Agenda for the Steering Group Meeting to be held on 11 August 2014

Transcription

Local Plan Steering Group
Agenda
Monday, 11 August 2014
Reception Room, Town Hall, St Annes at 16:00
1.
Apologies
2.
Chairman’s Introductions
3.
To consider the notes of the previous LPSG meetings held on 8 May 2014, 5
June 2014 and 10 June 2014, as attached (Appendix 1)
4.
To consider a Briefing Note relating to Fylde Employment Land and Premises
Study (Appendix 2)
5.
To consider a Briefing Note relating to the Gypsy and Traveller
Accommodation Assessment(Appendix 3)
6.
To consider a Briefing Note relating to the Blackpool Local Plan/ Core
Strategy Consultation (Appendix 4)
7.
To consider a Briefing Note relating to the Bryning-with-Warton
Neighbourhood Plan Consultation (Appendix 5)
8.
To receive a verbal update on Health Impact Assessments
9.
Date of Next Meeting
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Notes of the Local Plan Steering Group – 8 May 2014
Appendix 1
Notes of the
Date:
Thursday, 8 May 2014
Venue:
Reception Room, Town Hall, St Annes
Group members:
Councillor Dr Trevor Fiddler - Portfolio Holder - Planning and
Development
Chairman- Development Management Committee - Councillor Ben
Aitken
Vice-Chairman- Development Management Committee - Councillor
Kevin Eastham
Councillors Christine Akeroyd, Susan Ashton, Julie Brickles, Alan
Clayton, Peter Collins, Peter Hardy, Angela Jacques, Barbara Nash,
Linda Nulty, Elizabeth A Oades, Richard Redcliffe, Heather A Speak,
Vivienne M Willder
Officers:
Allan Oldfield, Paul Walker, Mark Evans, Mark Sims, Michael Eastham,
Nicola Martin, Fiona Riley, Lyndsey Lacey
Other representatives:
None
1. Apologies
Apologies were received from Councillors Tim Armit, Maxine Chew, Fabian Craig- Wilson, Charlie
Duffy, Kiran Mulholland and Albert Pounder.
2. Introductions
Councillor Dr Fiddler (Portfolio Holder for Planning and Development) introduced the meeting by
making reference to the significance of the Fylde Coast Strategic Housing Market Assessment
(SHMA) which remained to be determined by Cabinet. He then went on to invite the group to
consider the detail in the Preferred Option Consultation Paper on a page by page basis.
3. Fylde Local Plan to 2030 - Preferred Options Consultation- Draft Consultation Statement
Members had before them a copy of the Draft Consultation Paper and were invited to comment on
each page of the document.
In summary, the document included a the background and purpose of the consultation exercise,
different methods used to inform and engage with the public and stakeholders including
consultation events, material used during the consultation together with a summary of the
comments received and associated Council responses.
Appendix 1
The comments received, along with the results of the Interim Sustainability Appraisal, evidence base
and other considerations, including changes to government policy, will inform the Council’s
Preferred Options.
Appendix 1 to the report included a consultation statement which set out the material that was used
during the consultation, along with how the Council consulted. It also provided an evaluation of the
success of the consultation.
Appendix 2 of the report included a summary of the comments received (divided by chapter) along
with the Council’s proposed response to the comments and an indication of how the Publication
Version could be developed through recommendations for changes in the text. The results of the
Preferred Options consultation would be used to inform the Publication Version.
Members sought clarification on various areas referred to in document including: “the 691
respondents to the consultation” (page 4), shale gas implications/impacts (page 10), appropriateness
of the wording “major changes to the local plan are not anticipated” (page 11), heritage evidence
base (page11), accuracy re estimated population growth (page 14), outcome of negotiations taking
place regarding the location of secondary schools (page 16), review of the Green Belt in Freckleton
(page 17), proposals to introduce a static caravan policy (pages 18 and 22), flood risk issues (page
19), effects of the retail offer/ Ribby Hall Village (page 20), proposals to include the northern part of
the Warton Aerodrome within the Warton settlement boundary including proposals to redefine the
centre (page 21), consideration of an alternative name for the area of land currently labelled as the
“Blackpool Periphery” (page 22), pockets of deprivation (page 23) reference to the role of a key
service centre (page 24), BAE systems (pages 26-28), village status (page 27), English Heritage’s
comments re Objective 4 (page 32), Green Belt review (page 35), reference to Great Birchwood
(page 35) “Sustainability” definition (page 39), housing numbers (pages 40-41), jointly commissioned
SHMA (page 43), Key Service Centres (page 44), town centre naming/separating (page 46), Minority
Groups (page 47), five year supply (page 48), Standardisation of Strategic Locations (page 79),
Infrastructure and service provision (page 82), mixed use development/ potential of Naze Lane being
expanded for employment purposes (page 87).
Within the time specified for the meeting, the Group had considered pages 1- 85 in full and
recommended the following with a view to determining the remainder of the document at its next
meeting:
Referenced as “Member Decisions” in draft Consultation Statement:
1. To further clarify the name of the area currently labelled as Blackpool Periphery
2. It was agreed there was no need for a policy on the unauthorised use of static holiday caravans
and that the Status Quo remain (page 22 refers)
3. It was agreed that mixed use development site at Warton will be considered at a future meeting
Other matters discussed:
3. Reference to the “Minority Group” (page 47 onwards) be clarified in the document to refer to the
“Minority Report Group”
4. It was agreed that reference to “Kirkham and Wesham” in the document remain as separate
settlements
Appendix 1
5. It was agreed that reference to “Lytham and St Annes” in the document remain as separate
settlements
6. It was agreed that Officers will prepare a revised policy which seeks to secure a master planning
approach to strategic locations in policy SL1 – SL4 inclusive.
7. It was agreed that the strategic locations for development will be considered at a future meeting
and that officers will consider the feasibility of Naze Lane being expanded for employment
purposes.
8. It was agreed that the allocation of the residential development site at Dowbridge would be
considered at a future meeting with regard to the potential flood risk issues.
9. The appropriateness and consequences of delaying the Local Plan to revisit the scale of
development at Warton area to be considered at the next meeting.
It was agreed that potential for future development at Fylde-Blackpool Periphery will be
considered at a future meeting.
5. Date of next meeting
It was AGREED that the next meeting of the Group be held (16:00- 19:00) on Thursday, 5 June at a
venue to be agreed.
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Notes of the Local Plan Steering Group – 5 June 2014
Appendix 1
Notes of the
Date:
Thursday, 5 June 2014
Venue:
Community Room, United Reform Church, St George’s Road, St Annes
Group members:
Development
Aitken
Vice-Chairman- Development Management Committee - Councillor
Kevin Eastham
Councillors Susan Ashton, Julie Brickles, Maxine Chew, Fabian CraigWilson, Charlie Duffy, Barbara Nash, Elizabeth A Oades, Albert
Pounder, Richard Redcliffe and Heather A Speak.
Officers:
Allan Oldfield, Paul Walker, Mark Evans, Julie Glaister, Michael
Eastham, Fiona Riley, Andrew Hunt, Katharine McDonnell
1. Apologies
Apologies were received from Councillors Christine Akeroyd, Angela Jacques, Linda Nulty and
Vivienne Willder.
2. Notes of previous meetings
The group agreed the notes from the previous meetings dated 25 March, 16 April and 23 April 2014.
It was agreed that, for clarity, any future agreements on the way forward would be decided by a
show of hands, rather than by general consensus.
3. Introduction
Councillor Dr Fiddler (Portfolio Holder for Planning and Development) welcomed everyone to the
meeting and invited the group to continue to consider the detail in the Preferred Option
Consultation Paper on a page by page basis, starting from page 87 where discussions had concluded
at the last meeting.
4. Fylde Local Plan to 2030 - Preferred Options Consultation- Draft Consultation Statement
Members had before them a copy of the Draft Consultation Paper and were invited to comment on
each page of the document.
Appendix 1
Within the time specified for the meeting, the Group had considered pages 88-129 in full and
recommended the following with a view to determining the remainder of the document at its next
meeting:
•
•
•
•
•
•
•
•
•
•
•
Page 88 – Secondary school – it was AGREED there was a need for an additional secondary
school in Fylde, with the group preferring the site of Great Birchwood, west of Warton, but
there were issues with the site as it is located within the Green Belt, in Flood Risk Zone 3 and
its distance from the centre of Warton It was agreed that discussions with Lancashire
County Council via the Education Liaison Group, needed to be concluded to ensure that
need was established to ensure sustainability of that site. Action: Julie Glaister to contact
Nicola Martin to request a meeting of the Education Liaison Group to consider the location
of an additional secondary school in Fylde.
Page 88 –It was noted that the windfall allowance should be increased to an expected 200
units, based on past trends through the full plan period to the year 2030.
Page 91 – Member’ Decision – The Members AGREED the delivery of a masterplan for
Warton could be achieved by way of methods 1 ) and 3), i.e. to set out the objectives and
requirements and associated infrastructure in policy SL3 of the Local Plan (Part 1) and focus
on the emerging Neighbourhood Plan process to produce a village wide masterplan.
Page 92 Recommendations for change. It was AGREED that the wording: “prepare a
masterplan for Warton” be deleted and replaced by “Work with the Bryning-with-Warton
Neighbourhood Planning Steering Group”. It was AGREED to reduce the number of
residential units planned for Warton from 1160 to 650. There would need to be a critical
mass, in terms of the number of units in Warton, for the level of infrastructure required to
be delivered.
Page 92 – Recommendations for change – clarity was sought in the wording regarding the
distinction of local service centre, district centre etc. Action: it was AGREED that an
explanation of the settlement hierarchy (i.e. key service centre, local service centre) and the
retail hierarchy (i.e. town, district/village and local centres) would be provided in the next
version of the Local Plan (Part 1).
Page 98 – Site H7 Land North of Dowbridge, Kirkham – it was AGREED that this site should
be deleted.
Page 98 – Site H13 – Land North of Mowbreck Lane, Wesham – it was AGREED to leave this
site in the Local Plan as a proposed allocation.
Page 99 – Site M3 – Land North of Blackpool Road, Kirkham - it was AGREED that the
employment land identified at Kirkham Triangle be removed and that this land should
instead be identified for residential development. That is the whole of the site will be for
residential development.
Page 99 – Site E4 – Land West of Fleetwood Road, Wesham – it was AGREED to leave the
proposed allocation as described (i.e. employment and leisure), but to re-visit the
boundaries of Site E4.
Page 102 – Recommendations for change – it was AGREED to leave the northern part of BAE
Systems, Warton as a designated employment zone and not to include it within the Warton
Settlement Boundary.
Page 108 – Recommendations for change – add the following text to the first bullet point:
“… including a map of all of the areas of separation …”. It was AGREED that there was the
possibility of identifying an Area of Separation between Treales and Kirkham, and Treales
and Wesham.
•
•
•
•
Appendix 1
Page 109 – Policy GD3 – Member’ Decision – it was AGREED that officers should work with
the Bryning-with-Warton Neighbourhood Plan Steering Group to identify a site for local
employment needs.
Page 114 – Policy EC1 – it was AGREED that further evidence, supplied by objectors, needed
to be assessed further before a final decision could be reached.
Page 117 – It was AGREED that the officers would look further at the employment land
evidence.
Page 125 – Policy EC4 – Recommendations for change – it was AGREED to
o add a threshold of 750m2 of retail floor-space.
o to improve the clarity of the terminology in reference to key service areas, district
centres, local centres, settlement areas etc.
o to add the monitoring of retail floorspace to the Performance Monitoring
Framework in Appendix 5.
o to add the monitoring of retail floorspace of St Annes and Kirkham, not just Lytham.
5. Date of next meeting
It was AGREED that the next meeting of the Group be held (16:00- 19:00) on Tuesday, 10 June in the
Reception Room, Town Hall.
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Appendix 1
Notes of the
Date:
Tuesday, 10 June 2014
Venue:
Reception Room, Town Hall, St Annes
Group members:
Development
Aitken
Councillors Christine Akeroyd, Julie Brickles, Alan Clayton, Peter
Collins, Fabian Craig- Wilson, Charlie Duffy, Angela Jacques, Linda
Nulty, Elizabeth A Oades, Richard Redcliffe,
Officers:
Allan Oldfield, Paul Walker, Mark Evans, Julie Glaister, Mark Sims,
Michael Eastham, Nicola Martin, Fiona Riley, Lyndsey Lacey
1. Apologies
Apologies were received from Councillors Tim Armit, Maxine Chew, Barbara Nash, Albert Pounder,
Heather Speak and Vivienne Willder.
2. Introductions
Councillor Dr Fiddler (Portfolio Holder for Planning and Development) introduced the meeting by
making reference to the conclusions of the previous meeting with particular reference to the
deletion of site H7- Land North of Dowbridge, Kirkham from the plan (for residential development).
The employment land at Kirkham Triangle will be removed and this land should instead be identified
for residential development. That is the whole of the site will be residential. In addition, issues
attached to the scale of development at Warton and the viability for development at sites such as
Great Birchwood and the Cropper Road area were considered. The need to further look at the
feasibility/need for a further secondary school in the area was highlighted which was currently being
investigated by Councillor Redcliffe.
