‘THE PLAN FOR BOROUGH – PUBLICATION’ – CONSULTATION RECEIVED FROM STAFFORD BOROUGH COUNCIL

Purpose of the Report

To highlight the key issues affecting Newcastle-under-Lyme Borough contained in ‘The Plan for Stafford Borough – Publication’ consultation document and to recommend a formal consultation response to the Plan.

Recommendations

(a) That the Committee note the document and its contents.

(b) That the Committee endorse the content of this report and that the following wording is used to form the basis of the Borough Council’s formal response to the consultation within the required timescale:-

(i) The Borough Council support the development strategy contained within ‘The Plan for Stafford Borough – Publication’ document including the housing and employment requirements. (ii) Policy ‘Stafford Town 1 (vii)’ and the relevant paragraph in ‘Policy Stone 1 – Stone Town’ with regard to office development in the town centres should be re-worded for the purpose of clarification to make it clear that B1(a) office development outside of these town centres should be subject to a sequential assessment. (iii) The Borough Council object to the provision of pitches being made in-line with ‘successor documents’ in Policy C6 - Provision for Gypsies, Travellers and Travelling Show-people. Any revised figures and evidence should be published before the Local Plan is formally submitted to the Planning Inspectorate for independent examination.

Reasons for Recommendation

‘The Plan for Stafford Borough’ is a Development Plan Document that will form part of the Local Development Framework for Stafford Borough. It will have implications for the future nature and scale of development in Stafford Borough. This consultation paper presents an opportunity for the Council to ensure that its views are taken into account at a key stage of the Plan’s preparation.

Background

The Borough Council has been consulted by Stafford Borough Council on the proposed ‘Submission Draft’ stage of their new Local Plan. The Plan sets out the overall strategic planning approach across the Stafford Borough area in terms of the vision, place-shaping objectives, targets and policies for the future development of Stafford Borough.

For any comments that the Borough Council may have on this proposal to be taken into account, they have to be received by Stafford Borough Council by no later than Thursday 28 February 2013. Any representations received should be made on the soundness and legal compliance of the plan.

The full plan can be accessed via the following link: www.newcastle-staffs.gov.uk/planning/planforstafford

Previous Representations

The Borough Council has made representations on previous consultation stages of the Plan between 2008 and 2012; these include joint responses with Stoke-on-Trent City Council. Officers of the Borough Council and City Council have also contributed towards ‘The Plan for Stafford Borough’ through meetings held as part of the ‘Duty to Co-operate.’ The ‘Duty to Cooperate’ is a legal requirement, which requires neighbouring authorities to cooperate to ensure that strategic priorities across local boundaries are properly coordinated and are clearly reflected in individual Local Plans.

In summary the issues and concerns raised in previous representations have been the following:

(a) The need to phase the release of greenfield sites and strategic housing sites around Stone until towards the end of the plan period. (b) The lack of definition for the various levels of centres within Stafford Borough. (c) The employment land delivery options (8 hectares or 12 hectares per year). (d) The need to phase the release of employment land to prioritise brownfield land. (e) The need for clarity regarding policies for B1(a) office development. (f) The requirement for Hadleigh Park, Blythe Bridge, to be identified as a major development site in the Green Belt and allocated for employment uses.

It is considered that all of the issues and concerns raised in previous representations have been addressed and resolved in previous stages of the ‘The Plan for Stafford Borough’ except issues a) relating to the phasing of sites and e) relating to office development which are considered later in the report.

Key Issues

Housing

The Plan makes provision for the development of 10,000 new dwellings at a rate of 500 dwellings per year, excluding additional requirements for military housing and provision for gypsies and travellers. This housing provision is distributed (Policy SP4) between Stafford (72%), Stone (8%), the Key Service Villages of Eccleshall, Gnosall, Hixon, Great Haywood, Little Haywood / Colwich, Haughton, Weston, Woodseaves, , Tittensor and Yarnfield (12%) and the rest of the Rural Area (8%).

It is your Officer’s opinion that the levels of housing take into account the targeted regeneration strategy for North , the stemming of out-migration from the conurbation and the efficient re-use of brownfield land.

Paragraph 3.10 of the Local Plan recognises the need to balance development requirements in Stafford Borough with the urban regeneration initiatives of the conurbation and reduce out-migration from North Staffordshire.

Importantly the Plan proposes to phase the development of strategic housing around Stone until after 2021 in response to issue a) above. The Plan states ‘ Pending restoration of the housing market in North Staffordshire, substantial additional development in the north of Stafford Borough could harm the fragile market’. This approach should lessen the impact of the development on the North Staffordshire housing market and has taken into consideration the Newcastle-under-Lyme and Stoke-on-Trent City Council Joint Core Spatial Strategy. It is your Officer’s opinion that this approach should be supported.

