Inspector's Schedule of Modifications

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Object

Inspector's Schedule of Modifications

MM51 (Main)

Representation ID: 453

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

MM 51 – We find the reasoning provided to be precisely why this illustrative plan is so problematic, as it acknowledges that foundational details such as points of vehicular access are not confirmed within the DPD. This modification does not resolve the problem as it remains the only mapping presented within the DPD to show these features, but is not supported by policy, despite many assumptions being based upon it.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

Object

Inspector's Schedule of Modifications

MM52 (Main)

Representation ID: 454

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

MM 52 – As per the reasoning presented it is acknowledged that the road network and capacities is not fully understood, if the DPD was an effective plan using an evidence led approach this problem would not exist. Such a degree of flexibility to alter established road networks already serving local communities, including Crockleford within the area in question, makes this modification a substantial change that would require additional consultation.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

Object

Inspector's Schedule of Modifications

MM54 (Main)

Representation ID: 455

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

MM54 – this weakening of language is not effective plan making, encouraging such an effect does not guarantee any positive results, and there are sufficient assumptions based on the success of this policy that it must be guaranteed.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

Support

Inspector's Schedule of Modifications

MM55 (Main)

Representation ID: 456

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Representation Summary:

MM55 – support this change to recognize alternate means of public transport may emerge as preferable over the timeframe of the development.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

Object

Inspector's Schedule of Modifications

MM57 (Main)

Representation ID: 457

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

MM57 – seems like an unnecessary watering down of an effective policy. For neighborhood center proposals to be an effective community placemaking principle, there needs to be direct access to the RTS, without the potential for varying interpretations of the ‘serve’ wording that could complicate decision makers process during planning applications.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

Object

Inspector's Schedule of Modifications

MM61 (Main)

Representation ID: 458

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

MM61 – strongly disagree with the assertion that design cannot ensure such matters, the drastic weakening of wording does not make for effective plan making, and the suggestion that significant issues with parking are merely rectified at later planning phases is unacceptable. A proposal may both seek to avoid such parking issues while evidence shows it will cause problems. The design of the development can functionally make significant negative parking impossible, so the policy should aspire to do this, not push rectifying foreseeable issues to future development phases to rectify.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

Object

Inspector's Schedule of Modifications

MM63 (Main)

Representation ID: 459

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

MM63 – the insertion of ‘aiming to’ restrict vehicular access is another drastic weakening of an already effective policy. The current wording is far more effective plan making and so should not be altered. If by the reasoning presented for this modification there is evidence
that conflicts with the DPDs own evidence base, this would suggest that either one or both methods of testing are functionally flawed and so the DPD policies are based upon incorrect assertions. To only now be exploring the potential ‘need’ for a direct access from the A133 to
the southern community, when said junction is already under construction shows a significant shortcoming in planning thus far. To install such a connection would drastically alter many of the traffic models relied upon for the DPD. This modification represents a major alteration that would require additional public consultation and re-examination, alongside an updated evidence base to assess its effectiveness.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

Object

Inspector's Schedule of Modifications

MM64 (Main)

Representation ID: 460

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

MM64 – While we support the intention of the modification, a commitment to full funding must be more than demonstrated, it must be agreed upon in a legally binding contract to enable planning permission to progress. Demonstrated is not adequate phrasing for such an essential purpose.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

Object

Inspector's Schedule of Modifications

MM65 (Main)

Representation ID: 461

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

MM65 – Once again the alteration to language is weakening an already effective policy – ‘to reflect’ is ambiguous and unenforceable, if the travel plan is utilizing best practice, it will be in accordance with the guidance. While we acknowledge the supporting evidences inclusion, this is effectively two modifications portrayed as one.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

Object

Inspector's Schedule of Modifications

MM70 (Main)

Representation ID: 462

Received: 24/10/2024

Respondent: Elmstead Parish Council

Agent: Elmstead Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

MM70 – removing the annual review to an undetermined timescale is a significant change when it is an unlimited change. While there are small changes to the policies annual frequency that would be acceptable such as every 2 years, if the frequency is instead changed to every decade it is unacceptable. An effective policy tool would have been to instead simply agree the preferred timeframe for this modification and we are concerned this seemingly wasn’t possible.

Change suggested by respondent:

Strengthened policy wording to ensure policies are effective and not merely suggestive.

Updated traffic modelling and re-examination of transport and movement policies to form an effective, evidence based approach.

Completion of the full link road, to be operational before domestic development commences. (as promised in previous rounds of consultation, and removed without adequate opportunity for additional input)

Integrated phasing plan overview enshrined in policy. Updated viability study to confirm potential proposal is above viability threshold as currently queried in evidence base: financial viability study confirms a 15% profit on cost was approved during section 1, appropriate range reduced to 10-14% but the same document establishes liability at 9.65% - below acceptable thresholds and which we believe will only have fallen further due to changing economic circumstance. By the DPDs own evidence base’s assertion – it does not meet the threshold to be viable.

Full text:

While we support a number of modifications suggested by statutory bodies such as natural England and sport England, we have listed numerous concerns where policy wording is being unnecessarily weakened to the extent it is no longer effective.

As noted there a small number of modifications we believe contradict one another with regards to effective transport planning, and require significant changes, or the omission of illustrative mapping with no planning purpose that obfuscate the policies they’re intended to support.

We remain concerned that an evidence based approach has not been taken with regards to effective transport and movement, especially given the reasoning for main matter 63 which itself concludes the existing traffic modelling is fundamentally flawed. This, and other modifications require substantial changes that need additional evidence, and further consultation to constitute a proper plan making process.

We can only reiterate representations made at the examination in public that we believe too much detail has been pushed to later stages of the planning process, which is supported by the numerous reasonings suggesting policy must be loosened to allow for a wider flexibility.

Attachments:

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