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COMMITTEE
REPORT BY DIRECTOR OF
Committee:
PLANNING
Date of
Meeting: 26 AUGUST 1998
Title of
Report: PLANNING GUIDANCE, TILEHURST POORS LANDS
CHARITY ALLOTMENTS - KENTWOOD HILL
Agenda item
No. 8
For
Decision/Information: INFORMATION
Wards
affected: KENTWOOD/TILEHURST
Service(s)
involved: PLANNING
Officer
Contact
Name: GARY
RAYNER Tel: 0118 939 0431
Designation:
TEAM LEADER Service: PLANNING
1. PURPOSE AND SUMMARY OF REPORT
To
report to members the responses received from
the consultation exercise with regard to the
potential for development at the Kentwood Hill
allotments and to recommend guidance to be given
to the Charity Trustees with regard to their
development potential.
2.RECOMMENDATIONS
That:
- The
consultation responses be noted.
- The
policy appraisal and conclusions be agreed and
be passed to the Charity Trustees for their
information.
3.BACKGROUND
Following
a Resolution by Planning Committee on 3/6/98 a
consultation exercise has been carried out to
allow local residents and organisations to
express views with regard to the Tilehurst Poors
Lands Charity's stated intention to submit a
planning application for development on part of
the allotment land at Kentwood Hill.
A copy of
the circulated questionnaire is attached. A
public meeting was held on 12/6/98.
4. SUMMARY
OF RESPONSES
The
questionnaire was circulated to local households
and to allotment plot holders, and copies were
made available for general distribution by
interested parties. Approximately 950
questionnaires were issued, and 383
questionnaires were returned, some with
additional letters in response to question 7.
136 separate letters were received, and 16 notes
made on a leaflet circulated by the Tilehurst
Allotments Action Group.
The
responses to the individual questions on the
questionnaire are reported below. Not all the
questions were answered on all the
questionnaires and the percentages given are
with regard to the number of responses to each
question and are not percentages of the
total number of questionnaires
returned.
Ql.Of the
402 responses to the question, 304 (75.6%)
replied "No" to supporting some kind of
development on the allotments, only 34 (8%)
replied yes and 62 (l5%) supported part of site
development, compared to the 2 (0.5%) responses
in support of all of the site being
developed.
Q2.With
regard to site uses, 254 (6l.5%) of the 413
responses preferred allotments only. The next
most popular choice was a combination of
allotments and other public leisure with 79
(l9.1%) . The least popular options were all
public leisure and all housing, which received
5(1.2%) and 1(0.2%) respectively. The remaining
options of allotments/leisure/housing,
allotments and housing and other had 29(7%),
22(5.3%) and 23(5.6%) responses respectively.
The main other uses suggested were for car
parks, public gardens, parks and general open
space/leisure.
Q3.If any
development was to be accepted on this site
69(23.6%) responses agreed that yes housing
would be the most appropriate use. A far larger
number of 223(76.4%) answered no, housing would
not be the most appropriate use. 86 alternatives
were suggested. The main uses put forward were
car parking, public gardens, nature/wildlife
area, parkland, playground and general leisure
use.
Q4.Site
'A' was marginally most popular and least
opposed site for development, with 59 (20.8%) in
favour and 224 (79.2%) against. Sites B and C
had exactly the same figures with 42 (14.7%) in
support of development on these sites and 243
(85.3%) being opposed.
These
responses relate quite closely to Ql responses,
ie. no development 75.6% and part of site
development 15%
Q5.
|
Type
|
|
Style
|
|
Private
|
33
|
29.5%
|
|
Flats
|
15
|
l4.9%
|
|
Hsg
Assoc
for
Rent
|
9
|
8%
|
|
Terraced
|
6
|
5.9%
|
|
Retirement
|
52
|
46.4%
|
|
Detached/semi
|
15
|
l4.9%
|
|
Combined
|
18
|
16.l%
|
|
Mix
of the above
|
23
|
22.8%
|
|
|
|
|
|
Bungalows
|
42
|
41.6%
|
With regards the housing type felt to be most
appropriate, retirement followed by private
received the most responses, with 52(46.4%) and
33(29.5%) respectively. Housing association for
rent gets little support with only 9(8%)
positive responses.
