Local Development Framework Consultation

KENDAL

R124

Support

Case fully explained in submissions made in relation to the previous consultation exercise.

Oppose

Land East of Ullswater Road, Kendal (R124)
Representation on behalf of Mrs McCallum and Mr Downham

Consultation Issue 2: Time Span of the Land Allocations Document

The proposal to shorten the time span of the Allocations document to 2020 is not supported.
The Further Allocations document highlights the planning authority’s commitment to meeting Core Strategy housing targets and the pressing need to increase the supply of land for new housing in the short term. Indeed the current housing land supply is marginally over a two year supply, so it is agreed by the objectors that there is an urgent need to deliver housing completions.
GOVERNMENT POLICY

Government policy is misinterpreted in the Further Allocations document.
PPS12: Local Spatial Planning indicates:-
“4.13 The time horizon of the core strategy should be at least 15 years from the date of adoption.”
“4.6 Core strategies may allocate strategic sites for development. These should be those sites considered central to achievement of the strategy...”
“5.3 In order to aid delivery of sustainable development, the local planning authority may prepare other development plan documents to provide additional detail which would not be suitable in a core strategy and which requires the status of a development plan...Core strategies can allocate strategic sites, as explained in paragraph 4.6. If it is necessary to allocate sites which have not been allocated in the core strategy, a DPD must be used to allocate these sites.”
The South Lakeland Core Strategy did not seek to allocate any strategic sites and therefore the Allocations document is now the only relevant DPD where all sites can and should be identified.
The Further Allocations document refers to the need to identify sites for 5 years, deliverable sites for 6-10 years and broad locations for future growth for the 11-15 year time period. It is submitted that this is a misinterpretation of Government Policy.

PPS3: Housing states:-
“Delivering a flexible supply of land for housing

52. The Government’s objective is to ensure that the planning system delivers a flexible, responsive supply of land. Reflecting the principles of ‘Plan, Monitor, Manage’, Local Planning Authorities and Regional Planning Bodies should develop policies and implementation strategies to ensure that sufficient, suitable land is available to achieve their housing and previously-developed land delivery objectives.

“53. At the local level, Local Planning Authorities should set out in Local Development Documents their policies and strategies for delivering the level of housing provision, including identifying broad locations and specific sites that will enable continuous delivery of housing for at least 15 years from the date of adoption...”

“54. Drawing on information from the Strategic Housing Land Availability Assessment and or other relevant evidence, Local Planning Authorities should identify sufficient specific deliverable sites to deliver housing in the first five years. ...

55. Local Planning Authorities should also:
– Identify a further supply of specific, developable sites for years 6-10 and, where possible, (my emphasis) for years 11-15. Where it is not possible to identify specific sites for years 11-15, broad locations for future growth should be indicated.
– Linked to above, identify those strategic sites which are critical to the delivery of the housing strategy over the plan period.
– Show broad locations on a key diagram and locations of specific sites on a proposals map.
– Illustrate the expected rate of housing delivery through a housing trajectory for the plan period.

Several significant points emerge from the above guidance:-

1. The requirement is to identify housing sites for a 15 year period either by identifying specific sites or by identifying broad locations on a key diagram. The opportunity for identifying broad locations on a key diagram in the context of the Core Strategy has passed, so the Allocations document must run for a 15 year period and identify specific housing sites in the 0-5 and 6-10 year periods and identify specific sites or broad locations on a key diagram in the 11-15 year period or specific allocations for a 15 year period. Either way there is no scope for the Allocations document to run for less than a 15 year period.

2. The most appropriate place for a key diagram would have been the Core Strategy. Now that the Core Strategy has been adopted the Allocations document should identify specific sites.

3. By identifying specific allocations the Allocations document should assist in meeting the key objective to “enable a continuous delivery of housing for at least 15 years from the date of adoption.”

4. The planning authority has invested resources in completing a Strategic Housing Land Availability Assessment and identifying specific sites in earlier draft Allocations documentation. The planning authority has demonstrated that it is possible to identify specific developable sites for the 11-15 year period and therefore there is no need to rely on a key diagram at this stage.

