Non Site Allocation Representations Report.pdf

SECTION FOUR - SPATIAL POLICIES, KEY DIAGRAMS AND SUPPORTING DEVELOPMENT CONTROL POLICIES
4.5.10 Open Space, Policy CFS/11 DEVELOPMENT AND OPEN SPACE
Rep No Name
People Type
14137 Sport Wales/Chwaraeon Cymru (Mr Rhodri Edwards) [4266]
1 Support
Summary Sport Wales welcomes the requirement that all new housing developments of 30 or more dwellings include a financial contribution to off-site outdoor sports
space and for developments of 200 or more dwellings to include on-site outdoor sport provision.
However - the Plan has adopted the TAN 16 referenced Fields in Trust's recommendations on outdoor playing space but there has been an error. While
Sport Wales welcomes the higher 3.6 hectares of open space per 1000 of the population, the figure should be 2.4 hectares per 1000 population. The 1.2
hectares playing pitch component is part of, not additional to, the 1.6 hectares for outdoor sport. This error is repeated in the Planning Obligations SPG.
22382 Mrs Searl [5170]
1 Support
Summary Due regard was paid to the requirements of this policy in the formulation of the revised masterplan included at Appendix 2. The plan has ensured the
provision of on-site open space which includes playing fields and general open amenity space around the site, some of which has been centred around the
attenuation ponds.
22337 Welsh Assembly Government (Mr Mark Newey) [2176]
Summary There is a lack of local justification for the open space requirement in the plan which is higher than set out in TAN 16.
Change Sought:
Although the plan text at 4.5.10.4/6 suggests national open space standards rather than a justified local variation are to be used in the plan area, Policy
CFS/11 (1) does not accord with the national guidance (TAN16, paragraphs 2.10 & 2.11 and Annex C) on open space requirements which equate to 1.6
hectares for all outdoor sport and 0.8 hectares of children's playing space per 1000 population (i.e. 2.4 hectares in total).
If national standards are to be used the policy CFS/11 (1) requires amending to align with national policy and any implications for increasing dwelling yields
and potential benefits for improved plan flexibility and affordable viability to be identified.
14454 Beech Developments (NW) Ltd (Mr Mike Roberts) [1966]
1 Object
Summary It makes no sense to be required to provide open space which results in the provision of facilities which are of no practical use; this is particularly the case in
relation to playing pitches and outdoor sport provision where it is only in relation to very large developments that on-site provision results in a facility of a
sufficient size to result in a useable facility. The LPA will be aware that this issue was addressed relatively recently at the appeal in relation to Albini House
with the Inspector agreeing that sports provision should be off-site for the above reasons.
Change Sought: The Policy should be amended so that, whilst children's play provision and amenity space should generally be provided on-site, sports facilities should
generally be provided by means of a financial contribution.
22438 Countryside Council for Wales (Mr Richard Ninnes) [1948]
1 Object
Summary CCW supports the principle of the policy, but considers that as currently drafted it fails to make provision for informal recreation space, dealing only with areas
required for formal play and sport provision, and therefore does not meet ToS C2.
The planning system has a large role to play in integrating the links between health and well being and sport and recreation. This is recognised in PPW and
TAN 16, which state that development plans should contain clear policies for the provision, protection and enhancement of sport, recreation and leisure
facilities.
Change Sought: To meet ToS C2, we therefore recommend that that the policy is amended accordingly.
14124 Home Builders Federation Ltd (Mr Richard Price) [1934]
1 Object
Summary The HBF objects to this policy requirement as we believe it does not correspond to National Guidance, it is not founded on a robust and credible evidence
base and is not reasonably flexible enough to enable it to deal with changing circumstances.
Change Sought: 1. Policy CFS/11 and its requirements, including the threshold, should be justified by an appropriate Open Space Assessment as required by TAN 16, or
removed.
2. The policy should include information to state that where it is required, the impact of its requirements on development viability will be taken into account and
certain dispensation will be allowed where these requirements cannot be supported by land values. This will include taking into consideration all other
planning obligations, as well as development and maintenance costs.
1
Object
360