NEWCASTLE-UNDER-LYME AND STOKE-ON-TRENT CORE SPATIAL STRATEGY EXAMINATION

DOCUMENT CCD3

Response to Planning Inspector’s Question (ICD3)

Question 1

1.1 Have there been any changes made to the content of the CS document since it was published, for example updating of references to more recent policy documents or correction of typos? Do the Councils wish to make any such changes? If so they should start to prepare a schedule.

1.2 No changes have been made to the content of the Core Spatial Strategy since it was published. The Councils believe the updating, formatting, factual and grammatical corrections in the schedule of amendments (see CCD3 Appendix 3) could help improve the document, subject to approval from the Inspector. The Councils would welcome the opportunity to add to the schedule, subject to approval from the Inspector, should the need arise.

Question 2

2.1 Explain the reasons underlying the Addendum to the CS, the evidence on which it is based, whether it has been the subject of public consultation (and if so what was the response) and whether it raises any issues regarding sustainability appraisal or Appropriate Assessment.

2.2 In accordance with the Conservation (Natural Habitats, &c) (Amendment) Regulations 2007 (SI 2007/184) a ‘screening’ assessment was carried out to determine whether it was likely that the policies and proposals in the Newcastle-under-Lyme and Stoke-on- Trent Core Spatial Strategy would have any significant effect upon any European site.

2.3 The Screening Report for Newcastle-under-Lyme and Stoke-on-Trent Core Spatial Strategy set out the methodology and the outcomes of the screening process. The report concluded that the Core Spatial Strategy would not have any significant impact upon any European site and therefore it would not be necessary to carry out a full Appropriate Assessment.

2.4 In accordance with the Habitats Regulations 2006 85B (2), consultation with Natural on the process and outcomes of the Screening

1 Report took place in May 2008. Natural England’s comments are included in CCD3 Appendix 2 of this paper.

2.5 Following this, the final Screening Report (SUB/008) was produced taking into account the improvements suggested by Natural England and re-submitted to Natural England for further consultation in July 2008.

2.6 Natural England confirmed in August 2008 (see CCD3 Appendix 2) that they were satisfied that the Screening Report presented a robust case for not having to undertake a full Appropriate Assessment, subject to a strengthening of the Core Spatial Strategy Policy CSP4 – Natural Assets to address the possibility of significant effects upon Black Firs and Cranberry Bog Ramsar site due to waste water from any additional development within the water catchment area of the site.

2.7 The Core Spatial Strategy Submission Draft was finally cleared for publication in May 2008. Officers were also authorised to make any minor textual changes necessary to improve the accuracy and quality of the Strategy. Following this, bulk copies of the Strategy were printed for consultation purposes.

2.8 As the decision to incorporate Natural England’s additions to CSP4 into the Submission Draft was made after printing, it was necessary for them to be included as an addendum.

2.9 The addendum was subject to the full 8 week publication period. There were no specific comments/objections regarding the additional text included in the addendum.

2.10 It was considered that because the addendum only added local detail to the original policy aims of protecting and enhancing important natural assets, which had been subject to a full Sustainability Appraisal, it was not considered to have any fundamental impact on sustainability principles. Therefore it was not necessary to undertake further work, especially since the Core Spatial Strategy does not propose any major development within the area encompassing the Balterley Heath Settlement.

Question 3

3.1 The Councils’ response CCD 1 explains the relationship of County Council’s Community Strategy to the Core Strategy (CS) and the Sustainable Community Strategy for Newcastle. Wording should be prepared to add a sentence to Para 2.15 to show that regard has been had to the County Council’s Community Strategy.

3.2 The following sentence should be added to paragraph 2.15. This addition has been included in the schedule of amendments (see CCD3 Appendix 3):-

2 ‘The preparation of the Core Spatial Strategy has also had regard to the vision and aims of the Staffordshire Community Strategy 2005-2010 undertaken by the Stoke-on-Trent and Staffordshire Strategic Partnership. The revision of this Strategy, published in September 2008, is also closely aligned with the Borough’s Sustainable Community Strategy, adopted February 2008.’

Question 4

4.1 In Para 6.34 of the CS, an Appropriate Assessment is mentioned. Does this mean the Screening Report SUB/008?

4.2 Yes, the Appropriate Assessment mentioned in Para 6.34 is the Screening Report (SUB/008). A minor textual amendment to this paragraph would improve the clarity and accuracy of the Core Spatial Strategy.

4.3 It is suggested that the second sentence of paragraph 6.34 should read:-

“A screening exercise was carried out to identify any potential significant effects and therefore the need to carry out a full Appropriate Assessment of the Core Spatial Strategy. As a result of this exercise, it was determined, in consultation with Natural England, that a full Appropriate Assessment of the Core Spatial Strategy was not necessary. The process and outcomes of this exercise are set out in the ‘Screening Report for Newcastle-under-Lyme and Stoke-on-Trent Core Spatial Strategy (July 2008).”