CABINET REPORT

The proposal to prepare an Allocations document for the period to 2020 is explained in the Cabinet Report dated 13th July as follows:-

The time horizon of the allocations process

“Although the allocations document must be in conformity with the Core Strategy, there is no compelling planning reason for allocating sites for the period until 2025 in a single allocations document. Were the timescale of the land allocations to be amended to 2003-2020, it would allow for a greater degree of certainty about deliverability, the early release of priority sites, soundness
in relation to the proper phasing of development and infrastructure provision and the timely updating of the strategic basis of the LDF. Any revised time frame would need to be taken into account in revisions to the Local Development Scheme.”

IMPLICATIONS FOR HOUSING LAND SUPPLY

It is difficult to see how shortening the timescale of the plan by five years assists in delivering a flexible and responsive supply of land envisaged by PPS3 or the greater degree of certainty about deliverability suggested in the Cabinet Report. Indeed from the table enclosed within the Further Consultation document it is clear that altering the time span of the plan alone reduces the net housing requirement that needs to be accommodated from 5911 dwellings to 3843 dwellings.
The suggestion of removing any allocations in the small villages and hamlets further reduces the amount of housing to be identified in the Allocations document by 308 dwellings, so only 3535 dwellings will be identified in the Allocations document.
Reducing the number of houses to be identified in the Allocations document by 40% simply reduces flexibility and increases uncertainty.
The housing figures set out in the table within the Further Consultation document are not agreed net requirements. From the information made available, there is an underestimate of net requirements. This exacerbates an issue already raised in previous submissions that the Allocations document intends to allocate land on the basis that each and every site will deliver the required number of completions within the relevant time periods with no allowance for slippage.


COMPELLING REASONS FOR ALLOCATIONS TO 2025

We offer several compelling planning reasons for allocating sites for the period to 2025.

1. A 15 year time horizon meets Government Policy requirements regarding housing provision.

2. Identifying specific sites would ensure the flexible and responsive supply of housing land that Government policy envisages.

3. Rather than provide a greater degree of certainty, a shorter plan period will require the commencement of a review within five years of adoption providing no long term certainty or confidence for local communities.

4. One can envisage another significant five year housing land supply shortfall soon after a 2020 plan is adopted in 2012/2013, particularly bearing in mind the intention to phase the release of many sites post 2014/15. In such a circumstance, and assuming a more favourable economic climate, sites will be promoted by the application and appeal process rather than through a development plan lead process.

5. The purpose of phasing within the adopted Core Strategy and in the previous Allocations Consultation document was to identify priorities. Presumably the higher priority sites were identified in the first and second phases. This is the more appropriate mechanism for delivering priority sites than abandoning a 15 year plan.

6. A plan for 15 years provides certainty to residents and the business community.

It is submitted that the planning authority offer no compelling or sound planning reasons for not progressing a plan to 2025.

MAJOR CHANGES TO THE PLANNING SYSTEM

The Allocations document indicates that “in view of the major changes to the planning system introduced by the Coalition Government, opportunity exists to reduce the time of the Land Allocations document to 10 years.” The document then goes on to refer to three changes, but only one has been implemented at this stage and none suggest the 15 year time horizon for identifying housing sites as specific sites or broad locations on a key diagram has been abandoned.

Each of the “three changes” are discussed are discussed below.


1. Localism Bill

There is nothing in the Localism Bill that refers to reducing the timescale of development plans.

Should the authority decide not to provide for allocations in small villages and hamlets, where 11% of housing and employment requirements are to be met, and instead rely upon local neighbourhood plans to come forward to deliver that 11% requirement, then it is even more important to plan for a 15 year period.

Local neighbourhood plans, is a new and untried concept. Such plans may not come forward in the numbers envisaged and in all probability will not deliver the housing requirements in the timescale that the authority perhaps envisages. If that proves to be the case there will be further difficulty in identifying a five year land supply and an increased likelihood of schemes being progressed through the application and appeal process rather than through a plan led approach.

2. Presumption in favour of sustainable development where plans are absent, silent or out of date.

This is related to a point made above. A plan to 2020 will require early plan review if the authority are to avoid a five year land supply shortfall. It will quickly become out of date and development will necessarily progress by application and appeal rather than a proper plan led approach.

It is unclear how a presumption in favour of sustainable development leads the authority to the conclusion that a shorter plan period would be appropriate.

3. New National Framework

The Draft National Planning Policy Framework was issued for consultation on 25th July after the proposal to shorten the time horizon was considered by members on 7th and 15th July, so it would appear this is a retrospective justification for shortening the plan period. However, there is nothing in the draft framework to suggest shorter development plans are appropriate but rather suggests longer term development plans are required.

