2 responses from Mr Allan Large, Government Office for the North West
1. Mr Allan Large, Government Office for the North West : 10 Jul 2008 12:43:00
Please write your comment or explain your reasons for supporting or opposing this part of the Report. You may also wish to refer to the tests of soundess in the glossary of the Preferred Options document before making your comments.
GOVERNMENT OFFICE FOR THE NORTH WEST COMMENTS
The following are supplied, on behalf of the Secretary of State, as representations on the published Core Strategy Preferred Options report. They are comments and suggestions on the preferred options as they relate to identified good practice and to national and regional policy. Alongside comments on the text, references may be made to issues of soundness. These comments are intended as pointers towards the Submission version of the document and are made without prejudice as to any representations which may be made at that time.
As the strategy is further developed, we recommend that continuing reference be made to the available guidance and other tools, notably the PPS12 good practice manual (shortly to be made available), various Planning Advisory Service publications, especially those on Core Strategy preparation and the evidence base, as well as the Soundness Self Assessment Toolkit, and the Planning Inspectorates document ‘Lessons Learnt Examining Development Plan Documents’.
You will already have made contact with the Planning Inspectorate, but we would draw your attention to their advice that a Programme Officer be recruited so as to be in post from the date the Examination begins, namely when the document is submitted.
Section 2. The spatial portrait
This is issue-focused, contains a clear and credible vision, links in well to spatial objectives and commendably cross-references these to the Community Strategy, Corporate Plan and other strategies.
The ‘Policy context’ boxes, weaving this through the document, are also a worthwhile feature.
Section 3.
This section is complicated. It is less clear than the recommended approach of producing strategy options that present clear alternative strategies for the district.
However, that does not automatically rule out such an approach. We appreciate that the circumstances of South Lakeland are such that this kind of ‘pick and mix’ presentation may be valid. On the face of it the approach meets the terms of Soundness Test 7, though much may depend on the Council being able to demonstrate that the size and complexity of the document has not inhibited public debate.
We have no comment to make on the content of the options presented; these appear to provide good coverage of the possibilities available and are well rooted in the issues identified and responses made to earlier consultation.
Paragraph 3.6. How does the Core Strategy take account of planning proposals within adjoining planning authorities? It is not clear.
PO1 Option 6 raises questions.
1. One can infer implications for accessibility and public transport which do not seem to be addressed; how will these clusters of settlements operate together? What will knit them together other than their being physically close to each other when viewed on a map? Will development in the smaller settlements within a cluster generate more car traffic than a more concentrated pattern?
2. The relationship with the also preferred Option 5 is unclear. Inclusion in Option 6 ‘clusters’ might be taken to mean that those settlements could be expected to take a higher share of development than those outside, which are implicitly more rural. Is this the case? Should it be?
PO2 rural areas
(A terminological point. Reference is made in the policy and elsewhere “… x% affordable with …% being for local need”. It might be clearer if statements were expressed as ‘all new housing … local need with x% affordable’ – as presumably, the ‘affordable’ units will be similarly fettered.)
In view of the known difficulties with IPATH, it is important that the Council demonstrate that the 70% ‘affordable’ target is achievable without being compromised by site viability problems.
Paragraph 3.48 refers to ‘rural exception’ sites’. To specify that not all such sites will be ‘affordable’ is not in line with national policy, the point of that policy being that the homes are permitted on land where house building would not normally be countenanced, because they are ‘affordable’. We are prepared to listen to arguments in favour of setting this aside as proposed, but will need to be persuaded if we are not to object to it. The Inspector will likewise need to be persuaded, with reference to the evidence base and demonstrations of special local circumstances.
PO3 distribution of development
The breakdown of the share of development between different settlements is needed. The approach here is very precise.
Also, rather oddly, the ‘preferred option’ does not quite conform to any of the options suggested.
At submission, the monitoring framework will need to demonstrate how this will be monitored, what degree of tolerance will be exercised (and over what periods of time) with regard to the consequences of any settlement or category of settlements exceeding these figures, and what might be done if that becomes a problem.
The point with house building in small settlements is not so much (precisely) how many homes are built, but whether they are being built in numbers large enough to threaten other policy objectives, such as the maintenance of the viability of service centres, the provision of developments of sufficient scale to provide affordable units, or, more generally, sustainable development. We should also bear in mind that house building figures are not maxima, so if rural house building exceeded 4% of the total, but that building was meeting local needs in sustainable locations, that might be perfectly acceptable. On the other hand, if there were a shortfall, developers might try to use that to push through proposals which were not affordable or sustainable. Thus, at this end of the spectrum, the Council may wish to consider whether the interests of its most rural areas would be better served not by allocating them a percentage, but by expressing an intention to encourage house building in appropriate numbers and of appropriate types to meet local need, including subsidised housing on ‘rural exceptions’ sites.
