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									Cabinet 29.06.04

APPENDIX 1

ROCHESTER RIVERSIDE DRAFT DEVELOPMENT BRIEF

COMMENTS RECEIVED AND RECOMMENDED RESPONSES


NAME                         COMMENT                                    PROPOSED RESPONSE AND/OR
                                                                        AMENDMENT
Environment Agency           Any development proposals will need        Add levels to current comment on page
                             to incorporate the construction of a       27 that states, “development proposals
                             new flood defence and the raising of       will need to address flood risk issues in
                             ground levels to 5.8m AOD. New             line with Environment Agency advice
                             residential development is to have a       and guidance.”
                             property threshold level of at least
                             600mm above the 1:200 year flood           All development proposals will need to
                             level. This corresponds at this            agree and respond to flood risk issues.
                             development to a finished floor level of
                             6.1m AOD.
                             Term „river wall‟ to be replaced by        Replace term throughout the
                             „flood defence‟.                           document.
                             Unobstructed vehicular access              This is already stated on page 27 as
                             adjacent to the flood defences is          follows: “once construction of a new
                             required in the design to enable any       river wall is complete it will require
                             maintenance and/or improvement             ongoing maintenance. Vehicular
                             works to be carried out.                   access for maintenance will need to be
                                                                        discussed and agreed with the
                                                                        Environment Agency.”
Sensitive, improved interface between       Add comment to design principles
the development on the land and the         section as follows: “development
river.                                      should provide an improved interface
                                            to the river edge of the site and be
                                            sensitive to ecological issues.” This is
                                            already considered in the site
                                            constraints section.
More weight to be given to the              On page 32 add the following point:
biodiversity aspects of the site.           “an environment which protects and
                                            preserves the important and unique
                                            habitat features of the intertidal area.”
The intertidal mud in front of the          An Environmental Statement is needed
existing defence and within the tidal       for development proposals. This will
creeks must not be adversely affected       assess the impact of scheme on
by the proposals. Intertidal mud is         intertidal habitats. The development
listed as a priority habitat under the UK   brief seeks to not adversely effect
Biodiversity Action Plan (BAP) and          intertidal habitats.
Kent BAP. One of the main objectives
set out in the Kent BAP is “to maintain
the area of intertidal mud ensuring no
net loss, except to natural processes.”
Contamination issues are to be fully        The brief already states that
addressed at the site providing             remediation measures will be
adequate investigation is undertaken        necessary before development can
and remediation objectives and              proceed. Expand on this point and
strategies are agreed with the EA at        make reference to the fact that
the appropriate time, and under the         measures will have to be
planning conditions imposed on any          agreed/consulted with the Environment
development.                                Agency.
Water Quality - The development brief     Comment to be added as follows:
does not outline proposals for foul       “proposals must include all the
effluent disposal or surface water        pollution prevention measures which
disposal from the temporary or            are being considered to protect
permanent structures.                     controlled waters (this includes
                                          watercourses and into/on to land) from
                                          contamination. Under the Water
                                          Resources Act 1991, Schedule 10
                                          there must be no discharge of sewage
                                          effluent or surface water (site drainage)
                                          to controlled waters without first
                                          obtaining the EA‟s written permission.”
The EA expects an ongoing, proactive      Comment to be added to sustainability
approach to the efficient use of water    section. Proposals should ensure best
throughout the lifetime of this           practice with regard to the use of water
development.                              throughout the lifetime of development.
Encourage the provision of a              The development brief states that a
continuous river walk/cycleway plus       riverside walk and cycleway should run
access provision for water recreational   the full length of the site and that this
users.                                    should be designed in collaboration
                                          with the Environment Agency. The
                                          brief also proposes a new marina.
                                          Comment should be added that
                                          proposes that moorings for recreational
                                          use of the river will be encouraged and
                                          explored with the relevant authorities.
Buildings should not impinge or           Principle to be added to access and
compromise the width and continuous       movement section and open space
effect of the walkway. Disabled           section that requires development,
requirements should be incorporated       open spaces and routes to accord with
into any designs.                         disabled standards.
