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Storrington, Sullington and Washington Neighbourhood Plan

Health Check

June 2015

Andrew Ashcroft

Assistant Director – Economy, Environment and Culture

Herefordshire Council

Neighbourhood Plans Independent Examiner

1 Storrington Sullington and Washington Neighbourhood Plan

Introduction

I was commissioned in June 2015 to carry out a health check of the evolving Storrington, Sullington and Washington Neighbourhood Plan (SSWNP). A revised pre-submission plan was published in April 2015.

This report sets out a series of findings and recommendations.

As part of the health check I have:


Executive Summary

The Storrington, Sullington and Washington Neighbourhood Plan has been in preparation since late 2013. It sits within the strategic context set by the adopted Horsham Core Strategy 2007. Its development has been closely related to the emerging Horsham Local Plan/Planning Framework. A key element of the neighbourhood plan is to provide local clarity on the location and type of sustainable development in general, and housing in particular.

Very significant progress has been made on the Plan in a relatively short time. The Plan sets out a focus for its aims and objectives. This translates into a series of policies. This health check has been commissioned to secure advice on any outstanding work necessary to allow it to proceed both smoothly and effectively through the consultation, examination and referendum stages of Plan making.

The Plan is well-presented. It sets out a substantive basis for the future planning of the Plan area. It is distinctive to the Plan area. It has been particularly positive in promoting the viability of village centres and has allocated a wide range of employment and housing sites. The health check identifies certain policies which would benefit from additional clarity. To this extent the health check sets out to provide a more robust set of policy wording to a Plan where the fundamental elements are in place and where sustainable development will result from the implementation of its various policies.

The health check reinforces the need to ensure that the associated Sustainability Appraisal/Strategic Environmental Assessment has been prepared to a standard that will withstand examination. There has been a particularly detailed analysis of this work in recent months.

The health check sets out a series of recommendations on the range and the nature of the work that is reasonably required to produce a final plan which is both effective in its purpose and which meets the basic conditions.

Read the documents as provided to me by Horsham District Council Read the SSWNP Read its associated Sustainability Assessment/SEA Read key elements of the emerging Horsham Local Plan (HLP) and the interim

findings of the Inspector (December 2014) Looked at certain sites on Google Maps to assist my understanding.

Structure of the Health check

This health check provides an overview of the emerging SSWNP and an assessment of its relationship to the basic conditions against which it will eventually be examined.

I have also looked at the wider package of documents and which include:

The SEA/Sustainability Assessment The Site Assessment Report The Policies Maps

Overall Findings

The Plan is well-presented and constructive. It sets out a positive and in general terms a realistic basis for the future planning of the SSWNP area. It has been very positive in identifying opportunities for sustainable growth and is very clear about where this growth should take place. It is distinctive to the Plan area both generally, and in terms of how it promotes growth in particular.

The associated Strategic Environmental Assessment (SEA) has recently been expanded and has been linked with the preparation of the SSWNP itself. Following the commissioning of specialist advice by the South Downs National Park Authority there is an on-going debate on the extent to which the document has been prepared. I have made some observations on this matter in this health check.

The combined effect of these two related documents will give significant confidence in general terms to the appointed independent examiner that the submitted SSWNP meets the basic conditions for neighbourhood plan preparation. The remainder of this note sets out areas where the Plan could be improved. In particular it identifies areas where the plan could be made stronger and its linkages with the emerging SEA could be consolidated. It also identifies certain policies where the current drafting is unclear. The health check sets out to identify potential revisions to the Plan that would reduce the number of modifications that the independent examiner may be minded to make in order to ensure full conformity with the basic conditions. These revisions will provide an even stronger context for the future delivery of the Plan through its statutory processes

The Plan


In general the Plan reads well. It sets out a package of visions and objectives and is underpinned by a robust yet proportionate evidence base. To the non-local reader it succinctly sets out the parish profile and the strategic planning context. The remainder of this section highlights areas for refinement. In the majority of cases my comments raise issues around the clarity of the policies rather than the direction or purpose of the Plan itself. The underpinning philosophy of the plan is clear. In some cases that philosophy does not precisely translate into the relevant policies. In other cases it does so in a very prescriptive fashion and which may reduce the longer term flexibility that the Plan will need.

