Statement of Consultation on the Pre-Submission Draft Local Plan
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Statement of Consultation on the Pre-submission Draft Local Plan March 2018 1 1. Introduction …3 2. Details of Consultation …4 3. Results of Consultation: Drop-In Events …6 4. Results of Consultation: Written Responses …7 5. Evaluation of Consultation …9 Appendix 1: List of those consulted on the Pre-submission Draft Local Plan …10 Appendix 2: Consultation email text …20 Appendix 3: Summary leaflet …26 Appendix 4: Press release …28 Appendix 5: Press articles …30 Appendix 6: Exhibition boards …31 Appendix 7: Summary of late responses related to CA1b: Reading Golf Course …34 Appendix 8: Summary of proposed changes to the Sustainability Appraisal …38 Appendix 9: Summary of written responses …42 2 1.0 INTRODUCTION 1.1 The consultation that took place in November 2017 to January 2018 related to the new Local Plan for Reading. It was decided to proceed with a new comprehensive Local Plan to replace the three existing development plan document (the Core Strategy, Reading Central Area Action Plan and Sites and Detailed Policies Document), particularly in view of changes that were made in the 2012 National Planning Policy Framework. A new Local Development Scheme was produced in 2013 (and updated in 2014 and again in 2016) which set out this intention. 1.2 The first consultation stage was on Issues and Options. Rather than a draft plan, this was a discussion paper that highlighted the important questions that inform what the plan should contain and how it should address the key matters. The Issues and Options document was particularly informed by the Berkshire Strategic Housing Market Assessment, which identified the level of objectively assessed housing need for Reading. The Issues and Options document also identified possible sites for inclusion in the draft plan. 1.3 The second consultation stage was on the Draft Local Plan. This document was a full draft, after taking account of all the comments received during the Issues and Options consultation as well as other emerging information. Supporting documents such as a Proposals Map, Sustainability Appraisal and Infrastructure Delivery Plan were also made available for comment. Consultation occurred from May 2017 to June 2017. 1.4 The third consultation was on the Pre-Submission Draft Local Plan. This document was another full draft, taking account of all the comments received during the Draft Local Plan consultation as well as other emerging information. Supporting documents were also updated and made available for comment, including a Proposals Map, Sustainability Appraisal, Infrastructure Delivery Plan and Housing and Economic Land Availability Assessment, as well as guidance on making a representation. 3 2.0 DETAILS OF CONSULATION 2.1 Consultation on the Pre-Submission Draft Local Plan, along with the accompanying Proposals Map, and Sustainability Appraisal began on Thursday 30th November 2017 and lasted until Friday 26th January 2018, a period of eight weeks. The Infrastructure Delivery Plan and Housing and Economic Availability Assessment were also made available as supporting documents. 2.2 In terms of an approach, the consultations on planning policy documents need to be undertaken in line with the Council’s adopted Statement of Community Involvement (SCI). The latest version of Reading’s SCI was adopted in March 2014. 2.3 The SCI sets out some general guidelines for how consultations on the local plan should take place, with the main principle being involving stakeholders at the earliest stage. Figure 1 shows the general approach to each stage of consultation. Figure 1: Approach to Development Plan Documents from Statement of Community Involvement 2.4 The SCI gives some examples of the types of exercise that might be appropriate at the pre- submission stage, which corresponds to this consultation, and these include: • Directly contacting important consultees, including those involved at earlier stages; • Direct discussion with key stakeholders; • Drop-in events, particularly in locations and at times where interested individuals have a chance to discuss aspects of the policy or plan with Council representatives; and • Publication of the policy or plan online. 2.5 Therefore, the overall approach for the Pre-submission Draft Local Plan was similar to that of the Draft Local Plan and somewhat more focussed than the Issues and Options stage and was centred on consultation rather than involvement and collaboration. 2.6 Consultation consisted of the following elements: • Directly emailing over 1000 contacts on the Council’s consultation lists, including statutory consultees, adjoining local authorities, Parish Councils, community and 4 voluntary groups, commercial organisations, businesses and interested individuals. The full list of those consulted is in Appendix 1, the text of the email is set out in Appendix 2, and the summary leaflet that was attached to the email is included in Appendix 3; • Documents (including the Pre-Submission Draft Local Plan, Sustainability Appraisal, Proposals Map, Infrastructure Delivery Plan, Housing and Economic Land Availability Assessment and summary leaflet) being made available on the Council’s website; • Copies of the summary leaflet and of the Pre-submission Draft Local Plan being made available at Reading Borough Council libraries; • A press release was also prepared and distributed (see Appendix 4). From this, articles on the Local Plan appeared in the local press (www.getreading.co.uk) (see Appendix 5); and • Two drop-in events, when members of the Planning team were on hand together with exhibition boards (see Appendix 6) to discuss any issues arising, held at Reading Civic Offices on Wednesday 6th December and Tuesday 12th December. 