Southern Water    There are a number of water mains           The following comment to be added to
                  and sewers within and adjacent to the       site constraints section: “there are a
                  development areas. These must be            number of water mains and sewers
                  protected or diverted; the details will     within and adjacent to the development
                  need to be considered once a detailed       areas. These must be protected or
                  layout becomes available.                   diverted, the details will need to be
                                                              considered once a detailed layout
                                                              becomes available.”
                  Substantial off site sewers and water       Include reference to this in site
                  mains are required to provide               constraints and
                  adequate capacity for foul sewage           phasing/implementation.
                  flows and water supply respectively.
                  Any development proposals should
                  include for phased provision of
                  infrastructure to serve developments
Highways Agency   Major engineering work will be required     These will be considered in the
                  to raise, stabilise and decontaminate       Transport Assessment (TA) that will
                  the site. The development brief should      accompany planning application(s) for
                  give an indication of the likely off-site   the site. A comment will be added in
                  highway improvements since the              section 7 of the brief where there is
                  additional cost of providing these          discussion of planning obligations.
                  essential works may affect the ability of   Also, section 6.6 as part of the
                  the development to fund other               principle “consideration of impacts”.
                  infrastructure identified in the
                  development brief.
                  The need for off-site highway works is      Same as above.
                  to be considered at the masterplanning
                  stage rather than left to the formal
                  planning application(s).
                          The Highways Agency wish to be            This will be considered in TA. Also,
                          assured that the development would        state that the Highways Agency should
                          not have a significant impact on the      be given the opportunity to consider
                          A2/M2/A289 junction (in line with         the transport assessment at an early
                          Circular 04/2001).                        stage in the design of proposals.
                          Para 4.2 needs a reference to the         Reference to Regional Transport
                          emerging Regional Transport Strategy      Strategy to be added. Detailed
                          and section 6.6 needs to be               proposals will be assessed against this
                          considered against the policies           in the Transport Assessment.
                          contained in that strategy.
Medway Youth Parliament   We are keen to see that industry is not   The development brief is in
                          removed from the area, and if these       accordance with adopted local plan
                          proposals were approved, we would         policy. The Environmental Statement
                          wish to see that it doesn‟t mean the      (ES) will consider the impact of
                          end to an already struggling local        removing existing industry.
                          shipbuilding industry.
                          Concern about the viability of being      SEEDA has been in detailed
                          able to move the gasometers.              discussions about the removal of the
                                                                    gas holders with Transco. The
                                                                    procedure for removal of gasholders is
                                                                    well established. The forthcoming ES
                                                                    will assess the impact of removing the
                                                                    gasholders.
                          We wish to see appropriately sized        Section 6.1 states that proposals will
                          accommodation instead of cramming         include the offer of many types of
                          too many houses on the area, causing      tenure, including affordable housing.
                          an inappropriate population density on    Proposed density is in accordance with
                          the site.                                 government policy guidance.
The history and surrounding area        Future design codes for the site will
should be considered in the housing     consider this in detail. In general the
design, and should befit the periodic   development brief aims to encourage
and historic vicinity.                  development that responds to the
                                        historic context of its location. The aim
                                        is to create a development will embody
                                        the strengths of historic Rochester and
                                        create a physical environment that is of
                                        the highest quality and admired by all.
The site access is insufficient.        At present the site is effectively
                                        separated from the city centre.
                                        Proposed development principles seek
                                        to rectify this and create good access
                                        to historic Rochester. In particular
                                        there will be strong and attractive
                                        pedestrian connections between
                                        Rochester Riverside and historic
                                        Rochester. A comprehensive
                                        masterplan for the site will consider
                                        measures to improve pedestrian
                                        connections across Corporation Street.
                                        The sufficiency of access points will
                                        also be dealt with in a forthcoming
                                        Transport Assessment.
Impact on secondary school education    Developer contributions will be sought
in the vicinity.                        towards improvements to secondary
                                        schools in the area that are required
                                        because of additional students as a
                                        consequence of the development
Kent Police                     Need for developers to have                 Add reference to this document in
                                awareness and adopt practices as            section 6.8 and planning policy context
                                outlined in the recently published          section.
                                document “Safer Places”. Reference
                                needs to be added with regard to the
                                forthcoming PPS1.
