Comment or question: Q234
| General comment or question | |||
| Comment no.: | Q234 | Date: | 14/09/2014 17:27 |
| Comment by: | Roger Hepher | Post code: | Savills |
| Below are the representations on the draft plan on behalf of Chelveston Renewable Energy. I shall be grateful if you will confirm receipt, and that the representations will be taken fully into account as the Neighbourhood Plan is progressed. As a major local land owner and employer, CRE is keen to have a co-operative relationship with the local community and its Parish Council. We will therefore be pleased to discuss these representations with you in due course. Regards. Para 2.1. An important part of sustainability is for there to be enough suitable local jobs to minimise the need for outward commuting (a feature of the Parish acknowledged in the draft plan). Throughout the plan, the emphasis is largely on housing development, and the need for a sufficient and appropriate employment is given little emphasis. Para 2.3, Fig 5.1. No justification has been given for seeking to restrict renewable energy activities to the northern end of the old Chelveston Airfield. Subject to appropriate screening and other measures, the whole of the former airfield is potentially suitable for such activities, and there is no justification for imposing an arbitrary limit. Renewable energy development is desirable in terms of the NPPF; para 97, for example, says that, \\"local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources\\". It is also supported by the North Northamptonshire Core Spatial Strategy; para 4.14, for example, says, \\"it is anticipated that new wind energy development proposals and decentralised biomass fuelled power plants will, in principle, be considered favourably in North Northamptonshire\\", and beneficial development should not be frustrated by an arbitrary measure. The draft Neighbourhood Plan acknowledges (section 1.1) that it must conform to the policies contained in both documents. Policy H1. Additional housing on the former barracks site to the east of Chelston Rise would make that settlement more sustainable, without developing on land that has not previously been developed. Policy H4i not only refers to the 400m sterilisation zone, which we address in our representations relating to Policy REN1, but goes on to say that \\"No developments will be permitted on undeveloped fields or naturalised green field sites outside the settlement boundary, and outside the EC1d and REN1 boundaries, other than for agricultural use\\". This policy is substantially more restrictive than Green Belt policy, and is neither supported by evidence as to why such a restrictive policy is justified, nor by policy in higher level documents. We acknowledge that the amenities of the Chelston Rise houses must be taken into proper account in any planning decisions, but that is a function for the development management process. Policy RoW (page 72). Chelveston Renewable Energy is keen to work with the Parish Council and the local planning authorities to make the central right of way across the former airfield safer and more attractive to users, particularly by separating vehicular traffic from the surface used by pedestrians and horses. This improvement should be referred to in the policy, and in Policy REN1. Policy EC makes no reference to the potential for additional employment to be created at the Chelveston Renewable Energy Park, with the supporting text saying this is \\"Because of the negative impact on its amenity value\\". Whilst the precise meaning of this phrase is unclear, if it is being claimed that any additional employment will necessarily have an unacceptable effect upon amenity, this is not supported by evidence, and is in any event a judgement that can only properly be made on a case-by-case basis. Policy REN. The second part of this policy is inconsistent with the NPPF and the NNCSS, as noted above. Furthermore, the proposed policy appears not based upon evidence. Why would it be objectionable to construct additional turbines if these are seen as part of the existing cluster? Why should further anaerobic digestion facilities or solar PV arrays be prevented if it can be shown that they would not be objectionable in planning terms? Why should activities increasing vehicular activity be prevented if it can be shown that there would be no sustainable safety or amenity objection? Imposing arbitrary restrictions is not consistent with the requirement of the NPPF that development plans should be evidence based, and that there is a presumption in favour of sustainable development Policy REN1. The former airfield should be regarded as Previously Developed Land, in that there remains clear evidence of the former use. The features listed at (B) are not the only surviving features; furthermore, they themselves can only be understood by the observer in the context of the former airfield use. Para D is misleading. The site is crossed by a number of footpaths and bridleways, which it is accepted have some amenity value. However, the majority of the site has no amenity function except insofar as grassland and energy structures may to some degree enhance the experience of pedestrians and riders. Re para E, as noted above, the draft Plan contains no evidence that existing traffic movements are objectionable according to any objective test, and any future proposals should be assessed on their merits. In any event, further development would not necessarily increase vehicular activity (for example, once installed, solar PV arrays generate less vehicular activity than many agricultural activities). Some of the stipulations in para G are arbitrary, and have no rational basis: in particular, i, ii and v. Others are simply a statement of matters that would in any event be taken into account in the determination of any planning application, and it is inappropriate for them to be included in a policy document. The sterilisation zone adjacent to Chelston Rise, referred to in para H, has no evidential basis, and should not be included in the plan. Any proposals for this previously developed land should be considered on their merits, and development should not be ruled out for arbitrary reasons. |
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