Councillor Fiddler then went on to invite the group to consider the detail in the Preferred Option
Consultation Paper on a page by page basis starting from page 130 where discussions had concluded
at the last meeting.
Appendix 1
3. Fylde Local Plan to 2030: Part 1 - Preferred Options Consultation- Draft Consultation Statement
Members had before them a copy of the Draft Consultation Statement and were invited to further
comment on each page of the document. Within the time specified, the Group considered page 130
to the end of the document and made the following recommendations:
1. To include a reference to the County Council’s emerging supplementary planning document on
shale gas exploration and extraction in Chapter 1.
2. To agree that there should not be a definition of ‘rural worker’ in the Local Plan and that this be
left to the discretion of the Development Management Committee when determining individual
planning applications.
3. To arrange a further meeting of the Group as soon as possible to revisit/consider the
Employment Land Assessment/ housing land supply figure.
4. To request officers to make an assessment of the suggested further sites submitted by
developers, landowners and local residents, map all of them and report back to the Group.
5. To resolve the ‘Members’ Decision’ on an alternative name for the area currently labelled as
“Blackpool Periphery”.
6.
To agree in principle with the concept of reducing the proposed scale of development at Warton
which supports the Warton Neighbourhood Plan and that a figure of around 650 is deemed a
more acceptable figure than the figure of 1160 detailed in the Preferred Options Document.
7. To set up a meeting between officers from Lancashire County (Highways) and members and
officers at Fylde Council to discuss/consider the current consultation exercise into the Preston
Western Distributor road, the East-West Link Road and Cottam Link Road and the associated the
impact on accessibility and connectivity between Central Lancashire and Fylde. The current
consultation exercise ends on 13th July 2014.
8. To circulate to the Steering Group an updated revised version (with tracked changes) of the
Fylde Local Plan to 2030: Part 1 – Preferred Options consultation – Draft Consultation Document
– Section A: Summary of Consultation to allow further consideration by Group with a view to
signing off by the Portfolio Holder/ Executive.
9. To seek Full Council’s endorsement of the revised version of the Preferred Options Document
and also approval to go out for further public consultation.
10. To further explore/revisit with the Portfolio Holder for Planning and Development and the
Chairman and Vice-Chairman of the Development Management Committee the criteria for
dealing with deferred motions/ public speaking protocol at Development Management
Committee with a view to providing committee with further guidance in due course.
---------------------------------------------
Appendix 2
Fylde Local Plan
Steering Group
Briefing Note
Fylde Employment Land and
Premises Study
A draft report to the Portfolio Holder in regard to a representation referring to the Fylde
Employment Land and Premises Study is attached.
Appendix 2
REPORT
REPORT OF
MEETING
DEVELOPMENT
SERVICES
DRAFT PORTFOLIO HOLDER REPORT
DATE
EMPLOYMENT LAND EVIDENCE BASE UPDATE
SUMMARY
In May 2014 a representation to the Fylde Employment Land and Premises Study (FELPS) was
received from a local resident. The Portfolio Holder requested that that the representation be
considered separately to the Local Plan - Preferred Options - Consultation Feedback. Consideration
and a proposed response to the representation is set out in this report.
RECOMMENDATION
1. That the Portfolio Holder considers this report and endorses the commentary set out under
section 2 i) – vi) to be sent to the author of the representation as the Council’s considered
response to his representation and that the Fylde Employment Land and Premises Study (July
2012) be retained in the Council’s evidence base.
CABINET PORTFOLIO
This item falls within the following cabinet portfolio(s):
Planning and Development
Councillor Dr Trevor Fiddler
SUMMARY OF PREVIOUS DECISIONS
6 August 2012
Following detailed consideration IT WAS AGREED –
1. To note the report and acknowledge the publication of the Fylde Employment Land and
Premises Study (July 2012).
2. To thank Mr Peter Crompton and Dr Chris Wilson of BE Group and Mr Kevin Riley of AECOM
for the comprehensive report and their attendance at the meeting.
Appendix 2
REPORT
1.
Background
1.1 The Fylde Employment Land and Premises Study 2012 since its completion has been used for the
purposes of development management and policy preparation. The policies in the Fylde Local
Plan to 2030, Part 1 – Preferred Options (June 2013) used the study as part of its comprehensive
evidence base. Consultation on the Local Plan Preferred Options document and its associated
evidence base took place 27 June – 22 August 2013.
1.2 In May 2014, after the formal consultation period had closed, a representation to the Fylde
Employment Land and Premises Study (FELPS) was received from a local resident. At the
request of the Portfolio Holder, this representation is being considered separately to the Local
Plan - Preferred Options - Consultation Feedback.
1.3 The representation is both substantial in its volume (16 pages) and detailed in its content. In
summary six main points are raised, each of which are then rehearsed in detail. By
considering and addressing each of the six points the Council will be able to form a view
relating to its own evidence base.
2.
The Issues raised
2.1 This section of the report sets out each of the six points raised as part of the representation.
They are shown in bold font and the proposed response is set out under each.
i)
The Grimley study of 2006 contained a major error that led it to significantly overestimate the
amount of land required to meet future employment demands in the period 2005 -2015.
This issue has not been addressed in detail as part of this report. The Fylde Local Plan to 2030,
Part 1 has not relied upon the GVA Grimley Study (2006). This study was superseded by the Fylde
Employment Land and Premises Study 2012.
ii) FBC compounded and magnified this error in its contribution to the 2010 Sub region Review by
using it as the basis of an unsound extrapolation to predict the amount of additional
employment land required by 2027.
This issue has not been addressed in detail as part of this report. The Fylde Local Plan to 2030,
Part 1 has not relied upon the Sub regional Review (2010). This Review was superseded by the
Fylde Employment Land and Premises Study 2012.
iii) AECOM/BE Group used 7 different models to predict the need for additional employment land
in the period to 2030. Two show we will not need any more employment land and can release
up to 29ha of the land currently in use; four predict that we will only need to use a fraction
(about a quarter) of the 22.3ha of employment land already identified as becoming available
under existing plans; one model (based on historic employment land take-up) shows that we
will need more than twice as much land as is currently identified as becoming available (a total
of 48.6ha). Bizarrely this latter model has been used without amendment as the basis of the
study’s recommendation.
Appendix 2
Paragraph 10.39 of the FELPS explains why BE Group have recommended using the historic takeup trends. Ultimately, in other comparable local authority areas they have discounted the use of
employment and labour supply models which have generated unusually negative outcomes.
From a Fylde perspective negative outcomes do not square with the vision in the Fylde Local Plan
to 2030, Part 1 – Preferred Options (June 2013). The vision for Fylde to 2030 includes the
following aspirations specific to employment land:
“Station facilities at Kirkham and Wesham will have been improved, making the town
more accessible to other parts of the North West and increasing its sustainability as a
residential and employment centre.
Opportunities for sub-regionally important employment at BAE Systems at Warton,
Blackpool International Airport and Whitehills will have been realised and employment
will have been provided close to where people live.
There will have been proportionate levels of employment growth to strengthen and
diversify the local economies and reduce the need to travel.”
The Local Plan vision is a positive statement of how the Council wants the borough to be in
2030. Clearly Fylde is a place which aspires to growth. It wants to show it is open for
business and employment land provision is part of that vision.
In support of the above is the Council’s Economic Development Strategy 2012 – 2030
(January 2013). It aspires to the following:
“The economy of Fylde will be dynamic; providing economic growth, wealth creation
and employment opportunities for a growing population from 2012 to 2030. This
growing population will have the opportunities to ‘up-skill’ to meet the changing
economic circumstances throughout this period and experience a quality of life in excess
of that available in most of the rest of the UK. The Fylde will have the reputation of an
area that embraces development and investment and is seen as a destination of choice
for many businesses across many sectors.”
Under the provisions of the Duty to Co-Operate, a Memorandum of Understanding (MoU)
between Blackpool Council, Fylde Borough Council, Wyre Borough Council and Lancashire County
Council has been drafted and agreed by this Council’s Executive. The MoU addresses a number
of areas for co-operation between the authorities, but with specific regard to business and
industrial development, the MoU addresses sub-regional employment land requirements;
strategic priorities to strengthen the Fylde Coast economy around Junction 4 of the M55/
Fylde/Blackpool boundary; promotion of sustainable development on key strategic sites
/corridors such as the Blackpool Airport corridor – Fylde/Blackpool boundary; The Lancashire
Enterprise Zone, Warton and potential employment development at Whyndyke Farm.
The methodology utilised in assessing the historic take up of land in the FELPS included the motor
vehicle franchises that have been developed at Whitehills as employment uses. This is because
they are mixed uses involving an element of B2 use in the servicing and maintenance of motor
vehicles and B1 uses related to administration. It is considered that this approach is justified,
however, if a counter approach is taken and these sites are excluded in their entirety, the historic
take up figure would be reduced from 2.7ha per annum to 2.5 ha per annum. This would reduce
Appendix 2
the amount of employment land required during the plan period by 3.8 ha. An alternative
approach would be to calculate the amount of land used for B1 and B2 uses, i.e. excluding the
sales showrooms, and calculate the land take-up accordingly. Whilst this exercise has not been
undertaken, it is estimated that about 50% of the area of these sites is used as showroom, which
would mean a reduction of 1.9 ha.
iv) When the historic land take-up model is amended to account for land lost to employment use
(based on FBC’s own figures), it also predicts a reduction in the amount of employment land
required over the period to 2030. The true significance of the historic land take-up data is that
they record the migration of employment land at a progressively reducing rate from older sites
to new sites.
No weight should be given to the above statement as it is logically flawed. Historic land take-up is
a measure of the amount of land developed for employment uses in any given year and is
presented in the Council’s annual Business and Industrial Land Schedule (Section 4). This is not a
measure of the migration of firms as suggested above. Demand or take-up can be the result of
new investment by firms from outside the Borough, speculative development or expansion of
firms within the Borough who can either continue to occupy their existing premises/site or
vacate, not migration. Any vacated premises or sites could be subject to re-occupation by
businesses and this need or demand would not be shown in the Council’s annual Business and
Industrial Land Schedule as new demand or need for land.
Where a site or premises is no longer used for an employment use this is recorded in the
Council’s annual Business and Industrial Land Schedule (Table 1 below). It is not however ‘netted
off’ on an annual basis, rather this exercise is performed as and when needed through the
production of an Employment Land Study (ELS). This is set out in Section 6 of the Council’s most
recent ELS.
Table 1: Land lost to Business and Industrial Use Since Mid-Year 2001
Hectares
Car Showrooms, Whitehills
Guardian, Ballam Road, Lytham
Cooksons Bakery Site, Preston Road, Lytham
Retail Applications, Whitehills Park
Whitehills Park, Health and Fitness Racquet Club
Lytham Quays, Dock Road, Lytham - Housing
Former Holt Jacksons, Preston Road, Lytham - retail
5.0
0.6
5.2
0.2
1.7
2.3
0.5
Units 1, 2 & 3 Lytham Trade Park, Preston Road, Lytham - C/U to D2
0.4
Waltons Coaches, Naze Lane Industrial Estate, Freckleton - B1, B2 & B8 to
Coach Repair
0.7
Units 2 & 4 Naze Lane Industrial Estate, Naze Lane, Freckleton - C/U from B2 to
Bus/Coach repair
Electronic Data Systems, Heyhouses, St Annes, Mixed Use Housing/Retail
Total
0.1
7.3
23.8
Source: Fylde Borough Council, Business and Industrial Land Schedule 2012-2013. Summary Table, page 20.
v)
In the period to 2030 the weight of evidence predicts a reduction in the amount of
employment land required notwithstanding a predicted increase in employment in the
Appendix 2
Borough. Some movement from existing sites to new ones will continue albeit at a reducing
rate and it would be sensible to use the additional land already identified (22.32ha) to provide
the flexibility to deal with these changes rather than immediately allocate it to other uses.
There is no requirement to allocate any further land to employment use.
No weight should be given to the above statement. It is incorrect, not substantiated by
evidence and fails to understand the actual workings of the commercial property market and
more broadly the development industry. The FELPS clearly and methodologically sets out how
the need for additional employment land is generated and clearly states that there is a
requirement for additional land during the plan period (to 2030) for the Borough of Fylde.
The scenario above is predicated on there being a declining demand for employment land and
uses the findings of the economic forecasting within the FELPS as a basis for this. The forecasts
are set out in Section 10 of the FELPS. All economic forecasting is uncertain and in the case of
the FELPS these predictions are based on the best available evidence at the time. The FELPS
does not recommend taking a ‘weight of evidence’ approach to incorporating the findings of
the forecasting models. Rather it suggests that the forecasting models, inherently uncertain,
should be considered (a requirement of the NPPF) but that in the experience of the authors the
historic land take-up model has been used. Much of the narrative within Section 10 of the FELPS
illustrates the limitations of the models in predicting future demand for employment land.
vi) Most of the new employment sites brought forward in the last 20 years have been situated in
the North of the Borough on or close to the boundary with Blackpool and the M55. Since these
sites have been open to occupation by businesses from Blackpool and Fylde, they have been
serving the Blackpool requirement for employment land as well as that of Fylde for many
years now. There is no requirement to make separate special provision over and above the
conclusions drawn from the existing data.
