from: owen jones sent: to: swdp cc: subject: swdp proposed ... · south worcestershire development...

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From: Owen Jones Sent: 16 November 2014 09:00To: SWDPCc: Richard Bergmann; Duncan MacKay Subject: SWDP Proposed Modifcations response from Bloor Homes (Western) LtdAttachments: 141116 SWDP Proposed Modifications response.pdf; Ltr - Paul Bayliss (SWDP

Project Manager - 16th November 2014.pdf; PM2 Form.doc; PM8 Form.doc; PM9 Form.doc; PM12 Form.doc; PM100 Form.doc; PM101 Form.doc; PM102 Form.doc; PM103 Form.doc; PM104 Form.doc; PM105 Form.doc; PM106 Form.doc; PM240 Form.doc

Dear sir/madam, please find enclose the representations which are submitted on behalf of Bloor Homes (Western) Ltd to the Proposed Modifications consultation which closes on the 17th November 2014. I would be grateful to receive an acknowledgement of their receipt. Hard copies have also been sent in the post. Kind regards Owen

Owen Jones MRTPI Director Head of Boyer Cardiff

Correspondence Address: Boyer Planning Ltd ‐ Registered Address:

. Registered in England 2529151. To see full disclaimer that applies to this email please click here. To see our Standard Terms and Conditions of Contract please click here.

Date: 16th November 2014

Ref: OJ/RB/08.815

Paul Bayliss, SWDP Project Manager

c/o Wychavon District Council

Policy Plans Team

Civic Centre

Queen Elizabeth Drive

Pershore

Worcestershire

WR10 1PT

Dear Mr Bayliss,

South Worcestershire Development Plan (SWDP): Proposed Modifications – November 2014

Representations on behalf of J S Bloor (Western) Ltd

I am pleased to enclose, on behalf of my client, J S Bloor (Western) Ltd, representations in response to

the Proposed Modifications (PMs) to the Proposed Submission SWDP.

These representations relate to the following:

- Proposed Modification 2 concerning Policy SWDP2 and the distribution of housing provision;

- Proposed Modification 8 concerning Policy SWDP3 and the amended housing requirement;

- Proposed Modification 9 concerning Policy SWDP3 and housing at the ‘Wider Worcester Area’;

- Proposed Modification 12 concerning Policy SWDP3 and components of housing supply;

- Proposed Modifications 100 – 106 concerning SWDP45 that refers to site-specific Proposed

Modifications relating to SWDP45/2 allocation at Temple Laugherne;

- Proposed Modification 240 concerning Annex E and outlines the Proposed Modification to the

housing trajectory across the SWDP period.

I would be grateful to receive an acknowledgment that these have been received.

Yours sincerely,

Owen Jones

Director

Boyer Planning Ltd

South Worcestershire Development Plan Examination Representation Form Consultation on Proposed Modifications to SWDP: 6 October – 14 November 2014 South Worcestershire Councils

Please use a separate sheet for each modification response There is an extension form available on the SWDP website that can be downloaded / completed and appended to this form as many times as required. This will enable the Inspector to consider your comments on each modification as promptly as possible. Consultation runs from Monday October to Friday November 2014. All comments must be received by 5.00pm on the November.

Please use a separate Part A / B form for each modification you wish to respond to and attach to the one containing your contact details.

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South Worcestershire Development Plan Proposed Modifications: 6 October – 14 November 2014

The South Worcestershire Councils (SWC) are seeking representations on the Proposed Modifications to the SWDP, following stage 1 of the Examination (March 2014). The changes are proposed by the SWC to address issues around the need for an uplift of housing numbers to meet the objectively assessed housing need for the area and we are only able to accept representations on these matters.

. You can access the SWDP documents online and obtain additional copies of this form from the SWDP website ://www.swdevelopmentplan.org/?page_id=5393 Completed forms should be returned either by Email to: @swdevelopmentplan.

Post to: Paul Bayliss, SWDP Project Manager c/o Wychavon District Council Policy Plans Team Civic Centre Queen Elizabeth Drive Pershore Worcestershire WR10 1PT Please note: Unfortunately we are now unable to receive responses sent to the Freepost address previously used. Please ensure that only the address given in this current guidance and associated response forms are used. ALL REPRESENTATIONS MUST BE RECEIVED IN WRITING NO LATER THAN 5.00PM ON NOVEMBER 2014.