Draft NPPF states:-

“19...planning should be genuinely plan-led, with succinct Local Plans setting out a positive long-term vision for an area.”

“24. Crucially Local Plans should:-

• Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements and be kept up to date.”

Whilst the guidance does not prescribe that a 15 year time horizon is a policy requirement, it clear the intention is for plans to be long term and that development requirements beyond the 15 year period should be taken into account. The guidance is suggesting plans should be for longer than 15 years, not shorter.

There is nothing in the Draft NPPF to suggest Government Policy is to abandon long term development plans.


The Allocations Consultation document refers to “major uncertainties...about the long term national picture” but there is nothing in any of the documents referred to that suggests an uncertain Central Government policy regarding a long term development plan lead system.

CONCLUDING COMMENT

The planning authority has not justified the reduced timescale of the Allocations document and there are very sound planning reasons as to why it would be inappropriate to do so.

Oppose

Land North of Grange Fell Road, Grange over Sands (RN34)
Representation on behalf of Mr Brocklebank
Consultation Issue 2: Time Span of the Land Allocations Document

The proposal to shorten the time span of the Allocations document to 2020 is not supported.
The Further Allocations document highlights the planning authority’s commitment to meeting Core Strategy housing targets and the pressing need to increase the supply of land for new housing in the short term. Indeed the current housing land supply is marginally over a two year supply, so it is agreed by the objectors that there is an urgent need to deliver housing completions.
GOVERNMENT POLICY

Government policy is misinterpreted in the Further Allocations document.
PPS12: Local Spatial Planning indicates:-
“4.13 The time horizon of the core strategy should be at least 15 years from the date of adoption.”
“4.6 Core strategies may allocate strategic sites for development. These should be those sites considered central to achievement of the strategy...”
“5.3 In order to aid delivery of sustainable development, the local planning authority may prepare other development plan documents to provide additional detail which would not be suitable in a core strategy and which requires the status of a development plan...Core strategies can allocate strategic sites, as explained in paragraph 4.6. If it is necessary to allocate sites which have not been allocated in the core strategy, a DPD must be used to allocate these sites.”
The South Lakeland Core Strategy did not seek to allocate any strategic sites and therefore the Allocations document is now the only relevant DPD where all sites can and should be identified.
The Further Allocations document refers to the need to identify sites for 5 years, deliverable sites for 6-10 years and broad locations for future growth for the 11-15 year time period. It is submitted that this is a misinterpretation of Government Policy.

PPS3: Housing states:-
“Delivering a flexible supply of land for housing

52. The Government’s objective is to ensure that the planning system delivers a flexible, responsive supply of land. Reflecting the principles of ‘Plan, Monitor, Manage’, Local Planning Authorities and Regional Planning Bodies should develop policies and implementation strategies to ensure that sufficient, suitable land is available to achieve their housing and previously-developed land delivery objectives.

“53. At the local level, Local Planning Authorities should set out in Local Development Documents their policies and strategies for delivering the level of housing provision, including identifying broad locations and specific sites that will enable continuous delivery of housing for at least 15 years from the date of adoption...”

“54. Drawing on information from the Strategic Housing Land Availability Assessment and or other relevant evidence, Local Planning Authorities should identify sufficient specific deliverable sites to deliver housing in the first five years. ...

55. Local Planning Authorities should also:
– Identify a further supply of specific, developable sites for years 6-10 and, where possible, (my emphasis) for years 11-15. Where it is not possible to identify specific sites for years 11-15, broad locations for future growth should be indicated.
– Linked to above, identify those strategic sites which are critical to the delivery of the housing strategy over the plan period.
– Show broad locations on a key diagram and locations of specific sites on a proposals map.
– Illustrate the expected rate of housing delivery through a housing trajectory for the plan period.

Several significant points emerge from the above guidance:-

1. The requirement is to identify housing sites for a 15 year period either by identifying specific sites or by identifying broad locations on a key diagram. The opportunity for identifying broad locations on a key diagram in the context of the Core Strategy has passed, so the Allocations document must run for a 15 year period and identify specific housing sites in the 0-5 and 6-10 year periods and identify specific sites or broad locations on a key diagram in the 11-15 year period or specific allocations for a 15 year period. Either way there is no scope for the Allocations document to run for less than a 15 year period.

