(ITEM 9)
TO: THE EXECUTIVE 20 DECEMBER 2005
BRACKNELL FOREST BOROUGH LOCAL DEVELOPMENT FRAMEWORK -ANNUAL MONITORING REPORT (Director of Environment and Leisure)
1 PURPOSE OF DECISION
1.1 The Planning and Compulsory Purchase Act 2004 requires every local planning authority to produce an Annual Monitoring Report (AMR) which will form part of the Local Development Framework for the area. The AMR is to cover the period 1 April to 31 March each year and is to be submitted to the Secretary of State by the end of the following December.
1.2 The first AMR, which is attached as an appendix to this report, covers the period 1 April 2004 to 31 March 2005 and is to be submitted to the Secretary of State via the Government Office for the South East (GOSE) by the end of December 2005. It must then be made available to local communities both in hard copy and electronically on the Council’s web site. The purpose of this report is to seek authorisation to submit the report to GOSE and subsequently make it available to the public.
2 RECOMMENDATIONS
2.1 That the Bracknell Forest Borough Annual Monitoring Report (Appendix 1), including the Joint Mineral and Waste Annual Monitoring Report (Appendix 2), be approved for submission to the Government Office for the South East and subsequent publication;
2.2 That the Bracknell Forest Borough Local Development Scheme, December 2005 (Appendix 3), be approved for submission to the Government Office for the South East and subsequent publication; and,
2.3 That authority be delegated to the Executive Member for Planning and Transportation to make any necessary minor amendments to the Annual Monitoring Reports or Local Development Scheme prior to submission.
3 REASONS FOR RECOMMENDATIONS
3.1 The enactment of the Planning and Compulsory Purchase Act 2004 (the Act) implemented the Government’s reform of the planning system. As a result, the Council must produce a Local Development Framework (LDF) which will contain documents providing the framework for delivering the spatial planning strategy for the area. The AMR will be one of the portfolio of documents.
3.2 The first AMR must assess the implementation of ‘saved’ policies in the Berkshire Structure Plan, Bracknell Forest Borough Local Plan and the Minerals and Waste Local Plans. As a Joint Minerals and Waste LDF is being produced with the other unitary authorities of Berkshire, it has been decided to produce a joint minerals and waste monitoring document which should be read in conjunction with the Bracknell Forest document in order to give a comprehensive view of spatial planning within the Borough. The reports must include a section on the local development schemes and progress in meeting the milestones contained within the schemes.
In order to qualify for an element of Planning Delivery Grant, the document must be submitted by 31 December 2005. There is also to be a check on progress on plan making against the milestones set out in the local development schemes.
4 ALTERNATIVE OPTIONS CONSIDERED
The production of an AMR is a statutory requirement. The failure to submit an AMR by 31 December 2005 might jeopardise an element of the pay that could be awarded through the Planning Delivery Grant. The Government believes that the AMR should be the means of assessing how an Authority is working to deliver outcomes.
5 SUPPORTING INFORMATION
Content of the AMR
5.1 The Government published a Good Practice Guide on monitoring the Local Development Framework in March 2005. The latter gives information on what should be included in an AMR. It should:
• review actual progress in terms of local development document preparation against the timetable and milestones in the Local Development Scheme (LDS); • assess the extent to which policies in local development documents are being implemented; • where policies are not being implemented, explain why and set out what steps are to be taken to ensure that the policy is implemented; or, whether the policy is to be amended or replaced; • identify the significant effects of implementing policies in local development documents and whether they are as intended; and, • set out whether policies are to be amended or replaced.
The first AMR
5.2 The Government recognises that only limited progress will have been made in preparing development plan documents at this stage. The Good Practice Guide therefore suggests that the first AMR should look at the implementation of (‘saved’) policies i.e. policies and proposals of adopted plans saved under the transitional arrangements of the new planning system. This task is undertaken by drawing upon core output indicators that have been set by the Government. Some contextual indicators have also been included which measure change in the wider, social, economic and environmental environment.
5.3 The Good Practice Guide also asks authorities to highlight any problems encountered in meeting the requirements of the Act. Whilst the topics of housing, employment, transport and the environment are dealt with in the Bracknell Forest document (see Appendix 1), the topics of minerals and waste are dealt with in a Joint Minerals and Waste AMR (see Appendix 2). Together, the documents also cover progress on implementing the Bracknell Forest LDS (Appendix 3) and the Joint Minerals and Waste LDS.