(The following form can be edited electronically by clicking into the boxes and typing – boxes should automatically expand as needed. Cursor marks will not affect the text or readability of the document)

REPRESENTATIONS MUST ONLY RELATE TO THE CURRENT PROPOSED MODIFICATIONS.

Further representations to the submitted SWDP will not be accepted. There is no need to repeat representations that you submitted at the Pre-Submission consultation stage (January/

February 2013).

http://www.swdevelopmentplan.org/?page_id=5393

mailto:[email protected]


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Before completing the response form we would be grateful if you could tell us more about yourself:

1. Personal Details 2. Agent Details (if applicable)

Title Mr

First Name Owen

Last Name Jones

Job Title (if relevant)

Director

Organisation (if relevant).

J S Bloor (Tewkesbury) Ltd Boyer Planning

Address c/o Agent

Postcode

Tel. No.

Email

HOW WE WILL USE YOUR DETAILS The personal information you provide on this form will be processed in accordance with the requirements of the Data Protection Act 1998. It will be used only for the preparation of local development documents or any subsequent statutory replacement. However, your name and representations will be made publicly available when displaying and reporting the outcome of the consultation stage, and cannot be treated as confidential. OTHER DETAILS, INCLUDING YOUR ADDRESS AND SIGNATURE, WILL BE TREATED AS CONFIDENTIAL. In agreeing to the holding of your information you are giving permission for your details, held on the database, to be shared between the three local authorities. If you have any concerns or queries relating to this process, please contact 01905 722233. I agree that contact details and any related responses can be held by the planning service departments of the three South Worcestershire local authorities. I understand that they will only be used in relation to the plan making process as required by the Planning and Compulsory Purchase Act 2004 and other planning-related legislation. Signed: Date: 14/11/2014


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3. Are you attaching any additional sheets that relate to this representation?

Yes ✓ No Number of sheets 1

4. Which Proposed Modification does your representation relate to?

Modification Number PM2

5. Do you consider the Proposed Modification to be legally compliant?

Yes No No Comment ✓

6. If you consider the Proposed Modification to be unsound, please identify which test of soundness your comments relate to? (tick all that apply)

Positively prepared Effective

Justified Consistent with National Policy

As also set out in the accompanying guidance note (paragraph C, page 2 of GUIDANCE NOTE – How to Respond to the Proposed Modifications), these are the tests of soundness to which your comment(s) should relate: Positively prepared – the plan should be prepared based on a strategy which seeks to meet

objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework


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Part A

Please use a separate sheet for each modification response – there is an additional document available on the SWDP website that can be completed and appended to this form as many times as required. This will enable the Inspector to consider your comments on each modification as promptly as possible.

Please give details of why you consider the Proposed Modification is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the Proposed Modification please also use the box below to set out your comments. Please note - your representation should provide evidence and information to support / justify your representation and any suggested change. Your representation should relate only to the current Proposed Modifications.

Please refer to the attached representation.

Expand box / use additional page as necessary


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Part B Please set out what change(s) you consider necessary to make the Proposed Modification legally compliant or sound, having regard to the test(s) you have identified above. You will need to say why this change will make the Proposed Modification legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Your representation should relate only to the current Proposed Modifications. Please refer to the attached representation.


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7. If your representation is seeking a change to the Proposed Modification, are you content for it to be considered by written representations, or do you consider it necessary to participate in person at an examination hearing?

Written representations Participate at an examination hearing ✓

8a. If you wish to participate at an examination hearing, please outline why you consider this to be necessary:

Due to the significant policy issues involved.

8b. Where there are a large number of identical or very similar responses to a particular modification, it would assist the Inspector if individuals could work together on presenting a joint case at the hearing. If you are able to do this, please indicate below who will be representing you. Your individual comments will still be considered by the Inspector.

Thank you for taking the time to complete this representation.