Policy 1 – A Spatial Plan

This policy sets an appropriate plan context. It properly sets out to concentrate development within and adjacent to the principal settlements covered by the Plan. The policy makes a distinction between the type and scale of development that would be granted planning permission in the three principal settlements and in the settlement boundary as defined at Old London Road. Paragraphs 4.16 and 4.17 provide a useful explanation of the different approach adopted. However the policy requires a reasonably detailed explanation of very small scale infill development. Otherwise an examiner may want to delete this element due to uncertainty (and therefore conflict with the NPPF). Given the clarity and appropriateness of the thought process in paragraph 4.16 it would be best to amend this section of the policy to replace very small with infill development of up to 5 dwellings. There is a possibility that an independent examiner may also consider that a maximum of five dwellings is too prescriptive. However given the nature of the settlement pattern within this boundary the identification of a maximum figure of five appears generous rather than prescriptive.

The final paragraph of the policy identifies the concept of ‘green gaps’. These gaps are not immediately obvious on the policies maps and I cannot find any reference to green gaps in the keys on these maps. The supporting text does not address the matter directly. This clarity will be required by land owners and the local planning authority in particular, and other interested parties in general.

In a broader sense the following issues also need to be clarified on green gaps:

Why their identification/designation is necessary beyond national and local policies. The extent to which they overlap with identified Local Green Spaces (Policy 13). The extent to which Policy 13 would be insufficient to satisfy the spatial objective

otherwise promoted through green gaps.

Policy 2 – Site Allocations

In principle this is a robust and appropriate policy. It underpins the scale and direction of growth in the Plan. It is a key success area of the Plan – nine housing/mixed use sites are identified and which are anticipated to yield approximately 300 dwellings. This is entirely the positive approach the government had in mind in promoting the introduction of neighbourhood planning.

I make a few general comments as follows:


The letters (key to sites) are not easy to read on Inset maps 1-3. Sites B, E and F are particularly difficult to identify as a non-local person.

It would help if there was a link made between the sites as listed in the policy and their reference keys on the policies maps.

The scale of the maps does not readily identify the sites themselves. In some cases the sites are obvious (C/DG/). In others it is less obvious (see above). This is important given the significance of the SSWNP within the development plan framework and the engagement of developers and landowners. Ideally each site should have its own smaller scale plan clearly identifying its boundary.

There may be merit in combining the allocation of each site directly with its supporting text. By way of example the Robell Way site would be immediately followed by paragraphs 4.22 to 4.24. To maintain your policy structure you could then have policy 2/A, policy 2/B etc. That said the existing arrangements are perfectly satisfactory if either time or your own preference does not support this proposed approach. In this plan context however the nine sites result in a position where each element of supporting text is some distance away in the document from the policy itself. This makes navigation and understanding less than clear for the reader.

I set out below some detailed comments on each of the nine sites.

Robell Way

This appears to be a good housing allocation. The potential conflict with Policy CP11 of the Horsham Core Strategy is addressed in paragraph 4.23. The policy would read better if the description included details of its size/yield as currently set out in criterion b of the policy

The first criterion is too restrictive in practical terms. In particular it is not clear about the scale and nature of the employment development required. Its link to Policy 4 is also loose given that the basis of that policy is a general supporting policy for employment development. Whilst other employment policies in the SSWNP are site-specific there is no reference to them in the policy. In any event the current wording of the policy simply requires the granting of planning permission for alternative employment development rather than its implementation.