2. The most appropriate place for a key diagram would have been the Core Strategy. Now that the Core Strategy has been adopted the Allocations document should identify specific sites.

3. By identifying specific allocations the Allocations document should assist in meeting the key objective to “enable a continuous delivery of housing for at least 15 years from the date of adoption.”

4. The planning authority has invested resources in completing a Strategic Housing Land Availability Assessment and identifying specific sites in earlier draft Allocations documentation. The planning authority has demonstrated that it is possible to identify specific developable sites for the 11-15 year period and therefore there is no need to rely on a key diagram at this stage.

CABINET REPORT

The proposal to prepare an Allocations document for the period to 2020 is explained in the Cabinet Report dated 13th July as follows:-

The time horizon of the allocations process

“Although the allocations document must be in conformity with the Core Strategy, there is no compelling planning reason for allocating sites for the period until 2025 in a single allocations document. Were the timescale of the land allocations to be amended to 2003-2020, it would allow for a greater degree of certainty about deliverability, the early release of priority sites, soundness
in relation to the proper phasing of development and infrastructure provision and the timely updating of the strategic basis of the LDF. Any revised time frame would need to be taken into account in revisions to the Local Development Scheme.”

IMPLICATIONS FOR HOUSING LAND SUPPLY

It is difficult to see how shortening the timescale of the plan by five years assists in delivering a flexible and responsive supply of land envisaged by PPS3 or the greater degree of certainty about deliverability suggested in the Cabinet Report. Indeed from the table enclosed within the Further Consultation document it is clear that altering the time span of the plan alone reduces the net housing requirement that needs to be accommodated from 5911 dwellings to 3843 dwellings.
The suggestion of removing any allocations in the small villages and hamlets further reduces the amount of housing to be identified in the Allocations document by 308 dwellings, so only 3535 dwellings will be identified in the Allocations document.
Reducing the number of houses to be identified in the Allocations document by 40% simply reduces flexibility and increases uncertainty.
The housing figures set out in the table within the Further Consultation document are not agreed net requirements. From the information made available, there is an underestimate of net requirements. This exacerbates an issue already raised in previous submissions that the Allocations document intends to allocate land on the basis that each and every site will deliver the required number of completions within the relevant time periods with no allowance for slippage.


COMPELLING REASONS FOR ALLOCATIONS TO 2025

We offer several compelling planning reasons for allocating sites for the period to 2025.

1. A 15 year time horizon meets Government Policy requirements regarding housing provision.

2. Identifying specific sites would ensure the flexible and responsive supply of housing land that Government policy envisages.

3. Rather than provide a greater degree of certainty, a shorter plan period will require the commencement of a review within five years of adoption providing no long term certainty or confidence for local communities.

4. One can envisage another significant five year housing land supply shortfall soon after a 2020 plan is adopted in 2012/2013, particularly bearing in mind the intention to phase the release of many sites post 2014/15. In such a circumstance, and assuming a more favourable economic climate, sites will be promoted by the application and appeal process rather than through a development plan lead process.

5. The purpose of phasing within the adopted Core Strategy and in the previous Allocations Consultation document was to identify priorities. Presumably the higher priority sites were identified in the first and second phases. This is the more appropriate mechanism for delivering priority sites than abandoning a 15 year plan.

6. A plan for 15 years provides certainty to residents and the business community.

It is submitted that the planning authority offer no compelling or sound planning reasons for not progressing a plan to 2025.

MAJOR CHANGES TO THE PLANNING SYSTEM

The Allocations document indicates that “in view of the major changes to the planning system introduced by the Coalition Government, opportunity exists to reduce the time of the Land Allocations document to 10 years.” The document then goes on to refer to three changes, but only one has been implemented at this stage and none suggest the 15 year time horizon for identifying housing sites as specific sites or broad locations on a key diagram has been abandoned.

Each of the “three changes” are discussed are discussed below.


1. Localism Bill

There is nothing in the Localism Bill that refers to reducing the timescale of development plans.

Should the authority decide not to provide for allocations in small villages and hamlets, where 11% of housing and employment requirements are to be met, and instead rely upon local neighbourhood plans to come forward to deliver that 11% requirement, then it is even more important to plan for a 15 year period.