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South Worcestershire Development Plan Examination Representation Form – Additional Pages Consultation on Proposed Modifications to SWDP: 6 October – 14 November 2014 South Worcestershire Councils

Additional sheet(s) for responses to individual modifications – to be appended to main form as required Please use a separate sheet for each modification response to enable the Inspector to consider your comments on each modification as promptly as possible. Consultation runs from Monday October to Friday November 2014. All comments should be received by 5.00pm on the November. (The following form can be edited electronically by clicking into the boxes and typing – boxes should automatically expand as needed. Cursor marks will not affect the text or readability of the document)

SWCs: October 2014

Additional sheet for responses to individual modifications – to be appended to main form as required

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Please use a separate sheet for each modification number.


Modification No. PM100





Justified ✓ Consistent with National Policy

As mentioned above, these are the tests of soundness to which your comment(s) should relate:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.

Your Name / Organisation Name (if relevant) (for tracking purposes only) Mr Owen Jones / Boyer Planning


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Part A Please use a separate sheet for each reference number.




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Part B

Please set out what change(s) you consider necessary to make the Proposed Modification legally compliant or sound, having regard to the test(s) you have identified above. You will need to say why this change will make the Proposed Modification legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

Your representation should relate only to the current Proposed Modifications.


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South Worcestershire Development Plan Response to Proposed Modifications Bloor Homes (Western) Limited November 2014

Document name | Site Name

REPORT CONTROL

Document checking

Issue Date Status Checked for issue

1 12/11/14 1st Draft OJ

2 16/11/14 Final OJ

Project: West of Worcester

Client: Bloor Homes (Western) Limited

Job Number: 08.815

File Origin: SWDP Proposed Modifications Response

Primary author: Owen Jones Initialled: OJ

Review by: Initialled:

SWDP – Proposed Modifications | Representation by Bloor Homes (Western) Ltd

Contents

1. INTRODUCTION ......................................................................................... 1

2. SWDP 3 – HOUSING PROVISION ............................................................. 2 The Housing Requirement ..................................................................................... 2 Housing Supply ..................................................................................................... 2 Revised Housing Trajectory ................................................................................... 3

3. TEMPLE LAUGHERNE STRATEGIC SITE ................................................ 4

Planning History .................................................................................................... 4 Proposed Modification 100 .................................................................................... 5 Proposed Modification 101 .................................................................................... 6 Proposed Modification 102 .................................................................................... 6 Proposed Modification 103 .................................................................................... 6 Proposed Modification 104 .................................................................................... 6 Proposed Modification 105 .................................................................................... 6 Proposed Modification 106 .................................................................................... 6

4. SUMMARY .................................................................................................. 8


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1. INTRODUCTION

1.1 These representations have been prepared on behalf of Bloor Homes (Western) Limited in

response to the Proposed Modifications to the South Worcestershire Development Plan which were

published on the 6th

October 2014.

1.2 Previous representations have been submitted to the SWDP on behalf of Bloor Homes (ref

764296). Certain of these were considered at the Phase 1 Examination which resulted in the

Interim and Further Interim Conclusions from the Inspector and are relevant to the Proposed

Modifications. Other representations are matters for Phase 2 of the Examination.

1.3 We have supported the allocation of the Temple Laugherne strategic site to the west of Worcester

in earlier representations as the SWDP has evolved since its formative stages in 2008. Bloor

Homes control a substantial tract of land in this location.

1.4 However, the representations relating the Submission Version of the Plan argued that the allocation

should be enlarged, consistent with the identified capacity of land in this location to accommodate

development, the opportunity afforded to provide additional transportation infrastructure to support

movement and accessibility to the west of Worcester and the need to increase the housing

requirement generally. It follows that we support the Proposed Modification which intends that this

strategic site be enlarged from 975 new homes to 2150 (PM100).

1.5 In this response we focus on the Proposed Modifications and in particular those relating to the

enlargement of the Temple Laugherne strategic site (Policy SWDP45/2). Where necessary it cross

refers to other submission made in the context of the SWDP historically.

1.6 The representations are focused around three main policy aspects. Firstly, the overall housing

requirement; secondly, the distribution of new housing; and thirdly the Temple Laugherne Strategic

Allocation. We also comment on other consequential modifications.