Future AMR’s
5.4 An integrated monitoring framework is being developed as work on the development plan documents progresses. As the spatial vision and objectives become more clearly defined and the drafting of policies is undertaken, contextual indicators, significant effects indicators, output indicators (both national and local) and related targets can be developed in conjunction with key stakeholders. Ultimately, it is also hoped that a joint approach to monitoring will be developed encompassing other strategies/plans aimed at contributing to the delivery of sustainable development. An example is the Community Plan which is likely to use a similar evidence base in respect of certain issues.
5.5 Whilst the first AMR focuses on the Government’s core output indicators, future reports will increasingly draw upon the new monitoring framework.
Future Risks
5.6 Chapter 2 of the AMR relates to progress being made against milestones in the Bracknell Forest Borough LDS. This part of the AMR is specifically noted for members as it highlights the serious concern officers have relating to the delivery of future milestones.
5.7 Whilst we have delivered all milestones to date, significant concerns over the progress of the South East Plan and more recently the potential implications arising from consideration of the Thames Basin Heaths Special Protection Area (SPA), mean future milestones may be in jeopardy. Whilst the Council is involved heavily in discussions and debates around both topics, their impacts are beyond our direct control.
5.8 We have suggested some minor changes in milestones due to delays in Government Guidance coming through (e.g. review of the Limiting the Impact of Development SPD). At this point we are not recommending significant changes relative to our Core Strategy and Site Allocations Development Plan Documents (DPD’s), but are highlighting the possibility that without significant progress on these two issues, more delays are likely to result.
5.9 A revised LDS (December 2005) is attached as Appendix 3 for the Executive to approve for submission to the Government Office for the South East.
6 ADVICE RECEIVED FROM STATUTORY AND OTHER OFFICERS
Borough Solicitor
6.1 The requirement for an AMR is set out in Section 35 of the Planning and Compulsory Purchase Act 2004. This is further developed in Regulation 48 of the Town and Country Planning (Local Development) (England) Regulations 2004.
Borough Treasurer
6.2 The AMR forms part of the LDF process.
6.3 The preparation of the constituent documents of the LDF is now a continuous process. There is revenue budget provision in 2005/2006.
6.4 The 2006/2007 budget setting process has identified a commitment budget projection which represents the work in preparing the LDF as part of a continuous rolling programme. The budget proposals will be out for public consultation from the 20 December for a period of six weeks.
6.5 When a Local Development Document is taken to inquiry significant costs can arise, specifically Planning Inspectorate costs and Counsel fees. Because of the uncertainty of whether an inquiry will take place and if it does, the timing, it is proposed that an earmarked reserve of £200k will be set aside in the 2006/2007 budget.
Impact Assessment
6.6 Whilst the report does highlight issues that may warrant further investigation, it is essentially a factual document. Some of these issues concern the collection of data which may have an impact on individuals and systems. Others involve policy approaches. However, any change in policy stance would need to be dealt with through the SCI/LDS/DPD process, which would consider social impacts.
6.7 The necessary Equalities Impact Assessment for this report is attached as Appendix 4.
7 CONSULTATION
Principal Groups Consulted
7.1 The production of the document has involved the collection and analysis of various sets of data. The majority of the information collated has come from sections within Environment and Leisure.
