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Report to Knowsley Metropolitan Borough Council

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Report to Knowsley Metropolitan Borough Council Report to Knowsley Metropolitan Borough Council by Martin Pike BA MA MRTPI an Inspector appointed by the Secretary of State for Communities and Local Government Date: 24th November 2015 PLANNING AND COMPULSORY PURCHASE ACT 2004 (AS AMENDED) SECTION 20 REPORT ON THE EXAMINATION INTO KNOWSLEY LOCAL PLAN: CORE STRATEGY Document submitted for examination on 19 July 2013 Examination hearings held between 5 November 2013 and 4 June 2015 File Ref: PINS/V4305/429/1 Abbreviations Used in this Report AA Appropriate Assessment ALC Agricultural Land Classification BREEAM Building Research Establishment Environmental Assessment Methodology DCLG Department for Communities and Local Government dpa dwellings per annum dph dwellings per hectare EVA Economic Viability Assessment Framework National Planning Policy Framework ha hectares IDP Infrastructure Delivery Plan JELPS Joint Employment Land and Premises Study KLPCS Knowsley Local Plan: Core Strategy LCR Liverpool City Region LDS Local Development Scheme MM Main Modification PPG Planning Practice Guidance PPTS Planning Policy for Traveller Sites PRA Principal Regeneration Area RSS North West Plan: Regional Spatial Strategy to 2021 SA Sustainability Appraisal SADP Site Allocations and Development Policies SCI Statement of Community Involvement SHLAA Strategic Housing Land Availability Assessment SHMA Strategic Housing Market Assessment SPD Supplementary Planning Document SuDS Sustainable Drainage System SUE Sustainable Urban Extension UDP Unitary Development Plan -1- Knowsley Local Plan: Core Strategy Inspector’s Report, November 2015 Non-Technical Summary This report concludes that the Knowsley Local Plan: Core Strategy provides an appropriate basis for the planning of the borough, providing a number of modifications are made to the plan. The Knowsley Metropolitan Borough Council has specifically requested me to recommend any modifications necessary to enable the plan to be adopted. All of the modifications to address this were proposed by the Council but where necessary I have amended detailed wording and/or added consequential modifications and I have recommended their inclusion after considering the representations from other parties on these issues. The Main Modifications can be summarised as follows: Changing the Council’s proposed Green Belt ‘reserve locations’ for development to ‘Sustainable Urban Extensions’ (SUEs) with specific policy requirements; Removing the phased release of Green Belt development to ensure sufficient land is available to meet short term needs; Clarifying and reducing slightly the employment land requirement; Modifying the approach to retail development in town centres to better reflect national policy; Reducing the affordable housing requirement within urban areas to help ensure development is viable; Updating the policies for housing standards and sustainable construction to reflect national policy; and Adjusting the approach to biodiversity, heritage assets, open space and minerals to be consistent with national policy. - 2 - Knowsley Local Plan: Core Strategy Inspector’s Report, November 2015 Introduction 1. This report contains my assessment of the Knowsley Local Plan: Core Strategy (KLPCS – the Plan) in terms of Section 20(5) of the Planning & Compulsory Purchase Act 2004 (as amended). It considers first whether the Plan’s preparation has complied with the duty to co-operate, in recognition that there is no scope to remedy any failure in this regard. It then considers whether the Plan is sound and whether it is compliant with the legal requirements. The National Planning Policy Framework (paragraph 182) makes clear that to be sound, a Local Plan should be positively prepared, justified, effective and consistent with national policy. 2. The starting point for the examination is the assumption that the local authority has submitted what it considers to be a sound plan. The basis for my examination is the KLPCS Submission Document of July 2013. 3. My report deals with the main modifications that are needed to make the Plan sound and legally compliant and they are identified in bold in the report (MM). In accordance with section 20(7C) of the 2004 Act, the Council requested that I should make any modifications needed to rectify matters that make the Plan unsound/not legally compliant and thus incapable of being adopted. These main modifications are set out in the Appendix. 