Local neighbourhood plans, is a new and untried concept. Such plans may not come forward in the numbers envisaged and in all probability will not deliver the housing requirements in the timescale that the authority perhaps envisages. If that proves to be the case there will be further difficulty in identifying a five year land supply and an increased likelihood of schemes being progressed through the application and appeal process rather than through a plan led approach.

2. Presumption in favour of sustainable development where plans are absent, silent or out of date.

This is related to a point made above. A plan to 2020 will require early plan review if the authority are to avoid a five year land supply shortfall. It will quickly become out of date and development will necessarily progress by application and appeal rather than a proper plan led approach.

It is unclear how a presumption in favour of sustainable development leads the authority to the conclusion that a shorter plan period would be appropriate.

3. New National Framework

The Draft National Planning Policy Framework was issued for consultation on 25th July after the proposal to shorten the time horizon was considered by members on 7th and 15th July, so it would appear this is a retrospective justification for shortening the plan period. However, there is nothing in the draft framework to suggest shorter development plans are appropriate but rather suggests longer term development plans are required.

Draft NPPF states:-

“19...planning should be genuinely plan-led, with succinct Local Plans setting out a positive long-term vision for an area.”

“24. Crucially Local Plans should:-

• Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements and be kept up to date.”

Whilst the guidance does not prescribe that a 15 year time horizon is a policy requirement, it clear the intention is for plans to be long term and that development requirements beyond the 15 year period should be taken into account. The guidance is suggesting plans should be for longer than 15 years, not shorter.

There is nothing in the Draft NPPF to suggest Government Policy is to abandon long term development plans.


The Allocations Consultation document refers to “major uncertainties...about the long term national picture” but there is nothing in any of the documents referred to that suggests an uncertain Central Government policy regarding a long term development plan lead system.

CONCLUDING COMMENT

The planning authority has not justified the reduced timescale of the Allocations document and there are very sound planning reasons as to why it would be inappropriate to do so.

Oppose

Land at Greenside Farm, Hincaster (RN128 and EN43)
Representation on behalf of WA McHardy & Son Ltd

Consultation Issue 2: Time Span of the Land Allocations Document

The proposal to shorten the time span of the Allocations document to 2020 is not supported.
The Further Allocations document highlights the planning authority’s commitment to meeting Core Strategy housing targets and the pressing need to increase the supply of land for new housing in the short term. Indeed the current housing land supply is marginally over a two year supply, so it is agreed by the objectors that there is an urgent need to deliver housing completions.
GOVERNMENT POLICY

Government policy is misinterpreted in the Further Allocations document.
PPS12: Local Spatial Planning indicates:-
“4.13 The time horizon of the core strategy should be at least 15 years from the date of adoption.”
“4.6 Core strategies may allocate strategic sites for development. These should be those sites considered central to achievement of the strategy...”
“5.3 In order to aid delivery of sustainable development, the local planning authority may prepare other development plan documents to provide additional detail which would not be suitable in a core strategy and which requires the status of a development plan...Core strategies can allocate strategic sites, as explained in paragraph 4.6. If it is necessary to allocate sites which have not been allocated in the core strategy, a DPD must be used to allocate these sites.”
The South Lakeland Core Strategy did not seek to allocate any strategic sites and therefore the Allocations document is now the only relevant DPD where all sites can and should be identified.
The Further Allocations document refers to the need to identify sites for 5 years, deliverable sites for 6-10 years and broad locations for future growth for the 11-15 year time period. It is submitted that this is a misinterpretation of Government Policy.

PPS3: Housing states:-
“Delivering a flexible supply of land for housing

52. The Government’s objective is to ensure that the planning system delivers a flexible, responsive supply of land. Reflecting the principles of ‘Plan, Monitor, Manage’, Local Planning Authorities and Regional Planning Bodies should develop policies and implementation strategies to ensure that sufficient, suitable land is available to achieve their housing and previously-developed land delivery objectives.

“53. At the local level, Local Planning Authorities should set out in Local Development Documents their policies and strategies for delivering the level of housing provision, including identifying broad locations and specific sites that will enable continuous delivery of housing for at least 15 years from the date of adoption...”

“54. Drawing on information from the Strategic Housing Land Availability Assessment and or other relevant evidence, Local Planning Authorities should identify sufficient specific deliverable sites to deliver housing in the first five years. ...