The first sentence of the above is an acceptable account of events, the second fails to
understand the exercise undertaken by the FELPS. The historic development pattern for
employment land has shown a preference for allocations of new sites at or around the M55
junction with a loss in and around the settlements of Lytham and St Annes. This is probably a
product of both market pressure on historic employment sites (greater land values for housing)
and policy making by the Council (strategic allocation of Whitehills circa 2003).
Evidence presented in the FELPS and also the Whitehills Development Appraisal (October 2013)
supports the statement that the vast majority of firms that have located in that area have come
from the Boroughs of Blackpool and Fylde and to a lesser extent Wyre. However this does not
support the conclusion that this essentially removes the need for employment land for
Blackpool and Fylde. The need or demand for employment land, as derived from the historic
take-up model in the FELPS, shows the demand for employment land within the boundaries of
Fylde. The FELPS methodologically sets out the need for additional employment land to meet
this demand or need for the Borough of Fylde. This same exercise has been undertaken at
Blackpool Council and their ELS methodologically sets out the need for additional employment
land to meet this demand or need for the Borough of Blackpool. The fact that businesses,
largely ignorant of Borough boundaries, have chosen to locate in one Borough or the other does
not affect this ‘calculation’.
Blackpool Council’s ask of Fylde Council to accommodate 14 hectares of its employment land
requirement on lands in Fylde is based upon historic land take-up in Blackpool.
Appendix 2
3.
Conclusion
3.1 It is proposed that the commentary set out under section 2 i) – vi) above be sent to the author
of the representation as the Council’s considered response to his representation. It remains
that the Fylde Employment Land and Premises Study 2012 is considered to be a robust part of
the emerging Local Plan’s evidence base.
3.2 If the author of the representation should decide to pursue his challenge to this, or any other,
part of the emerging local plan’s evidence base, there will be ample opportunity for him to
comment upon it through the formal consultation process. It is likely that the Council will carry
out further consultation based upon a reappraisal of the strategic options for the Borough.
IMPLICATIONS
Finance
None arising directly from the report.
Legal
Community Safety
Human Rights and Equalities
Sustainability and Environmental Impact
Health & Safety and Risk Management
REPORT AUTHOR
TEL
DATE
Mark Sims
01253 658656
July 2014
LIST OF BACKGROUND PAPERS
Name of document
Employment Land Note
Submitted by Mr Tony
Guest
Date
Where available for inspection
May 2014
Planning Policy Office
DOC ID
Appendix 3
Fylde Local Plan
Steering Group
Briefing Note
Gypsy and Traveller
Accommodation Assessment
A draft report to the Portfolio Holder in regard to the revised Gypsy and Traveller
Accommodation Assessment is attached.
1
Appendix 3
REPORT
REPORT OF
DEVELOPMENT
SERVICES
DATE
Draft Portfolio Holder Decision
FYLDE COAST AUTHORITIES GYPSY, TRAVELLER AND TRAVELLING
SHOWPEOPLE ACCOMMODATION ASSESSMENT (GTAA)
REPORT
Portfolio Holder Decision
SUMMARY
To inform the Portfolio Holder of the findings of the Fylde Coast Authorities Gypsy, Traveller and
Travelling Showpeople Accommodation Assessment (GTAA) and to seek approval to circulate
the GTAA to Lancashire Authorities for comment in line with the provisions of the Duty to Cooperate.
RECOMMENDATION
1. That the Portfolio Holder accepts the findings of the GTAA; and
2. That the Portfolio Holder approves the GTAA for circulation to Lancashire Authorities under
the Duty to Co-operate on strategic planning issues, which was introduced through the
Localism Act and the National Planning Policy Framework (the NPPF).
CABINET PORTFOLIO
This item falls within the following cabinet portfolio(s):
Planning and Development
Councillor Dr Trevor Fiddler
SUMMARY OF PREVIOUS DECISIONS
None
2
Appendix 3
Report
1. Fylde Borough Council, Wyre Borough Council and Blackpool Council (the Fylde Coast
Authorities) jointly commissioned consultants, Opinion Research Services (ORS) to carry out a
Gypsy, Traveller and Travelling Showpeople Accommodation Assessment (GTAA). It is intended
that the GTAA will form part of the evidence base for the Fylde Local Plan to 2030 (Part 1).
2. The principle purpose of the GTAA is to inform the development of local plan policy in the Fylde
Coast sub-region relating to Gypsies, Travellers and Travelling Showpeople in accordance with
the NPPF and Planning Policy for Traveller Sites, 2012. The GTAA provides an up-to-date
understanding of the likely permanent and transit accommodation needs of Gypsies, Travellers
and Travelling Showpeople within the sub-region as a whole and for each of the three local
authorities. The study also provides an evidence base to enable the authorities to comply with
their requirements towards Gypsies and Travellers and Travelling Showpeople under the
Housing Act, 2004. Planning Policy for Traveller Sites says that local planning authorities should
identify a supply of deliverable sites sufficient to provide five years-worth of sites, identify a
supply of specific developable sites or broad locations for years 6-10 and where possible years
11-15.
3. The consultants, ORS, methodology for carrying out the GTAA consisted of a 7 stage process:
Stage 1: Desk Based Research
Stage 2: Stakeholder Engagement
Stage 3: Working collaboratively with Neighbouring Planning Authorities
Stage 4: Survey of Travelling Communities
Stage 5: Bricks and Mortar Households (i.e. currently own or rent a house, flat or bungalow)
Stage 6: Current and Future Pitch/Plot Requirements (supply of pitches, current / future need)
Stage 7: Conclusions.
4. In Fylde, 31 Gypsy and Traveller caravans were recorded as being on private sites without
planning permission in July 2013. There were also 12 caravans on sites with permanent planning
permission. The setting up of the unauthorised site at Angels Lane, in Hardhorn first occupied in
November 2009 included 15 pitches (15+ households).
5. There are two existing Gypsy and Traveller sites in Fylde, which together amount to 21 pitches:
The Conifers on Bambers Lane has 6 plots on a private site with planning permission. Angel Lane
Caravan Park has 15 pitches, but this constitutes an unauthorised development.
6. There is one existing private yard with permanent permission, incorporating two plots, for
Travelling Showpeople at Chain Lane in Fylde.
7. Part of the GTAA focusses on the extra site provision for Gypsies, Travellers and Travelling
Showpeople required in the Fylde coast sub-region over a 17 year period. The estimated extra
pitch provision required for Gypsies and Travellers in the Fylde Coast over the next 17 years is 82
pitches to address local needs. A total of 26 extra pitches are required in Fylde up to the year
2031: 17 of which need to be delivered in the period 2014-2019, 3 more are needed in the
period 2019-2024, 4 more pitches in 2024-2029, and 2 additional pitches in 2029-2031.
3
Appendix 3
8. The estimated extra residential plot provision required for Travelling Showpeople in the Fylde
Coast over the next 17 years is 14 plots, to address local needs. No extra plots are required for
Travelling Showpeople in Fylde over the next 17 years to 2031.
9. The GTAA recommends that the Fylde Coast Authorities use appropriate resources to help
develop closer working relationships, for instance, the three authorities should work together to
collate data on unauthorised encampments. The GTAA also recommends that the Lancashirewide Gypsy and Traveller Forum, which has met once, be continued.
10. Appendix 1 to this report comprises the draft GTAA.
Conclusion
11. It is proposed to circulate the GTAA to Lancashire Authorities, following which the document will
be adopted as part of the evidence base for the Local Plan (Part 1).
IMPLICATIONS
Finance
Legal
Community Safety
Human Rights and Equalities
REPORT AUTHOR
TEL
DATE
Mike Eastham
01253 658695
July 2014
DOC ID
Name of document
Gypsy , Traveller and
Travelling Showpeople
Accommodation
Assessment (GTAA)
Date
Planning Policy Office
June 2014
Attached document
Fylde Coast Authorities Gypsy and Traveller and Travelling Showpeople DRAFT Accommodation
Assessment, June 2014. (This item is available to view on a secured link)
4
Appendix 4
Fylde Local Plan
Steering Group
Briefing Note
Blackpool Local Plan/Core
Strategy Consultation
The attached briefing note sets out a proposed response to Blackpool Council’s consultation
in regard to their local plan/core strategy and Draft Statement of Compliance with the Duty
to Co-operate.
Appendix 4
BLACKPOOL COUNCIL CONSULTATION JULY – AUGUST 2014.
BLACKPOOL LOCAL PLAN PART 1: CORE STRATEGY - PROPOSED
SUBMISSION.
DRAFT STATEMENT OF COMPLIANCE WITH THE DUTY TO COOPERATE.
- BRIEFING NOTE
SUMMARY
Blackpool Council has prepared the Blackpool Core Strategy – Proposed Submission, which it
intends to submit to the Secretary of State for Examination. The purpose of the examination is to
consider whether the Core Strategy is legally compliant, satisfies the Duty to Co-operate and meets
the tests of soundness.
Representations are invited on the Proposed Submission and various supporting documents.
As a neighbouring Authority to Blackpool, Fylde Borough Council has along with other prescribed
bodies, also been consulted on the draft Statement of Compliance with the Duty to Co-operate.
This document forms part of the comprehensive evidence base to the Core Strategy.
Consultation on these documents is taking place from Friday 4th July 2014 to 5pm Friday 29th August
2014.
It is proposed that:
1. That the response, as set out in Appendix 1 to this report, be sent as Fylde Borough Council’s
response to Blackpool Council’s Consultation on Blackpool Core Strategy – Proposed
Submission; and
2. That the response, as set out in Appendix 2 to this report, be sent as Fylde Borough Council’s
response to Blackpool Council’s Consultation on draft Statement of Compliance with the Duty to
Co-operate.
REPORT
Background
Appendix 4
1.
The Core Strategy is a key planning document for Blackpool and sets out where new development
including housing, employment, retail and leisure should be located to meet Blackpool’s future
needs to 2027. It identifies areas which will be regenerated, protected or enhanced and sets out
key development principles such as design and affordable housing. The Core Strategy will be used
to determine planning applications and priorities for the Borough over the next 15 years.
2.
This report refers to two documents:i) Blackpool Core Strategy – Proposed Submission, together with the necessary supporting
documents. The extensive list of supporting documents, all of which are substantial in their
content, are referenced under ‘Background Papers’. Rather than this report address each of these
supporting documents, they have only been referred to if there is a particular matter of relevance
to Fylde Borough.
ii) Draft Statement of Compliance with the Duty to Co-operate – which sets out how Blackpool
Council has worked, and continues to work, with neighbouring authorities in order to comply with
the Duty to Co-operate.
3.
In addition to the above Blackpool Council is also undertaking consultation on the draft Statement
of Community Involvement (SCI). It sets out how and when the community and other stakeholders
will be consulted on the preparation and revision of planning documents that make up the
Blackpool Local Plan and how the community will be consulted on planning applications. It is
proposed that Fylde Borough Council has no observations to make in respect of the SCI.
BLACKPOOL CORE STRATEGY – PROPOSED SUBMISSION
4.
Comments at the Proposed Submission stage should only be made in relation to the issues outlined
below, which will be considered by the appointed Inspector, whose role is to assess whether the
Local Plan has been prepared in accordance with the Duty to Co-operate, meets the legal and
procedural requirements, and is a sound planning document.
Duty to Co-operate - Blackpool Council has a Duty to Co-operate on strategic planning issues that
cross into neighbouring areas. This includes working collaboratively with Fylde Borough Council and
other neighbouring councils to ensure that strategic priorities across local boundaries are properly
co-ordinated and clearly reflected through the Core Strategy.
Observations relating to the Duty to Co-operate are specifically addressed below under ’draft
Statement of Compliance with the Duty to Co-operate’.
Legal and procedural compliance - the Core Strategy will be checked to ensure it is legally
compliant and has:
• been prepared in accordance with the Council’s Local Development Scheme and in general
compliance with the Statement of Community Involvement;
• been subject to a Sustainability Appraisal;
• had regard to national policy
Comments relating to the way Blackpool Council has prepared the Core Strategy are likely to be a
matter of legal and procedural compliance. In terms of Fylde Borough Council’s opportunity to
Appendix 4
comment upon and influence the preparation of Blackpool’s Core Strategy, it is noted that
Blackpool Council has undertaken extensive consultation on the progression of the Core Strategy to
date. Previous key consultations have involved the Issues and Options (2008); Preferred Option
(2010) and Revised Preferred Option (2012) stages.
Soundness - to be found sound the Core Strategy must be:
• Positively prepared - the Core Strategy should be prepared 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 Core Strategy should be the most appropriate strategy, when considered against
the reasonable alternatives, based on proportionate evidence;
• Effective – the Core Strategy should be deliverable over its period and based on effective joint
working on cross-boundary strategic priorities; and
• Consistent with national policy – the Core Strategy should enable the delivery of sustainable
development in accordance with the policies in the National Planning Policy Framework (2012).
Comments relating to the actual content of the Local Plan are likely to be concerned with the
soundness of the Plan.
Content of the Core Strategy
5.
The Core Strategy is underpinned by four goals:
• Sustainable regeneration, diversification and growth;
• Strengthen community wellbeing to create sustainable communities and reduce inequalities in
Blackpool’s most deprived areas;
• Regeneration of the town centre, resort core and inner areas to address economic, social and
physical decline; and
• Supporting growth and enhancement in South Blackpool to meet future housing and
employment needs for Blackpool and the Fylde Coast.
