The Planning Inspectorate Room 406 / Kite Wing Direct Line 0117-372 8902 Temple Quay House Switchboard 0117-372 8000 2 The Square Fax No 0117-372 6241 Temple Quay GTN 1371-8902 Bristol BS1 6PN e-mail: [email protected] http://www.planning-inspectorate.gov.uk Petar Kanuritch Your Reference: Bob Wilson Director of Environment and Development Our Reference: DP000431/N3020 Gedling Borough Council Civic Centre Date: Arnot Hill Park Arnold Nottingham NG5 6LU Dear Sir Gedling Borough Local Plan Review 1. As you know, I was appointed by the First Secretary of State to hold a public inquiry into objections to the Draft Gedling Borough Local Plan Review. The Local Plan Inquiry began on 18 March 2003 and closed on 26 August 2003. The inquiry sat for 72 half-day sessions, although in some of these sessions, objections from more than one objector were heard. A pre-inquiry meeting was held on 13 December 2002. Before, during and after the Inquiry I made accompanied or unaccompanied site visits to all the sites that were the subject of objections. 2. The District Local Plan Review covers the whole of the Borough of Gedling. When adopted it will replace the Local Plan adopted in 1990. The review plan covers the period until 2011. 3. The Council supplied me with a database listing all the representations made on the Draft Local Plan, updated to the close of the Local Plan Inquiry. They also supplied me with a skeleton report that contained headings and listed all the objections with summaries. My report uses the structure of the skeleton report, which broadly reflects the structure of the Local Plan itself. 4. The Programme Officer, in conjunction with the Council’s Planning Officers, have prepared Appendices to my report listing the objectors, those who appeared at the Local Plan Inquiry and the Core Documents used during the Inquiry. It is my understanding that these appendices have been supplied directly to the Council. A complete set of the documents submitted in connection with the Inquiry is held in the Local Plans Section at Gedling Borough Council, Civic Centre, Arnot Hill Park, Arnold NG5 6LU and may be inspected or referred to there. 5. A copy of this letter has been sent for information to: • the Government Office for the East Midlands; • the Office of the Deputy Prime Minister in London. The Representations 6. As you know, the Nottinghamshire County Planning Authority did not issue a Statement of Conformity confirming that the Local Plan is in general conformity with the adopted County Structure Plan. However, I was able to consider the matters that are of concern to the County Council as objections to the Local Plan. 7. The Local Plan was placed on deposit twice, in 2000 and 2002, following the publication of an earlier consultation draft plan. As a result numerous representations were received from organisations and individuals. According to the Council’s database there were 8640 objections to the Draft Local Plan, of which 1034 had been withdrawn by the end of the Inquiry. There were also 4211 representations supporting the Draft Local Plan, of which 125 had been withdrawn by the end of the Inquiry. These figures include some representations that the Council had originally classified as “comments” but which, on my insistence, were reclassified either as objections or as support. The Phased Release of the Local Plan Inquiry Report 8. The government attaches great importance to speeding up the planning system in general and the plan-making process in particular. I am also aware there are important and difficult planning decisions to be taken in Gedling and that some of the developments that are needed require a long lead-in time. There is a pressing need to move forward. 9. For these reasons I have approached and organised my work by splitting it into two parts: • all the policies (and objections) in the Local Plan with a direct bearing on how much development is needed and where it should take place; • the other policies, which may be regarded as less pressing. 10. I am releasing the report to the Council in two parts, so the first part does not have to wait for the completion of the second part. I anticipate that the first part of my work will be the most contentious, although to some extent this is a guess because I have not begun work on the second part yet. However, I hope that delivering the report in two parts will give the Council more time to consider the most contentious matters, speed the process overall and bring forward the time when implementation can start. 11. The first part of my report contains the complete chapters on Housing, Employment, Transport and Community Services and selected policies in the Environment chapter. All being well, the rest will follow about two months after this. Matters Taken into Account 12. In considering the objections, I have had regard to the submissions made by or on behalf of the various objectors and for the Council, and to all other material considerations, including current Planning Policy Guidance and Circulars where appropriate. I have also had regard to the representations made in support of the plan. 13. The Council will need to take into account any PPG, Circular or other government advice published after the delivery of my report. Unless otherwise stated, my references to government policy as set out in Circulars or PPGs relate to the versions that were current at the close of the Inquiry. The Council will 2 need to have regard to any subsequent revisions to government guidance or policy that occur prior to the adoption of the Plan. 14. I have not been able to have regard to any changes in local planning circumstances that may have occurred since I closed the Inquiry. The Council will also need to take any such changes into account when they consider my report. General Approach 15. I have no illusions that my report will be popular, either with the Council or with the majority of objectors, although I believe that a better Local Plan will result. Because of the report’s length and the numerous matters of detail it covers, I will highlight the key components of my thinking here. 16. I consider that broadly speaking the Council set itself the correct parameters for preparing the Local Plan because these were derived from the adopted Structure Plan. In general terms I endorse the Council’s starting points regarding the number of new dwellings to be accommodated, residential density, the amount of employment land to be found and the general principles guiding locational choices. 17. However, there are five major issues on which I part company with the Council: • the extent to which the delivery of dwellings at Gedling Colliery / Chase Farm can be relied on by the end of the plan (2011); • whether it is (yet) safe to allocate land for major areas of development in the Trent valley; • how urgent it is to identify an adequate and varied supply of developable land to enable an immediate and sustained increase in the rate at which new housing is being delivered in Gedling; • whether (more) land (than is needed for development) should be taken out of the Green Belt and designated as White or Safeguarded Land; • whether it is wise or helpful for the Local Plan to deal with developer contributions in the way it does. 18. Nearly all of the major modifications to the Local Plan I am recommending can be traced back to these main issues. Land for New Dwellings 19. As I have said, I have largely accepted the case advanced by the Council concerning how much land will be needed for residential development to satisfy the requirements of the Structure Plan. What flows from this is the recognition that a considerable amount of greenfield land will need to be developed and that this will involve taking land out of the Green Belt. 20. I recognise that many members of the public (and groups) do not accept this but the evidence is clear that enough development land cannot be found unless considerable areas are removed from the Green Belt. I am satisfied this is both necessary and sanctioned by the Structure Plan. Some objectors believe that the latest government guidance (as in PPG3), in effect, prohibits development on greenfield sites but this is not so. Rather, it establishes that greenfield land should not be used if enough brownfield land is available. It is also sometimes overlooked that government guidance places a strong emphasis on the need to ensure there is enough housing land available to enable housing needs in the area to be met. 3 21. However, against this background it is also important that too much greenfield land is not made available for development because this could inhibit the use of previously developed land in the wider urban area in the short or longer term. This is why I have resisted pressure from house builders that even more land should be released. Employment Land 22. Things are less clear cut in relation to land for employment. Again, I have accepted the Structure Plan as the starting point and am satisfied that some greenfield and Green Belt land has to be released for development. However, the evidence (from CPRE and others) that past demand for employment land has been far slower than the Structure Plan anticipated is persuasive enough for me to conclude that it is not of overriding importance that the Structure Plan guideline is met in its entirety.