Method of Consultation
7.2 There is no requirement for formal consultation.
Background Papers The Town and Country Planning (Local Development) (England) Regulations 2004 Local Development Framework Monitoring: A Good Practice Guide (March 2005)
Contact for further information Sue Scott, Environment and Leisure Department – 01344 352575 [email protected]
Bev Hindle, Environment & Leisure Department – 01344 351902 [email protected]
Doc. Ref 09 Annual Monitoring Report
APPENDIX 1
Bracknell Forest Annual Monitoring Report
2004-2005
Bracknell Forest Annual Monitoring Report 2004-2005
Executive Summary
Background
This is the first AMR for Bracknell Forest which reports on the period 1 April 2004- 31 March 2005. It looks at whether or not certain ‘saved’ policies in the Berkshire Structure Plan 2001-2016 (adopted July 2005) and the Bracknell Forest Borough Plan 1991-2006 (adopted January 2002) are being implemented successfully. The ‘saved’ policies in the E Replacement Minerals Local Plan for Berkshire (Incorporating Alterations) and the Waste Local Plan for Berkshire are looked at in a Joint Minerals and Waste AMR collated by the X Joint Strategic Planning Unit on behalf of the Unitary Authorities of Berkshire. E
The AMR looks at the implementation of key policies by focusing on the national core C output indicators identified in ODPM’s Local Development Framework Monitoring Good U Practice Guide published in March 2005 and subsequently updated in October 2005. T As a minimum, the report establishes a baseline. Whilst it is far too early in the monitoring I process to draw any firm conclusions about trends, a brief review of the main findings of this year’s AMR is provided below, including a paragraph on the Local Development V Scheme. E
Findings S U Local Development Scheme M
In respect of the Development Plan, a minor alteration to the adopted Bracknell Forest M Borough Local Plan was adopted on 30th November 2005. Good progress is being made A towards the preparation of a Local Development Framework, with all milestones for the monitoring year met. For the future, the AMR proposes small amendments to the R timetables for the preparation of two Supplementary Planning Documents to accommodate Y a delay in the issue of Government guidance, and the loss of a skilled staffing resource. Risks associated with the Thames Basin Heaths Special Protection Area, the South East Plan and internal resources are also flagged up, in particular that they may impact upon future timetables for the preparation of the Core Strategy and Site Allocations Development Plan Documents. In fact, a change is already proposed to the Development Management DPD timetable to accommodate these risks.
Housing
The Berkshire Structure Plan requires 1,950 net dwellings (or 390 net dwellings per annum) to be completed between 2001 and 2006. By March 2005, 1,342 net dwellings had been built leaving a requirement for a further 608 to be completed during 2005/06. The under-delivery of housing in Bracknell Forest has been primarily due to delays in the implementation of two large sites allocated in the Bracknell Forest Borough Local Plan. The Council has been working closely with GOSE to produce a joint action plan for the delivery of housing and some progress is now being made on the implementation of
Bracknell Forest Annual Monitoring Report 2004-2005
permissions relating to the two sites referred to. Projections of completions show a significant rise from around 2006-07 onwards.
The proportion of new and converted dwellings provided on previously developed land has been increasing over the last few years. 97% of new and converted dwellings were provided on previously developed land during 2004-05.
Densities are increasing. 61% of dwellings on wholly completed sites were provided at a density of more than 30 dwellings per hectare during 2004-05. E X The planning system has contributed 62 net affordable dwellings to the stock of affordable housing during 2004-05. E C In support of the Government’s emphasis on smaller units, almost 60% of new dwellings U that were completed during 2004-05 were 1 and 2 bed units and just over 50% were flats. T Almost all dwellings on wholly completed sites were located on sites within settlement I boundaries. V E Employment
21,248m² gross of business, industrial and storage and distribution floorspace was S completed during 2004-05. This represents a low level of activity compared with previous U years. The majority of completed floorspace was for business purposes and related to two large sites. 1,381m² or 6% of the total completed floorspace was on the defined M employment areas. M
All employment floorspace that was completed during 2004-05 was on sites involving A previously developed land. R
36.25 ha of land had planning permission for business, industrial and distribution purposes Y at March 2005 (excludes sites accepted in principle or BFBLP outstanding allocations). Almost all of the supply of employment land relates to sites in and around Bracknell and is committed for business purposes. It should also be noted that schemes on some of the land forming part of the land supply are either likely to be superseded by the Town Centre proposals, if permitted, or are being re-negotiated for alternative uses.
There were no losses of employment land to completed non-employment schemes, including those involving residential uses during 2004-05. However, a number of schemes are being negotiated or have recently been permitted for residential use.
Whilst the majority of completed employment development has taken place outside settlement boundaries, most of it has been on ‘major’ employment sites as defined in the Bracknell Forest Borough Local Plan (TRL and Syngenta).
897m² gross of retail and leisure floorspace was completed during 2004-05 and of this 39.1% was in Bracknell Town Centre.
Bracknell Forest Annual Monitoring Report 2004-2005
Transport
Almost all wholly completed residential sites were within 30 minutes public transport time of a GP, a primary school, a secondary school, areas of employment and retail centres. 82% were within 30 minutes public transport time of a hospital.
Environment E Nearly half the Borough’s open space is managed to Green Flag Award standard. X
The Borough has 1SPA, 1 SAC (both were still proposed at March 2005), 9 SSSI’s and 79 E WHS’s, totalling over 5,600ha. 99% of SSSI’s are in favourable or unfavourable but C recovering condition. U Actions For The Future T
Comprehensive data is not available for all ODPM’s core output indicators and further I work is required on addressing some of these issues. Some of the data has been collated V manually at the end of the monitoring year and further work needs to be done on trying to E automate data collection as developments are permitted.
