatial Plan for the
Town 8 |
4.3 Housing Policies 8 |
Policy 3: Housing Supply 10
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Policy 4: Housing Site Allocation 10 |
Policy 5: West Bank 11 |
Policy 7: Business Land
Allocation 12 |
Policy 11: Littlehampton
Leisure Centre 13 |
Policy 12: The Windmill 13 |
Policy 13: Littlehampton
Community Centre 13 |
Policy 15: School Provision 14 |
Policy 16: Local Green Spaces 14 |
Strategic Environmental
Assessment 16 |
Additional Concerns outside the
Policies 16 |
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1. Introduction |
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1.4 Consultation (p7) |
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Comments and Representations |
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Who is eligible? |
The Plain Guide to the Localism Act Says… |
‘communities, both
residents, employees and business’ |
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So this appears not to restrict comment to residents
of the Plan Area, but can include employees and employers operating in the
Area. |
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We would like to see… |
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Logging of and Evaluation of
Representations. |
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All to be logged and have a summary record / index
card |
All submissions to be readily available for
reference in entirety, not just as summaries |
If deemed ineligible, reason must be given |
Each point to be considered as follows: |
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- Relate to the
Policy or Policies it concerns |
- Summarise the substance of the issue |
- Evaluation, and
when / by whom evaluated |
- Whether the draft was revised to take account |
- If draft was revised, what change was made |
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- If draft was not revised, why the point was
disregarded |
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Before finalising the next
draft, a methodical re-assessment of the issues is to be carried out to make
sure a balanced response has been made to all – it is unsound to rely on snap
judgements and memory. |
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There is also a noticeable amount of dissatisfaction
among individuals and groups who did make representations that the
pre-submission draft either ignores or has been revised contrary to their
representations, and would like to see, possibly under Freedom of
Information, but preferably freely and willingly, the text of the
representations that were made at the previous two consultation stages. |
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2. State of the Town |
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2.3 Community Views (pp10-12) |
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A reasonable test for the Plan is how successfully
and fully it has embodied and satisfied the views gathered in the
Consultation Stage. We can all judge this for ourselves, by comparing the
Likes, Wants, Concerns and Priorities listed in this section against the
actual policies. |
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The Commentary, and the Representation might, time
and resources permitting, have gone deeper into the ‘To Five Areas of
Concern’ (p11). |
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It would be wise for the drafters of the NP to go
through the list and see how well they have been accommodated, because it’s
unlikely that all the ones that have been more or less passed over are not
capable of being addressed without being in conflict with some Strategic
Policy or other. It has already been established early in the Consultation
that these are things the Community would want to see in the Plan. |
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Among the Top Five Priorities: 2. Employment -
seen as a high priority by all age groups even though a significant number of
respondents were over retirement age. |
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The response by those over retirement is probably
indicative of the widespread need to continue working because of longer lifespans and plummeting pensions, and also concern about
the prospects of their children and in many cases of their grandchildren too.