The core policies which support these include, amongst other things the following:
Housing Provision – 4,200 new homes between 2012 and 2027. (280 new homes per annum).
Urban Area
South Blackpool Growth Area
Windfall
Number of homes
1,950
750 (including 150 on Whyndyke Farm)
1,500
Economic Development and Employment – Safeguarding 180 Ha of existing industrial/business
land; Promoting office development in the town centre; and Promoting South Blackpool as an
employment opportunity. Providing for future requirements of employment land as follows:
Employment land needed to 2027
Ha
31.5
Appendix 4
Supply of employment land
17.8
Shortfall
13.7
It is understood that Fylde will provide for this shortfall, which will be added to Fylde’s requirement
over our Local Plan period to 2030.
Retail and Other Town Centre Uses - Protecting the vitality and viability of the town centre. The
2011 Fylde Coast Retail Study identifies capacity for additional retail growth in the town centre of
16,390 square metres of comparison goods floor space to 2021.
6.
Blackpool’s future growth development and investment will be focused on inner area regeneration,
comprising: Blackpool Town Centre, The Resort Core and Neighbourhoods within the inner area.
Chapter 8 of the Core Strategy ‘South Blackpool Growth Area’ is being promoted to help meet
wider housing and employment needs.
Enabling South Blackpool Growth and Enhancement
7.
Chapter 8 of the Core Strategy ‘Enabling South Blackpool Growth and Enhancement’ concerns
employment growth and housing growth on lands on the Blackpool/Fylde boundary, extending
from junction 4 of the M55 along the Blackpool Airport corridor and includes Marton Moss. This
whole growth concept in this area is predicated upon several things:
• Marton Moss 600 homes;
• Whyndyke Farm 150 homes; and
• Major new business/industrial development at Blackpool Airport Corridor (Squires Gate
Industrial Estates and Blackpool Business Park) and Land at M55 Junction 4 (Preston New Road,
Clifton Road Sites).
Key to the above is the wider development on land within Fylde, including 14ha of employment
land around junction 4 of the M55 to meet Blackpool’s requirements to 2027; and Whyndyke Farm
accommodating a total of 1,500 dwellings.
8.
Comments relating to the Blackpool Core Strategy – Proposed Submission are included in Appendix
1 to this report.
CORE STRATEGY – SUPPORTING DOCUMENTS
Infrastructure and Delivery Plan
9.
The Infrastructure and Delivery Plan (IDP) for the Blackpool Local Plan Part 1: Core Strategy seeks to
establish what additional infrastructure and service needs are required to support the overarching
strategy for new homes and jobs in the Borough to 2027.
10. The term ‘infrastructure’ includes ‘physical’ infrastructure such as road and rail needs, flood
alleviation, electricity and gas supply, and waste water; ‘social’ infrastructure such as education,
health and community facilities and 'green' infrastructure such as parks, playing fields, allotments,
Appendix 4
public open space and footpaths/cycle ways. Comments relating to cross boundary infrastructure
of regional and sub‐regional significance, are included in Appendix 1 to this report.
Sustainability Appraisal
11. The Sustainability Appraisal (SA) evaluates the likely social, economic and environmental effects of
the spatial vision, objectives and policies, including the cumulative effects. The latest SA Report
(May 2014) has been produced for the Proposed Submission and is accompanied by a NonTechnical Summary. Blackpool Council has responded to the SA recommendations in a separate
paper, including changes made to the policies where appropriate. Comments relating to cross
boundary SA matters are included in Appendix 1 to this report.
DRAFT STATEMENT OF COMPLIANCE WITH THE DUTY TO CO-OPERATE
12. It is considered that Blackpool Council has complied with the guidance set out in the National
Planning Policy Framework (the NPPF) “on planning issues that cross administrative boundaries,
particularly those which relate to the strategic priorities set out in paragraph 156” (p37, NPPF). The
five strategic priorities comprise: the homes and jobs needed in the area; and the provision of
retail, leisure and other commercial development; the provision of infrastructure for transport,
telecommunications, waste management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat); the provision of health,
security, community and cultural infrastructure and other local facilities; and climate change
mitigation and adaptation, conservation and enhancement of the natural and historic environment,
including landscape.
13. The three Fylde Coast Authorities (i.e. Blackpool, Wyre and Fylde) have established a draft
Memorandum of Understanding (MoU), so as to assist in meeting the requirements of the Duty to
Co-operate and to formalise the ongoing dialogue and co-operation that currently exists for those
strategic planning issues which require cross boundary co-operation and collaboration to ensure the
requirements of the Duty are met. It is considered that Blackpool Council has worked with the two
neighbouring Fylde coast authorities within the framework of the MoU in producing its core
strategy/local plan.
Conclusion
14. At the time of preparing this report it is not considered appropriate nor necessary to raise an
objection to the Blackpool Core Strategy – Proposed Submission.
From a Fylde Borough
perspective it is not considered that the Core Strategy raises issues in respect of being legally
compliant, satisfying the Duty to Co-operate or meeting the tests of soundness. The response
included at Appendix 1 has therefore been drafted as comments, including points of clarification
and correction of factual inaccuracies, for observation by Blackpool Council.
15. It is considered that the draft Statement of Compliance accurately reflects the engagement that
Blackpool Council has undertaken with Fylde Borough Council. It is proposed that Fylde Council
raises no objection to the level of co-operation undertaken by Blackpool Council, which is set out in
the Statement of Compliance with the Duty to Co-operate.
Appendix 4
16. Subject to the discussion and input of the Local Plan Steering Group, it is proposed that the
observations made in appendices 1 and 2 are presented as Fylde Borough Council’s response. In
the event that the Local Plan Steering Group should choose to raise an objection to either
consultation this would raise serious significant resource implications for Fylde Borough Council in
the form of officer time having to prepare for and participate in an Examination in Public.
Name of document
Blackpool Core Strategy –
Proposed Submission
Date
July 2014
www.blackpool.gov.uk/corestrategy
draft Statement of
Compliance with the Duty
to Co-operate
July 2014
draft Statement of
Community Involvement
http://www.blackpool.gov.uk/Residents/Planningenvironment-and-community/Documents/Duty-toCooperate-Draft-Statement-of-Compliance-June2014.pdf
July 2014
www.blackpool.gov.uk/planningconsultations
Statement of Consultation
(June 2014)
Schedule of Representations:
Revised Preferred Option
Proposed Submission Core
Strategy Sustainability
Appraisal: Non Technical
Report
Proposed Submission Core
Strategy Sustainability
Appraisal: Full Report with
Appendices
Blackpool Council Response
to the Proposed Submission
Core Strategy Sustainability
Appraisal (June 2014)
Proposed Submission
Habitats Regulation
Assessment (May 2014)
Infrastructure and Delivery
Plan (June 2014)
Local Development Scheme
Equality Analysis
APPENDICES:
Appendix 4
Appendix1: Response to Blackpool Core Strategy – Proposed Submission.
Appendix 2: Response to draft Statement of Compliance with the Duty to Co-operate.
Appendix 4
Appendix 1:
RESPONSE TO BLACKPOOL LOCAL PLAN PART 1: CORE STRATEGY - PROPOSED
SUBMISSION (JUNE 2014)
The opportunity to comment upon Blackpool Core Strategy’s Proposed Submission and supporting
documents is welcomed. It is not considered appropriate nor necessary to raise an objection to
the Blackpool Core Strategy – Proposed Submission. This response includes points of clarification and
correction of factual inaccuracies which may result in minor amendments to improve the clarity of the
documents without altering their substance.
Proposed Submission
• Fylde Borough Local Plan to 2030
Fylde Borough Council’s Local Plan Steering Group (LPSG) has considered the comments raised as a
result of the Preferred Option consultation. As a result of that deliberation the Portfolio Holder (PH)
is minded to reconsider the distribution of strategic housing and employment sites throughout the
borough. This would result in a re-examination of the strategic development sites at Warton and
Kirkham and the examination of potential additional development sites in the vicinity of the M55
junction 4/Whitehills. New data was published by the Office for National Statistics earlier this month
which may have implications for the Strategic Housing Market Assessment and the potential number
of houses to be delivered during the plan period. This will require further appraisal which will need to
be considered by the LPSG/PH. The PH has also asked officers to review the Employment Land Study
in the light of additional representations received by the Council. Accordingly it will be necessary to
carry out a reappraisal of these development options along with other factors and to carry out
further consultation in respect of them.
Presently the position which is recorded in the Preferred Option consultation statement is one where
Fylde Council agrees to refer to the sub-regional significance of Whyndyke Farm as a strategic site in
the justification to policy. Furthermore, Fylde Council has resolved to bring forward the phasing of
housing development at Whyndyke Farm from a projected commencement date of 2020 to a start
date of 2015. This will result in Whyndyke Farm being fully delivered and completed within the plan
period.
The reason for setting out the position above is to provide a context to the specific comments which
follow in respect of ‘Enabling South Blackpool Growth and Enhancement’.
• Enabling South Blackpool Growth and Enhancement
Key to the delivery of this area’s growth and the implementation of policies CS24 and CS25 is the
agreement which has been achieved via the Duty to Co-operate: Memorandum of Understanding
Appendix 4
(MoU) between the Fylde Coast Authorities and Lancashire County Council (2013).
acknowledged that it includes the following key issues:
It is
“To work together to agree the strategic priorities for land around junction 4 of the M55 –
Fylde/Blackpool boundary with the aim of attracting major new economic development to help
strengthen the Fylde Coast economy; and
Promote a strong and distinctive sustainable urban extension closely integrated with the surrounding
areas on land on the Fylde/Blackpool boundary around Junction 4 of the M55;“
Para 8.3 states “neighbouring authorities are co-operating over future development of lands…” and
para 8.7 refers to ”…new development on wider lands in neighbouring Fylde.” It is suggested that
the MoU and the Blackpool Core Strategy’s Proposed Submission place a different emphasis upon
what has been agreed to date. Agreeing strategic priorities, and promoting a sustainable urban
extension is different to Blackpool Council assuming that there will be strategic sites promoted and
for development on the Fylde-Blackpool Periphery.
Ultimately a final decision is yet to be made by Fylde Council on the location and quantum of
development lands which are to be promoted on lands in Fylde, including on the Fylde-Blackpool
Periphery.
To avoid confusion the document should be clear when it is referring to lands close to junction 4 of
the M55, whether it is referring to land located within the Blackpool boundary or land located within
Fylde Borough. If, as appears to be the case Blackpool’s Core Strategy is dependent upon the
allocation and development of lands in Fylde, then that too should be made clear.
• Figure 18: South Blackpool Growth and Enhancement - It should be noted that area ‘5 Whitehills
(Fylde)’ appears to illustrate the areas of employment and industry allocated by the saved policies
EMP1 and EMP2 of the adopted Fylde Borough Local Plan 1996 - 2006, Alterations Review, (2005).
You will be aware that Fylde Council’s Preferred Option consultation included proposed allocations
for employment land on the Fylde/Blackpool boundary. As set out previously Fylde Council is
reappraising its development options here and elsewhere.
• Para 8.16, states “The Fylde Local Plan identifies around 14ha of additional employment land close to
Junction 4 of the M55….” It is assumed that this referring to Fylde Council’s Preferred Options
document. This is an emerging plan which can only be afforded some material weight as Fylde
Council is reappraising its development options. It includes references to providing for Blackpool’s
shortfall in employment land on lands in Fylde at 5.16, 9.10 & 9.14. These reference are more
general in nature (land in, or land within the Fylde boundary). They do not specify precisely where
this provision is to be made, nor does it commit to it being close to M55 J4.
• Para 5.52 relies on the 2011 Retail Study which identifies 16,390 sq.m (gross) comparison floor space
for Blackpool town centre 2010 – 2021. You should be aware that the 2013 update of the retail
Study identifies -2,166 sq.m (net) Blackpool town centre 2013-2021.
Appendix 4
• There are references throughout to Fylde Council Core Strategy. Previously Fylde Council was
producing a Core Strategy however now it is referred to as a Local Plan and should be referenced
accordingly.
• Page 36 Strategic objective 17 states “Support economic growth at the Blackpool Airport Corridor and
on lands close to Junction 4 of the M55.”
As stated above a final decision is yet to be made by Fylde Council whether to promote development
in this area on lands in Fylde. To avoid confusion the document should be clear when it is referring
to lands close to junction 4 of the M55, whether it is referring to land located within the Blackpool
boundary or land located within Fylde Borough.
• Page 42, para 2 states “The Spatial Strategy indicates that, in the future, there may be scope to
develop a sustainable extension to the Blackpool urban area on land along the Blackpool/Fylde
boundary.”
A Sustainable extension along the Blackpool/ Fylde boundary would be dependent upon the
agreement of Fylde Council.
• Page 53, last para states “Policy CS25 also promotes the sustainable development of wider land to
support sub-regional growth.”
This is a particularly bold a statement, which if read correctly is promoting development of wider
land which presumably includes land in Fylde.
• Page 54, para 3 refers to “Policy CS25 promotes major redevelopment and enhancement of land
along the Airport corridor…”
This commentary appears to relate to policy CS24.