In all the circumstances I would recommend the deletion of this criterion and for two principal reasons. The first is that paragraph 4.22 has already come to a judgement about its lack of long term effective use as an employment site. The second is that there are sufficient new employment opportunities identified in the Plan to mitigate against the harm that would be caused to Policy CP11 of the Core Strategy. These two factors are linked together by the practical inability to link the development of this site (one of the largest of the proposed housing sites) to the development of any specific employment site. In any event the text in paragraph 4.23 demonstrates the thinking of the plan makers and provides indicative guidance to those preparing employment proposals in the plan area.

In criterion b (or its associated paragraph 4.23) it would be helpful to clarify the reasoning behind the view that the site is suited to smaller homes (and then what constitutes a smaller home). By definition the planning system cannot specify that new homes should be exclusively or mainly available for first time buyers. This may well prove to be the case as


sales of houses take place. However the houses on this or other sites may be purchased by a whole range of persons including older persons downsizing from larger houses. This aspect should be removed from the Plan.

I can understand the ambition set out in criterion d. However national policy is clear that new development should only be required to provide infrastructure based on the scale and nature of the scheme proposed. The criterion would read better as:

‘The scheme makes provision for an appropriately-sized area of public space and to include a multi-use games area.’

Paragraph 4.24 could then be amended to make reference to Horsham Council standards for open space and justify the local need for a multi-use games area

In criterion f there is little or no clarity on the long term ambitions for the amenity buffer. The first part of the criterion is appropriate (protection). The second part fail to provide clarity on the works that the developer would be required to undertake to ensure that it provides the effective amenity buffer sought.

I can again understand the ambition set out in criterion e. However there is no programme established for the development of the skate board park and I am uncertain on what basis planning permission would be refused for the development of this site if a contribution to a skate board park off site could not be achieved. I recommend that criterion e is deleted. In any event it is probable that a wider or more local application of CIL funding would underpin the implementation of the skate board park.

The Vineyard

This appears to be a positive housing allocation.

The description is specific about the development of primarily one/two bed starter houses. As with the Robell Way site a more detailed justification is required to give clarity to the Plan’s wider audience. Paragraph 4.25 almost certainly provides the answer/solution to this matter by making reference to the existing pattern of (residential) development. On this basis the detailed references to size of houses in the policy initial text could be removed and replaced with a third criterion to read

‘the scheme provides a proposal that complements the existing pattern of residential development off Old London Road and at a similar density’.

Old Ryecroft Allotments

Again this appears to be a good housing site

The same comments as the previous sites apply to this site on the size and scale of houses.

In criterion a the reference to Ryecroft Lane could be removed. It inappropriateness for access is adequately addressed in paragraph 4.26


Criterion c is entirely appropriate. However it would read better if its language overlapped with the Planning (Listed Buildings and Conservation Areas) Act 1990 as follows:

‘The scheme design will preserve or enhance the Storrington Conservation Area’

Amberley Rd

The same comments apply to house sizes. In this case further clarity would be helpful on the breakdown between 3 and 4 bedroom houses and the proportion of other dwellings. On the latter point it would be best to refer to the other houses as smaller houses 9that is less than 3 or 4 bedroom) rather than starter/low costs for reasons set out in the Robell Way section above

In criterion a the reference to Bax Close should be removed. It inappropriateness for access should then be addressed in paragraph 4.27

In criterion b the reference to the designation of the proposed open spaces as Local Green Space is best set out in supporting text rather than in the policy itself.

As currently drafted paragraph 4.27 reads somewhat negatively. Rather than set out the evolution of the site’s development since the recent refusal of planning permission it should set out the basis on which future proposals would achieve planning permission. By definition this is simply a change of emphasis in wording.

Criterion c needs to be stronger than merely requiring the scheme to ‘have regard’ to the national park designation. I recommend that the Plan is more prescriptive and that this criterion is redrafted to read:

‘The scheme design will sustain or enhance….’

Chantry Lane

Again this appears to be a sound allocation (in this case a combined residential/employment scheme).

