Stroud District Local Plan Review Regulation 18 Preferred Strategy - Stagecoach West Response 1. Introduction Stagecoach West welcomes the further opportunity to formally examine and comment further on the emerging proposals for the longer-term planning of the District. We applaud the decision of the District Council to undertake a second Regulation 18 consultation, allowing further work to be presented in support of the emerging development strategy and the resulting proposed allocations, and allowing appropriate opportunity for this to be scrutinised and tested by a full range of interested parties. We understand that the stated purpose of this round of consultation is to help the Council and a wider range of Statutory Consultees to collectively understand how far:- • How far the community and key stakeholders support the Council’s preferred strategy for meeting Stroud District’s future growth and development needs. • What additional issues or constraints exist relating to the proposed sites, and how specific constraints, needs and opportunities should be reflected in the final site allocation policies. • What further changes to the proposed policies are considered necessary, including specific things that should be included in supporting text. Our comments are thus advanced in two broad sections: a commentary on the Plan and its key supporting evidence base; and site-specific comments and observations. Our site specific responses relate principally to the sites proposed for allocation. We strongly support the vast majority of the options that the Council has identified. Our observation are aimed at giving both the Council and a wider range of stakeholders, more confidence that we see a way in which the step change in public transport quality and attractiveness can be achieved, not just to the proposed allocations in question, but better serving the entire plan area. However, given the depth of the concerns we continue to raise with regard to Sharpness Vale - the largest and most technically ambitious allocation in the Plan by a considerable margin - we also advance some considered views on two areas we had highlighted at Issues and Options stage, where we continue to believe that clear potential is likely to exist for sustainable development to be delivered, that aligns much better with the Councils overarching spatial strategy, and are likely to much better address the challenges that are driving the Plan’s Strategic Objectives. We now are aware that sites in both areas are available, and under active promotion. 2. Structure of the Plan- Strategic policies Stagecoach recognises and applauds the level of diligence that has been applied to plan-making, both in terms of the process of plan-making, the approach to the evidence base, and to the content of the draft plan. This in most respects materially exceeds the time and effort that other authorities have generally made. The Draft Plan is unusually comprehensive goes into a great deal of detail, and unusually, sets out policy in at least three “tiers” of detail, even before one considers the articulation of Strategic 1 Challenges and Objectives, and the general development management policies. Much of this can and should be viewed as a welcome and thoughtful response to the particular nature of the challenges and opportunities facing the Council. This is reflected in a number of distinct policy approaches within the draft plan. The focus on settlement clusters demonstrates a very sympathetic and at times quite nuanced approach to the different needs and characters of sub-areas within the plan. The approach to creating flexibility for smaller scale growth in certain villages is a carefully considered one, and is a good example of the care taken by officers, as is the exemplary approach to other areas, such as self-build and community led development. Notably, all allocations are treated in the same depth of detail, whether they involve 11 dwellings or up to 5000. However the result is a very long document that in many ways is hard to follow, with relevant policies, particularly with regard to the development strategy and development allocations of a strategic scale, divorced from one another and from a clear spatial narrative and justification. As the plan approaches examination, we think it would be very useful and helpful to all stakeholders to pull together the strategic narrative and policies with the policies for strategic allocations, at least for sites over 150 units scope. This will help make much more evident how strategic allocations follow from the spatial vision and strategy, and effectively address the challenges in the District. The National Planning Policy Framework makes explicit that plans should be “succinct” 1. It goes on to require that they should “avoid unnecessary duplication of policies that apply to a particular area” 2. Strategic policies should be clearly signalled in a plan: “Plans should make explicit which policies are strategic policies. These should be limited to those necessary to address the strategic priorities of the area (and any relevant cross-boundary issues), to provide a clear starting point for any non-strategic policies that are needed” 3. These starting points do not always follow through to subsequent site specific policies. It goes on to say in footnote 13 that “ Where a single local plan is prepared the non-strategic policies should be clearly distinguished from the strategic policies .” That is the situation in this case. While we are less concerned that what is set out in the plan is spurious, we wonder if the structure of the plan might be carefully looked at to rationalise it significantly, in particular where the “settlement cluster” approach is used. This along with non-strategic allocations could be better placed towards the back of the plan. We wonder if allocations for fewer than 25 dwellings are appropriate at all, given the strategic policy suite, which would appear to provide clear and sufficient policy support for these, and indeed the basis for some other smaller unidentified sites to come forward, especially in Tier 3a-c settlements. 3. The Evidence Base for the Plan and its Development Strategy 3.1. The justification for the development strategy: an overview 1 NPPF 2019 paragraph 15 2 NPPF 2019 paragraph 16 f) 3 NPPF 2019 paragraph 21 2 We see that a great deal of further evidence has been advanced in support of the Plan, much of it in draft form. This, very importantly, includes the Draft Sustainability Appraisal of November 2019 prepared by LUC (SA 2019). From our perspective, the transport evidence base has been significantly broadened with the Draft Sustainable Transport Strategy. We welcome this level of transparency, allowing some clear scrutiny before the pre-submission version is consulted upon. We are aware that that Sustainability Appraisal is a statutory requirement under UK law, and an analogous process of slightly different scope is also required by EU law under the Strategic Environmental Appraisal Directive, which will separately be transposed into UK legislation as part of the process of leaving the EU. In line with guidance within NPPF, we note that the Council is satisfying both legal requirements together in the Sustainability Appraisal in support of the draft plan. Too often, we find that Sustainability Appraisal work, and other key elements of the evidence base, are used to retroactively justify a development strategy that is driven by more narrow political concerns than the principles of sustainable development, not least those principles set out in NPPF. In these cases, the SA methodology and the evidence set out the Sustainability Appraisal and elsewhere is contrived and distorted, to retroactively justify a pre-determined approach to strategic allocations. This is entirely contrary to the purpose of preparing Sustainability Appraisals set out in statute in the 2004 Planning and Compensation Act, usefully quoted in paragraph 1.13 of the SA. As the preparation of the West of England Joint Spatial Plan (JSP), and its subsequent Examination in Public made plain last Summer, this kind of approach cannot be legally compliant and therefore cannot be accepted by the Planning Inspectorate, despite the clear and public ministerial guidance issued in July 2019, that Inspectors should take a suitably “pragmatic” approach to examining plans. Stagecoach made plain its alarm that the SA advanced in support of the JSP was inconsistent, and the weighting given to transport-related issues in particular seemed to be so low. A consistent, robust and appropriately balanced evaluation of the reasonable options for development is essential, to give all stakeholders confidence that the outcomes of the plan, if delivered, support and serve to “maximise” the opportunities for the delivery of sustainable development, and do not undermine it. In particular, the SA process should show how the plan strategy and spatial approach can demonstrably address the transport-related Strategic Challenges and Objectives of the plan. 3.2. The Transport Challenges in Stroud District The challenges facing the District relating to transport are very plain from the supporting material, not least within Chapter 3 of the SA Final Report, but also in other key parts of the evidence base. This includes both the Sustainable Transport Strategy (STS) published in November 2019 in support of the Plan, and the Settlement Role and Function Study Update (SRFSU) published in May 2019. These include: • Exceptionally high levels of car ownership and use, with some of the UK’s highest levels of multiple car ownership per household in the UK • Very high levels of out-commuting from the District: over 50% of journeys to work 3 • An average journey to work of 17 km: well above that which can be substituted by walking or cycling, especially given the challenging topography within and surrounding most of the largest settlements • A relatively limited public transport offer, and low peak time bus mode share: 2% for journey to work, half that of the County as a whole and greatly less than the UK average of about 7% in 2011.