55. Local Planning Authorities should also:
– Identify a further supply of specific, developable sites for years 6-10 and, where possible, (my emphasis) for years 11-15. Where it is not possible to identify specific sites for years 11-15, broad locations for future growth should be indicated.
– Linked to above, identify those strategic sites which are critical to the delivery of the housing strategy over the plan period.
– Show broad locations on a key diagram and locations of specific sites on a proposals map.
– Illustrate the expected rate of housing delivery through a housing trajectory for the plan period.

Several significant points emerge from the above guidance:-

1. The requirement is to identify housing sites for a 15 year period either by identifying specific sites or by identifying broad locations on a key diagram. The opportunity for identifying broad locations on a key diagram in the context of the Core Strategy has passed, so the Allocations document must run for a 15 year period and identify specific housing sites in the 0-5 and 6-10 year periods and identify specific sites or broad locations on a key diagram in the 11-15 year period or specific allocations for a 15 year period. Either way there is no scope for the Allocations document to run for less than a 15 year period.

2. The most appropriate place for a key diagram would have been the Core Strategy. Now that the Core Strategy has been adopted the Allocations document should identify specific sites.

3. By identifying specific allocations the Allocations document should assist in meeting the key objective to “enable a continuous delivery of housing for at least 15 years from the date of adoption.”

4. The planning authority has invested resources in completing a Strategic Housing Land Availability Assessment and identifying specific sites in earlier draft Allocations documentation. The planning authority has demonstrated that it is possible to identify specific developable sites for the 11-15 year period and therefore there is no need to rely on a key diagram at this stage.

CABINET REPORT

The proposal to prepare an Allocations document for the period to 2020 is explained in the Cabinet Report dated 13th July as follows:-

The time horizon of the allocations process

“Although the allocations document must be in conformity with the Core Strategy, there is no compelling planning reason for allocating sites for the period until 2025 in a single allocations document. Were the timescale of the land allocations to be amended to 2003-2020, it would allow for a greater degree of certainty about deliverability, the early release of priority sites, soundness
in relation to the proper phasing of development and infrastructure provision and the timely updating of the strategic basis of the LDF. Any revised time frame would need to be taken into account in revisions to the Local Development Scheme.”

IMPLICATIONS FOR HOUSING LAND SUPPLY

It is difficult to see how shortening the timescale of the plan by five years assists in delivering a flexible and responsive supply of land envisaged by PPS3 or the greater degree of certainty about deliverability suggested in the Cabinet Report. Indeed from the table enclosed within the Further Consultation document it is clear that altering the time span of the plan alone reduces the net housing requirement that needs to be accommodated from 5911 dwellings to 3843 dwellings.
The suggestion of removing any allocations in the small villages and hamlets further reduces the amount of housing to be identified in the Allocations document by 308 dwellings, so only 3535 dwellings will be identified in the Allocations document.
Reducing the number of houses to be identified in the Allocations document by 40% simply reduces flexibility and increases uncertainty.
The housing figures set out in the table within the Further Consultation document are not agreed net requirements. From the information made available, there is an underestimate of net requirements. This exacerbates an issue already raised in previous submissions that the Allocations document intends to allocate land on the basis that each and every site will deliver the required number of completions within the relevant time periods with no allowance for slippage.


COMPELLING REASONS FOR ALLOCATIONS TO 2025

We offer several compelling planning reasons for allocating sites for the period to 2025.

1. A 15 year time horizon meets Government Policy requirements regarding housing provision.

2. Identifying specific sites would ensure the flexible and responsive supply of housing land that Government policy envisages.

3. Rather than provide a greater degree of certainty, a shorter plan period will require the commencement of a review within five years of adoption providing no long term certainty or confidence for local communities.

4. One can envisage another significant five year housing land supply shortfall soon after a 2020 plan is adopted in 2012/2013, particularly bearing in mind the intention to phase the release of many sites post 2014/15. In such a circumstance, and assuming a more favourable economic climate, sites will be promoted by the application and appeal process rather than through a development plan lead process.

5. The purpose of phasing within the adopted Core Strategy and in the previous Allocations Consultation document was to identify priorities. Presumably the higher priority sites were identified in the first and second phases. This is the more appropriate mechanism for delivering priority sites than abandoning a 15 year plan.

