Policy WC4 Ancillary Development on Employment Land

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Consultation Draft (February 2017)

Representation ID: 6312

Received: 07/04/2017

Respondent: Mount St. Mary's College

Representation Summary:

Policy WC4:
The requirement that "any proposal (to be determined under this policy) will need to accord with other policies in this Plan is unrealistic and unnecessary as it's purpose is allow for an exception to other restrictive policies.

Full text:

Local Development Plan Current Consultation - February to April 2017

Mount St Mary's College's Objectives & Priorities
My name is Nicholas Cuddihy and today I write to you in my capacity as the CEO of the Mount Trust; a charitable trust established in 2006 to manage the property, resources and aspirations of Mount St Mary's College, Spinkhill and its prep School at Barlborough Hall.

The story of our schools dates back to 1620 when the Jesuits first became active in this park of the UK. In 1842 the Jesuit Provincial established Mount St Mary's College in Spinkhill. The school at Barlborough Hall first opened in 1939. The Mount Trust as we know it today was set up as a Local Trust in 2006 to manage Mount St Mary's College and Barlborough Hall School as co-educational inclusive day and boarding schools in the Jesuit tradition, providing children and their families with access to a seamless education from the ages of 3 to 18 yrs. We have long been significant members of the community in Spinkhill.

Our lands and facilities are shared openly and are enjoyed by many in the village and others all year round. Locals and visitors walk our lands freely and access the footpaths and bridleways at their leisure. Our Memorial Chapel frequently hosts concerts and special religious and other ceremonies. We have long established and successful partnerships with many sports clubs and other local groups who enjoy our sports fields, our public gym and other facilities. Every day and every week athletes, footballers, walkers and others come and go and enjoy our beautiful site. We see ourselves as residents of Spinkhill village and we take our responsibilities seriously in this regard. You can understand therefore how we were surprised to note that our school is not located within the settlement boundary in the proposed Local Development Plan. I will address this concern in more detail later but for now I wish to highlight this concern as I set out the context within which we wish to comment on elements of the draft Local development Plan.

During this year, 2017, we will celebrate the 175th Anniversary of the foundation of our schools. As we celebrate we are also concentrating our efforts on planning for our future. Our schools and lands are obviously hugely expensive to manage and maintain. Our heritage buildings and more modern facilities require ongoing investment. We have been a major employer in the area for more than a century and a half. We currently employ more than 170 people and as we look to the future we know we have to fight hard to survive and to thrive.

The Trust has ambitious plans for the College focusing on making improvements to its facilities and improve the extent and quality of facilities it provides to the public and local community. We are keenly aware that a significant and extended increase in income will be required to secure the long term stability of the school. As we master plan for the long term future of our schools we know we will need to devote significant funds to the maintenance and development of our buildings and lands. It is in this context that we welcome the opportunity to comment on the Draft Local Plan in this current consultation.

1. Green Belt Policies
Having reviewed the draft Plan's evidence base related to housing and growth we are pleased to see that part of the College's previously developed land has been included within the Housing Sites Assessment Report dated February 2017 (Appendix C), as 'Land off Station Road, Spinkhill'. That acknowledges the site as an 'infill site'

Nevertheless, having reviewed the draft Plan's policies map we also note that the entirety of the College's lands within the Spinkhill area is identified as Green Belt. From our understanding of national planning policy (within the National Planning Policy Framework (NPPF)), local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access, sport and recreation amongst other things (para.81). Brownfield land should be acknowledged within the Green Belt, reflecting the exceptions test within the (paragraph 89). The current Local Plan identifies the College as a major developed site within the Green Belt and we feel that such major developed sites are dealt with by Policy GS3.

We wish to therefore object to the draft Local Plan's Green Belt Policy (Policy SS9) and the plan more widely as it fails, in our opinion, to identify the developed parts of the College as previously developed or Brownfield land in the Green Belt. Neither does it enable positive planning promoted by para.81 of the NPPF.