Criteria a to d set out the proposed delivery/design of the scheme. Its logic is reasonable and by definition would generate sustainable development. However it is likely that its details will be scrutinised by an independent examiner for the following reasons:

If the existing site is poorly located and poorly accessed for employment uses why is the site being promoted for an element of employment uses in the plan period?

This is emphasised by the site not been identified as a key employment site in the development plan

The justification underpinning the housing element being restricted to 50% of the site. The restrictions proposed on the occupation of the housing part of the site and its

implications on viability and delivery (criterion d) The specific reference to start up business uses in criterion c

Paragraphs 4.29/4.30 do not directly address these points. In particular they do not address the general mix of uses on the wider site and the justification for preventing the full implementation/occupation of the housing part of the site before the completion of the adjoining employment scheme. Paragraph 4.30 recognises that the residential element of


the proposal is likely to be a key element of enabling development. However as drafted the policy may undermine the effectiveness of an emerging or future package

On this basis I recommend that the policy is amended as follows:

Remove criterion b. Address the ambitions for the scale of housing development and the size of houses in the supporting text

Remove the final part of criterion c and replace with ‘….and will comprise a mix of unit sizes in business (B1) use’. This will not prevent start up uses being proposed.

Remove criterion d. Address the ambitions for the relationship between housing and employment development in the supporting text. The supporting text could make specific reference to the need for a detailed section 106 agreement to be negotiated to address this issue at the time of the determination of the initial comprehensive planning application (and as supported by an overarching master plan).

As drafted the final criterion is probably too specific. It could be explained better in the supporting text. On this basis it could then be replaced with a new and shorter criterion as follows:

‘The scheme makes appropriate provision to mitigate its own off site traffic movements and those traffic movements in combination with those generated by the development of Chantry Mill Quarry’

Old Mill Drive

The earlier comments on house sizes on other sites apply equally to this policy.

The supporting text in paragraph 4.32 is very clear about the intention for retaining and safeguarding commercial uses in the vicinity. The policy is far less clear. This could be addressed by including a criterion to this effect.

Old Post Office

This policy reads well. I recommend that criterion b is amended along the lines I have suggested for the Old Ryecroft allotments site to use the terminology in the legislation.

Ravenscroft

Again this housing allocation appears to be sound. Its implementation is assisted as it is linked to the proposed development of allotments on the adjoining site (and as set out in Policy 11).It is on this basis that the restrictive nature of criterion a is acceptable in this case.

The comments on house sizes made elsewhere apply to criterion b in this policy. I assume that the intention is that this site yields similar affordable houses to those recently developed off Ravenscroft (4.34). If this is the case the policy should say so and the text set out the reasoning behind that policy approach.


Criterion d raises two separate issues – satisfactory access and residential amenity. For clarity these should be split into two separate criteria.

Lucking’s Yard

This policy appears to be well-developed. It refers to a mix of residential and employment uses, although neither the policy nor the text at 4.35 sets out what is expected. You may wish to introduce an enhanced degree of clarity into this policy. As currently drafted it reads very differently to the Chantry Lane site (either as currently drafted or as I have recommended it to be amended).

Policy 3 – Managing Housing Supply

It is recognised that the local community wishes to see a phased and balanced release of housing land through the Plan period. Similarly it is acknowledged that the policy refers both to the grant of planning permission and the delivery of those permissions. I can see that it is attempting to apply the guidance as set out in paragraph 47 of the NPPF to the SSWNP. Nevertheless its approach is almost certainly too prescriptive for the relatively limited yield of housing proposed in the plan area (as opposed to the wider District).