Employment

Provision is made in the Plan for 8 hectares of employment land per year (160 hectares during the plan period). This employment land is distributed (Policy SP5) between Stafford (56%), Stone (12%) and the rest of the Borough Area (32%). The 32% distribution in the rest of the Borough reflects the three major developed sites in the Green Belt have been identified as being suitable for employment development:

• Hadleigh Park (Former Creda Works Limited), Blythe Bridge. • Moorlands Industrial Estate, . • Former Meaford Power Station, Meaford.

The employment sites have not been specifically phased although Policy SP7 states that the use of brownfield land should be maximised to reduce the need for greenfield sites. The Policy states ‘ Only where insufficient sites on previously developed land, in sustainable locations, are available to meet new development requirements should greenfield sites be released.’

Furthermore there have been a number of recent planning decisions which have granted planning permission for key strategic employment sites within the Borough including Redhill, Stafford. As these employment sites already have planning permission the discussion over whether such proposals are brought forward too early in the plan period is redundant as the decision has already been made.

It is your Officer’s opinion is that the quantum of employment land and the employment sites identified should be supported. Furthermore it is recommended there is no objection to the lack of phasing for employment sites for the reasons given above.

Office Development in the Town Centres

Policy Stafford 1 – Stafford Town states that:

‘vii The use of employment sites for employment purposes other than B1 (b & c) excluding offices (B1a), B2 and B8 will not be permitted unless it can be proved that the proposed use cannot be located within Stafford town centre.’

Policy Stone 1 – Stone Town uses the same wording to state where B1(a) office development should be directed . It is considered that these policies are not entirely clear and require re-wording to ensure that it is unambiguous that B1(a) office development should only be permitted on employment sites outside the town centres if it can be proved, through a sequential assessment, that proposed development cannot be located within the town centre or edge of centre sites. This town centre first approach to office development is in-line with national policy outlined in the National Planning Policy Framework.

Gypsies, Travellers and Travelling Show-people

The most-up-date evidence base used to inform the provision for Gypsies, Travellers and Travelling Show- people is the North Staffordshire Housing Market Area Gypsy and Traveller Accommodation Needs Assessment published in December 2007. This assessment covered the local authorities of East Staffordshire Borough, Newcastle-under-Lyme Borough, Stafford Borough, Staffordshire Moorlands District and Stoke-on-Trent City. This assessment required provision for 76 pitches in Stafford Borough.

Policy C6 – Provision for Gypsies, Travellers and Travelling Show-people states that provision for pitches will be made in-line with that document or ‘successor documents’. It is recommended that an objection is raised to the reference to ‘or successor documents’ as we are unable to support any evidence base that is not publicly available and we have not had the opportunity to review. A new study could recommend a reduction in the provision of pitches and this could in theory result in an increase in our own provision requirements. It is understood that Stafford Borough Council have commissioned an up-to-date Gypsy and Traveller Accommodation Needs Assessment although the results of that assessment are not yet available.

Proposal

The development strategy contained in ‘The Plan for Stafford Borough – Publication’ document has taken into consideration, and is generally aligned to, the strategy contained within the Newcastle-under-Lyme and Stoke- on-Trent City Council Joint Core Strategy. It is therefore proposed to support the Development Strategy including its approach to achieving sustainable development and Policy SP2 – housing and employment requirements.

However clarity is required for the policies managing B1 (a) office development in the town centres to ensure that a town centre first approach is adopted. Your Officer considers that the policy should be re-worded to ensure that it is unambiguous that B1(a) office development should not be permitted on employment sites outside the town centres of Stafford, or Stone unless sequentially preferable sites in, or on the edge of, those town centres cannot be found

Finally it is recommended that an objection is raised to the provision of pitches being made in-line with ‘successor documents’ in Policy C6 - Provision for Gypsies, Travellers and Travelling Show-people. Only publically available evidence and published figures should be used to inform adopted policies. Any revised figures and evidence should be published before the Local Plan is formally submitted to the Planning Inspectorate for independent examination.

It is anticipated that the assessment will be available before ‘The Plan for Stafford Borough’ is ‘submitted’ for examination. If this is the case and we accept the evidence and any revised pitch requirement we will be able to withdraw our objection at this next stage.

Next Steps

Subject to Member agreement it is proposed to submit a joint consultation response to ‘The Plan for Stafford Borough – publication’ with Stoke-on-Trent City Council. The City Council are considering a report with similar recommendations at their Development Management Policy Group on the 19 February 2013. Therefore if the Borough Council Planning Committee and the City Council Development Management Policy Group agree to the recommendations at their respective meetings a joint response to the consultation can be submitted to Stafford Borough Council before the deadline on 28 February 2013.

Background Papers Joint response to 'The Plan for Stafford Borough: Draft Publication' 21/11/11 Joint response for 'The Plan for Stafford Borough - Strategic Policy Choices' 12/7/12 The Plan for Stafford Borough – Publication consultation document National Planning Policy Framework