DPD) Local Plan Examination
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Managing Development Delivery (DPD) Local Plan Examination Inspector’s Report on Reading Borough Council Sites and Detailed Policies DPD WBC/31 April 2013 Report to Reading Borough Council by C J Anstey BA (Hons) DipTP DipLA MRTPI an Inspector appointed by the Secretary of State for Communities and Local Government Date: 11th September 2012 PLANNING AND COMPULSORY PURCHASE ACT 2004 (AS AMENDED) SECTION 20 REPORT ON THE EXAMINATION INTO THE READING SITES AND DETAILED POLICIES DEVELOPMENT PLAN DOCUMENT Document submitted for examination on 15 July 2011 Examination hearings held between 29 November 2011 and 15 December 2011 File Ref: PINS/E0345/429/8 Non-Technical Summary This report concludes that the Reading Borough Council Sites and Detailed Policies Development Plan Document provides an appropriate basis for the planning of the Borough over the next 15 years providing a number of Main Modifications (MM) are made to the plan. The Council has specifically requested that I recommend any Main Modifications necessary to enable them to adopt the Plan. The Main Modifications can be summarised as follows: Include specific policy on the presumption in favour of sustainable development (MM1); Revise Policy SA5: Park Lane Primary School, The Laurels and Downing Road (MM2 & MM5); Delete Policy SA8a: Land at Kentwood Hill (MM3, MM4 & MM7); Amend the Housing Trajectory table and graphs (MM6); Revise boundary of the Kennet and Holy Brook Meadows Major Landscape Feature identified under Policy SA17 to exclude the Burghfield site (MM8); and Revise boundary of the East Reading Wooded Ridgeline Major Landscape Feature identified under Policy SA17 to exclude areas of the University of Reading Whiteknights Campus (MM9). -1- Reading Borough Council Sites & Detailed Policies DPD, Inspector’s Report September 2012 Introduction 1. This report contains my assessment of the Reading Borough Sites and Detailed Policies Development Plan Document (SDPD) in terms of Section 20(5) of the Planning & Compulsory Purchase Act 2004 (as amended). It considers whether the SDPD is sound and whether it is compliant with the legal requirements. The National Planning Policy Framework (the 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 Sites and Detailed Policies Document, Submission Draft (July 2011), submitted to the Secretary of State on 15 July 2011. 3. My report deals with the Main Modifications that are needed to make the SDPD 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 go to soundness have been subject to public consultation and, where necessary, Sustainability Appraisal (SA) and I have taken the consultation responses into account in writing this report. 5. The National Planning Framework and the Planning Policy for Traveller Sites were issued after the hearings but before the close of the Examination. The Council and representors have been given the opportunity of commenting on these documents. All comments received have been taken into account in writing the report. 6. The introduction of new national guidance during the Examination means that a significant number of minor changes to the wording of the SDPD are required to reflect the current position. The Council is responsible for making such changes in the final version of the SDPD, together with any other minor changes required. - 2 - Reading Borough Council Sites & Detailed Policies DPD, Inspector’s Report September 2012 Assessment of Soundness Preamble 7. The first part of the SDPD sets out the detailed planning policies that will be used to manage new development across Reading Borough over the coming years. The second part identifies the specific development sites and designations required to deliver the spatial strategy set out in the Council’s Core Strategy (CS), adopted in 2008. 8. Reading is identified in the South East Plan as a Growth Point, a regional hub and a centre for change. Its continued growth and development is vital for the prosperity of the area. The boundary of Reading Borough is very tightly drawn with over 40% of the urban area of Reading lying outside the Borough boundary. It is estimated that of the 230,000 living within the Reading urban area in 2001, some 145,000 live within Reading Borough. Various elements vital to the sustained future growth of Reading will need to take place in adjoining local authority areas. The material available indicates that adjoining authorities, through their adopted and emerging core strategies, are seeking to ensure that such elements are planned for and provided. For example the Strategic Development Location south of Reading around Shinfield identified in Wokingham Borough Council’s adopted Core Strategy provides for about 2500 dwellings and other uses and will make a significant contribution to the area’s need for homes and jobs. 9. The Borough itself contains little unconstrained, undeveloped land. As a result the CS recognises that future development of the Borough is likely to be focused on the redevelopment of brownfield land. Such an approach accords with national policy, provided that the land is not of high environmental value. The CS envisages a significant amount of growth taking place in the Borough itself. Most new development is to be steered towards the Central Area and South Reading. The CS spatial strategy also focuses development on the District and Local Centres and recognises that some employment sites have the potential for re-allocation to other uses. 10. The Reading Central Area element of the spatial strategy was largely dealt with in the Reading Central Area Action Plan (adopted in 2009), which allocated development capable of accommodating in the order of 5,000 dwellings and 200,000 sq m of commercial space. Notwithstanding this the SDPD applies to the entire Borough although some policies are clearly not relevant to the Central Area. The main elements of the strategy that remain to be dealt with in the SDPD include detailed guidance on South Reading, the allocation of development sites, the definition of various boundaries, and the re-allocation of various employment sites to other uses. 11. It is important to recognise that the Examination of the SDPD is not the appropriate format for the re-opening of debate about key issues that have previously been resolved in the CS, such as the overall level of housing provision, affordable housing on larger sites, the hierarchy of centres, retail policy, the principle of a Green Network, and the protection of Major Landscape Features. The appropriate time for the re-consideration of such matters is when the CS is reviewed. The Council has indicated that the Review of the CS is likely to take place in the near future. - 3 - Reading Borough Council Sites & Detailed Policies DPD, Inspector’s Report September 2012 12. During the Examination the Council raised concerns about the amount and scope of some of the additional material submitted by certain representors in the period leading up to the Hearing sessions. After careful consideration the Inspector decided to have regard to most of this material as it developed arguments raised in the initial representations. However the Inspector stated during the relevant Hearing that he was not prepared to accept the detailed critique of the affordable housing policies submitted on behalf of the University of Reading. This was on the basis that these policies did not give rise to significant concerns in the representations and that affordable housing provision on larger sites had already been dealt with in the CS. Main Issues 13. Taking account of all the representations, written material, and the discussions at the examination hearings, various main issues upon which the soundness of the plan depends have been identified. These are dealt with in turn below. Representations on the submitted DPD have been considered insofar as they relate to its soundness, but they are not reported on individually. General Matters Does the SDPD accord with the National Planning Policy Framework and has it been positively prepared? 14. The National Planning Policy Framework (the Framework) emphasises the importance of encouraging sustainable development through enabling economic growth and promoting housing development. Such a positive approach has been followed by the Council for many years and is inherent in the Council’s adopted development plan documents. The SDPD is in line with this approach and seeks to meet the carefully identified needs of the Borough through a comprehensive suite of policies and proposals that have sustainable development at that heart. As a result the SDPD sits comfortably with the general direction of the National Planning Policy Framework and has been positively prepared. 15. Notwithstanding this there is a need to include in the SDPD a specific policy that reflects the overarching presumption in the Framework of favouring sustainable development. I realise that the Council’s main modification (MM1) which introduces a specific policy to this effect differs from the model wording published on the Planning Portal. However to my mind it is still in line with the intentions of the Framework and does not differ from the model wording to the extent that the soundness of the policy is brought into question. The inclusion of the words ‘where appropriate’ is understandable given that from the outset it may be evident that a particular development will not improve the economic, social and environmental conditions of the area.