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There seems to be no integrated component of the
Plan that deals with Employment. The majority of earned income in the town
comes from sources outside of the limited activities covered in the ‘Business
Allocation’ section. Care is a very sizeable sector of the local economy, and
Horticulture also is still significant. |
(See Expanded Policy 7, p2) |
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It can also be argued that Tourism - the
Holiday Trade including Accommodation for Visitors is so important it
deserves a general Policy to itself, rather than isolated items relating to Harbour Park, the Windmill and the Leisure Centre. |
(See Additional Policies A, p1) |
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Another Policy which would have a significant effect
on the income from Tourism is the proposal to build housing at the north end
of the Littlehampton Academy Field which includes
removing the Touring Campsite. This is the last one in the town, the other
one went when the Tesco store was built near the Arun Bridge. Significant income is brought into the town
by tourists who camp or use touring caravans, the idea of a seaside town
without a single space for camping is quite extraordinary. |
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The Link between Tourism and Leisure: |
The existence of attractive leisure facilities
brings tourists into the town, and the leisure facilities are also valuable
to the locals – as shown by recent events. |
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If this is a ‘Plan’, then it should be planning for
the future which promises a planned 20% population increase. |
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In the top ten ‘wants’ revealed by preliminary
consultation: Cinema, bowling alley, skating rink – improved leisure
facilities |
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In the face of this response the neighbourhood
Plan will not be representing the Community View if appears to concede to
moves to worsen provision of these resources. |
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2.5 Submission Arun Local
Plan (p13) |
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The New Neighbourhood Plan
must not conflict with the Strategic Aims of the Local Plan |
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The (Local) Plan sets out a series of strategic
objectives |
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To strengthen Arun’s
economic base and provide local job opportunities by increasing, diversifying
and improving the quality of employment within the district through the
provision of appropriate employment sites, better infrastructure including
road access, |
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quality affordable accommodation and the development of
business support and partnerships; |
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To reduce the need to travel and promote sustainable
forms of transport; |
Some parts of the Plan may be counter to this
strategy |
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To plan for climate change; to work in harmony with
the environment to conserve natural resources and increase biodiversity; |
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Some parts of the Plan may be counter to this
strategy inasmuch as is likely to be a net loss in spite of the intention to
establish conservation schemes |
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To plan and deliver a range of housing mix and types
in locations with good access to employment, services and facilities to meet
the district’s housing requirements and the needs of Arun’s residents and communities both urban and
rural, ensuring that issues of affordability and the provision of appropriate
levels of affordable housing are addressed while supporting the creation of
integrated communities; |
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To protect and enhance Arun’s
outstanding landscape, countryside, coastline, historic, built and
archaeological environment thereby reinforcing local character and
identity; |
Some parts of the Plan may be counter to this
strategy |
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To create vibrant, attractive, safe and accessible
towns and villages that build upon their unique characters to provide a wide
range of uses and which are a focus for quality shopping, entertainment,
leisure, tourism and cultural activities; |
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Residents of some villages and some parts off Littlehampton may have been hoping for peace and serenity
rather than vibrancy. The proposals for housing appear to go well beyond the neighbourhood’s housing requirements. |
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Plan B, as included in the document, is unreadable
in some important respects. (p15) |
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A large part of Littlehampton
on the east bank of the river appears to be allocated as an Economic
Improvement Area – and is also the area that will be hard hit by competition
from the various new hotels proposed in the Neighbourhood
Plan Draft or already approved. |
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3. Visions and Objectives (p17) (See Additional Policies B, p1) |
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Neighbourhood Plan Vision is stated as: |
‘To fundamentally improve the
economic, environmental, and social wellbeing of individuals and communities
in the town, particularly those in the most deprived areas. To enhance, improve and protect existing community
infrastructure and propose new where appropriate, that will deliver excellent
local and accessible facilities to all of the Littlehampton
population’ |
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It is a shame that the vision seems to be almost
totally non-visual, especially as the positive visual qualities are so valued
and the negative ones so deplored by residents and visitors alike. |
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This applies to both townscape and surrounding
fringes, some of which are definitely threatened by proposals in this Plan,
in spite of the Strategic Environmental Assessment test results. |
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An evaluation of the Visual qualities of the parts
of the Town and a statement of what is essential, what is desirable and what
improvements would be encouraged |
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Studies and inventories have been produced of the look
of the town; some of this will have been as recent as the gathering of
candidates for the list of Buildings of Character and Interest. It would be
of benefit for the Town to take a cool look at the buildings, open spaces,
streetscapes, and clutter in the town and to decide on and grade the
importance of the various features and of the qualities and scale of the
places and structures. |
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As with the other schedules referred to above, this
could be a Live Appendix that evolves and responds, subject to a defined
review procedure. |
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4. Policies and Proposals |
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4.2 General Policies |
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Policy 1: The Presumption in Favour
of Sustainable Development (p19) |
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Of course this is a principle everyone supports, but
Presumptions in Favour of Sustainability are ten a
penny. Every Local Plan has one. |
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The important issue is not intention but
comprehension and deliverability. |
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For the last ten years or so Planning Authorities
have had to be satisfied that proposals for new housing are ‘sustainable’;
much of this being a matter of complying with national standards for energy
and material resources use, but the other major factor is close access to
shops, particularly food shops, and access to good efficient |
public transport.