4.4 This proposed amendment will be included in the schedule of amendments referred to in CCD3 Appendix 3.

Question 5

5.1 The Appendices are missing from both Strategic Flood Risk Assessments (please provide). Has the Environment Agency confirmed it is satisfied with both SFRAs?

5.2 The appendices for both Strategic Flood Risk Assessments have been added to the end of Core Documents EB/021 and EB/060a. The SFRA maps have also been added to the Core Documents (see CCD3 Appendix 1 for details).

5.3 The ‘sign-off’ letter from the Environment Agency (EB/086), confirming their satisfaction with the SFRA, has been added to the Core Documents (see CCD3 Appendix 1 for details).

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Question 6

6.1 Do the Councils intend to produce a brief schedule responding to the main points raised in the representations? If so when?

6.2 Yes. The Councils will produce a schedule responding to the main points identified by ICD3a. This will be completed by the 26th February 2009.

Question 7

7.1 A brief response to the Highways Agency representations is requested at this stage. This should include a bullet point explanation of the situation as regards park and ride, including whether any services are already in operation, where they are situated, when they operate and by whom. Future proposals should be listed in terms of location, date and who would operate them.

7.2 The Core Spatial Strategy along with associated evidence has been produced in accordance with appropriate guidance and is considered to be at an appropriate level for a strategic document.

Highway Agency Representation 76/273

7.3 Arrangement for monitoring delivery of the transportation elements of the document are set out section 8 of the Core Spatial Strategy. Additional monitoring of the North Staffordshire transportation system will be carried as part of the Local Transport Plan (EB/052) monitoring regime.

7.4 Details regarding delivery of core strategic infrastructure planning are provided (EB/061).

7.5 Adopted Regional Spatial Strategy identifies the North Staffordshire Conurbation as the focus for strategic urban renaissance. The Regional Spatial Strategy review continues the emphasis on Major Urban Area Renaissance and strategic development targets are being brought forward to that effect. At the strategic planning level there are no known ‘show stoppers’ to delivery of the Core Spatial Strategy or revised Regional Spatial Strategy. Indeed the preferred strategy based on rejuvenation of the inner urban core of the conurbation and maximising use of sustainable transportation systems will assist reduction in the demand for travel when compared with more dispersed patterns of development. Preliminary investigations have been carried out regarding the transportation impacts of the proposed development (EB/028). Further detailed, iterative modelling is required to determine detailed site allocations having regard to capacity constraints together with associated determination of mitigation measures and apportionment of costs. Delivery does not rely on the Highways

4 Agency making additional investment to the transport network although we would not rule out co-operative initiatives if they were found to be of mutual benefit.

Highway Agency Representation 76/274

7.6 Maintaining the strategic function of the trunk road network and securing the sustained regeneration of the North Staffordshire Major Urban area are both national objectives. Delivery of those objectives are interrelated and securing development of the conurbation is likely to give rise to additional traffic generation which will undoubtedly have an impact of the network. PPS12, paragraph 5.4 indicates that Area Action Plans should attempt to resolve conflicting objectives. It is at this stage that appropriate remedial measures should be considered to deliver appropriate levels of service on the trunk road. Paragraph 5.56 attempts to apply the same principle to the preparation of the Core Spatial Strategy. The Councils contend that paragraph 5.56 is sound although remain open to consideration of alternative text which the Highways Agency may find less offensive.

Highway Agency Representation 76/275

7.7 The approved Local Transport Plan (EB/052) supports the Core Spatial Strategy.

7.8 In response to the representation submitted by GVA Grimley Ltd., on behalf of the Highways Agency, we refute the contentions and dismissive comments relating to the transport modelling and appraisal work. We consider that appropriate assumptions have been used and that the appropriate level of assessment has taken place to support the Core Spatial Strategy, and that the document is sound.

7.9 It should be noted that the transport modelling work carried out to assess the traffic impact of the Core Spatial Strategy was carried out in full consultation with the Highways Agency. The Highways Agency have been partners and fully involved in previous development and applications of the transport model. Furthermore, due to the general strategic nature of the proposals contained within the Core Spatial Strategy which were modelled as part of the traffic impact assessment work then obviously it is not appropriate to formulate detailed conclusions based on this work. The work, however, does provide a robust overall picture of the impact of the Core Spatial Strategy on the operation of the highway network. The formation of detailed site allocations plans will obviously require detailed transport assessments to be carried out. This will be at the Area Action Plan stage.

7.10 No strategic Park and Ride sites are currently in operation in North Staffordshire.

5 7.11 The Highways Agency contributed financially and provided appropriate input to the North Staffordshire Integrated Transport Study NSITS (EB/032). The study informed the North Staffordshire Local Transport Plan, which in turn provides an evidence base for the Core Spatial Strategy, identified a number of potential sites for Park and Ride. The proposed locations of these sites, which were assessed as part of the aforementioned traffic impact assessment, are in the following areas:

- Chatterley Valley; - Etruria Valley; - ; and - Bucknall.

7.12 Further detailed studies are required to identify the exact location and operation of these sites and also support appropriate bids for funding. Details regarding implementation of strategic park and ride facilities are provided at EB/061, page 9.