                                Reference to Section 17 of the Crime        Add reference to section 6.8.
                                and Disorder Act 1998. This requires
                                all local authorities to exercise their
                                functions with due regard to their likely
                                effect on crime and disorder. This
                                should be reflected in relation to future
                                proposals for Rochester Riverside.
                                Detailed TA to be undertaken in order       This will be considered in forthcoming
                                to ensure that present and proposed         TA for the site proposals.
                                road network and infrastructure will be
                                able to cater for projected increased
                                volumes of traffic should development
                                capacity be reached.
                                Adequate youth facilities.                  Add a comment regarding the
                                                                            encouragement of youth facilities and
                                                                            that detailed proposals will look
                                                                            carefully at the provision of youth
                                                                            facilities in consultation with the local
                                                                            community.
The City of Rochester Society   Nothing should be done that impairs         Proposed retail development will need
                                the status of the city centre as a local    to be in accordance with adopted local
                                shopping centre and tourist centre.         plan retail policy.
No reduction in car parking facilities.    The development brief states that the
                                           amount of public car parking presently
                                           available should remain and be well
                                           integrated in to future development
                                           proposals for the site.
There should be a comparable coach         A further principle is to be added to
park and facilities available before the   section 6.6 with regard to the coach
existing award winning facility is         park and text on page 37 amended to
demolished.                                emphasise the importance of the
                                           coach parking facility. A principle
                                           should be added along the lines of the
                                           following: “a coach park offering
                                           sufficient spaces for normal demand
                                           and equivalent facilities of the highest
                                           design quality.”
Blue Boar Lane car park is too small to    This issue will be addressed at the
house the relocated market. Where          detailed design stage.
will trader‟s vehicles be parked?
Pedestrian and vehicular accesses to       Vehicle access will be assessed in the
the site are inadequate. Is there          TA. The bridges are adequate for the
sufficient headroom under bridges?         type of traffic likely to be generated by
                                           the development. Opportunities to
                                           widen or heighten these will be
                                           investigated.
Will the river walk be open to both        The riverside walk will incorporate a
pedestrians and cyclists?                  cycleway. The riverside walk will be
                                           designed to safely accommodate the
                                           cycleway.
Further study for Corporation Street     This work is important to the
should happen now.                      integration of the new development
                                        with Rochester High Street; it is a
                                        medium-term priority.
A bridge link over Corporation Street   The viability and appropriateness of
should be considered.                   this will be considered at a later stage
                                        in the project.
It is vital that access across          The need to improve access across
Corporation Street is improved.         Corporation Street is clearly stated in
                                        the development brief. The brief states
                                        the following: “pedestrian activity to be
                                        encouraged through the provision of
                                        strong, direct and safe pedestrian
                                        connections between Rochester
                                        Riverside and Rochester City Centre,
                                        active uses, landscaping and public
                                        art. A detailed masterplan of the site
                                        should propose measures to improve
                                        pedestrian connections across
                                        Corporation Street.” [The indicative
                                        masterplan shows this in principle but
                                        more detailed work is required].
Siting of the new marina appears        A study is currently underway
impractical due to river conditions.    considering the viability of the marina
                                        locations. The new marina will be
                                        designed in collaboration with Medway
                                        Ports.
How do you expect to have two hotels       Consultant market advice has been fed
when the area has always struggled to      into the production of the development
attract a prestige hotel development?      brief. The brief states that successful
                                           implementation of the proposals
                                           require a phasing programme to be
                                           agreed with Medway Council. At
                                           present it is proposed that the 4 star
                                           hotel and conference centre be
                                           delivered towards the end of the
                                           phasing programme. Proposals will be
                                           able to respond to changing market
                                           conditions.

                                           Medway Council is keen to promote
                                           Rochester as a tourism destination.
                                           The development brief seeks to take
                                           forward this aspiration.
Convenience store would be better          The development brief proposes local
located near the school.                   retail facilities, including a small
                                           foodstore, that meet the daily needs of
                                           residents, workers and visitors. The
                                           indicative masterplan shows these
                                           facilities close to the Gas House Road
                                           junction where a large number of
                                           residents will pass by daily. However
                                           the site will be kept under review as
                                           the development proceeds.