• Page 57, Table 5.9 under ‘Townscape and landscape quality in the borough’ para 3 of Causes
states “Development to the south of Blackpool would be a natural extension to the existing function
of the area, and all development would reflect the existing character.”
Clarity is needed with regard to what the ‘area’ is. Is it referring to land located within the Blackpool
boundary or land located within Fylde Borough, or both?
Infrastructure Delivery Plan
• It is noted that para 2.2.2 recognises the sub‐regional level shared infrastructure issues as including:
• “road capacity and infrastructure including the A585 and evaluating the M55 to Norcross Link
(Blue Route);
• improving rail accessibility to key national and regional centres and strengthening the role of the
South Fylde rail line; and
Appendix 4
• consideration of surface water drainage issues along the urban coastal belt;”
In respect of the A585 there appears to be no further reference to the proposed link road elsewhere
in the IDP. Notwithstanding the fact that the line of this route lies outside the Blackpool Plan area its
implementation will directly impact upon the movement of vehicles in and around Blackpool. It may
therefore be appropriate to refer to the Blue Route in more detail under the Transport section.
In respect of the South Fylde rail line it is noted that para 3.1.19 of the IDP states that “To increase
service frequency a passing loop would be required.” No further information is provided about this
elsewhere in the IDP. Also absent is any reference to a possible Tram/Train service on the South
Fylde Line. Paras 5.69 and 5.71 of the Proposed Submission Core Strategy, include details of both
tram/train technology and providing double-track or passing-loops. It is suggested that the IDP
should provide similar details.
• There are references throughout to Fylde Council Core Strategy, previously Fylde was producing a
Core Strategy however now it is referred to as a Local Plan and should be referenced accordingly.
• Para 2.3.1 states “Supporting growth and enhancement in South Blackpool to meet future housing
and employment needs for Blackpool and the Fylde Coast.” and 2.3.2 states “Pursuing South
Blackpool Growth to meet housing and economic needs as part of a sustainable urban extension on
the edge of Blackpool.”
Please refer to previous comments on the proposed Submission Core Strategy relating to Fylde lands
on the Blackpool/Fylde boundary and the need for Fylde Council to reappraise its development
options.
• Para 3.1.23 states that “Blackpool and Fylde Councils are working with the owners of the Airport to
identify opportunities for appropriate future growth and development to support and strengthen the
function of the airport, with a Masterplan currently being prepared which will include the
development of the 25 acre site on the north side of the airport. The sustainable development of this
site will be essential to support the long term future of the airport”
This suggests that Blackpool and Fylde Councils are committed to supporting development on land in
Blackpool Airport. Fylde Council has not committed to this at the present time. Also the statement
that the sustainable development of this site is essential to support the long term future of the
Airport is considered to be too strong a statement to give and would seem to pre-determine
proposed development there. It is suggested that the wording in para 8.13 of the Blackpool Core
Strategy’s Proposed Submission is more appropriate.
• Para 3.10.1 states “Concerns were raised regarding the wider development of lands around Junction 4
of the M55, the majority of which is located within Fylde Borough.”
Please refer to previous comments on the proposed Submission Core Strategy relating to Fylde lands
on the Blackpool/Fylde boundary and the need for Fylde Council to reappraise its development
options.
Appendix 4
• Para 4.6.3 states “The Whyndyke Farm allocation forms part of a wider development in Fylde of
around 1500 dwellings in total,” it is suggested that this should be clarified that this could change as
no planning application has been approved at Whyndyke Farm and numbers of dwellings could
change.
• Para 4.6.35 & Figure 20: Traffic assessment Study Area - This map should be caveated to say that this
technical study was undertaken based upon hypothetical development locations. Particularly in
respect of the sites in Fylde (Whyndyke Farm and Peel Hill) and as stated above, a final decision is yet
to be made by Fylde Council whether to promote development in this area on lands in Fylde.
Should you wish to discuss any of the matters raised in this response then please to not hesitate to
contact me. I hope that you find these comments helpful. Fylde Council looks forward to working
closely with Blackpool Council under the Duty to Co-operate and progressing the delivery of our
respective development plans and determination of cross-boundary strategic planning applications.
Appendix 4
Appendix 2:
PROPOSED RESPONSE TO BLACKPOOL DRAFT STATEMENT OF COMPLIANCE
WITH THE DUTY TO CO-OPERATE
Blackpool Local Plan 2012 – 2027 Part 1: Core Strategy
Statement of Compliance with the Duty to Co-operate
Draft
June 2014
Blackpool Council has complied with the guidance set out in the National Planning Policy Framework
(the NPPF) “on planning issues that cross administrative boundaries, particularly those which relate to
the strategic priorities set out in paragraph 156” (p37, NPPF). The five strategic priorities comprise: the
homes and jobs needed in the area; and the provision of retail, leisure and other commercial
development; the provision of infrastructure for transport, telecommunications, waste management,
water supply, wastewater, flood risk and coastal change management, and the provision of minerals and
energy (including heat); the provision of health, security, community and cultural infrastructure and
other local facilities; and climate change mitigation and adaptation, conservation and enhancement of
the natural and historic environment, including landscape.
The three Fylde Coast Authorities (i.e. Blackpool, Wyre and Fylde) have established a draft
Memorandum of Understanding (MoU), so as to assist in meeting the requirements of the Duty to Cooperate and to formalise the ongoing dialogue and co-operation that currently exists for those strategic
planning issues which require cross boundary co-operation and collaboration to ensure the
requirements of the Duty are met.
Fylde Council agrees that Blackpool Council has worked with the other two authorities of Fylde and
Wyre, which make up the Fylde Coast Authorities, in the preparation of joint key evidence base
documents.
Fylde Council agrees that ongoing collaboration is taking place between the three Fylde Coast
authorities and Lancashire County Council (the Highways Authority) on the preparation of the Fylde
Coast Highways and Transport Masterplan.
Appendix 4
Fylde Council also agrees that ongoing dialogue is taking place between Blackpool Council (and the other
two councils that make up the Fylde Coast Authorities) and the Lancashire Local Economic Partnership
(LEP), through the quarterly meetings of the Memorandum of Understanding officer meetings, and
through the preparation of the Strategic Economic Plan (SEP). In addition, good progress is being
achieved by the Blackpool, Fylde and Wyre Economic Development Company in the preparation of the
Fylde Coast Local Growth Accelerator Strategy and Action Plan.
Impact on Neighbouring Authorities
Fylde Council agrees with Blackpool Council at paragraph 3.15 of the Statement of Compliance with the
Duty to Co-operate that “there are some cross boundary strategic issues which require continued
collaboration and monitoring to demonstrate the legal compliance aspect of the Duty and the
soundness aspects of the Duty” and that this is in line with paragraph 182 of the NPPF. To this end,
Fylde Council has agreed to accommodate around 14 ha of Blackpool’s unmet employment land
requirement through strategic land allocations in the emerging Fylde Local Plan (Part 1).
Fylde Council supports Blackpool Council’s comments in Table A (page 10) that “Blackpool Council will
work with Fylde and Wyre Councils in meeting the needs of Travellers and Travelling Showpeople across
the Fylde coast sub-region, to ensure the requirements set out in the 2014 GTAA are met through the
local plan preparation”.
Fylde Council supports Blackpool Council’s comment in Table A (page 11) that “The Core Strategy
supports wider strategic improvements to [the transport] infrastructure in South Blackpool on the
Blackpool / Fylde boundary benefiting sub-regional connectivity”.
Fylde Council supports Blackpool Council’s comment in Table A (page 12) that “Ongoing collaboration
with neighbouring authorities, LCC, EA and UU to ensure the required water-related infrastructure is
delivered”.
Fylde Council supports Blackpool Council’s comment in Table A (page 13) that “Blackpool will be
accommodating some of the secondary educational needs of the proposed housing located within that
part of the Whyndyke Farm site that lies within Fylde. Collaboration is ongoing to finalise the nature of
this contribution”.
Fylde Council supports Blackpool Council’s comment in Table A (page 13) regarding the natural
environment: “The importance of land to the south of Blackpool around Whyndyke and Whitehills in
Fylde is acknowledged in the HRA as important for foraging Annex 1 bird species”.
Appendix 4
Level of co-operation
Fylde Council raises no objection to the level of co-operation undertaken by Blackpool Council, which is
set out in the Statement of Compliance with the Duty to Co-operate.
It is considered that the draft Statement of Compliance accurately reflects the engagement that
Blackpool Council has undertaken with Fylde Borough Council.
Appendix 5
Fylde Local Plan
Steering Group
Briefing Note
Bryning with Warton
Neighbourhood Plan
Consultation
The attached briefing note sets out a proposed response to Bryning with Warton
Neighbourhood Plan Steering Group’s consultation in regard to the preferred option of
the Bryning with Warton Neighbourhood Plan.
Appendix 5
BRYNING WITH WARTON DRAFT NEIGHBOURHOOD PLAN 2030
– BRIEFING NOTE
SUMMARY
Bryning with Warton Parish Council have produced a draft Neighbourhood Plan (Pre-submission
version) to cover their whole parish to 2030. The document is currently undergoing a six week
statutory consultation and the closing date is 20 August 2014.
The local planning authority is required to advise and assist communities in their neighbourhood
planning work. To meet this obligation at this current stage, it is considered appropriate for the
local planning authority to submit a formal consultation response to the Parish Council. It is
expected that this response will assist the Parish Council in producing their Submission version,
which would then be submitted to the local planning authority who are responsible for undertaking
a further six week consultation. The document would then undergo an examination, and if passed
and ratified by the community through a referendum, it would become part of the development
plan for the area.
It is proposed that the response, as set out in Appendix 1 to this report, submitted as the local
planning authorities response to Bryning with Warton draft Neighbourhood Plan 2030 in
accordance with this Council’s approved scheme of delegation.
1. BACKGROUND TO NEIGHBOURHOOD PLANNING
1.1 Neighbourhood Planning is a new way for communities to shape the future of the places where
they live and work. Neighbourhood Planning cannot be used to stop development happening;
however, it will allow communities to decide where they want new development to be built and
what those new developments should look like.
1.2 The Neighbourhood Planning provision is set out in the Localism Act 2011 which amended the
Town and Country Planning Act 1990. The Neighbourhood Planning (General) Regulations 2012
set out the detailed arrangements which Neighbourhood Planning will have to follow.
1.3 The parish council will be the responsible body for producing a Neighbourhood Plan. In areas
where there is no parish council, a neighbourhood forum can be established, providing the
forum consists of a minimum of 21 individuals who live, work or represent the area and meets
the requirements of Part 3 of The Neighbourhood Planning (General) Regulations 2012.
1.4 At the start of the Neighbourhood Planning process, the Regulations require the responsible
body to designate the area which they intend to produce a Neighbourhood Plan for. This is
undertaken by an application to the local planning authority.
1.5 The Neighbourhood Plan will also undergo public consultation and be independently examined
before a public referendum is undertaken to seek community approval.
1.6 Neighbourhood Plans differ from Parish Plans because once the plan is agreed and all the
requirements are met, it will form part of the statutory Development Plan. The Neighbourhood
Development Plan will then be used in the determination of planning applications in that area.
Appendix 5
2. PROGRESS ON BRYNING WITH WARTON NEIGHBOURHOOD PLAN 2030
2.1 A Neighbourhood Area Application dated 17 July 2013 was submitted by Bryning with Warton
Parish Council to cover the whole of the area of that Parish Council. In accordance with
regulation 7 of the Neighbourhood Planning Regulations (2012) the local planning authority
undertook a statutory 6 week consultation into the proposed Neighbourhood Area. Following
consideration of the consultation comments, the local planning authority approved the
Neighbourhood Area on 25 October 2013 to cover the whole of the area of that Parish Council.
2.2 The draft Neighbourhood Plan has been prepared by a Steering Group working on behalf of the
Parish Council, consisting of representatives from the local community. The Steering Group
undertook an initial informal consultation as part of the Neighbourhood Plan launch event in
April 2014 to assist with the production of the draft plan.
2.3 On 10 July 2014, the Parish Council submitted their draft Neighbourhood Plan to the local
planning authority as part of the six week pre-submission consultation and publicity. This is a
formal consultation stage to accord with regulation 14 of the Neighbourhood Planning
Regulations. This stage also requires the qualifying body to bring the document to the attention
of people who live, work or carry on business in the neighbourhood area and to consult with
consultation bodies as identified in schedule 1 of the regulations which the Parish Council
considered may be affected by the proposals. This includes bodies such as the Environment
Agency and Lancashire County Council. The Parish Council are also required to submit the draft
Plan to the local planning authority, however the local planning authority are not obliged to
comment.
2.4 A Sustainability Appraisal of the draft Neighbourhood Plan was also included as part of their presubmission consultation, which was produced by Kirkwells Planning consultants, on behalf of the
Parish Council.
3. DRAFT RESPONSE
3.1 Local planning authorities are required to advise and assist communities in their neighbourhood
planning work. To meet this obligation at this current stage, it is considered appropriate for the
local planning authority to submit a consultation response to the Parish Council. It is expected
that this response will assist the Parish Council in submitting a Plan in a form which will allow the
local planning authority to take the document forward to examination and allow the
independent examiner to recommend the plan goes forward to referendum.