Bungalows
are the most popular choice of style, 42
(41.6%). Detached/semi-detached and flats have
equal support with 15(14.9%) responses each.
Terraced housing is least popular with only
6(5.9%). There are also 23(22.8%) responses
which would like to see a mix of flats, terraced
and detached/semi-detached.
The
relatively few responses to this question in
comparison to others, reflects the general
disapproval of any sort of housing.
Q6a.
125(42.8%) of responses support the improvement
of car parking facilities associated with the
allotment and the recreation ground. While
167(57.2%) would not want to see these
improvements.
Q7.
Additional comments made in response to this
question are included within the following
report of points made in the individual
letters.
The 16
notes returned on the Action Group leaflet all
proposed no building on the
allotments.
Comments
by letter: Building under no circumstances,
allotments keep elderly active, roads cannot
cope with increased traffic, loss of valuable
open space, overdevelopment of Tilehurst,
congestion, enough new development in the area
already, loss of facility for future
generations, loss of views and local amenity,
allotments are essential community provision,
impact on wildlife flora and fauna, impact on
foraging area for badgers, will put pressure on
to development those areas of allotments left
this time. Council could lease the land and open
to public, prevent pollution, short term view,
services not improved, should use brown field
sites, overcrowded schools, loss of area to grow
fresh produce, should be a Millennium Garden,
old character lost. Could provide
bungalows/flats/houses for elderly on part of
site.
2 letters
have been received from specialists,
highlighting the wildlife value of the allotment
areas as a whole. The reports identify a large
number of species of flora and fauna on the site
and it is obvious that the site warrants future
detailed assessment prior to any acceptance of
changes which might impact on the flora and
fauna identified at this time.
Response
by the charity: The Charity has submitted a
statement and questionnaire in support of its
proposals emphasising its considerations with
regard to compliance with planning policies and
reasserting its intentions to seek consent for
the provision of affordable housing, to improve
the problems of parking for the allotments and
recreation ground and to contribute to the
improvement of traffic problems on roads
neighbouring the allotments and finally to try
to create a situation which will secure the long
term future of the use of the recreation ground
and the remainder of the allotments for the
benefit of the community.
Pesponse
by The Tilehurst Allotments Action Group: The
Group has submitted a detailed response with
regard to the loss of open space and community
facilities, wildlife and conservation issues,
views, traffic and access, recreation and car
park issues, and the allotments and their
future. The response is summarised as follows;
loss of open, green space is not acceptable,
wildlife on the site is special, views from the
site would be adversely affected, access is
difficult and traffic is already a problem, the
car park is not a popular option, allotments
should be preserved to accommodate changing
leisure needs in the future.
A petition
of over 2000 signatures has also been submitted
supporting the retention of open space and
opposing any built development.
Details of
all the responses are held in the Planning
section.
5.PLANNING_CONSIDERATIONS
Any
application for planning permission on the site
must be considered with regard to the Deposit
Reading Borough Plan (CWD as amended). The Plan
does not formally allocate the land for any
particular future use.
The
Deposit Reading Borough Plan (as amended and
modified) has undergone two public inquiries and
is due to be adopted this autumn. Once adopted,
the plan will form part of the statutory
development plan for Reading and as such the
legislation requires all development proposals
to be determined in accordance with its policies
unless material considerations indicate
otherwise.
An
assessment based on the published planning
policies (outlined below) has been made with
regard to the principle of development at this
time.
The
principle of development
With
regard to housing development, "The general
principle of the plan is to encourage housing
development within the Borough, provided
it:
- does
not result in the loss of important areas of
open space or community
facilities;
- complies
with the policies on affordable housing in
the Plan;
- meets
normal development control requirements and
does not conflict with any of the other
policies of the Plan."
The
following list of planning policies has been
assessed prior to deciding if the development of
part of the allotment site is acceptable in
principle:
Key 2A,
Key 3, HSG 9, TRN 11, LEI 1, COM 9 and NE ~
(Deposit Reading Borough Local Plan as amended
and modified).