Furthermore, as existing policies are reviewed and new policies are formulated as part of the LDF process, it is likely that it will be necessary to reconsider the contextual indicators S and develop additional local output indicators. This process will involve consultation with U various stakeholders. M On the basis of the work undertaken in connection with the production of this AMR, the M following points are highlighted: A Housing R Y Progress Core Strategy and Site Allocations DPDs to ensure an adequate supply of land for housing following the principles set out in the BSP and emerging RSS.
Pursue a Housing Market Assessment to help compile a sound evidence base on which to base policies on affordable housing and dwelling size and type. Look at collecting data on these topics on a more regular automated basis.
Consider analysing the density of development by size of site and re-visit the definition given in the Good Practice Guide relating to core output indicator 2c (Density) which implies that any site upon which a completion is registered should be included in the analysis. Look at collecting data on a more regular automated basis.
Bracknell Forest Annual Monitoring Report 2004-2005
Employment
With reference to the results of the EPS, examine the needs of the local economy for employment land and buildings and ensure that appropriate provision is made through the Core Strategy and Site Allocations DPDs. As part of this process, look at the definition and extent of defined employment areas and the scope for change of use of employment sites.
Further discuss the need for gross internal employment floorspace figures with SEERA and GOSE to ensure a regionally consistent approach. E X Transport E C Set up a system for the monitoring of parking spaces provided on permitted non-residential development within Use Class Orders A, B and D. U T Progress parking standards DPD. I Look at incorporating the expanded definitions relating to core output indicator 3b V (Accessibility) that were published by ODPM in October 2005, particularly those relating to major retail centres and areas of employment. Take greater account of facilities beyond E the Borough boundary. Further discuss whether the accessibility analysis should be expanded to relate to any residential site where a completion was registered in the monitoring year as opposed to wholly completed sites. S U Environment M
Liaise with GOSE/SEERA over problems of monitoring the management of open space. M A Liaise with TVERC to ensure progress is made on gathering data in respect of core output indicator 8 (Biodiversity) and discuss data needs in respect of local indicators. R Y Look at setting up a formal means of monitoring facilities capable of generating energy from renewable sources.
Bracknell Forest Annual Monitoring Report 2004-2005
Contents
Page
C Executive Summary 2 O N Contents 6 T Abbreviations 7 E N Chapter 1 Introduction 8 T Chapter 2 Review of the Development Plan System 15 S
Chapter 3 The Borough and Its People 27
Chapter 4 Housing 33
Chapter 5 Employment 51
Chapter 6 Transport 78
Chapter 7 Environment 85
Appendices 103
Data Sources and References
Bracknell Forest Annual Monitoring Report 2004-2005
Abbreviations
AAP Area Action Plan AMR Annual Monitoring Report ASHE Annual Survey of Hours and Earnings BAP Biodiveristy Action Plan BIDS Business Industrial Distribution Storage A BFBLDS Bracknell Forest Borough Local Development Scheme B BFBC Bracknell Forest Borough Council BFBLP Bracknell Forest Borough Local Plan B BRP Bracknell Regeneration Partnership R BSP Berkshire Structure Plan BTC Bracknell Town Centre E BVPI Best Value Performance Indicators V DPD Development Plan Document
EA Environment Agency I EPS Employment Potential Study A GOSE Government Office for the South East T HMAA Housing Market Area Assessment JMW Joint Minerals and Waste I JSPU Joint Strategic Planning Unit O LDD Local Development Document LDF Local Development Framework N LDS Local Development Scheme S LID Limiting the Impact of Development LTP Local Transport Plan ODPM Office of the Deputy Prime Minister PDG Planning Delivery Grant PDL Previously Developed Land PINS Planning Inspectorate PPG Planning Policy Guidance PPS Planning Policy Statement RMLP Replacement Minerals Local Plan RPG Regional Planning Guidance RSS Regional Spatial Strategy RSL Registered Social Landlord SA Sustainability Appraisal SAC Special Area of Conservation SCI Statement of Community Involvement SEA Strategic Environmental Assessment SEERA South East England Regional Assembly SEP South East Plan SPA Special Protection Area SPD Supplementary Planning Documents SPG Supplementary Planning Guidance SSSI Sites of Special Scientific Interest TRL Transport Research Laboratory TVERC Thames Valley Environmental Records Centre UA Unitary Authority UKBAP UK Biodiveristy Action Plan UPS Urban Potential Study WHS Wildlife Heritage Site WLP Waste Local Plan
Bracknell Forest Annual Monitoring Report
2004-2005
C H A P T E CHAPTER 1 R
1
Introduction
Bracknell Forest Annual Monitoring Report 2004-2005
Introduction
Why do we need to produce an Annual Monitoring Report?