PO4 Balanced Housing Market
The principle of looking to focus local occupancy eligibility more widely onto related settlements beyond the District boundary is welcomed. But the Council might consider giving more explicit justification for applying this (as is implied by the map) to principal towns in those districts, especially Barrow, where prices are generally lower than in the Ulverston area.
The suggested policy looks very prescriptive and detailed. It will be important to establish, as far as possible, that it is viable, especially on smaller developments.
PO5 Sustainable economy
(1) We would question the usefulness of going in such detail into the share of development between different settlements. In house building, a degree of detail tends to be supportable due to the policy dealing with (in total) a large number of individual units, the relative flexibility of the industry, and the level of detail in the evidence base. Employment land, however, is more ‘lumpy’; there may be considerable variation in the floorspace requirements of different businesses in the same class; and strategic targets tend to be more notional because of the greater unpredictability of employment development. As far as smaller settlements are concerned, would it be better to rely on a criteria-based approach, subject to monitoring of performance against strategic targets?
We would also question the proposed distribution. It is much the same as for residential development, despite 58% of businesses wanting a greater concentration on Kendal (which is the location most accessible to a variety of transport modes). What is the basis for this? It requires evidential justification.
(2) The site at Shenstone is preferred despite having ‘critical water constraints’. In terms of demonstrating the robustness of the strategy, we would recommend that the monitoring and implementation framework demonstrate that these can be addressed, or what will be done if they prove insurmountable or that the measures needed make the site unviable.
PO6 Town Centres and retail strategy
Floorspace figures such as those quoted in 3.132 will mean little to lay readers, without some form of comparator to give an idea of scale.
PO7 to PO9
The themes covered here are much the same as one might find in any other Core Strategy, and add little or nothing to national and regional policy.
In PO8, more clarity might be helpful as regards safe cycle routed to schools – is it intended that provision will be universal or will there be a concentration on particular settlements, that is, the ones with most traffic? – and coach parking – what is ‘appropriate’, or ‘inappropriate’?
Section 4
The presentation of ‘options’ in this section is eccentric. Most of the ‘alternative options’ are not ‘alternatives’ but proposals which could, and in most cases do, sit together; the choice is ‘yes’ or ‘no’. As long as this is understood, then it should not be a problem.
Of more concern is the presentation of ‘alternative directions of growth’. These are listed, followed by lists of the chosen directions; but there is little in the way of justification as to why particular directions have been chosen or rejected. Neither is justification visible in the Sustainability Appraisal report, which appears to appraise the chosen packages without comparative appraisal of the options not chosen. On the face of it, this does not sit comfortably with Soundness Test 7, and, arguably, Test 3.
We would recommend that the Council give careful thought to how the Area Strategies are taken forward. You should consider the following questions.
1. Can it be demonstrated that those consulted have been given an adequate basis to evaluate the merits of the alternative directions of growth?
2. Have their merits in terms of sustainable development been properly appraised?
3. Would the Inspector have adequate information to allow him or her to recommend, if so persuaded, alternatives not preferred by the Council?
General comment; local distinctiveness
Overall it looks as though the submitted document will demonstrate that it has a locally distinctive approach, not least because of the Area Strategies.
However, we would recommend that you consider this attribute when drafting policies covering the ‘generic’ themes in section 2 (PO7 to PO9) and the ‘core’ themes in PO18 to PO24. Of the latter, at present we would suggest that PO20 and PO22 to 24 might add little to national and/or regional policy, unless their detailed drafting pays attention to their local relevance.
Monitoring, implementation and flexibility
The implementation framework has clearly already been given thought and appears to be shaping up well. We would recommend that, in developing it and refining it, consideration be given to the following.
· It is always likely that a plan will contain elements whose achievement may be problematic. The Inspector is likely to look for a ‘plan B’ to demonstrate what the Council will do if implementation falls short of the targets (and note our comments above in this respect on some aspects of the strategy).
· In particular, the provision of affordable housing stands out. The targets are ambitious and South Lakeland is already addressing the challenge of balancing the need to push for more affordable dwellings against the constraints o f development viability. It will be important for the submitted Core Strategy to demonstrate how the Council can react if targets are not being met.
· The Regional Spatial Strategy is under review, and the current expectation is that house building figures will increase further. The Strategy’s robustness will be greatly enhanced if it indicates how, and potentially where, such growth will be accommodated. In principle it should be possible for the Strategy to take such change on board without having to be reviewed.