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2. SWDP 3 – HOUSING PROVISION

The Housing Requirement

2.1 In representations concerning the Submission Version of the SWDP, and more recently in hearing

statements for Phase 1 of the Examination, Bloor Homes argued that the then housing requirement

of 23,200 new homes between 2006 and 2030 was not sufficient to meet the plan area’s needs.

We do not repeat those representations.

2.2 In the event, the Inspector Interim Conclusions and thereafter Further Interim Conclusions confirm

that the housing requirement should be increased. The recommendation set out in the Further

Interim Conclusion is that the housing requirement should be increased to 28,730 new homes

between 2006 and 2030 (paragraphs 57 and 61 refer). We do not demur from these conclusions or

this recommendation.

2.3 In this context we support Proposed Modification 2 which requires the Development Strategy to

“provide for and facilitate the delivery of sufficient housing to meet objectively assessed needs to

2030”.

2.4 Moreover Proposed Modification 8 gives effect to the Inspector’s recommendation and proposes

that the housing requirement is increased to 28,400 new homes over the plan period. We support

this proposed modification and the increase in housing provision.

Housing Supply

2.5 In respect of the individual components of supply, our representations also questioned the

suitability of including an empty homes allowance, the extra care housing release and the level of

windfall development assumed. We note that Proposed Modification 12 deletes or reduces these

allowances and we agree with this.

2.6 More fundamentally, Proposed Modification 9 increases the amount of new housing in the ‘wider

Worcester area’ to 12,350 dwellings (from 9,400 dwellings). As part of this strategy Proposed

Modification 12 similarly increases the amount of housing to be provided at Urban Extensions

within the ‘wider Worcester area’ from 3925 to 5,050 new homes (noting that the information is

presently slightly differently). We agree, for the reasons set out in our representations to the

Submission Version of the Plan, with the underlying strategy to maintain a focus on Worcester City

and the role of urban extensions in this regard in meeting the increased housing requirement to

retain the spatial strategy set out in Policy SWDP2 – the Settlement Hierarchy (Table 2).

2.7 In this regard, we support the enlargement of the Temple Laugherne strategic site, which we

comment on in the context of Policy SWDP45/2 and Proposed Modification 100.

2.8 Without prejudice to this support, we note that the overall supply of new housing set out in Table 4e

now amounts to 28,649 (PM12). Prima facia, this level of supply is marginally above that required

by the policy of 28,400. Whilst of 5% allowance has been applied to all commitments, this level of

supply does little to provide the necessary certainty that the amount of housing required during the

plan period will be provided; a point made in the context of housing supply in the Submission

Version of the Plan also.


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2.9 In this context we note that the National Planning Policy Framework (NPPF), which provides the

overarching Government policy document in relation to planning establishes the ‘presumption in

favour of sustainable development’ in Paragraph 14, which for plan-making means that:

“Local planning authorities should positively seek opportunities to meet the development needs of

their area.”

2.10 Accordingly where opportunities exist to provide greater surety of housing supply without

adjustments to the strategy of the allocations such opportunities should be considered. This is

relevant to the capacity of the Temple Laugherne allocation which we comment on later.

Revised Housing Trajectory

2.11 Proposed Modification 240 replaces the housing trajectories previously included in the Submission

Version of the Plan. Presently it indicates just 327 new homes being built in the period up to 2019

for SWDP45/2 – Temple Laugherne.

2.12 The form of the allocation now enables delivery to materialise quicker than was previously the case.

In short, by extending the allocation to Martley Road there exist three development areas that could

be brought forward simultaneously – land off Martley Road to the north, land of Oldbury Road to the

west and land to Bromyard Road to the south.

2.13 As a consequence, the delivery trajectory can show a greater number of houses being built prior to

2019 (the next identified Phase) and a quicker rate of delivery in the period thereafter.


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3. TEMPLE LAUGHERNE STRATEGIC SITE

Planning History

3.1 The Temple Laugherne proposals have been advanced by Bloor Homes (and Hallam Land

Management Ltd) in the context of the planning policy framework that has emerged over a number

of years at Worcester and the acknowledgement for almost 15 years that the City’s future growth

will necessitate urban expansion utilising land within the adjacent Districts of Malvern Hills and

Wychavon:

The Worcestershire EIP Panel (2000) confirmed that Worcester would not be able to meet its

future development needs within its administrative boundaries. Work undertaken in conjunction

with preparing the Worcestershire County Structure Plan in the 1990s indicated capacity for

growth to the west of the City.