2. Spinkhill Settlement Boundary
We would also like to take this opportunity as referred to earlier to raise our concerns regarding the Council's proposed settlement boundary for Spinkhill Village. The policies maps show that the College is not included within the settlement. We have reviewed the definition of a 'settlement' included in the glossary of the draft plan glossary and believe that the College should be included as part of the Spinkhill Settlement based on that definition. It has always been part of the village and has never been physically separate. For more than a century and a half we have played an important part in local life with leisure and recreation facilities available to the village. The village school was housed on our lands prior to its recent relocation across the road. The old Spinkhill railway station was also located on our land and accessed freely by all until it closed and the allotments which are enjoyed today by many villagers also lie on our land.

3. Housing
I note that the Council's most recent Annual Monitoring Report (AMR) (2015/16) identifies how between 2011 and 2015 the number of completions in the district has been below the Council's 300 dwellings per annum target each year. Between 2011 and 2016 the AMR notes a net undersupply of -484 dwellings for the period, and when the council includes projected completions for 2016/2017 this position worsens to-583 dwellings.

Policy SS2 states that the draft plan will make sufficient land available to accommodate a minimum of 6,600 dwellings during the Plan period (2011-2033). This figure equates to 300 dwellings per annum over the plan period and we understand that this is informed by the draft plan's 2013 Strategic Housing Market Area (SHMA) Assessment.

We note that the Council acknowledges that its approach to housing is to be reviewed and given that its Green Belt Review has established that land needs to be removed from the Green Belt, we propose that the College, as previously developed land in the Green Belt should be reconsidered to accommodate some housing capacity.

In conclusion and speaking more broadly we want to explore how we may be able to work together to succeed together. We would welcome an opportunity to engage with the Council proactively to see how specific education related policies could be included in the draft plan. This is particularly important to us as we look to the future. As we reach 175 years we are conscious of our need to develop and invest so that we can improve the educational and wider public facilities we own and provide to others. We have been a major employer and an important part of the life in Spinkhill for a long time. We want to preserve and develop that for today and for the future.

Additional Comments:

Policy SS£ & SS13:
Smaller settlements classified as "level 3" settlements in Table 4.1 can and should make a significant contribution to housing provision and this can help sustain community facilities. Limiting development in such villages to "limited infilling of one or two dwellings" is too restrictive.
In Spinkhill the land shown on the attached plan as Allotment area could make a significant contribution to housing need and the funds released by this development could help improve facilities at the Mount St Mary's College.

Policy SS9:
This policy only refers to dwellings for agriculture and forestry It should allow for "other occupational dwellings in the countryside"
The Green Belt is too tightly drawn around Spinkhill (see our comment on Appendix B - Green Belt Maps).

Policy LC3:
The limitations in this policy are too restrictive. Smarter homes and homes to provide employee accommodation, linked to established rural based employers should qualify as "affordable housing."

Policy LC7:
Although this policy is intended to include for "other occupational dwellings in the countryside" there is no such provision in the text. The policy only refers to dwellings for agriculture and forestry. This is a serious omission and requires correction. Mount St Mary's College is a rural based employer which will require employee's dwellings to be allowed for in this policy. In its present form this policy is inconsistent with Policy SS14 (b).

Policy SDC1:
This policy is too restrictive in that it only refers to buildings. It should refer to previously developed land. In its present form it is inconsistent with Policy SS14 (a) which refers to development being allowed on "vacant derelict or previously developed land." and SS9 (f).

Policy WC4:
The requirement that "any proposal (to be determined under this policy) will need to accord with other policies in this Plan is unrealistic and unnecessary as it's purpose is allow for an exception to other restrictive policies.

Policies Maps
We have the following comments on the Policies Maps.

The absence of a Map covering the whole of the District leaves a policy vacuum in regard to some areas as certain areas do not fall within any of the maps. This is the case in regard to Spinkhill only part of which is covered on the Renishaw Policies Map.

We attached a map of Spinkhill and request the following:-

- Area shown as Allotment area (on the attached plan) should be within the settlement limits and removed from the Green Belt. This wold allow for development of the land for housing and provide funding for improvement to the facilities at Mount St Mary's College.

- The area at Spinkhill identified as "GS3" in the existing Local Plan, comprising the building complex at Mount St Mary's College, should be within the settlement limits and removed from the Green Belt. It is clearly part of the settlement. This was previously shown as "major development in the Green Belt" which is illogical.