Part of its thinking is set out in paragraph 4.39. Whilst the community has particular expectations on development being achieved in a balanced way throughout the plan period there is a real risk either that the policy as currently drafted will not work or that it might otherwise restrict the supply of new housing to the market. Key issues that arise include:

Which sites would come forward earlier and later in the plan period? Are there sites that for policy reasons should come forward earlier than others? How will the market be affected by the delivery of specific house sizes? The impact or otherwise of phasing requirements on sites such as Chantry Lane on

the supply of housing land and the implementation of this policy.

The Plan as drafted is silent on all these matters. On this basis I recommend that the policy is deleted. If there is a wish to retain such a policy I suggest that it should address the implications of the points above.

Policy 4 – Employment Uses

This is a well-developed general policy. It will assist in the wider promotion of sustainable development.

I am uncertain of the practical value of the third criterion. In any event it reference is to a likely increase in number/quality. I recommend its deletion

In paragraph 4.43 there is particular reference to Rock Business Park. Whilst I do not disagree with the comments I suggest that the first part of the paragraph is removed as it adds no value to the policy itself.


Policy 5 - Storrington Village Centre

This is the type of policy that an examiner would expect to see in a plan for this type of neighbourhood plan area. The primary retail area should ideally be shown on the relevant SSWNP policies map for clarity. Otherwise an interested party will need to refer to another document for that clarity. It may also be helpful to make cross reference to Use Classes Order for the acceptable uses as defined

In effect the policy is about ‘retention’. It would be better if the policy was recast to indicate what will achieve permission and what will not do so. This will be more helpful to property owners and for development management officers

The second element of the policy appears to change the geographic focus from the ‘primary retail area’ to ‘land in or adjoining the village centre’. This is acceptable, but for clarity may best be expressed as two separate policies. The second element of the policy appears to conflict with rather than add value to the initial (and principal) part of the policy. The definition of ‘a viable area of land or premises in a village centre use’ is also unclear. The explanatory text at 4.46 does not give full clarity to the intentions, although it suggests that residential uses will be supported where they enable the retention of retail and commercial uses. However it is not clear whether residential uses are supported in order to generate additional trade for the units or as part of comprehensive development packages and which would retain/consolidate/extend policy compliant retail uses.

As such the policy needs to be redrafted to provide clarity. By way of example the second half could be redrafted to say:

‘Planning permission will be granted for housing proposals within the village centre subject to the following criteria:

The scale, density, massing, layout and materials of the proposals reflect the architectural and historic character of the village centre and otherwise conform to Policy 12 of the Plan and to the principles as set out in the Parish Design Statement; and

The proposals accord with Policy 16 of this Plan; and

The proposals do not result in the loss of retail, service, office or leisure uses in the primary retail area as defined in Policy 5 of this Plan. ‘

Policy 6 - Washington Village Centre

This is entirely appropriate. However its heading should best be changed to new retail uses in Washington Village Centre

Paras 4.48 to 4.50 make specific reference to the community’s wish to see a new convenience shop. This is entirely appropriate. However as the policy acknowledges all retail uses fall within Use Class A1. As such this policy would support the granting of planning permission for any kind of retail unit and which may not provide the use as anticipated. Also


there would be nothing to prevent a village shop being granted planning permission and opening and then for commercial or other reasons that use becoming a more specific use (e.g. a shoe shop/gift shop/fashion retailer)

The policy also refers to a singular shop. You may wish to reflect if there would be any harm created if the policy was re-worded to refer to shops in the plural?

Policy 7 - Tourism Development

There are three separate and distinct elements to this policy. In my view they should sit as three separate policies. I offer the following specific comments on the three separate components

Chantry Mill Quarry

I assume that the criteria are designed to be inclusive criteria. If so and should be included after each criteria to indicate that all need to be met.

In criterion 3 too much detail is provided. The policy requirement is for a master plan. The expectations for its content could sit in explanatory text.

Criterion 5 needs tidying. It is not clear what is expected of a developer (avoidance or mitigation or compensation).

Criterion 6 overlaps with my comments on the earlier related housing/employment site. In this instance the drafting is even more complicated.