3.2 To assist with this process, a draft response has been produced and is attached as appendix A to
this report. The draft response is generally supportive and where possible offers suggested
solutions and amendment to potential concerns. The response states the Council fully supports
the community’s initiative to produce a Neighbourhood Plan and recognise that this is a
community-led process which Fylde Council has a duty to support. The response is in two parts.
3.3 Part A considers the draft plan against the basic conditions which the independent examiner will
assess the plan against, these being:
-
Whether the draft plan has regard to national planning policy and guidance;
Whether the draft plan contributes to sustainable development.
Whether the draft plan is in general conformity with the Council’s own development
plan;
Appendix 5
-
Whether the draft plan complies with various European Obligations;
3.4 Part B considers the operation of the draft neighbourhood plan in recognition that the local
planning authority would become the main user of the document, as the made (adopted)
Neighbourhood Plan would form part of the development plan and be used when determine
planning applications for that area of Fylde.
4. IMPLICATIONS
Finance
4.1 The Council received a grant of £5,000 for the designation of the Bryning With Warton
Neighbourhood Plan. A second grant of £5,000 will be received when the local planning
authority publicises the neighbourhood plan prior to examination. A final grant of £20,000 will
only be received following successful completion of the neighbourhood plan examination. It
should be noted that the pre examination and examination stages will require the incurring of
costs that might be funded from the neighbourhood planning grants but may not cover the full
cost. The final grant of £20,000 is only payable following the successful completion of the
examination and the Independent Examiner may not recommend the plan to proceed to
referendum. There is potential for legal challenges which would incur additional cost.
Neighbourhood planning is currently included in the Council’s approved revenue budget,
however this may not cover the full cost of this and other emerging neighbourhood plans and a
subsequent funded budget increase to the Council’s current approved budget may be necessary.
Legal
4.2 The local planning authority is required to accord with the regulations at relevant stages of the
process. There will be a potential need for legal officer input at relevant stages, which will have
time resource issues.
4.3 The Draft Neighbourhood Plan is supported by a Sustainability Appraisal. The Neighbourhood
Plan should promote the principles of sustainable development.
4.4 There is a possible risk that the level of request to undertake Neighbourhood Planning will
exceed the capacity of the Council to provide support and have a detrimental impact on
progressing the Local Plan.
Name of document
Date
At the Public Offices and on the Bryning with Warton
Parish Council
website: http://www.bryningwithwarton.org/
Bryning with Warton Draft
Neighbourhood Plan 2030
July 2014
The Neighbourhood
Planning (General)
Regulations 2012
At the Public Offices and available
April 2012 online: http://www.legislation.gov.uk/uksi/2012/637/c
ontents/made
Appendix 5
Bryning with Warton Neighbourhood Plan
C/O Parish Clerk - Mr A Wood
10 Lea Road
Preston,
PR2 1TN
Our Ref:
BwW Neighbourhood Plan
Your Ref:
Please Ask For:
Telephone:
Email:
Date:
Fiona Riley
01253 658419
[email protected]
X August 2014
Dear Mr Wood
Bryning with Warton Draft Neighbourhood Plan 2030: Pre-submission Consultation and Publicity
Thank you for sending the pre-submission Bryning with Warton Draft Neighbourhood Plan 2030 to
Fylde Council for comment. This response has been provided in line with the Council’s approved
scheme of delegation, but its content was considered by the Local Plan Steering Group on 11 August
2014 and is provided to assist the Parish Council in producing a submission version.
The Council fully supports the community’s initiative to produce a Neighbourhood Plan and
recognises that this is a community-led process which the local planning authority has a duty to
support. It is considered that This Council’s duty at this stage is to assist the Parish Council in
formulating a submission version. The suggestions set out in this report are intended to help the
draft Plan to progress through the examination process and forward to referendum. The eventual
content of the plan and whether to take the comments on board ultimately rest with the Parish
Council.
To assist with this process, the response is in two parts: Part A considers the draft Plan against the
basic conditions which the examiner will assess the plan against and Part B considers the operation
of the draft Plan.
The response is generally supportive and where possible offers suggested solutions to potential
concerns. The local planning authority would welcome the opportunity to discuss these comments
further with the Neighbourhood Plan Steering Group (NPSG). This response is based upon the
information provided and available on the Parish Council website at the time of reviewing the Plan
(22 July 2014), this being the draft Neighbourhood Plan (July 2014), Sustainability Appraisal Scoping
Report and Baseline (June 2014) and the Sustainability Appraisal (June 2014). While this Council has
not been able to review the evidence base behind the draft Plan, an opportunity to do so would be
welcomed.
1. PART A
Appendix 5
The Independent Examiner will assess the Plan against the basic conditions as set out in paragraph 8
(1) (a) (2) of Schedule 4B to the Town and Country Planning Act 1990 (inserted by the Localism Act
2011). These being:
- Whether the Plan has regard to national planning policy and advice;
- Whether the Plan contributes to sustainable development.
- Whether the Plan is in general conformity with the Council’s own development plan;
- Whether the Plan complies with various European Obligations;
National Planning Policy Guidance & Framework and Sustainable Development
The majority of the National Planning Policy Framework (NPPF) and associated Guidance (NPPG) is
directed to the local planning authorities’ production of a Local Plan and decision making, however
direction is also specifically provided to what a neighbourhood plan should contain. The basic
conditions require the Neighbourhood Plan to have regard to national planning policy and guidance.
Section 1.3 of the draft Plan states that it is in line with national planning policy. Following a review
of the draft Plan and the Sustainability Appraisal (SA), the local planning authority (LPA) consider
there to be some potential areas of conflict which should be further explored. If these matters are
unable to be resolved or you consider that such a departure is justified in light of the local situation
in Bryning with Warton, it may be the case that you will have to reassure the Examiner.
Alternative Options
It is acknowledged in the SA of the draft Plan that alternative options have not been considered due
to the ‘iterative process led by a clear idea and vision for the future of the village’. The LPA raises
concern that the draft Plan, and thus the SA have not considered, therefore, all reasonable
alternatives. This is an important stage in developing the Plan and associated SA, and could be
considered contrary to national policy. The treatment of alternative options through the SA process
has been seen as an area where Local Plans have received challenge at Examinations in Public. It
may be the case that the Plan has considered all reasonable alternatives but this information has not
been sufficiently documented and appraised thought the SA process. As part of the SA, it will also be
important to consider ‘business as usual’ scenario to consider the effect of not developing a
neighbourhood plan.
Housing Growth ‘Cap’
Draft Plan Objective 1 and policy BWH1 sets a ‘cap’ on the level of housing growth up to 2030 for
Bryning with Warton. The LPA acknowledged that policy BWH4 provides housing ‘reserve sites’
which would be released upon the completion of sites H1 and H2 (as identified in policy BWH1), and
policy BWH4 permits windfall sites of less than 5 dwellings on previously developed sites. However,
the policy ‘cap’ could be suggested to conflict with the presumption in favour of sustainable
development, resulting in less development coming forward than would have occurred without a
Neighbourhood Plan and remove the potential choice in the market. The NPSG may therefore wish
to consider the wording, operation of the policy and the trigger to release reserve sites in Policy
BWH4.
Level of Growth
The NPPF paragraph 184 states that neighbourhood plans should not promote less development
than set out in the Local Plan or undermine its strategic policies. The draft Plan refers to the ‘Fylde
Borough Council has recently agreed to reduce the number of houses planned for Warton to 650 in
the next version of the Local Plan’.
Appendix 5
The Local Plan Steering Group has considered the comments that were raised as a result of the
Preferred Option consultation on the emerging Local Plan. As a result of that deliberation the
Portfolio Holder is minded to reconsider the distribution of strategic housing and employment sites
throughout the borough. This would result in a re-examination of the strategic development sites at
Warton and Kirkham and the examination of potential additional development sites in the vicinity of
the M55 junction 4/Whitehills.
New data was published by the Office for National Statistics recently which may have implications
for the Strategic Housing Market Assessment (SHMA) and the potential number of houses to be
delivered during the plan period. This will require further appraisal which will need to be considered
by the Local Plan Steering Group/Portfolio Holder. Accordingly it will be necessary to carry out a
reappraisal of these development options along with other factors and to carry out further
consultation in respect of them.
At this stage, the Portfolio Holder has agreed the principal of reducing the proposed scale of
development at Warton to a figure around 650, but a revised Preferred Option of the Fylde Local
Plan to 2030 needs to be drafted and appraised in order to confirm that this approach can be
delivered. It may be that following further appraisal that this figure is not ratified by the Council and
an alternative scale of development may be identified in the Local Plan- Revised Preferred Options.
Viability and Deliverability
Paragraph 173 of the NPPF requires the plan to be deliverable and viable. The NPPG states that sites
and scales of development identified in the plan should not be subject to such a scale of obligations
and policy burden that their ability to be developed viably is questioned. The draft Plan places extra
burdens on developers which have not been tested – for example, policy BWH3 requires all new
development to provide a minimum of 30% affordable housing. This is a more restrictive policy
approach than operated through the current Interim Housing Policy and proposed in the emerging
Local Plan, both of which include a viability test. The approach set out in the Neighbourhood Plan
needs to be justified, this is important as the document would form part of the development plan
and would need to stand up to scrutiny by developers and Inspectors at Planning Appeals. The
justification of policies in the draft Plan may, therefore, need to be bolstered.
Affordable Housing
Policy BWH3 in relation to affordable housing provision requires affordable housing ‘suitable to meet
the needs of older people and those with disabilities’. This Council supports the approach of
providing affordable housing to meet a wide range of needs; however, there is concern that this
restrictive approach goes against the spirit of providing affordable housing to all eligible households
whose needs are not met by the market, as set out in annex 2 of the NPPF.
Residential Amenity
The draft Plan emphasises the protection of existing residential amenity. The NPPG is clear that
amenity is important for all existing and future occupants of land and buildings. It is suggested that
the wording be amended in this respect in order to resolve this matter in the relevant policies.
Garden development
Paragraph 53 of the NPPF states that LPA’s should consider the case for restrictive policies to
prevent the inappropriate development of residential gardens. Policy BWH4 proposes housing
‘reserve sites’, of which R1 and R3 would incur the development of residential gardens, which could
be considered to go against the spirit of preventing inappropriate development of residential
gardens. It is acknowledged that the second aspect of the policy permits windfall sites of less than 5
dwellings providing it meets a range of criteria, which presumably if met means the sites are not
Appendix 5
considered ‘inappropriate development’ as set out in NPPF paragraph 53. It is clear from the housing
‘reserve sites’ R1 – R5 within the first half of the policy, that they would not necessary meet all of
these criteria. The selection criteria which the NPSG have used to consider sites should be made
available, this point goes back to the need to demonstrate all reasonable alternatives have been
considered and reason for dismissing alternatives is adequately justified.
Sustainable Development
Sustainable development is a ‘golden thread’ running through the NPPF. The basic conditions
require the qualifying body, in this case, the Parish Council, to demonstrate how their Plan will
contribute to sustainable development. The NPPF (Reference ID: 11-026-20140306) suggest the use
of a sustainability appraisal as a useful method to demonstrate this. This approach has been carried
out by the NPSG and can be commended. Compliance with this ‘golden thread’ should be clearly
demonstrated through the basic condition statement. Guidance on producing a basic condition
statement, including a template is available on the Locality website. The NPSG may find it beneficial
for the LPA to also assist with this process.
General conformity with the Development Plan
The Council recognises that section 1.3 of the draft Plan states that the draft Plan is in general
conformity with the strategic planning policy of the LPA, in this case, the Local Plan as Amended
2005. It is recognised that this test is one of general conformity rather than complete conformity.
There is no current Government guidance on what is meant by general conformity, but an
established principle in a now defunct Planning Policy Statement 12 suggest:
‘The test is of general conformity and not conformity. This means that it is only where an
inconsistency or omission in a development plan document would cause significant harm to the
implementation of the spatial development strategy, that it should be considered to not be in general
conformity. The fact that the development plan document is inconsistent with one or more policies in
the spatial development strategy, either directly or through the omission of a policy or proposal, does
not, by itself, mean that the document is not in general conformity. Rather the test is how significant
the inconsistency is from the point of view of delivery of the spatial development strategy.’ (para
4.20)
The NPPF suggests although a draft NP is not tested against the policies in an emerging Local Plan,
the reasoning and evidence informing the Local Plan process may be relevant to the consideration of
the basic conditions against which a neighbourhood plan is tested.
The examiner’s report for the Tattenhall and District Neighbourhood Plan highlights that ‘it makes
good sense for neighbourhood planners to understand and have a mind to how the
neighbourhood plan fits with the emerging strategic policies of the development plan and be
able to clearly explain the rationale for any significant differences, should there be any.’
In accordance with NPPF, it is suggested that the NPSG and LPA should discuss and aim to agree the
relationship between policies in: the emerging neighbourhood plan; the emerging Local Plan, and
the adopted development plan. It is suggested that this process is carried out prior to the Plan’s
submission to the LPA (under regulation 15 of the Neighbourhood Planning Regulations) and
evidence of this discussion is provided as part of the basic condition statement which will be made
available to the independent examiner.
European Obligations and human rights requirements
Appendix 5
Sustainability Appraisal and Strategic Environmental Assessment
There is no legal requirement for a neighbourhood plan to undertake a Sustainability Appraisal (SA).