7.13 Appropriate modelling assumptions were therefore made to facilitate the assessment of the impact of these sites on the highway network. As recognised in the Park and Ride Modelling Assumptions paper the transfer rate of trips to the Park and Ride sites will be dependent on the exact location, operational characteristics and complimentary traffic management and car parking measures implemented as part of these schemes. The 25% transfer rate of trips to the Park and Ride sites is based on data from areas where schemes already operate and is not considered optimistic when considered in the context of the objectives of the North Staffordshire Local Transport Plan.

Highway Agency Representation 76/276

7.14 The Core Spatial Strategy is based upon the Regional Spatial Strategy Phase 2 Revision Preferred Option strategic development targets. The RSS Phase 2 Review Examination in Public will be investigating the Preferred Option together with additional growth allocation in April 2009. These strategic growth options have been tested by the Highways Agency using the North Staffordshire transportation model and no insurmountable objection has been identified. In the event that higher growth targets emerge from the regional plan making programme, and these could increase housing targets by as much as 33%, then this would require a review of the Core Spatial Strategy. This approach is advocated by Government Office for the West .

Question 8

8.1 Without a self-assessment of soundness, how do the Councils intend to demonstrate that the CS is sound? Have the Councils completed a Self-Assessment of Soundness and if not, what is the timetable for its preparation?

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8.2 Yes. A self-assessment of soundness will be added to the Core Documents and issued to the Inspector by the 26th February 2009.

Question 9

9.1 Are any other substantial reports in preparation, and if so, what is the timetable for their publication?

9.2 Stoke-on-Trent City Council has not published a formal Strategic Housing Land Availability Assessment (SHLAA) or Strategic Employment Land Assessment (SELA). Work on both documents has commenced. The data required to complete both documents has been assembled, analysed and published in the form of our ‘Strategic Housing and Employment Land Availability Assessment’ (EB/058). Some work remains to be done before this can be published as a formal SHLAA or SELA. The table below provides the timetable for publication.

9.3 An Employment Land Review for Newcastle-under-Lyme and Stoke- on-Trent will be produced to test future demand and supply and to inform subsequent Development Plan Documents.

9.4 Newcastle Borough Council has published a first draft of the Strategic Housing Land Availability Assessment; however, a comprehensive review is ongoing involving the consideration of new nominated sites.

Report Publication

Strategic Housing Land Availability May/June 2009 Assessment – Stoke-on-Trent Strategic Housing Land Availability June/July 2009 Assessment – Newcastle-under-Lyme Employment Land Review – December 2009 Newcastle-under-Lyme and Stoke-on- Trent

Question 10

10.1 Why are natural assets under policy CSP4 included in the Newcastle section of the proposals map and not the Stoke section?

10.2 National planning policy regarding natural heritage interests is provided in PPS9: Biodiversity and Geological Conservation (NAT/005). Development plan policies should be based upon up to date

7 information including the relevant biodiversity and geological resources of the area (paragraph 1 (i)). The local development framework should indicate the location of designated sites of importance for biodiversity, making clear distinctions between the hierarchy of international, national, regional and locally designated sites (paragraph 5 (i)). These matters do not have to be specified in the Proposals Map accompanying the Core Spatial Strategy. In this particular area the specific policy areas would be added as daughter Development Plan Documents are produced and the composite Proposals Map developed.

10.3 The Borough Council and City Council have been responsible for preparation of the Proposals Maps for their own administrative area. The local wildlife sites in the Borough, known as Sites of Biological Importance are marked as CSP4 on the Newcastle Proposals Map (SUB/003a & SUB/003b). The difference between the two Proposals Maps reflects the different level of up to date information in the two authorities.

10.4 Within Stoke-on-Trent the higher order sites are known but in accordance with the government 2006 publication ‘Local Sites – Guidance on their identification, selection and management’ (See CCD3 Appendix 1) sites of local interest in the City of Stoke-on-Trent are currently being comprehensively reviewed with a view to an up to date list being produced in 2009. It is known that some of the current sites of notified interest will be de-classified based on their bio-diversity characteristics and additional local sites will be designated. It was considered in the case of the City of Stoke-on-Trent that identification of classified CSP4 sites on the Proposals Map (SUB/004a & SUB/004b) at this stage would be premature. Once the technical criteria for selection in Stoke-on-Trent is agreed and the list of up to date sites was produced, it would be for daughter development plan documents to specify the planning policy areas and detailed planning policies associated with them, all in accordance with due process. It is accepted that this may not be necessary in connection with international and national designated sites which would not be affected with this local review. The Borough Council criteria are already in place and the list of up to date CSP4 sites available however, the submitted Newcastle Proposals Map does not include international or national sites designations.