1.1 The Planning and Compulsory Purchase Act 2004 changed many aspects of the planning system, including the replacement of local plans with a system of LDFs which are to contribute towards the achievement of sustainable development. Monitoring is seen as a means of measuring progress in the achievement of this aim. Section 35 of the Act requires every local planning authority to produce an AMR. This is further developed in Regulation 48 of the Town and Country Planning (Local Development) (England) Regulations 2004. The Report is to cover the period 1st April to 31st March each year and is to be submitted to the Secretary of State by the end of the following December. C 1.2 Further advice is set out in PPS 12: LDF (paras. 4.45-4.52) and LDF Monitoring: A H Good Practice Guide. The latter states (at para. 3.2) that the AMR should: • Review actual progress in terms of local development document preparation A against the timetable and milestones in the local development scheme; P • Assess the extent to which policies in local development documents are being implemented; T • Where policies are not being implemented, explain why and set out what steps are E to be taken to ensure that the policy is implemented; or, whether the policy is to be amended or replaced; R • Identify the significant effects of implementing policies in local development documents and whether they are as intended; and, 1 • Set out whether policies are to be amended or replaced.
What are we monitoring?
1.3 As the 1st AMR is required to cover the period 1st April 2004 to 31st March 2005, since the commencement of the Act, it is recognised that only limited progress will have been made on preparing local development frameworks. Consequently, the Good Practice Guide suggests that the analysis of data associated with the indicators should look at the implementation of existing (‘saved’) policies i.e. policies and proposals of adopted plans saved under the transitional arrangements of the new planning system (see para 6.2 of the Bracknell Forest Borough LDS (March 2005).
1.4 The Development Plan for Bracknell Forest comprises: • RPG for the South East (RPG9), March 2001 • BSP, July 2005 • BFBLP, January 2002 • The RMLP for Berkshire, Incorporating Alterations adopted in December 1997 and May 2001, and, • The WLP for Berkshire, December 1998.
1.5 RPG9 was approved by Government in March 2001. The regional planning body, namely the SEERA is responsible for monitoring the policies in this plan and the emerging RSS. The Government also requires regional planning bodies to publish
Bracknell Forest Annual Monitoring Report 2004-2005
AMRs. It is hoped that data collected for the Bracknell Forest report will feed into the regional reports resulting in a streamlined approach to interpretation and analysis.
1.6 Although the BSP 1991-2006 was the adopted structure plan for this area during the period covered by this report, the replacement plan covering the period 2001-2016 carried considerable weight by this stage, having been subjected to an Examination in Public in 2003 and subsequently amended. As a UA, Bracknell Forest is charged with the responsibility of monitoring the implementation of policies in this plan in this area. For the purposes of this report, the policies in the new BSP 2001-2016 (adopted July 2005) have been examined.
1.7 Whilst work is currently being carried out on the first stages of producing a LDF for Bracknell Forest, the BFBLP is currently the adopted local plan and its policies remain saved for at least 3 years, until the new Local DPDs are adopted. This report therefore endeavours to monitor the implementation of policies in the BFBLP. C
1.8 Similarly, the policies in the RMLP, and, the WLP for Berkshire have been saved. H The implementation of these policies is covered in a joint report for Berkshire, co- A ordinated by the JSPU. P Links with other strategies T
1.9 The Government is keen to encourage an integrated approach to monitoring, there E being a number of other policy documents which interact with local development R documents. An example is community strategies which share the same task of delivering sustainable development and potentially require the setting of communal targets and collection of similar data. 1
1.10 Bracknell Forest has a community plan called ‘Shaping Tomorrow Together’ which sets out 5 ambitions including developing sustainable communities. This plan is currently under review and an updated plan is being developed. It is hoped to use common indicators and targets where applicable.
1.11 There is also a degree of overlap with the LTP and the BVPIs. The possibilities of setting up a corporate monitoring system are to be investigated.