Community facilities, business and         In general the proposals seek to
retail uses are spread through the site.   concentrate a mixture of uses in
                                           clusters rather than spreading them
                                           throughout the site.
Locate facilities close to railway       A mixture of uses is located close to
station.                                 the railway station.
The historical significance should be    The development brief highlights the
emphasised – the display of the city     areas of historical significance (city
wall and northern bastion should         wall and northern bastion) and
feature more strongly.                   recognises that further assessment is
                                         required. Historical features will be a
                                         key part of the design of a future
                                         masterplan. A clear message
                                         throughout the brief is that
                                         development should be of the highest
                                         quality and respect its historic context.
                                         In particular development must respect
                                         and not infringe upon important views
                                         of the castle and cathedral.
The land also includes the site of the   This proposal has merit and should be
former St Clements Church in             looked into further. At present the
Horsewash Lane – “St Clements”           names of character areas are only
would make a suitable name for the       indicative. Developers often want to
area and have historic significance.     name the sites they are building.
Consideration for appropriate            A principle should be added that
landscaping and treatment to be          proposes appropriate landscaping and
considered for existing uses.            treatment to be put in place that acts
                                         as a buffer between new and existing
                                         development.
Colin S Johnston, 14 Conyers Walk   Close collaboration with existing          Rochester Riverside has an extensive
                                    businesses should be sought in             history of stakeholder involvement. As
                                    relation to any development proposals      part of the development brief
                                    for the site.                              consultation there has been a
                                                                               stakeholder workshop evening and
                                                                               public exhibition. Regular liaison
                                                                               meetings take place with the
                                                                               „remaining businesses‟. There will be
                                                                               ongoing consultation with stakeholders
                                                                               as both outline and detailed proposals
                                                                               are put forward.
                                    Proposals are against Medway Council       Rochester Riverside is a flagship
                                    economic development policy for            regeneration site for mixed-use
                                    “attraction, after-care and retention of   residential development. The site is
                                    businesses”.                               highlighted as a significant opportunity
                                                                               in the Thames Gateway and as an
                                                                               Action Area for redevelopment in the
                                                                               Medway Local Plan. The development
                                                                               brief proposals are in accordance with
                                                                               the hierarchy of relevant policy
                                                                               documents, in particular Policy S7 of
                                                                               the adopted local plan.
                                    Losses of wharf and dock facilities        The development proposals involve the
                                    should be a primary concern of the         closure of a number of wharves
                                    Medway Council and Kent County             currently operating along the River
                                    Council transport infrastructure           Medway. Current local planning policy
                                    planners.                                  (Policy T10) protects well-located
                                                                               wharves in the Local Plan area but not
                                                                               those at Rochester Riverside.
                                      Displacement of income generating         The council accepts there will be some
                                      and employment providing businesses.      disruption to existing businesses that
                                                                                have been on the site for many years.
                                                                                It has worked with a number to help
                                                                                find alternative sites. Some
                                                                                businesses are continuing on the site;
                                                                                a number of short-term tenants took on
                                                                                leases knowing that they would have to
                                                                                vacate when the development went
                                                                                ahead.
                                      Given no alternative facilities for       The council will give what support it is
                                      relocation, then support should be        legally and financially able to do. Only
                                      considered for the continuing operation   businesses whose property has been
                                      of the riverside companies and their      compulsorily acquired are entitled to
                                      employment provision in the area.         help with relocation.
                                      Other uses would be more attractive       Proposed uses are in accordance with
                                      and require less land decontamination     adopted local plan policy.
                                      costs.
                                      Increased road haulage.                   This will be considered in forthcoming
                                                                                Transport Assessment for a
                                                                                comprehensive masterplan.
Royal Society for the Protection of   Extra principal aim should be added to    Add another principal aim: “to
Birds                                 section 1.1: to recognise its role in     recognise the site‟s role in securing
                                      securing the area‟s ecological            and enhancing the area‟s ecological
                                      potential.                                potential.”
More needs to be made early on in        Add comment on page 3 regarding
document with regard to creating         natural open space. A requirement for
habitats.                                the future masterplan to incorporate
                                         natural open space. This should
                                         include a mix of intertidal habitat and
                                         terrestrial habitat in the form of trees,
                                         scrub and naturally managed
                                         grassland for the benefit of wildlife and
                                         people.
