Local Plan Issues and Options Consultation Responses and Progress Report (Agenda item 9)
Report of the Planning Policy Team Leader.
Appendix A to follow.
The Chairman explained that this report featured three elements and the intention was to discuss each item at each stage and to be interactive to ensure that the Local Plan reflected the Working Group’s opinions.
The Planning Policy Team Leader explained that the aim of the Local Plan Working Group report was to present to the Working Group a summary of the responses from the Issues and Options Consultation and to have a discussion around three areas that were fundamental to the production of a timely Local Plan; namely - the time period, the emerging work in order to define a spatial strategy and the setting of a housing target. The purpose of this meeting was for Members to provide a steer in order to guide work over the next few months so that progress could be made in a timely and efficient manner with regard to the timetable set by the Council.
The report had been split into three elements covering the plan time period, the work done so far in order to identify the Objectively Assessed Needs and the approaches to setting a spatial strategy i.e. defining the hierarchy of centres and deciding how much growth goes where in the district. This had been followed by a more general summary of the responses by section for Members information.
Although there were overlapping areas the aim was to focus debate on the individual sections in order to have a structured debate. Officers were in attendance to provide a short introduction to the topic area and a spreadsheet had been produced to provide Members with some visual indication of numbers around the potential scenarios and their implications to aid discussion.
Prior to the aforementioned discussions, the Planning Policy Team Leader had been asked to provide some additional contextual information.
- The Local Plan must be prepared with the objective of contributing to achieving Sustainable Development, the objectives should be realistic, planning positively through the setting of strategic polices for the delivery of the homes needed in the district and to identify sufficient sites to provide for five years worth of housing plus the additional 5% buffer.
- The existing Core Strategy had an existing housing target of 780 dwelling per year. This had been set through the now revoked Regional Spatial Strategy (RSS) and the Council had the primary responsibility for setting its own housing requirement and providing the right number of new homes was one of the most important challenges it faced. The setting of this target must be in the context of the National Planning Policy Framework (NPPF) and be based on current and future demographic trends and market trends.
- The approach taken was one of building on the strategic commitments of the Core Strategy - that of the 4,000 homes at Attleborough and the 5,000 homes in Thetford. Members needed to bear in mind that these commitments continued to influence the Local Plan spatial strategy.
- The NPPF requires the Council to prepare a Strategic Housing Market Assessment (SHMA) to identify the scale and mix of housing and the Council had committed to this through the joint evidence base of the Duty to Cooperate.
- If the 650 dwellings per year figure identified so far from the emerging SHMA was taken forward as the housing target and the plan period was set to 2036, there would be a need for 16,250 homes. However, 55% of this target would already be directed at the two Strategic Urban Extensions (SUEs) leaving only 7,250 homes to be distributed over the district over the plan period through the revised spatial strategy.
- Four alternatives had been consulted on around the setting of the spatial strategy and an additional set of options on how to define the local service centres. Such work had to be carried out in the confines of the NPPF and the consultation responses and it was important to remember that the existing Strategy, one of focussed development, had relied on 88% of the predicted growth directed at Thetford and Attleborough and only a positive allocation in 4 local services centres, this supply led approach had not delivered the requirement for a five year supply, so it was important to consider a step change in direction if the local plan was to influence where development was to take place.
- In terms of sustainable development, whilst planning cannot overcome market forces and personal behaviour, it could help to ensure that rural communities and settlements did not stagnate and decline and to that aim the Planning Policy Team had been asked to seek opinions on a more local definition of Sustainable Development. This specific question had received 32 responses. Many expressed a desire for a balance of employment and residential growth, with calls for development to be spread down to appropriate rural areas as well as market towns. Appropriate infrastructure and service provision was a consistent theme amongst responses. Other responses called for the definition to reflect more specific “self containment”; although this could be attractive, the Council was charged with planning for the whole district and must take into account the wider strategic influences in the district. This had been emphasised through the SHMA which identified the Central Norfolk Housing Market area extending as far as the North Norfolk coast, to the north and passed Diss to the South and almost to Thetford.
- The approach documented in the report had therefore been framed by Members views on promoting the rural economy, the consultation responses and the statutory requirements of the NPPF and Planning Practice Guidance (PPG) around a more balanced approach to distribution but also on the evidence of the emerging SHMA which the NPPF placed significant weight upon.
- There was still further work to do in these areas; however, it was important to keep Members informed of the direction of travel and to obtain a steer so that as things moved forward resources could be directed so as to make timely progress to the time line set by the Council for the production of the Local Plan.