The
current use of the site as allotments provides a
valuable open space and leisure facility in the
area. Some areas of the site are unused and
others have been allowed to be used for
non-conforming and inappropriate commercial use.
Removal of non-conforming uses from the site is
desirable. The Council may have legal powers to
remove from the site uses which require, but do
not have, planning permission. Those powers can
be enforced whether or not an application to
develop the site is approved.
The
current use as allotments is 'open' and 'green'.
However, the current Borough Plan does not
specifically recognise the site as a major area
of open space (LEI 2) , a neighbourhood
recreation area (LEI 4), a local nature reserve
(NEl), a wildlife heritage site (NE2) or a major
landscape feature (NE4)
Policy
LEIl of the DRBLP states that development that
results in the loss of open space will not
normally be allowed. Only in exceptional
circumstances will development be considered,
and then only if sufficient replacement open
space and/or improvements can be provided. One
such circumstance may be if the Borough was not
providing for an appropriate level of housing
land supply.
The five
and ten year figures for "housing land supply"
for the borough underwent a rigorous assessment
during the local plan modifications inquiry in
1997 and the Inspector found that the supply
would more than meet the requirements of the
approved structure plan (9991-2006) Provisional
figures for new housing permissions since the
Inquiry show a continued supply, in line with
previous forecasts. Given this, there is no
overriding justification or exceptional
circumstances sufficient at this time to
outweigh the loss of a significant area of open
space and to undermine the Council's
policies.
Policy Key
2A of the Borough Plan seeks to maintain and
enhance the natural environment for future
generations and states the Council's intention
to attach particular importance to the need to
conserve existing areas of open space. Policy
HSG9 prescribes against residential development
that would have a detrimental impact on the
physical and visual character and quality of the
area or result in the loss of wildlife
habitats.
I consider
that at this current time these are the
overriding policy considerations and
notwithstanding the provisions and requirements
of other policies of the Borough Plan, there is
currently no exceptional circumstance which
would warrant developing the site at the expense
of its openness.
6.POTENTIAL
APPLICATION
I do
not consider that development on the site is
appropriate with regard to the current Deposit
Reading Borough Plan but if the Charity wishes
to pursue an application it should include an
analysis of the policies and a consideration by
the Charity of how their proposal met the
various requirements of the local plan and why
such consideration differs from the view given
in this guidance.
Any
application should provide plans which clearly
illustrate the relative levels of the site and
its surrounds, and include cross sections which
show the relationships within the site and with
neighbouring land uses and
properties.
Depending
on the size of the proposed development and the
number of dwellings proposed it may be necessary
for an application to include a Traffic Impact
Assessment and an Environmental Assessment.
Whatever the size of the proposed development, a
detailed analysis of traffic and environmental
impact must form part of submitted
application.
If a
formal application was made the planning
authority would consult on a specific
proposal.
This
consultation would include the local community
and local residents as well as specialists in
respect of housing, leisure, open space wildlife
and highways.
Given the
nature of the site it would be preferable to
have a fully detailed planning application for
any proposed development. If an outline
application is submitted to agree the principle,
rather than the detail of development, the
Council will require that sufficient detail is
submitted in support of that outline to allow
the points raised earlier in this guidance to be
appropriately addressed.
If any
approval was to be given for development on the
site it would be likely that a legal agreement
would be required to secure such matters as
housing tenure, recreational provision, highway
improvements and associated environmental
improvements and maintenance.
It must be
stressed at this time that the Council does not
consider the principle of development on the
site to be acceptable.
7.LEGAL
IMPLICATIONS
None
arising directly from this report.
8.FINANCIAL
IMPLICATIONS
None.
9.EQUAL
OPPORTUNITIES IMPLICATIONS
None.
10.LIST OF
BACKGROUND PAPERS
Consultation
responses held in planning section.
Deposit Reading Borough Plan (CWD as
amended)
Plgen/comreps/26
Aug98/poorlands
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