RPG11 – first issued in 2004 – identifies the City as a sub-regional foci capable of balanced

growth to meet strategic development needs in the longer term.

During the Malvern Hills Local Plan Inquiry the District Council acknowledged that its

strategic/significant gap policy (DS17), which covers land between the western edge of

Worcester and Lower Broadheath, was not intended to preclude consideration of Worcester’s

future growth in this location.

The White Young Green Study entitled ‘Future Development of the City of Worcester 2011-

2021: Consideration of Potential Growth Options’ undertaken in 2006 in conjunction with the

County Council’s Section 4(4) Advice found that development to the west of Worcester is the

most sustainable option for achieving longer term growth.

The Government awarded Worcester New Growth Point Status in November 2006 on the basis

that it is capable of providing a focus for future strategic growth.

The RSS Phase 2 Revision consultation document (Jan 2008) identified Worcester as a

settlement of significant development and identified that future growth at the City is to be

accommodated, in the main, through urban extensions within Malvern Hills and Wychavon

Districts.

The South Worcestershire Joint Core Strategy Preferred Option (Sept 2008) identifies land to

the West of Worcester to accommodate an urban extension of 3,500 dwellings.

The submitted SWDP proposes a strategic site allocation in this location extending broadly

between the A44 Bromyard Road and Oldbury Road.

3.2 The established suitability of the western edge of Worcester to accommodate new development,

combined with the Inspector’s Further Interim Conclusion that the SWDP housing requirement

should be increased, have rightly led to the increase in the existing strategic allocation at Temple


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Laugherne (SWDP45/2) from 975 to 2150 new homes and associated uses on land that now

extends to Martley Road – Proposed Modification 100 refers.

3.3 A significant amount of background work has been prepared and submitted previously to the

SWDP in respect of the development capacity land controlled by Bloor Homes (and Hallam Land

Management Ltd ‘HLM’) to the West of Worcester. Most recently this was in the form of a

response to the ‘Call for Sites’ exercise undertaken by the plan making authorities earlier in 2014

and provided background information which supports the enlargement of this allocation. We do not

repeat that information here.

3.4 In this context we comment on the various aspects of the Policy SWDP45/2 as proposed to be

modified. These are set out under the individual Proposed Modifications.

Proposed Modification 100

3.5 Firstly, we support the increase in the amount of new housing to be accommodated – from 975 to

2150 new homes.

3.6 Secondly, we support the need for a masterplanning exercise to be undertaken to determine the

disposition of land uses across the enlarged areas as a whole. Hitherto, the work that had been

undertaken in relation to this – and advanced via two separate planning applications by HLM and

Bloor Homes respectively – is concerned only with the disposition of land uses associated with the

quantum of development and allocation boundary identified in the Submission Version of the Plan.

To this end, various meetings have been held involving HLM, Bloor Homes, Malvern Hills District

Council, Worcester City Council and Worcestershire County Council to discuss amendments to the

scheme’s parameters. Preliminary work undertaken the HLM and Bloor Homes has indicated that

the capacity of the allocated site could be greater than 2150 dwellings depending on assumptions

made about density. This work is on-going and will be reported at a later date.

3.7 Thirdly, we support the need for the masterplan exercise to ensure a comprehensive development.

It will be important that the respective development parcels are brought forward in a co-ordinated

fashion once the masterplanning exercise is complete. We do not see this as requiring a single

planning application but rather that together the schemes brought forward by Bloor Homes and

HLM deliver both the land use components of the allocation in an appropriately integrated manner

and the associated planning obligations and mitigation measures. In due course, the Local

Planning Authority will be able to determine whether the individual development proposals

satisfactorily achieve the necessary requirements and that neither scheme fetters the other so as to

prejudice a comprehensive development.

3.8 Fourthly, we note the references to integrated and cohesive urban design. Such matters are

pertinent in the context of the masterplanning exercise and are being taken into account

accordingly.