2. Mr Allan Large, Government Office for the North West : 10 Jul 2008 12:44:00
GOVERNMENT OFFICE FOR THE NORTH WEST COMMENTS
The following are supplied, on behalf of the Secretary of State, as representations on the published Core Strategy Preferred Options report. They are comments and suggestions on the preferred options as they relate to identified good practice and to national and regional policy. Alongside comments on the text, references may be made to issues of soundness. These comments are intended as pointers towards the Submission version of the document and are made without prejudice as to any representations which may be made at that time.
As the strategy is further developed, we recommend that continuing reference be made to the available guidance and other tools, notably the PPS12 good practice manual (shortly to be made available), various Planning Advisory Service publications, especially those on Core Strategy preparation and the evidence base, as well as the Soundness Self Assessment Toolkit, and the Planning Inspectorates document ‘Lessons Learnt Examining Development Plan Documents’.
You will already have made contact with the Planning Inspectorate, but we would draw your attention to their advice that a Programme Officer be recruited so as to be in post from the date the Examination begins, namely when the document is submitted.
Section 2. The spatial portrait
This is issue-focused, contains a clear and credible vision, links in well to spatial objectives and commendably cross-references these to the Community Strategy, Corporate Plan and other strategies.
The ‘Policy context’ boxes, weaving this through the document, are also a worthwhile feature.
Section 3.
This section is complicated. It is less clear than the recommended approach of producing strategy options that present clear alternative strategies for the district.
However, that does not automatically rule out such an approach. We appreciate that the circumstances of South Lakeland are such that this kind of ‘pick and mix’ presentation may be valid. On the face of it the approach meets the terms of Soundness Test 7, though much may depend on the Council being able to demonstrate that the size and complexity of the document has not inhibited public debate.
We have no comment to make on the content of the options presented; these appear to provide good coverage of the possibilities available and are well rooted in the issues identified and responses made to earlier consultation.
Paragraph 3.6. How does the Core Strategy take account of planning proposals within adjoining planning authorities? It is not clear.
PO1 Option 6 raises questions.
1. One can infer implications for accessibility and public transport which do not seem to be addressed; how will these clusters of settlements operate together? What will knit them together other than their being physically close to each other when viewed on a map? Will development in the smaller settlements within a cluster generate more car traffic than a more concentrated pattern?
2. The relationship with the also preferred Option 5 is unclear. Inclusion in Option 6 ‘clusters’ might be taken to mean that those settlements could be expected to take a higher share of development than those outside, which are implicitly more rural. Is this the case? Should it be?
PO2 rural areas
(A terminological point. Reference is made in the policy and elsewhere “… x% affordable with …% being for local need”. It might be clearer if statements were expressed as ‘all new housing … local need with x% affordable’ – as presumably, the ‘affordable’ units will be similarly fettered.)
In view of the known difficulties with IPATH, it is important that the Council demonstrate that the 70% ‘affordable’ target is achievable without being compromised by site viability problems.
Paragraph 3.48 refers to ‘rural exception’ sites’. To specify that not all such sites will be ‘affordable’ is not in line with national policy, the point of that policy being that the homes are permitted on land where house building would not normally be countenanced, because they are ‘affordable’. We are prepared to listen to arguments in favour of setting this aside as proposed, but will need to be persuaded if we are not to object to it. The Inspector will likewise need to be persuaded, with reference to the evidence base and demonstrations of special local circumstances.
PO3 distribution of development
The breakdown of the share of development between different settlements is needed. The approach here is very precise.
Also, rather oddly, the ‘preferred option’ does not quite conform to any of the options suggested.
At submission, the monitoring framework will need to demonstrate how this will be monitored, what degree of tolerance will be exercised (and over what periods of time) with regard to the consequences of any settlement or category of settlements exceeding these figures, and what might be done if that becomes a problem.
The point with house building in small settlements is not so much (precisely) how many homes are built, but whether they are being built in numbers large enough to threaten other policy objectives, such as the maintenance of the viability of service centres, the provision of developments of sufficient scale to provide affordable units, or, more generally, sustainable development. We should also bear in mind that house building figures are not maxima, so if rural house building exceeded 4% of the total, but that building was meeting local needs in sustainable locations, that might be perfectly acceptable. On the other hand, if there were a shortfall, developers might try to use that to push through proposals which were not affordable or sustainable. Thus, at this end of the spectrum, the Council may wish to consider whether the interests of its most rural areas would be better served not by allocating them a percentage, but by expressing an intention to encourage house building in appropriate numbers and of appropriate types to meet local need, including subsidised housing on ‘rural exceptions’ sites.