In some circumstances, where a neighbourhood plan could have a significant environmental effect, a
Strategic Environment Assessment (SEA) may be required.
To assess whether the NP may have a significant environmental effect, its potential scope should be
assessed, and the LPA can provide a screening opinion to the Parish Council on whether a SEA is
required (NPPG Reference ID: 11-028-20140306). As part of the LPA determining whether the
proposals are likely to have a significant environmental effect, the LPA are expected to consult the
three statutory consultation bodies (English Heritage, Natural England and the Environment Agency).
If the LPA determines the plan is unlikely to have a significant environmental effect, and therefore
does not require an environmental assessment, the LPA will provide a screening assessment with
reasons for its determination. A copy of this statement provided to the Parish Council could then be
made available to the Independent Examiner and form part of the evidence base for basic conditions
statement required at submission stage (regulation 15).
It is acknowledged that the draft Plan is supported by an SA which it states has incorporated the
legal requirements of the SEA Directive. However, it is unclear if the relevant statutory consultees
have been directly consulted on the SA Scoping Report & Baseline and thus concluded the need for a
SA/SEA of the draft Plan.
The NPPG (Reference ID: 11-026-20140306) suggest guidance on producing SA of Local Plans should
be referred to for undertaking neighbourhood plans. The SA process should be proportionate and
relevant to the Plan being assessed. The SA carried out for Bryning with Warton’s draft Plan has
tested the policies and site for inclusion against the established SA framework produced for the
emerging Fylde Local Plan to 2030. This approach to using the established SA framework is
supported as this will assist with the NP general conformity with the emerging Local Plan. This
approach could also be used for other elements of the SA process to avoid unnecessary duplication,
albeit that the SA of the Local Plan is dated June 2013. If this approach is taken, it would be
beneficial if the SA clearly stated which elements from the emerging Local Plan SA are being relied
upon.
It is suggested that the SA methodology is expanded to assess the vision and objectives of the draft
Plan against the SA objectives. This would further assist in ensuring the whole plan contributes to
sustainable development and ensure conformity with the emerging Local Plan.
The SA report states that the recommendations from the SA have been taken into account in
drafting the Plan. It is unclear if all SA recommendations have been taken forward as there appears
to be some anomalies between the draft Plan and SA recommendations. It could be beneficial for
the NPSG to make available the plan and policies which were appraised, this would also assist with
the provision of an audit trial.
The policy testing tables in appendix 1 of the SA have assessed the draft policies and housing sites
against the established SA Objectives from the emerging Local Plan. From an initial review of the
findings, there appears to be some inconsistencies in the comments and scoring criteria which may
benefit from a further review. There also appears to be no review of policy BWE2: Protect Existing
Employment and of housing reserve sites R3 and R4 in relation to policy BWH4. In relation to the
housing site testing, it is considered that there are some further differences between the sites which
it is expected would have been teased out through the appraisal process, which could assist with
sites inclusion justifications.
Appendix 5
Habitat Regulations Assessment
There are a Ramsar and Special Protection Area (SPA) to the south of the Neighbourhood Area. The
area also benefits from designations of a Site of Special Scientific Interest (SSSI) and a National
Nature Reserve NNR).
The Preferred Options version of emerging Local Plan to 2030 is supported by a Habitat Regulations
Assessment (HRA) Screening Report (June 2013). The screening report concluded that the Local Plan
would not lead to direct impact upon European Sites, however there are potential for indirect
effects, although it is considered unlikely that these would be significant in their own right. In regard
to the significance of the impact, it is likely to be greater the closer the proposed development is to
the European Site. The screening report concludes that the need for an Appropriate Assessment
may be avoided by strengthening existing policies. Natural England have been consulted and were
generally satisfied with the approach taken, following further discussions, the outstanding concerns
they did raise have been agreed to be addressed as part of further work on the emerging Local Plan
and further update to the Screening Report.
The draft Neighbourhood Plan allocates sites for residential development. Sites H1 and H2 were
included as part of larger sites within the emerging Local Plan which were assessed through the HRA
Screening process. Although it may be presumed that the HRA screening for the emerging Local Plan
can be relied upon, this is not necessarily the case as an assessment should assess the actual effects
of development. It is considered that further evidence in regard to the impact assessment will be
required. With regards to the housing ‘reserve sites’, it could be argued that these sites collectively
do not increase the quantum of development above the level assessed in the Local Plan, the sites are
also located in the general vicinity of the Local Plan sites and thus are not located closer to European
designations and the sites are individually less than 0.5ha and thus would not typically trigger the
need for an Environmental Impact Assessment (EIA) under UK Planning and Environmental Impact
Assessment Regulations if a planning application was submitted. While it could therefore be
presumed that the sites individually or collectively will not have a direct/indirect impact, this
assessment work has not been undertaken. Further consideration is needed whether a HRA
screening of the Plan is needed. The NPSG should liaise further with the LPA in regard to this matter.
Human Rights Requirements
For the purposes of the emerging Local Plan, a Health Impact Assessment, which incorporated
Equalities Impact Assessment was undertaken. It may be appropriate for the Parish Council to
consider if an equalities impact assessment of the draft NP is appropriate to assess the positive and
negative impacts on groups with protected characteristics.
2. PART B
Part B of this response considers the operation of the draft Plan in recognition that the LPA would
become the main user of the document, as the made (adopted) Neighbourhood Plan would form
part of the development plan and be used when determine planning applications for that area of
Fylde. Annex A to this response provides some further general factual observations on the Plan,
Sustainability Appraisal and Scoping report.
The NPPG (Reference IS: 41-041-20140306) says policies in a neighbourhood plan should be clear and
unambiguous. It should be drafted with sufficient clarity that a decision maker can apply it
consistently and with confidence when determining planning applications. It should be concise,
precise and supported by appropriate evidence. It should be distinct to reflect and respond to the
Appendix 5
unique characteristics and planning context of the specific neighbourhood area for which it has been
prepared.
The following observations seek clarification in order to ensure the operation of the future policies
are not hindered by any uncertainties over meaning or intent. If there are any areas where this has
been misinterpreted or misunderstood any policy or intentions please let us know.
Policy BWH1: To Allocate Land For Housing Growth of up to 638 Homes
It is not clear whether the proposal for up to 638 dwellings would be solely met by development at
sites H1 and H2, or whether this includes other existing commitments and completions from the
commencement of the Plan period. The text introduction (page 28) refers to 464 dwellings have
already been approved. Presuming this is already factored into the overall requirement, this would
leave a residual of 174 dwellings to be provided on sites H2 and the residual area of H1. The NPSG
may wish to identify all sites which are contributing towards the 638 homes and the number of
dwellings per site. All sites which are contributing to this requirement should be identified as a
housing allocation on figure 5.
Without reiterating the point made under Part A regarding alternative options, justification for why
the NPSG has decided to take these sites forward as opposed to other potential sites should be
justified, including supporting evidence including through the Sustainability Appraisal.
The emerging Local Plan assumes each strategic development site would consist of a 60%
developable area with 40% undevelopable area being available for other uses, such as public open
space, landscape and infrastructure. The 60% developable area would be built out at 30 dwellings
per hectare. It is the LPA’s understanding that the discussion with ATLAS referred to the percentage
of developable area of each strategic site rather than reducing the scale of development proposed in
this Council’s Preferred Option by 55%. As this appears to be the basis for arriving at the proposed
638 dwelling cap (1160 x 55%), it is considered that further justification for the setting of this cap,
which should be supported by evidence, will be required.
Policy BWH2: To Promote a Level of Housing Growth that is Proportionate to the Size and Function of
Warton Village
It is presumed that this policy is to be operated in relation to the release of sites H1 and H2 only and
all criteria 1 – 7 should be met. It is presumed that this policy does not apply to the identified
housing reserve sites and potential windfall sites as identified in policy BWH4, as for example, they
would be unable to meet criteria 1 and because they have criteria which they should meet set out in
BWH4.
If this is the case, you may wish to consider the incorporation of relevant criteria from policy BWH2
into policy BWH1. It would also be beneficial to incorporate key aspects from policy BWH2
incorporated into BWH4, for example criteria 3 in relation to Section 106 agreements, which should
also be expended to refer to Community Infrastructure Levy (CIL).
By ‘village boundary’ it is presumed that the plan is referring to the settlement boundary, which
would be altered to include sites H1 and H2. It may be beneficial to provide a map which
demonstrated this and the LPA would be able to provide assistance with mapping.
Criteria 1 and 5 would benefit from reference to future residents in addition to the amenity of
existing residents. To justify criteria 1 you may wish to explain the concept, operation and
maintenance of wildlife habitat and corridors. Some of the proposed buffers as set out in figure 6
Appendix 5
may not be appropriate or possible e.g. along the northern perimeter of BAE Systems and/or the
Enterprise Zone, particularly where planning permission has already been granted.
In regard to criteria 3, some forms of infrastructure will be provided through contributions from a
number of development schemes. This could be by way of CIL or pooled Section 106 contributions.
You should be aware that the CIL Regulations place restrictions on pooling Section 106 contributions
and that these restrictions are currently proposed to come into effect in April 2015.
Criteria 6 should be expanded to refer to access by all forms of transport, the policy currently
appears to be focused on vehicle users of the highway.
Policy BWH3: Housing mix, design and density (including provision of affordable housing)
This policy approach to encouraging an appropriate mix of housing types is supported by this
Council. You may wish to refer to the Strategic Housing Market Assessment (SHMA) in the policy
justification to support this approach. The policy should be clarified if it is intended that this policy
would apply, housing ‘reserve sites’ and windfall schemes as well as to sites H1 and H2.
The title of the policy implies that density is included; however this does not appear in the policy or
preamble and may be an omission.
The policy refers to homes designed for ‘older people’, it is presumed by this you mean specialist
accommodation, such as sheltered housing in addition to bungalows should be provided as part of
the housing mix, but this should be clarified in the policy.
BWH4: Housing Reserve Sites and Windfalls
The first part of the policy allows for the release of housing ‘reserve sites’ upon the completion of
the development at sites H1 and H2. It is unclear if the NPSG are proposing that all reserve sites will
be released concurrently, or whether their release would be phased. The number of reserve sites
needs to be clarified, figure 7 demonstrate five sites (R1 – R5), whereas the policy lists only (R1 – R3),
It is presumed that R4 and R5 could be a later addition which may explain why some reserve sites
have not been assessed as part of the SA process. It would also be beneficial if the estimated yields
from the sites are provided.
The Council is aware that this type of policy is often challenged by developers at Local Plan
Examinations in Public. It is often argued that if there is a need for reserve sites, this could indicate
that the Parish Council consider their housing requirement to be too low. Furthermore, housing
completions are monitored by the LPA on an annual basis, to the base date 31 March each year. It is
presumed this annual monitoring would feed into the trigger to release the housing ‘reserve sites’.
Due to the time needed to prepare, submit and receive full planning permission, this could lead to a
potential void in development, which could have implications for the LPA demonstrating that they
have an adequate five year housing land supply in accordance with paragraph 47 of the NPPF. The
NPSG may wish to consider whether there is an earlier release trigger which would overcome this
potential void.
Linked to earlier comments on site assessment, FBC is unsure as to why the chosen housing ‘reserve
sites’ have been selected as this Council is aware the Strategic Housing Land Availability Assessment
(SHLAA), which you suggest as a source of information, includes alternative options which do not
appear to have been considered. It may be the case that the alternative sites have been considered
but this has not been adequately documented. From an initial review of the selected ‘reserve sites’
as per figure 7, some sites appear to have constraints which may make them unviable and/or
undeliverable, the plan also does not say how the constraints could be overcome to allow them to
Appendix 5
be released if needed. For example site R3 (SHLAA ref. WA06) is in multiple ownership and site R5
(SHLAA ref. WA10) has potential ground contamination issues. Furthermore, based on the proposed
wildlife habitat and corridors as proposed in figure 6, it is considered reserve site R1 would not have
satisfactory access in accordance with policy BWH4 iii.
The second part of the policy permits windfall sites of less than 5 dwellings providing it meets a
range of criteria. It is presumed that residential windfall sites would have to meet criteria i-iii. This
Council also presumes that windfall sites of less than 5 dwellings which are not back land or tandem
development would not have to meet criteria ii. It would be beneficial if the Plan could define what
is meant by ‘back land’ and ‘tandem development’ or provide a relevant link to a definition in
existing guidance. Criteria ii. should not solely relate to the residential amenity of existing resident
but also the end user of the proposed development to protect the amenity of future occupants.
BWE1: Promoting Employment Growth
The policy operates to encourage new and improved employment opportunities for local people, it is
presumed that unlike the housing policies, this applies outside of Warton settlement to Bryning and
Kellarmergh and the surrounding area.
The LPA supports the protection of the employment land at BAE Systems, but considers the
boundary should be aligned to the adopted (saved) Local Plan policy EMP2.
With regards to allocating land within the Enterprise Zone, the policy acknowledged that the NPSG
will require cooperation of the Lancashire Enterprise Partnership, you may wish to explore the
potential of this prior to submission of the Plan.