Criterion 7 is unhelpful to any proposed investor. In effect this decision is the balancing act that Horsham Council would undertake at planning application stage. I recommend that the criterion is deleted.

Sandgate Country Park

The first sentence of the policy is in effect a supporting statement to a wider proposal. The second sentence promotes tourism and recreational facilities in the park once established. There would be merit in expanding paragraph 4.53 to explain the long term nature of this proposal and the need to work with the County Council and the site operator. It would also be useful to provide a brief overlap with any restoration obligations that already apply on the site in the supporting text.

In criterion 8 (as drafted) I recommend that ‘comprise’ is replaced with ‘incorporate’.

Bed and Breakfast/hotel

This policy reads well. In criterion 11 I recommend that ‘sufficient’ is replaced with ‘appropriate. In criterion 12 I recommend that the wording is strengthened to read ‘Does not detract from the amenities of any adjoining residential properties’.

Policy 8 - Broadband

Different examiners handle this issue in different ways. Some suggest its inclusion in a non-land use section at the end of the Plan. In your case you have directly linked it to development (of the installations). As such it sits comfortably within the Plan itself. There


would be merit in clarifying in paragraph 4.56 that many elements of broadband/telecommunications installations are permitted development. This would underpin your comments around installations that require planning consent.

Policy 9 – Education Uses

This policy is acceptable in principle. However you may wish to identify criteria to underpin the policy. Otherwise as currently drafted it would be difficult to resist insensitive proposals from the public, public/private or private sector.

Policy 10 – Community and Medical Facilities

In effect there are two separate policies in the wording as drafted. I suggest that they are separated into two separate policies.

The first element would benefit from criteria for the reasons as set out earlier for policy 9.

The second element reads as a statement of support rather than a policy. It would be helpful if the supporting text clarified what would need planning permission and what would not. Thereafter the policy could be reworded to read

‘Planning permission will be granted for the development of a skate park facility at SRG subject to the following criteria….’

Policy 11- Allotments

This is a sound and appropriate policy that overlaps with earlier elements of the Plan. I recommend that the second criterion is deleted - by definition this aspect has already been addressed in the allocation of the site for allotment purposes in the Plan.

Policy 12 - Design

This policy reads well and underpins the expectations for future development. The policy includes appropriate references to other adopted policy statements. Paragraph 4.66 makes reference to potential future supplementary planning guidance work. In doing so it could usefully indicate that references to such documents would then be incorporated into any review of the SSWNP.

Policy 13 – Green Infrastructure

This is an appropriate policy

Criterion 1 is a combination of policy and supporting text. As drafted the second criterion is too vague. The third criterion is also mix of policy and text

Policy 14 – Local Green Spaces

This policy reads well and is well-supported by the policy maps.


Policy 15 – Air Quality

This policy is understandable given the issues that exist in Storrington. This is helpfully set out in paragraphs 4.73 and 4.74. The first part of the policy reads well. As drafted the second part of the policy appears to be internally inconsistent with the first part. The casual reader would not expect the second part of the policy having read the first part, and there is no indication of the trigger points for the operation of the second part of the policy. Paragraph 4.75 helps in this matter by referring to the scale of proposals

I recommend that the second part of the policy is amended to read:

Any development proposals that are otherwise acceptable and which would however result in an adverse impact …..’

Policy 16 – Traffic & Transport

As paragraph 4.78 identifies this policy serves a number of purposes. For clarity I recommend that it is sub-divided into two parts – the first part concentrating on broader traffic measures (paragraphs 1 and 2 of the draft policy) and the second addressing car parking issues (paragraphs 3/4/5 of the draft policy)

I recommend that the second paragraph of the policy (as currently drafted) is amended to read:

‘Where appropriate development proposals will be required to contribute towards:

Existing criterion 2 Existing criterion 3’

I am not convinced that criterion 1 should be retained. Firstly its intention is unclear and the proposed measures are not defined. Secondly it is not the direct responsibility of new development to alleviate pre-existing traffic issues within their vicinity.