10.5 The current number of sites of natural heritage interests is indicated below.

Type Newcastle-under- Stoke-on-Trent Lyme

International – 2 0 RAMSARs,

8 SACs (Special Areas of Conservation sites) SPCs (Special Protection Areas sites) SSSIs (Sites of Special 5 (total includes 2 2 Scientific Interest) Ramsar sites detailed above) LNRs (Local Nature 3 9 (8 of which are also Reserves) designated Local Wildlife Sites) RIGs (Regionally 13 3 Important Geological or Geomorphological sites) Local Wildlife Sites 0 2 (Stoke) and Ancient Woodlands Local Wildlife Sites 56 34 (of which 10 are (Stoke) / Sites of located on Local Nature Biological Importance Reserves) and Ancient Woodland (Newcastle)

Question 11

11.1 The proposals map shows town centre boundaries related to saved Local Plan policies SP7 and SP8. How does this relate to the CS hierarchy of centres?

11.2 The seven ‘saved’ town centre boundaries indicated on the Stoke-on- Trent Proposals Map equate to the City Centre of Stoke-on-Trent and the six significant urban centres, all within Stoke-on-Trent and referred to at paragraph 5.7 of the submitted Core Spatial Strategy. The detailed centre boundaries will be reviewed during preparation of area action plans and the development portfolio document referred to in the local development scheme.

Question 12

12.1 A table is required to show in which subsequent DPD the boundaries of any designations shown on the Key Diagram will be defined.

Newcastle-under-Lyme

Boundary Development Plan Document

North Staffordshire Green Belt Newcastle-under-Lyme Site Allocations and Policies

9 Rural Areas Newcastle-under-Lyme Site Allocations and Policies

Town Centre Boundary Newcastle-under-Lyme Site Allocations and Policies

Village Envelopes (revised if Newcastle-under-Lyme Site necessary) Allocations and Policies

Regional Investment Site Newcastle-under-Lyme Site Allocations and Policies

Area of Major Intervention (Knutton Newcastle-under-Lyme Site and Cross Heath) Allocations and Policies

General Renewal Area (Chesterton) Newcastle-under-Lyme Site Allocations and Policies

Other Areas of Intervention Newcastle-under-Lyme Site Allocations and Policies

Stoke-on-Trent

Boundary Development Plan Document

Strategic Centre City Centre and Etruria Road Corridor Area Action Plan (AAP)

Significant Urban Centres Inner Urban Core AAP/Development Portfolio Development Plan Document (DPD)

Inner Urban Core Inner Urban Core AAP

Areas of Major Housing Intervention Inner Urban Core AAP/Meir AAP

General Renewal Areas Inner Urban Core AAP/Development Portfolio DPD

Other Areas of Housing Intervention Development Portfolio DPD

10 Sustainability Development Portfolio DPD Enterprise Park

Park and Ride Inner Urban Core AAP

Staffordshire University Quarter Inner Urban Core AAP

University Hospital of North Development Portfolio DPD Staffordshire

North Staffordshire Green Belt Development Portfolio DPD

Green Space Network City Centre and Etruria Road Corridor AAP/ Inner Urban Core AAP/ Development Portfolio DPD

Question 13

13.1 Following on from point 11, is the boundary of the Inner Urban Core to be set in the Core Strategy or a subsequent DPD?

13.2 The boundary of the Inner Urban Core will be set out in the Inner Urban Core Area Action Plan.

Question 14

14.1 References in the text need to be updated to refer to the next level of DPDs that are in the 2008 LDS for each authority, for example Para 6.37 refers to both Councils’ Generic Development Control Policies DPD but that does not accord with their 2008 Local Development Schemes. These editorial changes should be added to the schedule.

14.2 Noted. Changes included within CCD3 Appendix 3.

Question 15

15.1 Why are minerals in Stoke-on-Trent included in the CS rather than being dealt with jointly with the County Council? With reference to the representations from the Quarry Products Association Ltd, does the Council consider that the CS provides a relevant, comprehensive and firm foundation for minerals planning in the future for Stoke-on-Trent?

11 15.2 Prior to 1997 Staffordshire County Council was the mineral planning authority for the City of Stoke-on-Trent and therefore responsible for all aspects of statutory decision making. In 1997 Stoke-on-Trent City Council became a unitary authority and assumed responsibility for mineral planning. In adopting this responsibility the City Council had to develop information systems and competency in the specialised field of mineral planning. Arrangements were already in place for the production of the Staffordshire and Stoke-on-Trent Minerals Local Plan 2006. The City Council resolved to continue with joint plan making arrangements and the mineral plan was adopted in December 1999 (EB/076).

15.3 Introduction of the Local Development Framework required a review of the adopted minerals plan. The City Council resolved to include minerals in Stoke-on-Trent in the Core Spatial Strategy rather than continue with joint plan making arrangements with the County Council for the following reasons.

15.4 Although the City was historically built on the back of exploitation of coal, clay, ironstone and aggregates, at the time when the last mineral local plan was prepared mineral operations had greatly reduced in scale and number and there is no current primary extraction of minerals within the city or expressions of interest for future mineral extraction. As explained in the ‘Minerals in Stoke-on-Trent’ supporting documentation (EB/002), there remain two main mineral resources in the City: coal and clay. There are permitted clay workings in the City as shown on plan 9. Mineral resources in the rest of Staffordshire include for coal, clay, gypsum and anhydrite, salt, clay and shale, shale and limestone, sand and gravel, limestone (crushed rock); secondary aggregates (now being dealt with in waste planning), silica sandstone, building and dimension stone, peat, ironstone, metaliferrous deposits and whetstone. None of the specific mineral development proposals fell within the City of Stoke-on-Trent. Thus much of the mineral policy planning in Staffordshire has no direct relevance to Stoke-on-Trent.