5 3.0 RESULTS OF THE CONSULTATION: DROP-IN EVENTS 3.1 The two drop-in events were not particularly well-attended, possibly reflecting the increasing reliance on accessing information online. However, the low number of attendees did enable some quite in-depth discussions, which seem to have been reflected in the written representations that were subsequently made. Low attendance may also have been affected by the fact that much of the interactive consultation occurring during the Issues and Options phase and that two drop-in sessions occurred previously in the year during the consultation on the Draft Local Plan in May and June 2017. 6 4.0 RESULTS OF THE CONSULATION: WRITTEN RESPONSES 4.1 The Council received over 193 written responses to the Draft Local Plan (although one of these was a petition with 142 signatures). These responses came from a mix of individuals, community groups, landowners and developers and other local authorities and public sector organisations. The responses that were received were in general quite detailed, and a total of 583 individual comments were made. Some of the main points raised are set out below: • Generally, there was support for trying to accommodate the need for 671 homes per annum from the development industry. Adjoining authorities noted the position regarding the expected unmet needs. • Many individuals expressed support for encouraging higher density growth in the town centre, while some individuals expressed concern about the number of flats planned and the need for more family housing, as well as affordability concerns. • Many developers requested more flexibility, particularly with regard to energy efficiency, design and affordable housing. Additionally, some developers consider the requirement of employment development to mitigate impacts on housing to be onerous. • A number of developers supported the Council’s inclusion of a Private Rental Sector policy in order to encourage build-to-rent properties, but many disagreed with the specific approach taken and recommended changes. • Many individuals expressed concern about the impacts of new development on existing infrastructure, citing traffic congestion, limited school places and crowded GP surgeries, particularly in the north of Reading. • In terms of sites allocated for development, the sites that generated the largest volume of responses (most opposing development), were - Land at Kentwood Hill (WR3s) and Land at Armour Hill (WR3t) - Part of Reading Golf Course at Kidmore End Rd (CA1b) - Potential Traveller Transit Site at Cow Lane (WR4) • Many developers and landowners who had put forth sites earlier in the process responded with support. • Some individuals expressed concerns about the impacts of tall buildings on the character of the town. • Some landowners and developers advocated other sites located just outside Reading’s boundary, around Grazeley in Wokingham Borough and around the edges of Caversham and Emmer Green in South Oxfordshire District, as potential sites to help meet Reading’s housing need. • Numerous individuals and community groups expressed strong support for retention and improvement of existing open spaces. A number of responses were in relation to identification of sites as Local Green Space. The site most frequently mentioned was Mapledurham Playing Field. 7 • There were a number of detailed technical comments on the environmental policies from respondents such as the Environment Agency and Natural England. • Historic England, community groups and individuals were pleased with the greater emphasis placed on heritage within the Local Plan. 4.2 A summary of each individual representation is included in Appendix 9 to this document. 4.3 A number of responses related to development at Reading Golf Course (CA1b) were received after the close of the consultation. These are summarised in Appendix 7. 8 5.0 EVALUATION OF CONSULTATION 5.1 Generally, the approach to the consultation on the Pre-submission Draft Local Plan was considered to be reasonably productive, in view of the resource constraints for carrying out such a consultation, particularly in terms of officer time. There would certainly have been measures that would have brought a greater response, but that needed to be weighed up against limited resources and the fact that many of the policies and sites had been consulted on relatively recently. With 193 responses received, this is somewhat higher than the 150 or so received to the Draft Local Plan consultation. 5.2 Attendance at the drop-in events was low compared to previous years.