6JANUARY 2012
CITY COUNCIL RESPONSE TO REPRESENTATIONS RECEIVED ON THE PRE-PUBLICATION CORE STRATEGY
This schedule provides details of all of the comments received during the Pre-Publication Core Strategy consultation period, together with a brief response from the city council. A series of background reports to be published in February 2012 alongside the Publication Core Strategy will provide a much more detailed explanation of the reasoning behind the policies in the Publication Core Strategy and why other options have not been taken forward.
GENERAL COMMENTS
GENERAL COMMENTSRef / From / Chapter/policy / Comment / City council response
1 / Trevor Davies / General Comments / Regretfully I have not been able to understand your letter sufficiently to be able to offer any credible input.
Without wanting to sound impolite, I believe if you want to consult a lay person expecting them to respond, a much simpler form of words needs to be used. I think your original consultation was in a much clearer form. I am though interested in giving my thoughts and I hope this helps.
I do think it is necessary to increase our housing stock and in order to fill them we need excellent schools, which will attract parents who want the best education for their children. With also an increase in retail and industrial parks, to provide employment. And an enhancement of our places of interest such as Worsley canal basin and Ordsall Hall. Also making SwintonTown Hall as a centre of Salford by improving its surroundings. We must accept we are a satellite of Manchester and use this to our advantage. By providing quality accommodation to reduce commuting for Manchester workers. I am unable to offer any figures but again I hope this is of help. / The city council will seek to ensure that future consultations are more easily understood.
The Publication Core Strategy supports the improvement of housing, employment, retailing, education and heritage suggested.
39 / Network Rail / General Comments / Network Rail has no comments to make. / Noted.
69 / Sport England / General Comments / The said document is not a fully revised draft of the core strategy, rather it presents amendments to selected issues only. In summary, these issues include housing, employment, retail and renewable energy matters. Sport England has no further comments to add at this stage and would request that our comments submitted in response to the Draft Core Strategy (under cover of a letter dated 15 January 2011) are considered when preparing the publication version of the core strategy. / Noted.
88 / Theatres Trust / General Comments / The Theatres Trust is The National Advisory Public Body for Theatres. The Theatres Trust Act 1976 states that ‘The Theatres Trust exists to promote the better protection of theatres. It currently delivers statutory planning advice on theatre buildings and theatre use through the Town & Country Planning (General Development Procedure) (England) Order 2010 (DMPO), Articles 16 & 17, Schedule 5, para.(w) that requires the Trust to be consulted by local authorities on planning applications which include ‘development involving any land on which there is a theatre.’
Due to the specific nature of the Trust’s remit we are concerned with the protection and promotion of theatres and therefore anticipate policies relating to cultural facilities.
We note this document only focuses on Core Strategy topics where significant changes are being proposed. We are therefore disappointed that Salford’s existing first class cultural venues are not being recognised and supported as major contributors to a vibrant evening economy with a policy to enhance when necessary.
It is crucial to manage the growth of tourism including their relevant venues and to maintain and improve the quality of people’s experience of visiting and staying in Salford and it should be a duty of the Council to ensure that existing venues are exclusively safeguarded and enhanced through its LDF policies, as well as proposals for new and replacements in the future. / Policy DP2 of the Publication Core Strategy seeks to ensure that all land uses are appropriately accommodated. However, it is considered too detailed to include any specific provision for theatre uses in the Core Strategy, particularly in the absence of any detailed evidence on demand or that there are any specific problems of theatre loss in the city that need to be addressed.
130 / Countryside Properties / General Comments / General Comments- The consultation addresses a number of topic areas, and is not intended to be a fully revised document. However, as a result there are a number of omissions and areas where cross topic issues have been overlooked, particularly in areas relating to regeneration for example. This is an area of significant concern which goes to the heart of the document and the strategy being adopted by the Council. The approach of introducing such ad hoc amendments without consideration of the broader spatial vision and objectives seriously threatens the soundness of the document. Recent experience with other Core Strategies have demonstrated that such an approach is unacceptable.