Section 1.2 should make reference to     Add this comment to section 1.2.
the fact that Rochester Riverside will
be an excellent example of how
development can benefit both wildlife
and people.
Additional comment on page 28 to         Add this comment to page 28.
make it clear to developers that any
action on the site must ensure that
contaminants do not reach the
watercourse.
Strengthen comment on page 30            Add comment to page 30: “a
regarding biodiversity.                  masterplan will be created that will
                                         seek to achieve no net loss in intertidal
                                         habitat.”
Creating new intertidal habitat should       The development brief currently states
not be at the expense of existing            the following: “the scheme would seek
mudflats. New habitat should only be         to achieve no net loss of intertidal
created if there is scope for the existing   habitat in line with EA guidelines.
flood defences to be set back, creating      Flood defences should be established
extra room for the additional habitat.       at the same position in order to retain
                                             existing (uncovered) intertidal zones.
                                             However where this is not possible,
                                             flood defences should be pulled back
                                             to create new intertidal habitats of
                                             equal or greater area to that lost.”
Section 5.2 to include reference to the      References to the following surveys in
surveys that are likely to be needed         section 5.2: “a phase 1 habitat survey
under the EIA.                               should be carried out as well as a
                                             survey of the birds that use the site.
                                             Particular care should be taken in
                                             assessing areas of intertidal habitat
                                             and assessing where flood defences
                                             have acquired ecological value. These
                                             areas should be retained wherever
                                             possible and should be taken into
                                             account when positioning any jetties
                                             and marinas.
Page 32 principles to be amended to          Make amendment.
read: publicly accessible open spaces
that provide an attractive environment
for a wide range of users as well as
wildlife.
Page 32 principle on sustainability to     Make amendment.
read: “a development that achieves
energy efficiency, waste minimisation,
water resource efficiency and does not
contribute to water pollution or
increase flood risk.”
Page 41. Make it clear that proposed       Add comment.
waterfront spaces should be designed
and positioned to ensure that they do
not impact on any existing value of the
site for nature conservation and so that
they do not impact adversely on the
sediment movements of the River
Medway.
Page 41. Planting in the creation of       Add comment to page 41: “wherever
urban squares should be with native        possible natural species to be used.”
species. Careful planting with native
species to give a range of heights and
structure can create areas that are
attractive to wildlife, whilst being
principally areas for the community.
                   Section on sustainable development      NHER and BREEAM have already
                   (pages 45-47). Add a principle that     been referred to. Need for reference to
                   states the requirement to meet high     water resources, integrated sewage,
                   NHER and BREEAM standards. Also         etc to be added.
                   add a principle that refers to water
                   resources and water quality as
                   important components of sustainable
                   development. The development brief
                   should encourage developers to
                   consider techniques such as rainwater
                   harvesting and integrated sewage
                   treatment works to reduce the
                   development‟s impacts on water
                   resources and quality. Technologies
                   such as SUDS should also be
                   promoted.
                   The box on sustainability principles    Proposals will seek to achieve a net
                   should contain a commitment to          increase in habitat for biodiversity.
                   achieve a net increase in habitat for
                   biodiversity.
The Vines Church     Retain industrial use along Gas        The Vines Centre Trust perform a
                   House Road so that existing wharfage    valuable function but its continued
                   and the Vines Centre Trust could        operation in the heart of a regeneration
                   continue to operate.                    scheme is not appropriate. It was
                                                           aware of the pending development
                                                           when it leased its property. The same
                                                           point applies to the wharf operators.
                                                           Additionally, the council has not
                                                           proposed the retention of wharves on
                                                           this site in the Local Plan because of
                                                           their poor access to the strategic road
                                                                                 network and the inadequacy of the
                                                                                 existing roads into the site for heavy
                                                                                 goods vehicles.
                                     Would rather see a church than a “faith     Add comment that states that the faith
                                     centre”. It should be used as a centre      centre should be flexibly designed and
                                     for the community, run by the Christian     open to a number of faith groups, uses
                                     community. A building that is flexible      and activities. The council and SEEDA
                                     and open to a number of uses. A             are likely to invite expressions of
                                     building and activities for the             interest from faith and community
                                     community.                                  groups when the relevant phase of
                                                                                 development is imminent.