Arising out of the Kyoto agreements, the intention is to reduce the amount
use of personal fuel-powered vehicles. |
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Another factor that is rarely taken into
consideration is the availability of employment close by. Most people would
prefer to have to travel less. |
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What the Community hopes for is ‘joined-up’
thinking. What we have seen at a District level is not increased availability
of food stores close by, but an increase in out-of-town stores, some of which
draw a significant amount of trade from adjoining areas, involving five miles
or more round-trips, which is hardly in the sprit of Kyoto. Some of these
stores may be close to future development sites, anticipating the 20%
population increase, and this may be the factor which facilitated approval. A
future unexpected consequence of the expected increase in population may be
that the amount of travel to work will increase significantly. |
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Policy 2: A Spatial Plan for the Town (p20) |
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The Plan Diagram seems to successfully combine the
way the town is (the reality arising out of the history of the settlement)
with the revival of transport route ideas (that originated over sixty years
ago but were discarded about twenty years ago) with newer road and zoning
ideas that have emerged more recently. |
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It has the potential to work both as organisation and experience. It is clearly and
immediately intelligible to townspeople and visitors alike. |
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It has many features that clearly accord with Community
Preferences. Differences arise where the clearly stated structure of the
Spatial Diagram is compromised when the Neighbourhood
Plan tries to accommodate potentially conflicting courses of action by the
District Council in its roles as landowner of Leisure Facilities. |
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4.3 Housing Policies |
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What are the factors bringing about the requirement
for major growth in the housing provision, what kind of people (demographic)
are expected to occupy the new homes, and how much of the new associated facilities (schools,
health, employment, shopping) is due the make-up of the new population? |
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In drawing up the Plan, with advice from the
District Council, the Town Council Planning and Transport Group will have had
a ready-formed agenda for including the large tranches
of housing we see included in the Neighbourhood
Plan. |
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The draft Plan says “there (was) the possibility
of choosing options proposing a significantly lower or higher housing supply
target. These options were not assessed, as neither was considered plausible…”. (6. Strategic Environmental Assessment ( |
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On the other hand, much of the Community will not
feel comfortable with this kind of intensification, or have much enthusiasm
to support such large developments because it is likely to have a degrading
effect on those qualities (trumpeted in both Local and Neighbourhood
Plans) that brought them, or made them enjoy living here in the first place. |
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A large proportion of the infrastructure,
educational, employment and open space provision identified in this Plan does
not seem to be a response to existing needs, but |
in anticipation of the
increase in population brought about by the creation of about 2000 homes. |
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This presumably has also driven approval of
out-of-town-centre Supermarket developments contrary to attempts by central
government to strongly discourage this type of development. |
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An important, but unmentioned, issue is what factors
are driving this population increase? The plan states a 20% increase; But
increase in homes doesn’t always mean increase in population - in many places
the demand is not caused by, or results in, population increase, it’s simply
a matter of an increase in ‘headship rates’ as households tend to get smaller
– at the present time that process has been slowed down by economic factors
resulting in many young people and their growing families continuing to live
with their parents longer. |
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If, in the case of Littlehampton,
there will be a real increase in numbers, then why will people be moving
here? It would appear that significant numbers of the occupants of the new
housing developments in places such as Angmering
travel to work in areas like mid-Sussex, Crawley, Gatwick, and live here in Arun because it’s the nearest place with affordable
homes. |
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Knowledge of these factors turns planning of
facilities and infrastructure from guesswork onto some kind of factual basis.