Plan time period
Issues and options document put forward a timeline of 20 years (2031), or 25 yrs (2036).
There had been 11 expressions of support setting the plan period to 2031 and 20 for taking the plan period to 2036 (Option 3). A number of responses highlighted that the 15 yr period was all that was required to align with the NPPF, while others pointed out that it was better to align the evidence base with the plans of the neighbouring authorities where better co ordination of infrastructure was envisaged.
The majority of support for the longer period had come from statutory bodies such as Norfolk County Council, South Norfolk District Council and other Parish and Town Councils such as Attleborough, Beetley and Beeston with Bittering.
Support for the shorter time line came from developers and notably Dereham, Swaffham and Thetford Town Councils, for the reasons included, setting it to the NPPF requirement of a minimum 15 yrs and stating that the Office for National Statistics (ONS) population forecasts only went to 2021.
It had previously been expressed at the Local Plan Working Group (LPWG) that the longer time line was appropriate and would still recommend this so as to operate in the context of the Duty to Cooperate (DtC) (which was a legal requirement). A DtC Forum had been set up across Norfolk through which a platform was offered to identify and share information and commission joint evidence studies. Breckland Council had already lent its support to this. Through this Forum the 2036 date was put forward as a realistic end date for all local single Local Plans so that cross boarder issues could be identified and quantified. Most of the neighbouring authorities had given a commitment to an early review of their Local Development Frameworks (LDFs). A further advantage was that it offered an investment platform for infrastructure.
The Chairman pointed out that Breckland Council would fall at the first hurdle if under the DtC it could not agree a time period with other authorities.
Members were content with the recommendation provided, and it was:
RESOLVED that having regard to the positive support within the representations from both statutory consultees and the public, the preferred approach was for the Local Plan to cover the time period of up to 2036 be approved. This was in accordance with the NPPF and it allowed Breckland Council to align its Plan with adjoining authorities which would be beneficial under the DtC.
Objectively Assessed Needs
The Council was now in the position of moving towards setting the housing target for the district and a steer was required so that further work could be done. Both the NPPF and the PPG directed to evidencing the assessment through a SHMA and the identification of the ‘objectively assessed needs’ and setting polices to meet that need in full.
The primary objective was to identify the future total number of homes based on quantitative assessments but also on an understanding of qualitative requirements such as market signals.
In order to establish the evidence base, an initial housing paper setting out the possible scenarios had been brought to the LPWG and four options had been taken forward into the consultation. One of these options included planning for growth around the then yet to be published Joint SHMA.
The question generated significant responses (50), with the most supported option (approx 20-25) being that of seeking to align the Council’s housing target with that of the Joint Central Norfolk Strategic Housing Market Assessment.
The highest housing target received 6 representations of support which predominantly focussed on the NPPF’s requirements to positively secure housing growth.To plan for more housing and set a higher housing target was good as long as the plan included the positive development of the appropriate infrastructure and that it was seen as a reasonable prospect that the necessary infrastructure could and would be delivered. This was where we were now and history told us that it was not necessarily a sustainable position for Breckland.
Given the importance given to the SHMA in the PPG and NPPF it was likely that the SHMA would bear ultimate weight in identifying the ‘objectively assessed needs’. This was because the figure being proposed by the SHMA would have taken into account the latest DCLG projections, travel to work patterns and would have established the wider housing market areas that the Plan must have regard to and represent the most up to date evidence
This study unfortunately remained delayed and further work was still being carried out to address some of the district wide issues and in order to incorporate the latest Household projections that would see the time line of the study extended from its 2031 date to 2036. Nevertheless it provided the Council with a good steer in which to move forward on at this time.
The emerging study had identified a need for 650 DPA in Breckland, although this was subject to change and a Central Norfolk Housing Market Area, in which there were three levels of influence identified.
In order to progress, the Planning Policy Team was therefore proposing a spatial distribution based around the influences identified in the SHMA and the emerging OAN. The sheets that had been circulated gave a visualisation of this.
The Chairman felt that there was insufficient information to make a recommendation. Councillor North thought that local councils were very much hindered by Government setting targets as to how much housing they should have. The Planning Policy Team Leader explained that the responsibility of setting that target had now been devolved to local authorities and every two or three years these forecasts had to be updated. Councillor North mentioned the planning meetings that she attended where developers were always quoting the 5 year land supply to try and push through their requests. The Planning Policy Team Leader explained that Members did have to take the 5 year land supply into account at planning meetings and that it was a requirement of Local Plan making to demonstrate a 5 year supply. The approach being put forward was a more balanced approach than the existing Core Strategy which had relied on two large scale extensions coming forward. One strategy to achieve a five year supply could be to allocate smaller sites across the district to front load the Plan a little more as Thetford and Attleborough urban extensions would still not come forward until the latter stages of the new single Local Plan.