Transit Medway (operators of Crown   Concern that new residential                Development proposals are required to
Wharf)                               development opposite Crown Wharf            be in accordance with PPG24 Planning
                                     will be noise sensitive and new             and Noise. The ES will address this
                                     residents will complain about noise         issue that will need to be explored
                                     from the wharf.                             when detailed design work takes place.
                                     How will the future of Crown Wharf be       The Local Plan already includes a
                                     protected through the planning              policy to retain this use.
                                     process?
                                     Marina and moorings to take due             A study currently underway to assess
                                     consideration of the size of vessels        the viability of a new marina. Detailed
                                     berthing at Crown Wharf and their           design of marina and moorings will
                                     ability to manoeuvre in tidal conditions.   involve collaboration with Medway
                                                                                 Ports and other relevant authorities
                                                                                 and, stakeholders.
Mrs A Robinson, 28 Prospect Row      Concern over safety and security.           The development brief takes on advice
                                                                                 and comments from Kent Police and
                                                                                 sets out a number of principles that
                                                                                 work towards creating a safe and
                                                                                 secure environment for all.
Francis Iles   Concern regarding the consideration        Occupiers at both of these sites have
               being given to Acorn Wharf and Castle      been involved in regular liaison
               View Business Centre.                      meetings with the council.
               The divide of the A2 will serve to         At present the site is effectively
               underline the fact that we will end up     separated from the city centre.
               with two towns. Consideration needs        Proposed development principles seek
               to be given to flyovers and                to rectify this and create good access
               underpasses.                               to historic Rochester. In particular the
                                                          aim is to provide a strong and
                                                          attractive pedestrian connections
                                                          between Rochester Riverside and
                                                          historic Rochester. The indicative
                                                          masterplan for the site shows
                                                          measures to improve pedestrian
                                                          connections across Corporation Street.
                                                          The sufficiency of access points will
                                                          also be dealt with in a forthcoming
                                                          Transport Assessment.
               Provision of car parking is not sufficient Parking will be in accordance with
               for the scale of development and will      adopted standards and current levels
               force drivers to take up spaces for        of public car parking will be retained. A
               visitors to Rochester.                     controlled parking zone will be
                                                          proposed for the development. This
                                                          site has more potential than any other
                                                          in Medway to avoid dependence on
                                                          the car for access to jobs and services.
                            Building of multi storey car park must      The council and SEEDA will prepare a
                            be a priority because of the loss of        detailed phasing programme. It is
                            parking in recent years and proposals       currently proposed that the
                            to site the registry office in the Corn     construction of the multi storey car
                            Exchange                                    park will take place during the first
                                                                        phase. In any event no spaces will be
                                                                        lost as part of the development unless
                                                                        they are replaced.
Network Rail                All the bridges are unsuitable for HGVs     The suitability of access points will be
                            and high-sided vehicles. Several of         considered in the Transport
                            the bridges are narrow and again            Assessment. The widening on
                            unsuitable for large vehicles. If it were   structures will be considered as the
                            proposed to widen any of the                opportunities arise having evaluated all
                            structures then Network Rail would not      the costs and benefits for the site.
                            have any objections in principle.
                            Network Rail is willing to support a        A direct link into the station from the
                            direct link to Rochester Station from       site is currently being proposed. A
                            the site.                                   reference to this is needed in the
                                                                        development brief.
                            There must be no adverse impact on          Add a comment on this in the site
                            Network Rail‟s infrastructure.              constraints section. Include informative
                                                                        in any planning permission.
Health & Safety Executive   In view of the presence of notifiable       Statement to be added to constraints
                            installations in the area covered by the    section. The Health & Safety
                            plan, it would be helpful to potential      Executive has provided suitable text.
                            developers if the constraints likely to
                            be imposed by their presence were
                            indicated in a policy statement in the
                            plan.
                      Plan to be added to show the locations     Constraints plan to be added to
                      of the notifiable installations            constraints section.
                      (particularly notifiable pipelines).