15.5 The costs of statutory plan production were shared between the City and County Council based on pro rata population levels. These costs broadly related to the scope of mineral activities and the number of proposed allocations, all thirteen of which were located in the rest of Staffordshire. Thus the costs of plan production were disproportionally falling on the city of Stoke-on-Trent or put another way mineral planning in Staffordshire was being subsidised by the City of Stoke-on- Trent. Inclusion of mineral policy in the Core Spatial Strategy is a much more efficient method of plan preparation from the City Council’s point of view.

15.6 The City Council now has professional expertise in mineral planning and is self reliant in this field. Close working relationships are maintained with the County Council to share information and best practice.

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15.7 The proposed method of mineral policy production has not been challenged through the Local Development Scheme. It is accepted following representation from Government Office that for the avoidance of doubt Policy CSP8 should be re-titled ‘Minerals in Stoke-on-Trent’ rather than just ‘Minerals’.

15.8 At present neither the City Council nor anyone else proposes additional mineral development sites and the Local Development Scheme does not provide for production of a detailed Minerals Plan Development Plan Document including site allocations.

15.9 QPA contends that the Core Spatial Strategy lacks policy guidance in respect of coal and clay working.

15.10 National planning policy in respect of coal is provided in Mineral Planning Statement 1: Minerals and Planning and Mineral Planning Guidance 3: Coal Mining and Colliery Spoil Disposal (See CCD3 Appendix 1 for details) together with adopted Regional Spatial Strategy. The adopted Staffordshire and Stoke-on-Trent Mineral Local Plan included no specific allocation for coal working.

15.11 The extent of the shallow coalfield is indicated on Plan 9 of the Core Spatial Strategy. Accessibility to mineral resources is constrained by existing built development.

15.12 The City Council is content to rely on relevant national and regional planning policy. Production of local strategic planning policy in this regard is regarded as unnecessary and its absence does not impair proper consideration of unspecified coal working proposals which may be forthcoming in the future. The Core Spatial Strategy is considered to be sound.

15.13 National planning policy in respect of clay is provided in Mineral Planning Statement 1: Minerals together with adopted Regional Spatial Strategy. The adopted Staffordshire and Stoke-on-Trent Mineral Local Plan included no specific allocation for clay working in Stoke-on-Trent.

15.14 The extent of the Etruria Marl formation is indicated on Plan 9 of the Core Spatial Strategy. Accessibility to mineral resources is constrained by existing built development. Resource areas are identified on Plan 9 including indicative indications of where permitted clay workings are located.

15.15 The City Council is content to rely on relevant national and regional planning policy. Production of local strategic planning policy in this regard is regarded as unnecessary and its absence does not impair proper consideration of unspecified clay working proposals which may

13 be forthcoming in the future. The Core Spatial Strategy is considered to be sound.

15.16 Production of the Core Spatial Strategy provides the opportunity to review Mineral Safeguarding areas identified in the adopted Staffordshire and Stoke-on-Trent Minerals Plan. These were originally identified in the adopted Minerals Local Plan based on a comprehensive assessment of geological resources. With one exception the adopted Mineral Safeguarding areas have been replicated in the Core Spatial Strategy and are shown on Plan 9 and the Stoke-on-Trent Proposals Map. The one exception arose following provision of additional information from the land owner that viable resources had been exhausted by prior working. This was not disputed.

15.17 QPA also challenge some of the terminology used in Policy CSP8.

15.18 A Guide to Mineral Safeguarding in England was published by the British Geological Survey (BGS) in 2007 (See CCD3 Appendix 1 for details). This represents best practice on this topic. This repeats the national policy in Mineral Policy Statement 1 that mineral safeguarding areas should be identified so that resources should not be needlessly sterilised by non mineral development. Identification provides no presumption in favour of working the mineral.

15.19 The BGS guide at Annexe 3 defines a mineral resource as a concentration or occurrence of material of intrinsic economic interest in or on the Earth’s crust in such form, quality and quantity that there are reasonable prospects for eventual economic extraction. Resources are defined using published material and draws on desk analysis.

15.20 The BGS guide furthermore goes on to define a mineral reserve as that part of a mineral resource which can be economically extracted. Appropriate assessments demonstrate that the quality and quantity of the mineral can be estimated to a level of confidence which could reasonably justify planning permission being granted. Thus on site investigation is generally required to prove the quantity, quality and viability of mineral extraction. Furthermore, use of the term reserves should be limited to those minerals where a valid planning permission for extraction exists.

15.21 Policy CSP8 uses the term ‘potentially valuable reserves of scarce Etruria Marls’. Whilst not incorrect it is accepted that for the avoidance of misunderstanding it would be preferable to use the terminology set out in the BGS guide referred to above.