Referring to section 1.15 of the report, Councillor Duigan wanted to know if any steer had been received from the Government in relation to the SHMA for Thetford particularly in relation to the slow delivery. He also wanted to know what would happen if Dereham provided all the housing and others did not. The Deputy Planning Manager explained that there were two issues, the first was the SHMA, and the Central Norfolk SHMA would get the complete figure for the District and a broken down more granular figure for other wider areas. The second was about how the spatial distribution affected the 5 year land supply which means that other sites would need to be brought forward in other locations in the first 5 years of the Plan period. Councillor Bambridge agreed with the SHMA in principle and also agreed that Breckland would have to look over its borders and when it came to actual allocation of houses the physical needs of those villages needed to be taken into account.
RESOLVED that the recommendation at section 1.28 of the report be agreed.
Local Service Centres
Members were asked to reflect on the approach proposed for the identification of service centres. The Core Strategy had originally designated 14 Local Service Centre villages; however, following the Issues and Options consultation, work had been undertaken to assess the potential of individual villages beyond the original 14 to meet the criteria for Local Service Centres regardless of the population threshold in the form of a desk top study. In the first instance, this focused around villages with a primary school which resulted in 39 villages being identified within Breckland, including all villages previously identified, plus Bawdeswell, Hockering, Beetley, Garboldisham, Kenninghall, Sporle and Yaxham; however, Table 2 on page 17 of the report recommended that Bawdeswell, Garboldisham, Hockering, Kenninghall, Sporle and Yaxham met with the five criteria to be recommended as Local Service Centre villages. In relation to the recommendation for such designation, it had been recommended that those villages should be investigated further which would include looking at land availability within the said villages.
Referring to the recommendation, Councillor Lynda Turner pointed out that Beetley had access to Dereham not Watton as stated in the report at paragraph 1.51. It was noted that this reference referred to Saham Toney and its proximity to Watton in comparison to Beetley’s proximity to Dereham.
The Chairman raised concerns with regard to the Table on page 17 of the report. He knew for a fact that Carbrooke had at least two shops but according to the table it had none and felt that Carbrooke should be included as a Service Centre village. It was explained that the table attempted to separate the parts of Carbrooke which were included within the built up extent of Watton and the historic village centre of Carbooke.
Councillor Gould asked for the definition of a community facility. Members were informed that the error had been picked up and the Village Hall in Scarning would be included as a community facility. Councillor Turner pointed out that Garvestone did not have a shop or a post office. Councillor Joel highlighted the fact that Old Buckenham did not have any public transport. Councillor Jolly mentioned East Harling as a current Service Centre in her Ward and Garboldisham as a proposed one. She had listened to the general points made but the problems with East Harling as a Service Centre had been problematic. There had been a great deal of growth putting pressure on the school and the Doctors Surgery and in relation to the lack of parking in the village. People did not walk as the village was very long and pointed out that sometime ago the main road through the village had been classed as an HGV route and the traffic along that road had increased. In Garboldisham there had been many accidents so looking at this without the overlay of the transport infrastructure was not very good. Also, she was not entirely happy with the criteria being used for Norfolk County Council’s interpretation of peak hour travel and this she felt should be addressed and further growth should not be considered. Members were reminded that this was a working document.
Councillor Bambridge agreed that taking some development out of the towns and into the villages was needed and some were perfect for development but he felt that some villages had been missed and areas just outside the border should be looked at. He felt that there should be a lot more detailed conversations with these Ward Members as it all had to be driven by local opinion and what local people wanted.