Kent Wildlife Trust   We note that in the design principles of   Comment to be added in section 6.5
                      section 6.5 whilst there is an intention   indicating that mitigation should be
                      to conserve areas of existing              undertaken if conservation of existing
                      ecological value in situ where possible    ecological areas is not possible.
                      there is no clear undertaking to
                      mitigate for their loss where such
                      conservation is not possible.
                      Commitment to a suitable                   Comment to be added to sustainability
                      management strategy to be included to      section and also phasing and
                      ensure that biodiversity is not lost by    implementation.
                      inappropriate management.
                      No acknowledgement of the potential        Comment to be added in site
                      ecological value of waste land.            constraints section.
                      Opportunity in this project to mitigate    Comment to be added.
                      for potential habitat loss by innovative
                      use of building design.
                      Other minor changes, rewording, etc.       Proposed changes to be made (see
                                                                 letter).
Sport England         Sport England has also produced a          Refer to the good practice guide in the
                      Good Practice guide: Providing for         development brief.
                      sport and recreation through new
                      housing development (2001)
We would urge that the provision of the      Playing field to be planned and
sports facilities follows a planned          developed in line with an up to date
approach to the provision of pitches in      Council Sports Strategy and Playing
line with an up to date Council Sports       Pitch Strategy. This comment to be
Strategy and Playing Pitch Strategy to       added to the brief.
ensure that future demands are met.
Sport England has produced a
guidance note „Towards a Level
Playing Field‟ on production of Playing
Pitch Strategies as referred to in the
Companion Guide to PPG17.
Consideration should also be given to        Add a note on the possible location of
the type of other facilities that would be   off site facilities to the S106 section.
required e.g. indoor facilities, multi use
games areas etc. The brief should if
possible identify specific locations or at
least guidelines as to where the off-site
provision should be made which would
help to ensure that adequate provision
is made in terms of quantity and
accessibility in order to ensure its
implementation.
                      At present the requirements for off-site    Make a reference to off site
                      recreation provision are not particularly   recreational provision in section 6.1.
                      prominent in the brief. The reference to
                      off-site formal sports provision is
                      tucked away in section 7.2 under
                      planning obligations. This should be
                      referred to in section 6.1 under
                      „Community and Educational facilities‟
                      and „Public Open Space‟ albeit they
                      would be off-site so that the total
                      recreation requirements can be seen
                      as a whole.
                      We would also refer to our guidance         [The playing pitch is to accord with
                      note „Natural Turf for Sport‟ which sets    „Natural Turf for Sport‟ document.
                      out advice on minimum size                  Refer to this in the brief].
                      requirements for playing pitches as
                      well as facilities advice on drainage,
                      specifications and maintenance. This
                      document could be usefully referred to
                      in the brief.
Open Spaces Society   Section 6.5 Open spaces, green              [These comments were received after
                      spaces.                                     the requested date for comments but a
                      Welcome the value given to open             full response will be provided]
                      space as a key value. How much
                      green space is shown and is it
                      sufficient to provide all the different
                      habitats mentioned in the brief? Could
                      translocation of common reptiles to the
                      riverside areas be possible?
An area of former common land close         The latest masterplan shows the city
to the city wall was lost to car and        wall in an area of an open space
coach parking in the past; now would
be a good time to recreate this as a
green setting to this isolated section of
the river wall.
Children‟s‟ play areas should include       Amend brief to make this clear?
trees for shelter from the sun; roofed
areas provide shelter from rain
Section 6.6 Access and Movement             Amend brief to state segregated routes
Welcome priority given to good              should be provided where practical.
pedestrian links within the site and
around river edge; would like to see
segregated cycle and pedestrian
routes. This is particularly the case
where the cycleway will be part of the
National Cycle Route
What do „green routes‟ mean and
where will they be?
Section 5.1 Flooding
More information about flooding would       Main drainage will almost certainly be
have been welcome for those without         the responsibility of developers.
access to PPG 25; what about letting
storm water out as well as keeping
river water getting in. Land drainage
will be complex because a lot of
drainage channels have been filled in.
Will developers pay for this?
English Nature   The document adequately addresses
                 all those issues on which EN would
                 expect to comment in a planning
                 application

CDL 210604

								
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