With regard to employment opportunities on mixed use development sites, it is not clear if this
relates to existing sites which could be described as ‘mixed use’ or whether it is proposed to
encourage sites H1 and H2, housing ‘reserve sites’ and windfall sites for mixed use development. It
is presumed that by detrimental effect on the environment or well-being of people in neighbouring
properties that this is not limited to residential properties.
BWE2: Protecting Existing Employment
Policy EMP2 of the adopted Local Plan 2005 protects existing employment sites. The boundaries of
protected employment sites set out in figure 8 should be aligned with the adopted Fylde Borough
Local Plan proposals map. The NPSG may wish to define what is meant by ‘non-employment
generating uses’. It is presumed that the definition refers to a wider range of potential uses other
than B1, B2 and B8. It is also not clear what is meant by ‘small employment sites’.
BWT1: Sustainable Transport and BWT2: To promote the development of gateway roundabout at
specific areas in the village.
The LPA supports the NPSG concepts to encourage a sustainable transport strategy and key
gateways into the village. This Council is, however, not aware of the current highway proposals
which have been set out in figure 9, it would be expected that proposals of this nature be progressed
through the Infrastructure Delivery Plan for the emerging Local Plan following liaison with Lancashire
County Council. The NPSG should be aware of the emerging Fylde Coast Highways and Transport
Masterplan which is currently being produced by Lancashire County Council and you may wish to be
involved in the forthcoming Enterprise Zone Masterplan consultation.
BWLC1: Shops and Services
This Council supports the aim of the policy to improve the range and access to shops, focusing
development to the ‘principal village centre’ as identified on figure 10. It is suggested that the
Appendix 5
terminology is checked for consistency in this policy, for example, criteria 1 states the area will be
maintained for shopping and services, going on to say new retail and service will be permitted.
Criteria 2 could be considered to contradict a permissive approach to provision of services in criteria
1 by saying it will only be permitted where it can be clearly demonstrated the retail or service use is
no longer suitable…... It would be beneficial to define what is meant by ‘service’ and ‘non-retail’ in
criteria 2 and ‘local retail’ in criteria 3 to ensure the correct operation of the future policy.
Criteria 3 of the policy refers to the settlement boundary whilst Policy BWH2 refers to the village
boundary. It is presumed that this is an omission and will be updated for consistency throughout the
document.
Criteria 4 requires local retail and service uses which cannot be located in the village centre (again
presumed to be the principal village centre) will be permitted in accessible locations, providing they
have undertaken a sequential test and impact assessment regardless of the size of the development.
This Council’s initial understanding is that this policy has evolved from paragraph 24 and 26 of the
NPPG.
The NPSG should be aware that as part of an update to the Retail Study for Fylde, the Portfolio
Holder agreed a locally set retail floor space threshold of the NPPF assessment of impacts, to be set
at 750sq. metres (gross). This was agreed for the preparation of the Local Plan.
At this current stage, it is not clear how criteria 4 and criteria 3 would operate in practice and this
will require further clarification.
Policy BWLC2: Community, leisure facilities and greenspaces
The LPA supports the Parish Councils aspiration to improve and provide centrally located community
and leisure facilities. It is noted that the policy is more restrictive than paragraph 74 of the NPPF
which may require justification.
It could be beneficial to define what is meant by ‘community’ and ‘leisure’ facilities, or what is not
meant, for example it is presumed that this definition does not extend to include retail uses.
The policy suggests the buffer zone on figure 12 is illustrative, for the benefit of doubt, it is
suggested that this caveat is added to figure 12. It should also be clarified whether this illustrative
approach applies to other proposals, such as buffer zones and green routes as illustrated on figure 6.
There appear to be some inconsistencies in the boundaries of protected recreation and open spaces
on figure 11 and that of approved/current schemes which the LPA can assist in the mapping of.
BWNE1: Protecting and enhancing local wildlife and habitats and BWNE2: Protecting and enhancing
local character and landscape
In policy BWNE1 and BWNE2, by ‘all new development’, it is understood that this policy relates to
different types of uses (e.g. residential, employment and leisure) and at different scales. It is
presumed that this also includes change of use of buildings and/or land, and suggest the use of ‘new’
is removed from the policy wording to be fully inclusive.
In reviewing policy BWNE1, it is presumed that all criteria will need to be met. This suggests the
policy is specifically directed at sites H1 and H2 as the housing ‘reserve sites’ and potential windfall
sites may not meet all criteria, unless the policy would allow for appropriate financial contribution in
lieu.
Appendix 5
The first paragraph of the policy BWNE2 is repeated in the first criteria, which also sets out slightly
different criteria which could be streamlined in the policy.
In policy BWNE2, the term settlement fringe needs to be clearly defined. Does this relate to sites
within the settlement boundary and on the edge as opposed to development outside the settlement
boundary or both?
Policy BWNE2 begins to define the distinctive characteristics of Bryning with Warton. It would be
useful if this information is expanded and provided from the outset of the document, for example in
the vision.
Plan Delivery and Implementation
Section 5 of the Plan sets out key actions required to deliver the Plan. The LPA and NPSG will need
to work together carefully to ensure the successful delivery of the Plan. It will also be important to
develop a clear framework to monitor the success of the plan and establish what would require a
partial or early review of the Plan.
Next steps
The observations provided above are intended to be constructive and should not be seen as a
criticism of the draft plan. The LPA and NPSG will need to work closely together to ensure these
issues are resolved by the time the Plan is submitted. In the first instance, it would be beneficial to
meet and discuss the content of this response to establish key actions and the LPA would welcome
the opportunity to further explore the implementation of the policies in practice, this may be
beneficial as part of a small working group of NPSG members and Planning Officers. If in the
meantime, you require any further clarification regarding the content of the response, please do not
hesitate to Fiona Riley.
Yours sincerely
Paul Walker
Director Development Services
Annex A: General observations
Draft Neighbourhood Plan
Plan Period
The LPA supports the approach of aligning the Neighbourhood Plan to
the timeframe of the emerging Local Plan. However, it is unclear
when the Neighbourhood Plan period commenced. It would be
beneficial for this to be clearly set out at the start of the Plan. The
commencement date of the Plan should ideally align with monitoring
Appendix 5
period (i.e. 1 April) and the start date could have implications for
housing commitments which can be included towards the housing
requirement set out in Policy BWH1.
Figures/maps (throughout
the document)
Figure/titles missing.
LPA can work with the NPSG to provide relevant/improved mapping
for the document at a relevant scale for Bryning with Warton.
1.5 Neighbourhood Plan
Process (page 10)
It would be beneficial to explain NPSG have been appointed by the
Parish Council to take the Plan forward
Evidence base (page 7, 11
and throughout the
document)
About Bryning with
Warton (page 12)
This is mentioned throughout the document but does not appear to
be available for examination online.
Employment – Enterprise
Zone & Area assisted
status (page 13)
There is one Lancashire Enterprise Zone which consists of two sites at
Warton and Salmesbury.
Table 1 – Housing tenure
and household mix (page
14)
Key issues, core objectives
and vision for the future
(page 16 onwards)
Vision (page 19)
This table appears to sit alone with no commentary in the text.
Objectives (page 20)
3.1 National Planning
Policy (page 22)
3.2 Fylde Planning Policy
(page 23)
4.2 Housing (page 27)
Background/justification
(page 40)
Consideration should be given to explaining the difference between
Warton, Bryning and Kellamergh e.g. Warton is a village where the
majority of residents of the parish reside and where services and
facilities are available. Bryning and Kellamergh are small hamlets?
You may wish to mention the assisted area status for Westby and
Warton is connected to the economic opportunities at the Enterprise
Zone and at Whitehills adjacent to the deprivation at Blackpool.
May be beneficial where possible to support the views expressed with
evidence. Evidence for the emerging Local Plan can assist with this.
You should consider clearly setting out what the local distinctiveness
is which makes of Bryning with Warton special. This could be set out
in the vision which sets out an aspiration for how Bryning with Warton
should be by 2030.
You may wish to rationalise the Plans objectives. You may also wish
to consider which policies will meet which objective. A matrix table of
objectives versus policies could assist with this process.
National Planning Practice Guidance (NPPG)
…..with the adopted Fylde Local Plan (2005)
The text currently implies that the Plan is being used to prevent
development. You may wish to tease out the benefits of producing
the Neighbourhood Plan in relation to housing.
The minutes from the Warton Strategic Development Location
meeting in November 2013 are available online, Lancashire County
Council Highways and Transport said …..they could not
Appendix 5
support all development coming forward on an ad-hoc basis.
Reference to emerging
Local Plan (Page 40 and
throughout)
(page 49)
Glossary of terms (page 52
onwards)
The LPA consulted on its emerging Local Plan Preferred Options. The
document is no longer called a Core Strategy.
The Fylde Coast Masterplan is at consultation version stage. Key
objectives, bullet point 3 & 4 are missing from the text. The Coastal
Way also includes Freckleton.
It may be beneficial to check the definitions against those within the
NPPF, or duplicate the NPPF definitions.
Under ‘Local Plan’, it says the document should be in conformity with
the emerging Local Plan, but earlier in the document says it should
only be in conformity with the adopted plan.
Under ‘Local Authority’ you may wish to explain two tier authorities
and their different function
Also refer to NPPG in addition to NPPF
You may also want to refer to CIL in addition to S106
Reference document (page
55 onwards)
Refer to SEA and HRA in addition to Sustainability Appraisal
The Plan period for the emerging Local Plan runs from 2011 to 2030
A list of evidence produced in support of the plan should be provided
Sustainability Appraisal Scoping Report and Baseline
Maps (throughout the
LPA can work with the NPSG to provide relevant/improved maps for
document)
the document at a relevant scale for Bryning with Warton.
Evidence (throughout the
document)
It would be beneficial to provide evidence to support statement e.g.
Warton has very limited scope to attract smaller businesses (page 23)
Introduction (page 5)
Bryning with Warton National and Local Policy Assessment. This does
not appear to be available online.
Figure 2 (page 9) and (page
25)
This map is unclear.
European designations – Ramsar and SPA, you may also wish to note
NNR and SSSI
Health / Crime (page 13)
Is it beneficial to compare the finding to the borough to see if this is a
key issue for Warton.
Empty Homes (page 15)
It may be worth mentioning the Fylde Council Empty Homes initiative,
including changes to council tax which has resulted in a considerable
reduction in empty homes across Fylde.
Open Space (page 17)
The Open Space, Sport and Recreation Study: Strategy and Action Plan
is currently being updated, it is estimated that this work will take
around 6 months to complete.
Appendix 5
Page 29 onwards
You may also wish to mention the draft Coastal Masterplan
5.8 (page 30)
University of Manchester produced the Green Infrastructure Strategy
which is available on line – there is no outstanding commission.
5.23 (page 32)
Potential error with reference to West Lancashire and not Fylde?
5.25 (page 33)
Reference to December 2012 – this is out of date. Latest position:
next round of planning began in 2013 in the south plan area. Until
such time as a marine plan is in place for the North West plan area,
the MMO advise local authorities to refer to the Marine Policy
Statement for guidance on any planning activity that includes a
section of coastline or tidal river.
1.5 (page 12)
Neighbourhood Area designated 25 October 2013
2.2 (page 20)
Adopted and emerging Local Plan?
REC13: Public Open Space
(page 22)
2.9 (page 23)
Should be TREC 13
The text below is from a recent report which explains the current
position which you may wish to reflect in the SA:
The Local Plan Steering Group (LPSG) has considered the comments
raised as a result of the Preferred Option consultation. As a result of
that deliberation the Portfolio Holder (PH) is minded to reconsider the
distribution of strategic housing and employment sites throughout the
borough. This would result in a re-examination of the strategic
development sites at Warton and Kirkham and the examination of
potential additional development sites in the vicinity of the M55
junction 4/Whitehills.
New data was published by the Office for National Statistics earlier
this month which may have implications for the Strategic Housing
Market Assessment and the potential number of houses to be
delivered during the plan period. This will require further appraisal
which will need to be considered by the LPSG/PH.
The PH has also asked officers to review the Employment Land Study
in the light of additional representations received by the Council.
Accordingly it will be necessary to carry out a reappraisal of these
development options along with other factors and to carry out further
consultation in respect of them. This has introduced considerable
additional work streams which will not be achievable within the
timetable agreed by Cabinet. The report to Cabinet did highlight the
circumstances that could affect delivery of the timetable.
A revised timetable will be worked up with PH and a new strategic risk
action plan will be reported to the next meeting of committee.
Appendix 5
Summary of sustainability
issues (page 25)
4.Neighbourhood Plan
Proposals (page 27)
BWT2 (page 31)
BWNE2 (page 31)
5.3 (page 32)
Biodiversity - There is also a SSSI
Does not appear to be a mention of soil and air in the scoping and
baseline report but mentioned in summary in the SA.
No mention of proposed reserve site R5
Is it also true that the policy concentrates on highways improvements,
it is recommended that other modes of transport are included in the
policy
The policy appears to be aimed at new development but based on the
negative effect suggestion, it appears not.
It may be beneficial to mention a HRA screening report has been
undertaken for some of the sites. Do you want to mention which sites
have not been assessed in the emerging Local Plan SA/SEA and HRA
but are included in the draft Plan?

Agenda for the Steering Group Meeting to be held on 11 August 2014

Transcription

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