On the fifth paragraph of the policy I recommend that the policy wording ends in ‘provision’ on the second line. The deleted text can be moved into supporting text.

Sustainability Appraisal/ Strategic Environmental Assessment (SA/SEA)

The Plan is accompanied by a comprehensive SA/SEA.

This is an important document as part of the wider future examination of the Plan. In particular an examiner cannot modify a flawed SA/SEA.

Key areas on which the examiner will focus will be consideration of the scale of environmental effects, the assessment of alternatives and whether the plan itself has been directly informed and underpinned by the SA/SEA.


The situation is unusual to the extent that a detailed critique (by AECOM) of an earlier version of the SEA was commissioned by the South Downs National Park Authority. That critique was attached to its comments of March 2015. Depending on the depth to which the independent examiner looks at the detailed evolution of the Plan he or she may wish to compare the eventual submitted plan and its SA/SEA to the comments made by AECOM. This matter is particularly significant given that the SDNPA is an independent and statutory body and that AECOM is a well-respected organisation in this specialist area.

Plainly this scenario would be unlikely to arise if SDNPA was content that the appropriate remedies had been put in place and that it raised no comments/objection to either to the revised pre-submission plan and/or to the submitted plan.

I have carried out a very high level review of the January and April 2015 documents and the AECOM comments on the former. It is clear that the April 2015 SA/SEA is more detailed than the earlier document and has addressed some of the AECOM comments. This point is clarified in paragraph 1.6 of the April document. It is also clear that a decision has been taken not to take in account some of the comments made and for a variety of reasons (mainly proportionality/assessment of the environmental effects of the Plan policies and the testing of reasonable alternatives). From my reading of the documents the key areas of difference centre on the significance of the environmental characteristics of the Plan area (Section 5), the likely significant effects of the policies (Section 7) and the way in which various options and alternatives have been assessed (Section 7). I will comment further on this matter once I have had an opportunity to read any further comments from SDNPA/AECOM.

The Sites Assessment Report

This report has been produced to demonstrate how the relative merits of a range of potential housing sites were considered by the Steering Group.

It sets out a well-developed and structured approach to the assessment of the range of potential sites. By definition it underpins policies 1 and 2 of the pre-submission SSWNP. It is clear to the lay reader why the sites in the Plan have been chosen and why others have not been included in the Plan. It is very helpful to an examiner to find this level of detail in an emerging neighbourhood plan. This level of detail is not normally made available in other such plans.

The second page of the report usefully identifies the overlap with the SA/SEA. However the relationship between this document and the SA/SEA could usefully be highlighted to a greater extent in both documents. The analysis of the potential sites in the Site Assessment Report could usefully inform any on-going debate that may be necessary in the assessment of various alternative options in Section 7 of the SA/SEA

The Policies Maps

The size of the Plan area makes the preparation of Policies Maps particularly challenging. In general the Plan has tackled this aspect very well. However the arrangements would be improved by incorporating the following comments:

Providing a key to the overarching map on page 43 (and a link back to Plan A on p.6)


Providing clarity of the overlap between Map inset 1 and 2. No overlap is shown on p43 but there is clear overlap on both inset maps.

Producing each inset map to a smaller scale to add greater clarity and identification. This overlaps with my general comments on Policy 2.


Recommendations

As key outcomes of the health check process I would recommend that the following matters are considered and incorporated as appropriate into the Plan:

1. The various comments in this health check in relation to Policies 1-15; and

2. The early resolution of any outstanding professional differences on the SA/SEA.

Andrew Ashcroft

15 June 2015


Recommendations

As key outcomes of the health check process I would recommend that the following matters are considered and incorporated as appropriate into the Plan:

1. The various comments in this health check in relation to Policies 1-15; and

2. The early resolution of any outstanding professional differences on the SA/SEA.

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