Response to the consultation document What was said How the plan has changed
Consultation involved three processes 1)Deposition of the plan, appendices and background documents on the Parish Council website with a request for comments. 2)Circulation of a guide to the WNP and response forms to every household, business and landholder in the Parish. 3)Distribution of CDs with all documentation to the list of consultees provided by ABC. The official consultation period was from January 29 th until March 13 th, but late responses have also been considered.
The consultation statement summarises responses received From Parishioners including businesses and landholders, who replied with their response forms Comment on separate letters received from parishioners Comment on responses from statutory consultees and Imperial College London
Results of the analysis of response forms Of the respondents, 88% (621/729) were generally in support with 8% (55) ‘don’t knows’ and 4% (29) opposed.
While the majority agreed all of the plan, others did disagree with some aspects. Even the most frequently cited ‘disagree’ (36 times) ‘traffic impact’ equates to <5% of responses. Only 3.4% (24) disagreed with the plan’s proposals on parking. The 147 ‘disagrees’ fitted into 11 categories as charted above.
Dealing with specific policies
Q4 If you disagree with a policy/policies, what is the policy number and why do you disagree?
Housing numbers2 Moving Free School to Edwardian college buildings6 Proposals for ADAS4 Community use of Grade I buildings6 Of those who objected to Policy WNP 7, the disagreements were for: The highest numbers of disagrees (24) to a policy were for the WNP 7 relating to the former college or WYE3 site. The most common are set out in the Table below. The ‘disagrees’ each amount to <1% of total responses.
Age profile of those completing responses – comparison with Census 2011
A selection of the ‘cons’: I feel that the Wye 2030 Neighbourhood Plan is far too complicated for the ordinary person to follow!! I have only one comment, 162 houses will spoil Wye and make what is a village into a town and will ruin the village. I have lived in Wye for 46 years and seen it grow from a small village. I think it is disgraceful Imperial has had these houses and flats empty for 9 years and they should be done before they are allowed to build more new homes. I would like to thank everybody involved for their efforts in wanting to maintain a nice village to live in and seek the views of everyone who lives here - well done! Although I broadly agree with the principles in the plan, I cannot vote for only 50 new houses every 5 years - more people should be able to live here and contribute to the local economy.
A selection of the ‘pros’: A clean, comprehensive plan. Thank-you to everyone who has had a hand in producing it. A very comprehensive document. I am pleased to see that the beauty and community feel of our village will be retained under the plan with an excellent vision for the future so the village does not stagnate. A very well thought out document which is a massive step forward from some of the original proposals put forward by Imperial. The earlier proposals concerned me greatly but my concerns are largely mollified by the proposals articulated in the current plan. Well done to the team that drafted this Neighbourhood Plan!
Conclusions The overwhelming response to the draft plan from residents, businesses and landowners, is positive. Importantly, the responses have confirmed support for: o The scale of development proposed. o The importance of protection of the environment o The need for mixed development on WYE3 to replace lost business and education following College closure. o The critical assessment required to understand the impact of development on traffic in Wye.
Changes needed? In attempting to work with the consensus view it was concluded, based on the results of the circulated questionnaire, that no major changes were needed to the draft plan. However input from responses has resulted in More emphasis on the protected environment around Wye Thanks to Diana Pound for her detailed response Recognition of the historical significance of the settlement Greater definition of the need for support from developer contributions
Responses from consultees Ashford Borough Council Detailed response comprising Essential changes needed to fulfil Basic Conditions ie that the plan is in agreement with National and Local Planning Policy Suggestions for improvements
ABC - Changes needed to fulfil Basic Conditions Description of the village envelope and designation of green spaces Better definition of the need for contributions from developers More precision over local needs housing Policy for WYE3 not flexible enough But The response received from ABC, the local planning authority, whilst criticising certain points in the plan, indicates that the quantum of development proposed for WYE3 in the WNP meets the basic conditions tests (i.e. is consistent with the strategic policies of the adopted Development Plan and the NPPF).