The Chairman agreed and felt that the reason developers kept mentioning the 5 year land supply all the time was due to the fact that Breckland Council was very much in the forefront of getting its Local Plan in place compared to other authorities in the country. Members needed to get this right and he asked if villages closer to Breckland’s border had been looked at to see if they had any facilities as he was not minded to agree with the recommendation at section 1.52. The Planning Policy Team Leader advised that the principle of widening the service centre areas was the steer that the Planning Policy Team was looking for and those service centres nearer to borders would be investigated and reported back. The Chairman felt comforted that this was part of the process. Councillor Carter said that this had proved that there were issues but other work carried out in this document was laudable yet there were matters that needed to be looked at more closely. The Chairman asked the Deputy Planning Manager to send an email to all relevant Members to encourage them to come forward with their suggestions. Members were reminded that this document had been built upon the feedback from the Issues and Options document but as it moved forward, those opinions needed to be firmed up and taken on board. The Deputy Planning Manager explained that this work was iterative and ongoing. Members needed to be content with this work and be comfortable with the criteria and the approach at this stage. Councillor Jolly felt that health should be included on the chart. The schools were oversubscribed so just an existence of a school was not in her opinion good enough. All these issues were behind the housing, people and growth so what influence did the Council have on funding available and enabling these schools to grow. The Planning Policy Team Leader advised that the plan process was very much plan led and focused other service providers as to how they should invest. It actually provided more certainty to them and if the schools could not expand, how they were going to provide that education function. School choices were beyond Breckland Council’s control but these issues had already been factored in. The same for health, Doctors surgeries needed to know where the growth was going so that the NHS knew where to invest. NHS had had an impact to rural area health services but this was the reason why a steer was needed from Members. Referring to health matters, Councillor North asked if the same criterion was used for shops, the catchment area for the surgeries in Attleborough was vast as it covered many of the local villages. Councillor Turner felt that NHS England should be challenged as Shipdham surgery was overstretched and when it had offered to expand the request to fund the expansion was refused. Also, the primary school in the village was bursting at the seams and she felt that Councillors should speak to all concerned in a much firmer voice. Councillor Jolly said that she would like to understand the process more in relation to policy. The Planning Policy Team Leader stated that an update was circulated to Members on a monthly basis and the section on planning policy could include an update on the approach to health provision so far through the Local Plan.
Referring to standalone affordable housing, Councillor Joel asked the Planning Policy Officer if such housing would be included as part of the numbers in Local Service Centre areas. Members were informed that these were taken into account.
The Chairman asked Members if there were any further categories that they felt should be added other than health and in terms of a steer, it was
RESOLVED that work should continue with this section along the lines of the recommendation in paragraph 1.51 & 1.52 of the report and that more detailed work should be carried out in order to establish the extent of service provision (including health provision) and a review of those villages on Breckland’s borders.
Four potential options for the distribution of growth were presented, looking at whether the spatial distribution of growth should be focused around major towns, dispersed across the district or balanced growth between urban and rural areas. The detailed options had been summarised in the report. The Senior Planning Policy Officer provided Members with a detailed overview of each option.
· Concentrating primarily on Thetford and Attleborough;
· Development to a lesser extent on remaining three towns;
· Very limited growth in other areas.
Option 2 - Dispersed/Scattered Development Pattern
· Growth take place in greater number of settlements;
· More growth in Local Service Centres and other rural villages.
Option 3 - Balanced Development Pattern
· A balanced approach between focused and dispersed pattern;
· Proportionate development in Local Service Centres with greater level of development in Dereham, Watton and Swaffham.
Option 4 - A New Settlement / Upgrading Existing Settlement
· A new settlement or substantial development in an existing lower-tier settlement;
· Need to be combined with any of the options above.
Members were provided with a summary of the consultation responses on Spatial Strategy.This question generated significant response with 58 representations received. The most supported option (19 supporting responses) was option 3 which sought to plan for a balanced development pattern seeing a more balanced development between urban and rural areas. This option received support from a number of key stakeholders including, adjoining authorities and many parish councils.
The focused development option had also been supported by a good portion of consultees with 16 supporting responses from Norfolk County Council and a number of parish councils.
The development of a new settlement or upgrading an existing settlement had been supported on a number of occasions with either focused or balanced development patterns.
The main points raised from the consultation were:
· Feasibility of developing a new settlement as the overall growth quantum may not be sufficiently viable at this stage.
· Urban extension alone would not be able to address the shortfall of the immediate five year housing supply.
· The most appropriate spatial strategy should consider both the market towns and local key service centres in rural areas.
The main concerns raised from the consultation in relation to the Focused Development Pattern (similar to the approach taken in the adopted Core Strategy) were:
· Development around the major urban extensions allows for very limited growth in the wider area;
· less flexible and carries a higher degree of risk;
· large urban extensions often take longer to deliver;
· do not necessarily address the immediate shortfall of housing land supply.
The main concerns raised from the consultation in relation to the dispersed development patternwere:
· Less sustainable due to the rural nature of Breckland,
· Difficult to generate a sufficient level of community benefits (infrastructure).
The main concerns raised from the consultation in relation to the new settlements were:
· Not likely to gain sufficient quantum due to the predicted housing target – not viable
· However, it is thought possible that a new settlement might be a future option due to potential Duty to Cooperate requirements to address shortfalls for neighbouring districts
The most appropriate option was considered to be a more– Balanced Development Pattern.