6. A plan for 15 years provides certainty to residents and the business community.

It is submitted that the planning authority offer no compelling or sound planning reasons for not progressing a plan to 2025.

MAJOR CHANGES TO THE PLANNING SYSTEM

The Allocations document indicates that “in view of the major changes to the planning system introduced by the Coalition Government, opportunity exists to reduce the time of the Land Allocations document to 10 years.” The document then goes on to refer to three changes, but only one has been implemented at this stage and none suggest the 15 year time horizon for identifying housing sites as specific sites or broad locations on a key diagram has been abandoned.

Each of the “three changes” are discussed are discussed below.


1. Localism Bill

There is nothing in the Localism Bill that refers to reducing the timescale of development plans.

Should the authority decide not to provide for allocations in small villages and hamlets, where 11% of housing and employment requirements are to be met, and instead rely upon local neighbourhood plans to come forward to deliver that 11% requirement, then it is even more important to plan for a 15 year period.

Local neighbourhood plans, is a new and untried concept. Such plans may not come forward in the numbers envisaged and in all probability will not deliver the housing requirements in the timescale that the authority perhaps envisages. If that proves to be the case there will be further difficulty in identifying a five year land supply and an increased likelihood of schemes being progressed through the application and appeal process rather than through a plan led approach.

2. Presumption in favour of sustainable development where plans are absent, silent or out of date.

This is related to a point made above. A plan to 2020 will require early plan review if the authority are to avoid a five year land supply shortfall. It will quickly become out of date and development will necessarily progress by application and appeal rather than a proper plan led approach.

It is unclear how a presumption in favour of sustainable development leads the authority to the conclusion that a shorter plan period would be appropriate.

3. New National Framework

The Draft National Planning Policy Framework was issued for consultation on 25th July after the proposal to shorten the time horizon was considered by members on 7th and 15th July, so it would appear this is a retrospective justification for shortening the plan period. However, there is nothing in the draft framework to suggest shorter development plans are appropriate but rather suggests longer term development plans are required.

Draft NPPF states:-

“19...planning should be genuinely plan-led, with succinct Local Plans setting out a positive long-term vision for an area.”

“24. Crucially Local Plans should:-

• Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements and be kept up to date.”

Whilst the guidance does not prescribe that a 15 year time horizon is a policy requirement, it clear the intention is for plans to be long term and that development requirements beyond the 15 year period should be taken into account. The guidance is suggesting plans should be for longer than 15 years, not shorter.

There is nothing in the Draft NPPF to suggest Government Policy is to abandon long term development plans.


The Allocations Consultation document refers to “major uncertainties...about the long term national picture” but there is nothing in any of the documents referred to that suggests an uncertain Central Government policy regarding a long term development plan lead system.

CONCLUDING COMMENT

The planning authority has not justified the reduced timescale of the Allocations document and there are very sound planning reasons as to why it would be inappropriate to do so.

Option A - Allocating sites for houses and employment in the Land Allocations document

It is considered that the most appropriate means of meeting housing and employment needs in the District is by providing sufficient housing and employment sites to meet development requirements in the context of the Allocations document.
The Core Strategy indicates that 11% of development needs are to be met in the small villages and hamlets. Removing 11% of the requirement from the Allocations document jeopardises the ability of the District as a whole to meet established development needs. The implications go beyond the small villages and hamlets.
The Core Strategy went through a lengthy consultation process to establish that areas outside the defined Principal, Key and Local Service Centres should accommodate an appropriate proportion of development requirements. The evolving Allocations document has to date similarly been through an exhaustive consultation process.
All parties will have been given appropriate opportunity to put forward and object to proposed sites in a considered process.
It is inappropriate at this stage in the preparation of the plan, to decide that the Allocations document is not the appropriate document in which to identify larger allocations in the smaller settlements and open countryside.
It is considered that the Allocations document should identify all sites over 0.4ha but leave the opportunity for local initiatives and planning applications to bring forward infilling and rounding off opportunities.
The “exceptional allocation” (3.108) suggested for Greenside Farm, near Hincaster which the Allocations document indicates “would benefit the local environment” should certainly remain in the Allocations document. To enable such a development to proceed in the context of S38(6) Planning and Compulsory Purchase Act (2004), it is difficult to identify a development plan policy one could rely on to give certainty in drawing up detailed proposals, without having to rely on undefined material considerations.