PO4 Balanced Housing Market
The principle of looking to focus local occupancy eligibility more widely onto related settlements beyond the District boundary is welcomed. But the Council might consider giving more explicit justification for applying this (as is implied by the map) to principal towns in those districts, especially Barrow, where prices are generally lower than in the Ulverston area.
The suggested policy looks very prescriptive and detailed. It will be important to establish, as far as possible, that it is viable, especially on smaller developments.
PO5 Sustainable economy
(1) We would question the usefulness of going in such detail into the share of development between different settlements. In house building, a degree of detail tends to be supportable due to the policy dealing with (in total) a large number of individual units, the relative flexibility of the industry, and the level of detail in the evidence base. Employment land, however, is more ‘lumpy’; there may be considerable variation in the floorspace requirements of different businesses in the same class; and strategic targets tend to be more notional because of the greater unpredictability of employment development. As far as smaller settlements are concerned, would it be better to rely on a criteria-based approach, subject to monitoring of performance against strategic targets?
We would also question the proposed distribution. It is much the same as for residential development, despite 58% of businesses wanting a greater concentration on Kendal (which is the location most accessible to a variety of transport modes). What is the basis for this? It requires evidential justification.
(2) The site at Shenstone is preferred despite having ‘critical water constraints’. In terms of demonstrating the robustness of the strategy, we would recommend that the monitoring and implementation framework demonstrate that these can be addressed, or what will be done if they prove insurmountable or that the measures needed make the site unviable.
PO6 Town Centres and retail strategy
Floorspace figures such as those quoted in 3.132 will mean little to lay readers, without some form of comparator to give an idea of scale.
PO7 to PO9
The themes covered here are much the same as one might find in any other Core Strategy, and add little or nothing to national and regional policy.
In PO8, more clarity might be helpful as regards safe cycle routed to schools – is it intended that provision will be universal or will there be a concentration on particular settlements, that is, the ones with most traffic? – and coach parking – what is ‘appropriate’, or ‘inappropriate’?
Section 4
The presentation of ‘options’ in this section is eccentric. Most of the ‘alternative options’ are not ‘alternatives’ but proposals which could, and in most cases do, sit together; the choice is ‘yes’ or ‘no’. As long as this is understood, then it should not be a problem.
Of more concern is the presentation of ‘alternative directions of growth’. These are listed, followed by lists of the chosen directions; but there is little in the way of justification as to why particular directions have been chosen or rejected. Neither is justification visible in the Sustainability Appraisal report, which appears to appraise the chosen packages without comparative appraisal of the options not chosen. On the face of it, this does not sit comfortably with Soundness Test 7, and, arguably, Test 3.
We would recommend that the Council give careful thought to how the Area Strategies are taken forward. You should consider the following questions.
1. Can it be demonstrated that those consulted have been given an adequate basis to evaluate the merits of the alternative directions of growth?
2. Have their merits in terms of sustainable development been properly appraised?
3. Would the Inspector have adequate information to allow him or her to recommend, if so persuaded, alternatives not preferred by the Council?
General comment; local distinctiveness
Overall it looks as though the submitted document will demonstrate that it has a locally distinctive approach, not least because of the Area Strategies.
However, we would recommend that you consider this attribute when drafting policies covering the ‘generic’ themes in section 2 (PO7 to PO9) and the ‘core’ themes in PO18 to PO24. Of the latter, at present we would suggest that PO20 and PO22 to 24 might add little to national and/or regional policy, unless their detailed drafting pays attention to their local relevance.
Monitoring, implementation and flexibility
The implementation framework has clearly already been given thought and appears to be shaping up well. We would recommend that, in developing it and refining it, consideration be given to the following.
· It is always likely that a plan will contain elements whose achievement may be problematic. The Inspector is likely to look for a ‘plan B’ to demonstrate what the Council will do if implementation falls short of the targets (and note our comments above in this respect on some aspects of the strategy).
· In particular, the provision of affordable housing stands out. The targets are ambitious and South Lakeland is already addressing the challenge of balancing the need to push for more affordable dwellings against the constraints o f development viability. It will be important for the submitted Core Strategy to demonstrate how the Council can react if targets are not being met.
· The Regional Spatial Strategy is under review, and the current expectation is that house building figures will increase further. The Strategy’s robustness will be greatly enhanced if it indicates how, and potentially where, such growth will be accommodated. In principle it should be possible for the Strategy to take such change on board without having to be reviewed.