· In line with the guiding principles of the NPPF;
· Most consultation responses reflect this option;
· Provides flexibility to deliver the Objectively Assessed Needs;
· Caters for additional growth outside the urban extensions of Thetford and Attleborough
· More balanced development between urban and rural areas;
· Allow improved housing land supply from rural areas to meet the immediate shortfalls; whilst retaining strategic housing sites around larger towns to meet the long term housing needs during the remainder of the plan period.
· This strategy will be influenced by existing committed development in Thetford (no more development due to environmental constraints) and the Council's current focus to bring forward development in Attleborough.
· The principle established under the current strategy for the urban extensions to Attleborough and Thetford in any case will form a significant portion of growth.
In order to inform the proportion of development in towns and villages, an iterative new settlement hierarchy had been proposed.
As identified through the Local Service Centre survey, and reflecting the conclusions of the SHMA, the settlement hierarchy had been set as illustrated in the table at page 15 of the agenda. This included the 7 newly identified Local Service Centres under the new methodology.
Distribution had been based on the location and proximity to the following Housing Market areas as identified in the emerging joint SHMA:
· Core Housing Market Area
· Greater Norwich Housing Market Area
· Wider Norwich Housing Market Area
Local Service Centres with stronger links with Norwich or major towns should accommodate relatively more growth.
Key areas for major urban extensions
Rest of the Market Towns:
Medium scale allocations should be accommodated
Category 1 Local Service Centres
Settlements that are within or adjacent to Core/Greater Norwich Housing Market Area or Major Towns – higher growth should be accommodated
Category 2 Local Service Centres
Settlements that are within the Wider Norwich Housing Market Area – moderate growth should be planned
Category 3 Local Service Centres
Settlement outside Wider Norwich Housing Market Area or with significant constraints - limited or no development
* Newly identified Local Service Centres
In light of the identified settlement hierarchy, the Planning Policy Team had developed a number of possible ways to distribute the housing growth and these were visually presented in the spread sheets circulated.
Members were asked to bear in mind that the tables presented should be used for discussion purposes only to aid understanding on the consequences for the different options, they were not intended to represent a final spatial strategy but just to assist in the debate.
650 dwellings per year had been used as currently identified in the SHMA – although it will be further updated in light of the newly published CLG projection as part of the SHMA.
Members were asked to note that it was intended that the growth strategy for Attleborough would retain the 4000 (approx.) target. Any completions and commitment to date had not been deducted from the 4000 total. This was due to:
- The new Local Plan which covered up to 2036 (opposed to current Core Strategy 2026) therefore further growth should be planned.
- A reduced housing target could impact on the ability of deliver essential Infrastructure
Councillor Bambridge referred to the first spreadsheet in relation to Hockering and he asked how the ‘green’ column had been worked out. Members were informed that the figure of 244 in that column took account of current commitments, 6 dwellings already had planning permission so the net figure in the ‘pink’ column highlighted the future commitments for Hockering which was 238. Councillor Bambridge felt that there would be considerable opposition to this. Councillor Joel asked if the villages alongside the A47 had been given more weight. The Planning Policy Team Leader advised that employment forecasts had already been included in the base data. The Chairman raised grave concerns about the difference in the figures between Swaffham and Watton and presumed that Carbrooke had been included in Watton. He did not believe that the Council should continue to put Carbrooke and Watton together and felt that the Planning Policy Team should start to consider the physical size of the parishes. This he felt was very much work in progress and although he thought the strategy to be very good it was all dependent on the SHMA and the Service Centre Villages. The Planning Policy Team Leader advised that this was just a visualisation of what had been discussed and would evolve.
Following further debate, it was:
RESOLVED that the third option, the balanced development pattern be agreed.
Councillor Bambridge said that he would also like to keep the forth option in the pipeline. He advised that any new or significantly expanded settlement needed to be considered on a wider County or LEP wide basis and would be a significant matter for discussion with other authorities and bodies under the Duty to Cooperate. The Deputy Planning Manager advised that this fourth option was not for this plan but could be for a future plan.
The Planning Policy Team had produced a summary of all the consultation responses received for Members to consider and were attached as an appendix to this report, indexed linked to the appropriate question so that Members could review feedback received. In addition, all responses were available on the Council’s consultation portal. The remaining responses would be presented at future meetings of the Local Plan Working Group
- Local Plan Progress Report FINAL 13 03 15, item 18/15 PDF 317 KB
- Appendix A - Consultation Statement summary 13 03 15, item 18/15 PDF 2 MB