If the expected demographic is largely people who will be employed at a
distance, this has consequences in both environmental considerations (in
terms of increased travel) and employment requirement (less additional
provision needed). But if the expected demographic is largely made up of
older or retired people, then the focus moves
towards Health Care. While thought has been given to increasing development
land for employment (in quite specific ways that do not necessarily reflect
the kind of work the majority of working residents support themselves by) the Proposed Health Centre re-location does
not seem to result in enlarged capacity. |
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Although it is understood a Neighbourhood
Plan should probably be somewhat broad-brush, it is hard to get a feeling of
whether adequate provision is built-in when there is no statistical support
or analysis. |
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In the past, Littlehampton
grew because its families got larger; and because its fishing industry,
commercial port and shipyards, railway, new industrial employers such as Duke
and Ockenden, seaside landladies, the Beach Hotel,
numerous Public Houses and seashore activities and entertainments drew in
more people when the local families could not provide enough people to staff
these activities. We need to know whether this current phase of growth is the
town becoming more of a Dormitory or a Retirement Resort reliant on money
from outside the area, or whether it is a new self-sustaining wealth-creating
phase in the town’s history. |
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Knowledge of the cause would make it easier to
predict the consequential effects on all parts of the town – for instance
hopes for a vibrant town centre may be more relevant to some demographics
that it would be to others. |
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Policy 3:
Housing Supply |
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Growth of Town - What is the cause, and What is Effect? |
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As discussed in 4.3 (page 8, above) decisions about
Housing Supply should be informed by knowledge of the causes and details of
the needs or directives that are driving demand. Organic growth would be
preferred but that doesn't seem to be an option. Use of brownfield
land would be preferred, but that sustainable objective seems to have been
largely forgotten. Regard for natural forces, such as flooding and
groundwater would be preferred, but seems to be subordinated to the
unchallenged need to grow. |
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Policy 4: Housing Site Allocations (pp 23-24) |
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Affordable Housing |
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An expanded Housing Land Policy that allows for
development of more creative ways of providing Affordable Homes and Homeless
Accommodation, other than simply relying on Housing Associations (See Expanded Housing Policies 4.3,
p1) |
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There is a general requirement to include a
proportion of Affordable Housing when more than 15 new homes are built as a
development, and this is usually achieved by the intervention of a Housing
Association (although this is frequently only achieved on larger schemes, the
small and medium sized ones often discharge the requirement by paying a
commuted charge due to reluctance of the Housing Associations to manage small
projects). This only results in a specific type of Affordable Stock. But
there are other ways of enabling people with fewer resources to house
themselves, including Self-Build and Walter Segal Method co-operatives, both
of which have been successfully realised in
Brighton, for instance. No doubt collaborating with Housing Associations is
an easier option for Local Authorities, but as an alternative there could be
practical advantages in making agreements with the developers to make plots
(with roads and other infrastructure) available for sale to self-builders and
co-operatives. |
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Another issue is the matter of Homelessness among
both individuals and families. A Neighbourhood Plan
could review the possibilities of relaxing Use restriction on empty buildings
that might be turned to providing Homeless Accommodation. |
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North of the Littlehampton
(p24) |
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The Proposals Map shows an area of Housing at the
North end of the School Field that extends eastwards from the Fitzalan Road extension and covers the existing caravan /
camping park, with a Green Open Space to the east of that. |
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This proposal raises two concerns: |
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Firstly that the caravan park is on a Landfill site
which is subject to ongoing settlement and may be contaminated; and secondly
this will result in the loss of the only remaining touring campsite in the
town. The site operator claims that when fully operational the park can bring
over a million pounds a year into the town’s economy, much of which come from visitors from Europe. Were these factors taken
into account, and should the Neighbourhood Plan
support proposals that involve these issues? |
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St Martins
(pp24-25) |
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It is not clear how demand for retail use arises
when the High Street struggles to sustain existing shops, and supermarkets
face competition from large out-of-town stores. |
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Existing traders will have an opinion on the
car-parking issues and the effect on their trade. |
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Policy 5: West Bank (pp25-28) – (See Expanded Policy, p2) |
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The policy defers to the Local Plan Policies:(p16) |
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Policy SP11 proposes that the LNP provides for 200
new homes in Littlehampton in the plan period and
identifies land at West Bank for a strategic development of approximately
1,000 new homes |
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Policy DM4 on Littlehampton