15.22 QPA suggest alternative wording namely that “Planning permission will not be granted for non-mineral development within a Mineral safeguarding Area (MSA unless…”. Such a negative development

14 control policy is not considered appropriate for a Core Spatial Strategy and is not accepted.

15.23 The concerns raised by QPA could be addressed by modest adjustments of the policy to clarify the distribution between mineral resources and mineral reserves. A proposal will be made in CCD3.6.

15 Appendix 1

The following documents have been added to the Core Documents:-

Evidence Base Ref # Document EB/022a Newcastle-under-Lyme - Strategic Flood Risk Assessment Level 1 - Maps EB/060c Stoke-on-Trent - Strategic Flood Risk Assessment Level 1 - Maps EB/086 Environment Agency ‘Sign Off’ Letter on Flood Risk Assessments

National Documents Ref # Document NAT/038 Local Sites – Guidance on their identification, selection and management. NAT/039 Minerals Policy Statement 1: Planning and Minerals NAT/040 Mineral Planning Guidance 3: Coal Mining and Colliery Spoil Disposal NAT/041 A Guide to Mineral Safeguarding in England

16 Appendix 2 - Letter from Natural England dated 24th June 2008

Dear David

Appropriate Assessment and the North Staffordshire Core Spatial Strategy – Comments on Draft Screening Report Thank you for consulting with us on the draft screening report for the Newcastle – under-Lyme and the Stoke-on-Trent Core Spatial Strategy.

We welcome the production of a screening report. As you will be aware it is a statutory requirement that an Appropriate Assessment (AA) of the Core Strategy is undertaken. The purpose is to ensure that the protection of the integrity of European sites is part of the land use planning process at a regional and local level.

Overall we are concerned that many of the judgements in the draft assessment are not adequately explained and justified with supporting evidence and comment. By comparison to other AAs, the document is very brief and in our in opinion and it does not adequately show how the judgements regarding likely significant effects have been reached. We would recommend that this aspect is further elaborated upon.

Specific queries/ remarks that we have regarding the findings of the screening report are as follows:

Water Quantity p 19

Please clarify if you are saying that there will be no net increase in the use of water resources in the plan area up to 2026. What are the trends with average water consumption and how will policies in the CS influence directly/indirectly affect this? If there is likely to be an increase in water demand where will the extra supply come from?

Water Quality p 19

Whilst we welcome the promotion of SUDS in proposed policy CSP3 it will not adequately protect Black Firs and Cranberry Bog Ramsar site (component of Midland Meres and Mosses Phase1 Ramsar site), located in the western part of Newcastle district from possible water quality drainage impacts arising from the plan.

This site is in a unfavourable conservation condition due in part to the cumulative effects of excess nutrient levels derived from non-sewer connected built development and agricultural sources in the local area. This has been confirmed by Environment Agency water quality monitoring at the site. Increased nutrients threaten to cause the loss of the flora of special interest. Any built development in the hydrological catchment area of the site which mostly encompasses the Balterley Heath settlement may add to and exacerbate the situation.

We consider that the present Core Strategy needs to be amended to avoid possible likely significant effects on this Ramsar site:

In our view more precise and focused policy statements are required to satisfactorily address this matter. We would advise that two additional items should be considered for inclusion in the core strategy:

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1. Development that is likely to contribute additional nutrients to Black Firs and Cranberry Bog will not be permitted.

2. A partnership led by the local authority involving Crewe Borough Council, Parish Council, the Environment Agency, Water Company, and Natural England will be established to investigate best options for improving and eliminating SSSI water quality impacts from existing and future development including the extension of the mains sewerage network to connect properties in Balterley Heath.

In considering developments in the area of this SSSI the local authority will seek opportunities to extend the foul sewer network (1km away) to new and existing properties as means of remedying the pollution affecting the site.

Diffuse Air Pollution p19

With respect to diffuse air pollution we note that the assessment concludes no likely significant effect arising from the Core Strategy alone and in combination with other plans.

We are not convinced that sufficient evidential information and evaluation has been provided to adequately demonstrate that this conclusion is reasonable having regard for the precautionary principle. It has not been satisfactorily shown that a likely significant effect from the plan can be ruled out. In reaching this view we have taken account of the GOWM: HRA of Phase Two of the Regional Spatial Strategy for the .

The screening report indicates that South Pennines Moors SAC, Peak District Moors (South Pennine Moors Phase 1 and 2) SPA, and West Midlands Mosses SAC amongst other sites are affected by diffuse air pollution and over their critical loads for at least one pollutant. The RSS Phase 2 was assessed and it was concluded that the integrity of a number of European sites is at risk from additional air pollution associated with proposals set out in Phase 2 which includes increased housing in North Staffordshire.

To avoid and mitigate for the impacts on diffuse pollution the above mentioned document (page 64) recommends a number of measures relevant at the LDF level. These include air quality strategies, the need for LDDs and LTPs to consider air quality effects on sensitive European sites even when the plan does not contain proposals directly adjacent the sites, and adoption of “pollution neutral” approaches to NOx emissions by local authorities.