3.9 In the context of the above, we note that the diagram associated with this enlarged allocation, is

also labelled PM100. Whilst we support its enlargement, and the principle of a connection between

Bromyard Road and Martley Road we comment on the alignment of the ‘spine road’ in relation to

PM106 as we do not believe what is shown on the diagram to be justified at the present time.


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3.10 This is noted and we have no comment to make in relation to this.


3.11 We note the parameter set out in respect of the amounts of floorspace for retail provision at the

neighbourhood centre.






3.14 This is noted and we have no comment to make in relation to this, save to draw attention to the

need for such matters to comply with CIL Regulations so far as planning obligations are concerned

i.e. that they must be suitably and appropriately justified. Morevoer, CIL itself would be the

mechanism to secure financial contributions to such infrastructure.


3.15 We note the transportation measures that are listed in the amendment to criterion x. We are aware

that highway modelling undertaken by Worcestershire County Council as the Highway Authority

has considered the resilience of the local highway network (and to the extent relevant the strategic

highway network to the east of Worcester) to accommodate the increased levels of development

which the Proposed Modifications intend.

3.16 It follows that such assessment work will have demonstrated that the enlargement to Temple

Laugherne can be accommodated without severe impacts on the highway network.

3.17 Such modelling appears to have concluded that the increase in development at Temple Laugherne

does not require the construction of the North Western Relief Road (nor indeed does the level of

development which is to be accommodated in the Wider Worcester Area). However, it has

suggested that a link between Bromyard Road and Martley Road is required as part of the

development – this is referred to as a “spine road within the site”, whereas the diagram

accompanying the allocation proposes that this forms the outer edge of the development.

Importantly, this is supplemented by the words “subject to detailed design and assessment” in

paragraph 3.45 of the 30th

September 2014 Committee Report. It is therefore apparent that the

alignment shown on the accompanying diagram is not justified at the present time.

3.18 Clearly the precise form and alignment of this road will be a matter that is agreed through the

masterplanning exercise. As part of the discussions between HLM, Bloor Homes MHDC and WCC,

the options for the alignment of this route and how it could be upgraded at a future date to form part

of the NWLR are being considered (an aspiration illustrated in paragraph 3.45 of the 30th

September Committee Report).


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3.19 Accordingly, and until such time as a more refined masterplan is complete we suggests that the

route of alignment of the spine road be annotated as ‘indicative’ on the inset diagram – this would

be wholly consistent with the expression of the alignment of the spine road in the 30th

September

Committee Report.

3.20 Notwithstanding, in earlier representations we have identified the benefits of such a link in the

context of development options to the west of Worcester and recognise the importance of this

element of infrastructure being provided as part of a comprehensive development proposal.


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4. SUMMARY

4.1 For completeness we have set out below a summary of the representations made on behalf of

Bloor Homes Ltd to the Proposed Modifications:

4.2 Proposed Modification 2 – we support the distribution of the additional housing consistent with the

Development Strategy SWDP2.

4.3 Proposed Modification 8 – we support the increase in the overall housing requirement to 28,730

new homes between 2006-2030.

4.4 Proposed Modification 9 – we support the increase in the amount of housing in the ‘wider

Worcester area’.

4.5 Proposed Modification 12 – we support the adjustments to housing land supply but maintain the

concern that there is an overall lack of flexibility in the housing supply strategy.

4.6 Proposed Modification 100 – we support the enlargement of the Temple Laugherne allocation in

Policy SWDP45/2 to 2150 dwellings and associated uses. We further support the need for a

masterplanning exercise to be undertaken to determine the disposition of land uses across the

enlarged areas as a whole and to enable a comprehensive development. That said, we do not see

this as requiring a single planning application to be submitted for the whole of the allocated site.

4.7 Proposed Modifications 101 – 105 – we note these various proposed modifications.

4.8 Proposed Modification 106 – we recognise the importance of the highway link – ‘spine road’ -

between Bromyard Road and Martley Road, however, and consistent with the recognition that its

alignment is “subject to detailed design and assessment”, the allocation plan should annotate this

as an “indicative alignment” pending the completion of the comprehensive masterplan exercise

that is being undertaken.

4.9 Proposed Modification 240 the housing trajectory for Temple Laugherne could be adjusted to reflect

a quicker rate of development because of the opportunity afforded by three outlets.


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