Harbour encourages development proposals that
safeguard the harbour and address flood risk,
contamination, access and nature conservation issues in parallel with the
housing allocation in Policy SP11 |
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This raises some very fundamental issues - have they
been adequately debated? |
It is very doubtful whether the Community has had
the time or information to enable it to develop an attitude that corresponds
to the policies stated here. |
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There is a strong suspicion that proposals here may
conflict destructively with the earlier proposal for a Green Infrastructure
Corridor (if that’s what’s meant by ‘Strategic Green Link’ – but it may not
be), and although it includes a proposal for “a new country park facility
comprising publically (sic) accessible
informal recreation areas “ and “provision of a
protected Local Nature Area” this seems to be a reduced version of an earlier
Consultant’s Proposal. |
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A large area is defined, without differentiation or
statements that certain parts of the area will be preserved, or assigned
particular uses, although statements by Councillors
have said this is the intention. As this is an exceptionally sensitive area
and forms the western outlook from the town, and is part of the Climping Gap, and as there is a suggestion in Policy 15:
School Provision (p33) that a 10 Ha school site will be required in this
zone, then more specific proposals should be stated, if only as a statement
identifying satisfactory locations for different forms of development and
use. |
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Old Ferry Road heads off 1.5 km towards west,
meaning a round-trip of 2 miles for all traffic to reach the east side of the
bridge, or 3 miles into town centre. |
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Emergency access considerations,
and general convenience too will result in pressure to construct a new access
nearer the bridge, which would require major earthworks, an additional roundabout
with associated street lighting, and further loss of farmland. |
Among the top five ‘concerns’ (p11): The impact
of new development adjacent to flood plains and Flood management for East and
West Bank of the River Arun |
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The justification for developing the West Balk in
this way is that it will make it eligible for Government Assistance to
construct sea defences, unless it’s certain that
all the required defence work will be paid for by
the developers. Unlike the east bank, if 200-year flood risk is taken into
account, it will be necessary to protect all-round the area, rather than just
the river frontage. |
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This is actually a response to a short-term policy
rather than a Plan. Governments are fickle, and this policy will also change
with time (as it has frequently this century). And can it be confirmed that
adding new dwellings into an area where generally building would be
discouraged will in fact guarantee Government Expenditure? Is it not equally
likely that the Government would say it would prefer to save the money and
uphold existing policies to ban new development on areas of high flood risk? |
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It also needs to be made clear whether the only
reason for this proposal is to enable flood protection? It seems to being
suggested that |
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1. The West Bank needs to be
protected |
2. It would be politically
unworkable to suggest this should be paid for from locally-raised funds – the
community will not accept the financial cost |
3. Funds are only available if a
threshold value of property needs to be protected |
4. It is politically workable to
permit development of the West Bank – the community will accept environmental
and ambiental cost |
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There should be a proper debate on these issues.
It’s doubtful whether there would be widespread community support for the
changes being proposed, and very unlikely indeed that these policies would
have arisen if the community had led this process. If this is the way the
Town Council feels things must go, then they must carry the community along
with them by force of persuasion and sound argument, having properly aired
and considered all alternatives. |
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What the Plan doesn’t state is what the highest
preference would be – which is probably that the Climping
Gap should be protected – which would of course also guarantee the future of
the West Bank. |
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It would interesting to
compare the length of defence line that would needs
to be erected in each case. |
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4.4 Enterprise Policies |
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Policy 7: Business Land Allocations (p28) – (See Additional Policy, p2) |
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If the Clinical Commissioning Group intends to
relocate to a Business Unit on the former Costec / Morrisons Site, then the quantity of Business Premises
will be reduced correspondingly. |
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The location of the proposed Business Land conforms
to established zoning and conforms with the Spatial
Plan. |
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The Policy restricts use of the proposed new
Business Units to B1, but there is a case for Allocating and Implementing small B2 premises, because this is the type
of use that enables younger people, in particular the more creative less
academic ones, to develop employment opportunities. Delivery of these
business and industrial facilities should be a priority because Developers
are rarely prepared to provide small units. |
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4.5
Community Infrastructure Policies |
(See Policies that should be amended,
p2) |
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Policy 11: Littlehampton
Leisure Centre (pp31-32) |
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The Community and Town Council are agreed that the