Designation of green spaces protected from development
More precision needed over developer contributions The consultation document had a long wish list of projects. ABC pointed out that for Section 106 contributions..... NPPF Paragraph 204 states : ‘Planning obligations should only be sought where they meet all of the following tests: necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development’. The plan has been revised so support from 106 is more directly related to the site of development The Community Infrastucture Levy CIL is more of a tax on any house built and this provides a more flexible source of funding for projects
More flexibility on the WYE3 site The consultation version was too prescriptive so The revised version has the same level of mixed development Education Business Some housing But the exact location is flexible eg School in Edwardian buildings, OR School in Kempe Centre plus new build In both cases the Hop garden would become the playing field
Kent County Council Planning Policy The County Council welcomes the positive approach taken by Wye and Hinxhill Parish Council towards enhancing the sustainability of Wye, and in respect of paragraph 184 of the National Planning Policy Framework, recognises the Parish Council’s commitment towards the inclusion of policies consistent with adopted local planning policy (in particular, the adopted Ashford Borough Core Strategy 2008 and Tenterden and Rural Sites DPD 2010). The County Council also notes reference made to ABC’s New Local Plan to 2030 and advises that the Parish Council should remain cognisant of emerging local planning policy and to continue to engage with ABC to further ensure policy consistency. It is encouraging that KCC considers that the WNP adequately addresses National and Local Planning Policy.
KCC specific comments Heritage The publication of WNDP is welcomed as Wye is a historic town with origins dating back to the Roman period and has significant association with the medieval collegiate. The WNP has been revised to highlight the need for conservation of archeological sites in the parish. Biodiversity It is recommended that the following bullet point is added to Policy WNP 7: ‘n) Adequately assess the ecological value of the site and the potential for ecological impacts to arise as a result of the development proposals, demonstrating that the impacts can be avoided, mitigated or, as a last resort, compensated for.’ The revised WNP includes this statement in the revised Countryside and Policy WNP8 The policy is improved.
Natural England Concern over the scale of development and impact on the AONB The revised plan has more emphasis on environmental impact We stress that mixed development is needed in Wye to restore sustainability to the time when Wye College was fully operational
Natural England Examples of response and our comment The sum total of development in the plan is significant and it would be appropriate to secure at least a broad brush assessment of landscape and visual impact (in close cooperation with the AONB Unit) of the proposals, both individually and collectively The WNP Policies WNP1a, WNP1b, WNP8 and WNP11 all support the need for landscape and visual impact assessment. We welcome recognition in Policy WNP 10 - Countryside and Environment - that (inter alia) the impact of new developmenton the Wye and Crundale Downs SAC, NNR and SSSI must be specifically addressed in planning application documentation. This statement is in agreement with the principles stated in the WNP. Environmental impacts have been assessed by modelling traffic flows and through the completion of the Strategic Environmental Assessment document.
The Environment Agency Responses received highlighted the need to focus attention on water sources in the Parish. For example “We are pleased to see that proposals within the Neighbourhood Plan recognise the river as an important community asset. It could be a stated aim of the Plan to help the Stour achieve Good status.” “Groundwater protection The boundary of the proposed area where development may take place overlies a Principal Aquifer. The NHP allows for the development of brownfield sites. There is likely to be historic contamination at some of these proposed locations. As such we would recommend that reference is made to the Ashford Borough Council’s (ABC) Core Strategy (CS) Policy CS21 requiring the protection of groundwater.” The comments received provide a clear focus on the impact of development on water resources and have been incorporated into the text of the revised WNP, BD3 and Appendix E.
Imperial College London The response from ICL, perhaps not surprisingly, contradicted those from other bodies. They argue Not enough housing Must have 200 houses but state that the Hop Garden is brownfield The AONB will be enhanced by more development The draft plan does not comply with National Planning policies -and also suggest ABC do not either They do not mention the Free School site Suggest that almost twice as much traffic as modelled by the PC will be acceptable Change of use /windfall numbers too high Developer contributions vague On balance, no major changes have been made, but the numbers of houses proposed for change of use and windfall have each been reduced by five and comments on developer contributions have been corrected.
Concluding remarks Has the plan been improved by consultation? YES Has the right balance between development and protection of the environment been achieved? YES Has all the necessary documentation been completed properly? YES Is it correct to form a consensus given the strong support from most of the Parish? YES Who is right about fitting in with planning policies? Imperial or ABC and KCC? Can Imperial really ignore the comments from ABC, KCC, Natural England and others about environmental impact of building 200 houses on a green field site?
Thanks to all those who have contributed to the completion of the Neighbourhood Development Plan “FLOREAT WYE!”