As a result it is unclear whether this document has been produced to build upon the previous core strategy consultation or has been published simply as a means and forum for seeking the reduction in key targets, such as the housing land supply reduction from 1600 dwellings per annum to 1100. In this respect it appears from paragraph 5.3 that the Councils previous commitment to growth and the Growth Point programme which aimed for 20% provision over and above RSS targets was a simple way of securing additional funding rather than a real commitment to growth. / The scale of housing development proposed in the Core Strategy has been increased slightly, from 22,000 over the period 2010-2030 at the Pre-Publication Core Strategy stage to 22,100 over the period 2011-2028 in the Publication Core Strategy (an increase from 1,100 dwellings per annum to 1,300 dwellings per annum). The scale of housing proposed is based on household projections taken from the Greater Manchester Forecasting Model, with an additional allowance for the impacts of the extra office development proposed in the city. It should therefore reflect a realistic assessment of likely demand.
102 / The Highways Agency HA / General Comments / The Highways Agency would not wish to make any further comments with regard to the core strategy housing supply document dated June 2011. Our previous comments remain applicable; with the Highways Agency looking forward to further dialogue during the next phase of the core strategy consultation process. / Noted.
150 / LPC Living / General Comments / Conclusion and Recommendations- It is important in preparing Local Development Frameworks that any allocations stand a realistic prospect of being delivered. With this guidance in mind, and in the light of the above, LPC Living:
1. recommends greater emphasis is put on economic growth;
2. supports the overall message within the document to encourage future development;
3. supports the identification of a Regional Centre but recommends the proposed centre at Trafford Road, Ordsall should be included within the Regional Centre boundary;
4. supports the use of minimum dwelling provision targets, but recommends a higher minimum provision; and 5. supports the identification of further commercial floorspace throughout Salford. / The Publication Core Strategy places a strong emphasis on economic growth, but it is important that this is not at the expense of social and environmental considerations.
It is not considered appropriate to amend the boundary of the Regional Centre to respond to individual developments. Many of the city’s local centres are located outside the Regional Centre.
The scale of housing development proposed in the Core Strategy has been increased slightly, from 22,000 over the period 2010-2030 at the Pre-Publication Core Strategy stage to 22,100 over the period 2011-2028 in the Publication Core Strategy (an increase from 1,100 dwellings per annum to 1,300 dwellings per annum). The scale of housing proposed is based on household projections taken from the Greater Manchester Forecasting Model, with an additional allowance for the impacts of the extra office development proposed in the city. It should therefore reflect a realistic assessment of likely demand.
89 / NHS Salford / General Comments / General Comments
The updated Core Strategy’s aspirations should contribute to improving public health and reducing health inequalities in Salford – e.g. improved environment’s impact upon mental health and measures to encourage greater physical activity, greater access to jobs, focus on sustainable use.
- .We particularly welcome efforts to encourage greater walking and cycling and use of green space in the City Centre. However, we would like to see the same emphasis and commitment to increasing the provision of healthy food and reducing the provision of unhealthy food. Both physical activity and food are key aspects to reduce obesity.
- .The pre-publication document has acknowledged and developed a number of concerns expressed during the consultation e.g. the housing requirement and preservation of green belt land, to create an alternative approach more suitable for local needs.
- .It has further strengthened the original Core Strategy aspiration of creating local centres that cater for all the local needs reducing the need to travel and creating stronger communities.
- .It is important that the Core Strategy also links to the planned actions of the Family Poverty strategy, particularly in relation to housing and employment.
90 / NHS Salford / General Comments / To ensure the Strategy’s implementation is effective these further recommendations are made:
Food
Five per cent of people on low incomes report skipping meals for a whole day. Low income and area deprivations are also barriers to purchasing fresh or unfamiliar foods. Lower income households are the hardest hit by food price fluctuations.
Dietary change can also play a key role not only in mitigating climate change and adaptation strategies, but also in promoting health by reducing the consumption of saturated fat from meat and dairy sources. Food preparation and production contributes around 19 per cent of the UK’s greenhouse gas emissions; half of these emissions are attributable to the agricultural stage.
Food systems have the potential to provide direct health benefits through the nutritional quality of the foods they supply. Improving the food environment involves addressing issues concerning the accessibility of affordable and nutritious food that is sustainably produced, processed and delivered. Internationally, studies show that among low-income groups price is the greatest motivating factor in food choice. In the US, price reductions have seen positive increases in the sales of low-fat foods and fruit and vegetables. There are studies that show association between proximity, or lack of, to healthy food, and health outcomes such as obesity or malnutrition, but these studies should be approached with caution. They are most often observational and so do not show causality between inadequate access and health outcomes. One study in the UK on the greater access to unhealthy food has shown this may disproportionately affect those in more deprived areas. Data from the US shows more substantial links between schools and proximity to fast food outlets, as well as proximity to fast food outlets and obesity.