entire centre function should continue on its present site and agree that - the
site is of sufficient size to enable a larger facility with ancillary car
parking and better landscaping on its Sea Road frontage |
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Serious Points of Community Concern: |
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This policy continues to explicitly support the
District Council’s Alternative in case 'the local planning authority supports
a proposal to relocate', in this case |
to relocate the facility to land north of the Littlehampton Academy and the change of use of the Sea Road site for housing development
of up to 20 dwellings comprising only two storey houses. |
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The Community seems to be united in its opposition
to both these Alternatives and does not wish to give open implicit approval. |
Both Alternatives are also in conflict with the
Spatial Plan proposals. |
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Policy 12: The Windmill Theatre (pp32-33) |
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The Community and Town Council are agreed that
Theatre and Cinema should continue together on this site. |
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Serious Points of Community Concern: |
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- This policy
continues to explicitly support the District Council’s Alternative in case
'the local planning authority supports a proposal to relocate', in this case
stated as a D1 Hotel – but Use
group D1 is ‘Non-residential institutions’, so presumably an error. |
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- The Windmill is not
identified as an Asset of Community Value |
- The undertaking not to demolish until suitable and at
least equivalent facilities are ready and available for occupation (‘consented
and implemented’) by Theatre and Cinema users is no longer part of the
Policy |
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Policy 13: Littlehampton
Community Centre (p33) |
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This is a modern and purpose-built replacement for
the Dairy Centre, which has proved a indispensable
if not always ideal asset. |
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A clearer explanation of the scheme and its location
would have been useful. |
Evidently the intention is to demolish the
concrete-framed former office extension to the Manor House. |
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Policy 15:
School Provision (p33) |
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Considerations of the Demographic of the occupants
of the new homes referred to in this policy need to be properly factored-in.
10 Ha is a very substantial increase to the developed land on West Bank. |
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Of course there will be a vacant School Site available
in Elm Grove Road in the required timescale. |
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4.6 Environmental Policies (See Additional Policies C, p1) |
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Policy 16: Local Green Spaces (pp34-35) |
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What is included in the named Green Spaces? |
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The Plan identifies five green areas: |
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a) ‘The Green’; b) Mewsbrook
Park; c) Caffyns Field; d) Brook Field Park |
e) Land North East of the Academy (‘Oakcroft Green’) |
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The choice is a little perplexing as it identifies
some existing areas plus one that does not seem to exist; and fails to
mention several existing ones and does not define new Green Spaces that are
promised in the large new developments. |
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The first two Green Spaces, ‘The Green’ and Mewsbrook Park are shown on the Proposals Map as parts of
a contiguous green-edged zone. The zone also encloses the Norfolk Gardens and
the 9-hole Golf Course, the Sportsdome Surroundings
and the Ruby Conservation Wood. It is not clear whether these un-named spaces
are also explicitly protected as part of this policy. |
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To most people, ‘The Green’ is the area between the
promenade and South Terrace, and doesn’t include the Norfolk (Pleasure)
Gardens. There is concern that the Norfolk Gardens is not properly
identified, not is the area between the west wall of the 9-hole golf course
and Mewsbrook Park (the boundary being the gate
east of the Sports Dome entrance). |
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The entire swathe from Harbour
Park to the north east of Mwsbrook Park, as shown
on the Key Diagram, must be included as an integrated whole. |
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In view of the continued inclusion of a proposal for
new Housing on the Leisure / Swimming / Sports Centre campus, is future of
the Ruby Conservation Wood secure? |
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The fifth Green Space is part of Housing Site ii of
Policy 4, and probably arises out of the loss of the land reserved for the Fitzalan Road Extension which tended to be used as an
unofficial Public Space. While recognising the need
for an accessible public open space, the issue of the resulting loss of the
only touring camping site in the Plan Area was brought to the attention of
the recent Public Meeting, and is also referred to under Housing Site
Allocation Policy 4 above. |
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Some would also consider the peripheral green spaces
on the town edges to be equally important, and strong candidates for
identifying and including in the Plan. |
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The National Planning Policy Framework includes a
definition of a Local Green Space, which it is felt several, possibly the
majority, of the valued spaces not currently included in this Policy fall
into however, this can’t really be said of spaces which do not |
exist at the current
time, nor ones that have not been legally accessible to the public hitherto
unless exceptionally beautiful or of historic importance, (could apply to the
North end of Academy land). |
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Viz. NPPF para 77… |