We consider that the section on air quality in the screening report requires reconsideration and appropriate amendment.

In combination effects

Other than ‘no’ there is no information provided with respect to possible in combination effects. Accordingly we are not able to comment on the main potential in combination effects meaningfully with out some explanatory text.

The list of other relevant plans in 2.10 also appears incomplete. Other plans that are likely to be relevant include (not exhaustively) RSS 11 and RSS Phase 2 review and

18 Appropriate Assessment, County Waste Management Plan and the Local Transport Plan.

Please re-consult with us regarding any proposed changes to the HRA screening report and do not hesitate to contact us should you wish to discuss these comments further.

I apologise for the delayed reply.

Yours sincerely

R A Duff Conservation and Planning Adviser

cc Edward Sidley, Stoke CC

Appendix 2 - E-mail received on 15th August 2008

Dear David and Edward

I refer to the revised Core Strategy Screening Report dated July 2008. I confirm that Natural England is satisfied with the document subject to confirmation that the suggested amendments to the Core Strategy regarding the Black Firs and Cranberry Bog Ramsar site detailed in our letter of 24 June 2008 will be included into the submission Core Strategy. Please could you confirm this latter point?

Yours sincerely

Robert Duff Planning and Conservation Adviser Natural England

19 Appendix 3 – Schedule of changes

Ref Paragraph/Policy/Diagram Revision

General

1 n/a Replace Newcastle-under-Lyme Borough Council’s logo with new logo 2 Front Cover Update status and date of on the front cover.

Addendum

3 Addendum Move CSP4 policy addition to point 5 of CSP4 4 Addendum Move additional text in addendum to the end of Para 6.34 5 Addendum – 13th line Change ‘SSI’ to ‘SSSI’

Introduction

6 1.3 – 3rd line Hyphenate Newcastle under Lyme 7 1.5 – 1st line Replace ‘Core Strategy’ with ‘Core Spatial Strategy’ 8 1.7 – 8th line Replace ‘This’ with ‘These’ 9 1.7 – 8th line Replace ‘is’ with ‘are’. 10 1.7 – 10th line Hyphenate Newcastle under Lyme

Context and Conformity

11 2.2 – 1st line After ‘The Statement of Compliance’ insert ‘(also known as a regulation 30(d) statement)’ 12 2.2 – 3rd line Replace ‘These documents’ with ‘This document’ 13 2.4 – 3rd line Delete ‘is included in Appendix 2’ 14 2.6 – 1st line Replace ‘development plan document’ with

20 ‘Development Plan Document’ 15 2.8 – 1st line Replace ‘via Appendix 2’ with ‘virtual library’. 16 2.15 – 2nd line Hyphenate Newcastle under Lyme 17 2.15 At end of paragraph insert ‘The preparation of the Core Spatial Strategy has also had regard to the vision and aims of the Staffordshire Community Strategy 2005-2010 undertaken by the Stoke-on- Trent and Staffordshire Strategic Partnership. The revision of this Strategy, published in September 2008, is also closely aligned with the Borough’s Sustainable Community Strategy, adopted February 2008.’

Spatial Portrait

18 3.1 1st line Hyphenate Stoke on Trent 19 3.1 2nd line Hyphenate Newcastle under Lyme 20 3.2 – 4th line Hyphenate Stoke on Trent 21 3.4 – 5th line Hyphenate Newcastle under Lyme 22 3.6 – 1st line Replace ‘table’ with ‘histogram’ 23 3.7 – 5th line Hyphenate Newcastle under Lyme 24 3.8 – 1st line Replace ‘diagram’ with ‘histogram’ 25 3.15 – 1st line Replace ‘diagram’ with ‘graph’ 26 3.45 – 2nd line Hyphenate Newcastle under Lyme 27 3.47 - 4th/ 5th lines Hyphenate Newcastle under Lyme 28 3.48 – 6th line Hyphenate Stoke on Trent 29 3.64 – 2nd line Hyphenate Stoke on Trent

Strategic and Spatial Principles

30 5.4 – 1st 3 bullet points Hyphenate Stoke on Trent 31 5.5 – 7th/ 8th lines Replace ‘development plan documents’ with ‘Development Plan Documents’ 32 5.15 – 5th line Replace ‘core strategy’ with ‘Core Spatial Strategy’ 33 SP1 – page 40 Move ‘Spatial Principles of Targeted Regeneration:’