Availability of healthy food, and in particular fresh produce, is often worse in deprived areas due to the mix of shops that tend to locate in these neighbourhoods. A study of the location of McDonald’s outlets in England and Scotland showed per capita outlet provision was four times higher in the most deprived census output areas than in the least deprived areas. Low-income groups are more likely to consume fat spreads, non-diet soft drinks, meat dishes, pizzas, processed meats, whole milk and table sugar than the better-off. The creation of food deserts is likely to be a by-product of a complex interaction between local planning, regulatory and economic factors and the national location policies of large supermarket companies.
Food obviously has a key role in obesity but it is almost invisible in many planners’ remits – access to good quality, healthy food is essential. The World Health Organisation makes the following recommendation for planners to consider and implement:
Local, low-input food production – provision of allotments, smallholdings and city farms together with local healthy food outlets
Marmot meanwhile also recommends: Improving the food environment in local areas across the social gradient / The approach in Chapter 11 of the Publication Core Strategy is intended to ensure that all residents have good access to shops and other services. This should help to ensure that they can access healthy food, although the Core Strategy cannot control the type of shops that locate in centres.
163 / Trafford MBC / General Comments / As a general comment, concern is raised over the thrust of the changes being proposed within the document. It is considered that they have the potential to undermine, not only, the work being progressed through the Trafford Local Development Framework, particularly the Trafford Core Strategy, but also the objectives for the wider City Region. Additional detailed comments have been made. / The approach in the Publication Core Strategy is based on an objective assessment of development needs within Salford, and is therefore considered to be robust.
91 / NHS Salford / General Comments / To ensure the Strategy’s implementation is effective these further recommendations are made:
•Greenspace
In other parts of Salford, we should aim to ensure that as many people as possible have sight of greenery for as much of the time as possible. Green roofs, living walls, green security (thorny hedges instead of metal fences), trees on streets, small patches of greenspace along with gardens, formal greenspace and Green Belt need to be developed and maintained.
Numerous studies point to the direct benefits of green space to both physical and mental health and wellbeing. Green spaces have been associated with a decrease in health complaints such as blood pressure and cholesterol, improved mental health and reduced stress levels, perceived better general health, and the ability to face problems. The presence of green space also has indirect benefits: it encourages social contact and integration, provides space for physical activity and play (for adults as well as children), improves air quality and reduces urban heat effects. / Policy GI1 of the Publication Core Strategy seeks to secure a high quality network of green infrastructure extending throughout Salford. The need for a significant increase in the amount of green infrastructure in the Regional Centre is highlighted in Policy SF1, given the limited existing provision and the high density of development proposed there.
93 / NHS Salford / General Comments / To ensure the Strategy’s implementation is effective these further recommendations are made:
Health Facilities
Primary care services (such as GP surgeries and dentists) are an essential part of the local service infrastructure and must be considered whenever housing developments are proposed. Planners should consult with the statutory health agencies as part of a planning and informing the commissioning process. Consideration should be given to making available any resources for development of new primary care facilities to support new housing developments, particularly where extensive additional accommodation will be required.
Salford’s current GP provision is currently not at full capacity and with the increasing population further demands are put on individual practices’ capacity. / The city council has sought to involve the primary care trust throughout the Core Strategy process, to ensure that the implications of housing growth are taken into account in health investment programmes.
286 / Bridgewater Residents Association / General Comments / Bridgewater Residents Association (BRA) represents around 200 households, flats and houses, in the area identified as “Greengate North and Trinity” within the Core Strategy, an area bounded by the River Irwell, Blackfriars Road and Trinity Way. We welcome the opportunity to respond to this consultation.
General Comments - Our community is located just outside of the identified “Regional Centre” and “City Centre” and just south of the regeneration area of Broughton. As such, we are sandwiched between two areas of major investment and redevelopment and therefore it is important that the core strategy provides the necessary framework for supporting development and investment within the area.
Unfortunately, the Core Strategy does nothing for the Greengate North and Trinity area of the city, neglecting its needs whilst focusing and protecting investment in surrounding communities. The area is singled out for massive residential development, all of which will be the form of flats. There are no proposals to support retail, leisure or employment opportunities and nothing to protect and enhance the qualities of this area. This area has suffered from severe neglect by Salford City Council, left due to its proximity to the city centre but not included within any investment plans. The proposed Core Strategy will simply perpetuate this situation for many years to come.