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The Local Green Space designation will not be
appropriate for most green |
areas or open space. The designation should only be used:
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where the green space is in reasonably close proximity to
the community it serves; |
where the green
area is demonstrably special to a local community and holds a particular
local significance, for example because of its beauty, historic significance,
recreational value (including as a playing field), tranquillity
or richness of its wildlife; and |
where the green area concerned is local in character and
is not an extensive tract of land. |
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A schedule of all open spaces and associated infrastructure of
significance |
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In order to balance the Plan and to influence future
thinking and events, in the same way that the Plan has Policies relating to
Listed Buildings and Buildings of Character (in which it probably simply
follows the Local Plan format), there is a case for including and maintaining
an inventory of all the facilities and assets which provide open space or
premises for important or essential activities. The scope should be wide
enough to include for simple non-organised
activities, such as walking, non-structured exercise, and quiet places to sit
in peace and enjoy the surroundings and distant views. |
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This should include all Green and Recreational
Spaces, cultural facilities such as Community Centres
such as at Wickbourne and Southfields, land and
halls used for Youth, general Community, and Elderly
activities. It should also include all the Designated Green Infrastructure
areas in Appendix 1 of the 2012 GI Study. |
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Inclusion of surrounding green areas outside the
built-up townscape with statements of their value |
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There are many places in the town where their most
important and valued qualities are heavily dependent on features outside the
town and at a distance. There is always pressure to gobble up these outer
areas, and identifying the vital views and spaces will help in evaluating the
acceptability of future proposals and provide a basis for control. |
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A schedule of Assets of Community Value (See Additional Policies D, p1) |
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The previous draft listed the Assets of Community Value, the current draft has left them out. |
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As the Plan includes a schedule of Buildings of
Special Character, then there is no reason why a schedule Assets should not
be similarly appended so that they can be referred to as easily and stand as
a record of the importance attached to them. |
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6. Strategic Environmental Assessment (pp43-57) |
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The purpose of the |
“The assessment indicates there are no significant
environmental effects of the Plan. Those minor environmental effects of the Neighbourhood Plan will be addressed as identified…” |
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However, the factors considered and the method of evaluation employed are not necessarily those
that the Community would instinctively prefer. The conclusion that the
proposals for West Beach would have little environmental impact beggars
belief (p56). |
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Additional Concerns outside the
Policies |
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On what basis is the demand for new Hotel Bedspaces assessed? |
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Concerns have been expressed that an excess of
accommodation will arise, and the vacant rooms will be used as Homeless
Accommodation, as is happening around the country. Concern has also been
expressed about the impact on existing local providers. (referred
to in Policy 4 and Policy 12 – would have a major effect on suggested Tourism
Policy) |
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How does the LNP interface with the proposal for an
Economic Improvement Area in the Local Plan? |
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The problem here is more lack of clarity in the
Local Plan than the Neighbourhood Plan, in
particular what the references to education-related activities mean. |
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What is the future of the existing Health Centre,
and what is the scope, capacity and localities
served by the proposed health facility close to the A259? (Originally referred to in Policy 4: Housing Church
Street/Fitzalan Road, p25) |
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The purpose and detail of the proposed change of
location for the Health Facility is not readily obvious in this draft of the
Plan, a proper explanation is required. |
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Will Health and Medical capacity grow with the
anticipated Population Growth or simply re-locate? |
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Respondents to the preliminary consultation rated
Health Services as their Highest Priority. The Plan seems to be simply
reflecting the policy of the Clinical Commissioning Group, rather than
expressing the needs of the Population. The community clearly wishes to see
adequate and accessible facilities, the Plan should ensure the wants of the
Community are met, rather than the operational convenience of the
Commissioning Group if that results in less satisfactory provision. |
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A Health Facilities Policy (See Additional Policies E, p1) |
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Health Facilities are the Community’s Highest
Priority. The Community feels it has been pushed around and deprived of
important facilities, and would like to feel in control. The Plan is very
unassertive on this most important concern, and does nothing active to
influence the shape of future facilities. It does not even question whether
the proposed re-location is best for the users. |
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