The use of indicators
1.12 The Good Practice Guide advocates the use of an objectives-policies-targets- indicators led approach. It is suggested that different types of indicators should be developed which would fulfil different purposes in the assessment of the effectiveness of local DPDs.
• Contextual indicators - these are only indirectly related to the policies. They are aimed at providing a better understanding of the wider environment (economic, environmental and demographic background).
• Output indicators – these measure the quantifiable physical activities that are related to the implementation of policies. The Government has published a set of core output indicators that all authorities must use, in the interests of having consistent, comparable data. As the core output indicators may not address the output of all policies, the Government also suggests that it may be appropriate
Bracknell Forest Annual Monitoring Report 2004-2005
to develop local output indicators to ensure a comprehensive assessment of policy implementation.
• Significant effects – these measure the significant effects of the policies. They are linked to the sustainability appraisal objectives and indicators.
Sustainability Appraisal and Strategic Environmental Assessment
1.13 The monitoring of local policies will be fully integrated with the monitoring requirements of SAs and SEAs, as the process progresses. The Government’s guidance on SA of RSSs and LDFs (November 2005) states that the significant sustainability effects of implementing any relevant plan or policy should be monitored to identify unforeseen adverse effects and enable remedial action to be taken. Once C a Final SA report has been produced for each LDD, a more detailed monitoring H framework will be proposed and included in future AMRs. A 1.14 To date the SA process has identified and consulted upon 24 local sustainability P objectives which aim to embody the concept of sustainability. The process of scoring each emerging policy against all of these objectives can identify the significant T effects of implementing the policy and emphasises any social, environmental and E economic implications. When determining the significant effects of a policy against each objective, the probability, duration, frequency and reversibility of the effects, R including cumulative, secondary and synergistic effects must be considered. The magnitude and spatial extent of the effects need to be balanced against the value 1 and vulnerability of the receiving environment and population. Baseline data has been collected and published in an SA/SEA Scoping Report to guide this assessment of significant sustainability impacts, and information on relevant targets and indicators have also been compiled for this purpose.
1.15 Whilst it is acknowledged that the ‘saved’ policies have not been subject to SA, the policies (through the collected data) have been scored against the sustainability objectives for this AMR to give some idea of the delivery of sustainability. The key positive and negative significant effects of each indicator has been summarised at the end of each indicator. The scoring system and full details of the appraisal are included in Appendix 1.
Limitations of the 1st AMR
1.16 Whilst the objectives-policies-targets-indicators approach will be adopted in the development of policies in the LDDs, the policies in the currently adopted plans pre- date this approach, which makes it difficult to measure progress and relate to specified national indicators or develop appropriate local indicators. In spite of this, considerable effort has been made to attribute ‘saved’ policies to core output indicators and provide some data. In some cases the format of the data is not strictly in accordance with the definitions given in the Good Practice Guide. In such instances, an explanation is given in the text. A limited number of local indicators have also been developed, but more thought will need to be given to these in future.
1.17 The production of this report has also raised a number of issues about the collection and presentation of data which will need to be addressed before embarking on the second report. In some cases this means the collation of additional data from
Bracknell Forest Annual Monitoring Report 2004-2005
existing sources and in others it means setting up new areas of research. These are highlighted in the commentary. Whilst it has been possible to include some historic data to help assess general trends, this report essentially provides a benchmark against which to assess future performance. The value of the report should therefore increase as data is built up and trends over time can be recorded and analysed.
The preparation of this report
1.18 Bracknell Forest has liaised with the other UAs in Berkshire and the JSPU to secure some consistency in approach, particularly in the interpretation of the core indicators.
1.19 A Berkshire AMR Group was set up during the summer of 2005 and has subsequently met on a number of occasions. The Group has also tried to co-ordinate requests for further advice and specialist data from other bodies, for example from the TVERC. C
1.20 Whilst much of the data has come from BFBC and the planning applications and H commitments system managed by the JSPU, some data has been obtained from A secondary sources. This is particularly the case with the contextual indicators. P Issues facing the Borough T
1.21 The Good Practice Guide requires local planning authorities to highlight any E particular issues that have arisen during the monitoring period. The following issues R have been identified. These present considerable challenges and are looked at further in the relevant chapters: 1 Delivery of housing in view of the lack of progress on the development of 2 large sites released through the BFBLP, namely land at Peacock Farm and the Staff College (see page 39).