4. The main modifications that are necessary for soundness all relate to matters that were discussed at the examination hearings. Following these discussions, the Council prepared a schedule of proposed modifications and carried out sustainability appraisal; this schedule has been subject to public consultation. A separate consultation was undertaken on a changed approach to wind energy development (see Issue 7). I have taken account of the consultation responses in coming to my conclusions in this report, and in this light I have made some amendments to the detailed wording of the main modifications and added consequential modifications where these are necessary for consistency or clarity. None of these amendments significantly alters the content of the modifications as published for consultation or undermines the participatory processes and sustainability appraisal that has been undertaken. Where necessary I have highlighted these amendments in the report. 5. Many proposals of the KLPCS are repeated in different parts of the Plan (for example, strategic land allocations are repeated in the Area Priorities section). In most cases I have treated main modifications to repeat proposals as consequential and have not separately identified them as main modifications in the Appendix. In addition, the Council has proposed a large number of additional modifications which do not materially affect the policies of the Plan. These are solely a matter for the Council. In some instances, modifications identified by the Council as “main” I regard as “additional”, and vice versa. In this report and the Appendix I focus on what I regard as the main modifications necessary to make the Plan sound. Any of the Council’s main modifications which are not specifically mentioned in the report or Appendix are either consequential or additional, and can be made by the Council on adoption of the Plan. - 3 - Knowsley Local Plan: Core Strategy Inspector’s Report, November 2015 Public Consultation 6. There was major disquiet throughout the examination at the nature and extent of the Council’s consultation with the public during preparation of the KLPCS. Two main issues emerged – whether the dissemination of information about the evolving plan was sufficiently thorough, and whether the content of the information supplied was easily understood by most people. 7. In terms of the former, the statutory requirement is that the Council complies with its own Statement of Community Involvement (SCI). The SCI requires consultation by a wide range of methods (at least 6-8 different methods at the main stages), so the framework for consultation is thorough. There is evidence of a wide range of authorities, organisations, agencies, partners, local groups and individuals being consulted by many different methods during KLPCS preparation. Thus at each stage the Council carried out (and mostly exceeded) the required methods of engagement set out in the SCI. Moreover, at two early stages (‘Issues and Options’ and ‘Preferred Options’), a leaflet was delivered to all households in Knowsley. A small number of addresses appear not to have received the leaflet at ‘Issues and Options’ stage, which is unfortunate, but the problem does not seem to have been widespread and, given the range of other methods used, does not amount to non-compliance with the SCI. The Council used a different carrier for the ‘Preferred Options’ leaflet delivery and no significant problems were reported. 8. Turning to the content of the information disseminated, the Council has been criticised for not making its proposals clear. The main concern relates to the release of Green Belt land for development, which at ‘Preferred Options’ stage was depicted by coloured ‘blobs’ on the key diagrams included in the 8-page leaflet distributed to all households. It is true that these diagrams require careful study to gain an understanding of the proposed developments, yet many people in the communities affected were able to understand the emerging Plan and make their objections known. With hindsight the Council could have used simpler visual representations which focused solely on the main proposals, with perhaps greater detail in the text to better describe the Green Belt locations (road names and so on). Nevertheless almost 2,400 individual comments were submitted at this stage (1,400 in petitions) from 389 respondents, a significant response which suggests that the information was adequate for its intended purpose. 9. The consultation on Proposed Modifications during the examination attracted a much greater level of objection primarily because the Council directly consulted all residents living within 200m of the proposed Green Belt sites; this was a consequence of the change in status of the sites from broad locations to specific allocations. It is unclear why major objections to the long term Green Belt site at Knowsley Village were only made at this stage.1 Whatever the reason, Knowsley village residents received the same information about the Plan at earlier stages as all other residents, so the lack of response can hardly be blamed on inadequate consultation.
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