21 into grey box, immediately after ‘SP1’ 34 5.26 - table On left hand column, insert Annual (net) Housing completions 35 5.29 – 1st line Delete ‘Urban Area’ 36 5.29 – 3rd line Hyphenate Newcastle under Lyme 37 5.32 – table Hyphenate Newcastle under Lyme and Stoke on Trent 38 SP2 – page 46 Move ‘Spatial Principles of Economic Development’ into grey box immediately after ‘SP2’ 39 5.38 – 5th line Replace ‘Borough of ’ with ‘District of ’. 40 5.40 - table Hyphenate Newcastle under Lyme and Stoke on Trent 41 5.42 - table Hyphenate Newcastle under Lyme and Stoke on Trent 42 5.46 – 1st / 2nd lines Replace entire first sentence of paragraph with ‘Additional sites will be identified and allocated in each authorities subsequent Development Plan Documents. Full details can be found in each authorities respective Local Development Scheme.’ 43 5.51 - table Hyphenate Newcastle under Lyme and Stoke on Trent 44 5.52 – 9th/ 10th lines Replace last sentence of paragraph with ‘Suitable sites will be identified and allocated in each authorities subsequent Development Plan Documents. Full details can be found in each authorities respective Local Development Scheme.’ 45 5.53 – table Hyphenate Newcastle under Lyme and Stoke on Trent from table headings 46 5.53 - table Insert ‘comparison’ after ‘Additional’ on left hand columns 47 5.54 – 5th/ 6th/ 7th lines Replace last sentence of paragraph with ‘Suitable sites will be identified and allocated in each authorities subsequent Development Plan Documents. Full details can be found in each

22 authorities respective Local Development Scheme.’ 48 SP3 – page 52 Delete ‘Spatial principles’ from top of page and insert ‘Spatial Principles of Movement and Access’ to grey box, immediately after ‘SP3’ 49 5.76 – 4th line Insert full stop after ‘core’. 50 5.76 – 1st line Replace ‘regional spatial strategy’ with ‘Regional Spatial Strategy’ 51 5.84 – 1st line Insert brackets for RSS. 52 5.100 – 3rd line Insert ‘the’ prior to Business District. 53 5.107 – 3rd line Hyphenate Stoke on Trent 54 5.116 – 7th line Replace ‘rationalize’ with ‘rationalise’. 55 5.123 – 3rd line Replace ‘maximizing’ with ‘maximising’. 56 5.123 – 5th line Replace ‘building’ with ‘build’. 57 5.125 – 5th line Replace ‘stabilization’ with ‘stabilisation’. 58 5.129 – 3rd line Replace ‘core spatial strategy’ with ‘Core Spatial Strategy’. 59 5.138 Add a semi-colon to the end of each line other than last line. 60 5.139 – 1st line Insert brackets for RSS. 61 5.141 – 4th line Replace ‘maximize’ with ‘maximise’. 62 5.142 Add a semi-colon to the end of each line other than last line. 63 5.146 – 3rd line Replace ‘maximization’ with ‘maximisation’. 64 5.162 – 2nd line ‘Solution’ with ‘solutions’. 65 5.166 – 2nd line Insert brackets for RSS. 66 5.171 – 4th line Replace ‘prioritization’ with ‘prioritisation’. 67 5.177 – 3rd line Replace ‘maximization’ with ‘maximisation’. 68 5.182 – 6th line Replace ‘Lymebrook’ with ‘Lyme Brook’ 69 5.185 – 7th line Replace ‘town Centre’ with ‘Town Centre’ 70 5.189 – 2nd line Hyphenate Newcastle under Lyme 71 5.193 – 2nd line Insert full stop after ‘professional services’ 72 5.203 – 1st line Replace ‘is preparing’ with ‘has prepared’ 73 5.203 – 2nd line Replace ‘will set out’ with ‘sets out’ 74 5.204 – 1st line Replace ‘an Allocations DPD’ with ‘a Sites

23 Allocations and Policies Development Plan Document’ 75 5.205 – 1st line Delete ‘draft’ 76 5.209 – 5th/ 6th line Hyphenate Stoke on Trent 77 5.216 – 3rd line Hyphenate Newcastle under Lyme 78 5.220 – 13th line Replace ‘Knutton and Cross Heath Design SPD’ with ‘Knutton and Cross Heath Development Sites Supplementary Planning Document.’ 79 5.222 – 4th/ 5th line Replace ‘a community building’ with ‘community facilities’ 80 5.225 Replace entire paragraph with ‘ The Strategic Housing Market Assessment 2007, along with the Development Viability Impacts of Affordable Housing Policy Proposals 2008 study, provides the evidence base for determining local affordable housing requirements and for identifying the appropriate mix of housing types, sizes and tenures to be delivered.’ 81 5.234 – 4th line Replace ‘maximization’ with ‘maximisation’ 82 5.234 – 8th line Delete ‘to be published later in’ 83 5.235 – 4th line Hyphenate Newcastle under Lyme 84 5.238 – 1st line Replace ‘Site Allocations DPD’ with ‘Site Allocations and Policies Development Plan Document’ 85 5.243 – 3rd line Renumber as 5.244 (and all subsequent paragraphs accordingly) 86 5.249 – 1st line Hyphenate Newcastle under Lyme 87 5.251 - 6th line Replace ‘aging’ with ‘ageing’ 88 5.256 – 7th line Replace ‘council’ with ‘Council’ 89 5.257 – 4th line Replace ‘Site Allocations DPD’ with ‘Site Allocations and Policies Development Plan Document’ 90 5.260 – 5th line Replace ‘Site Allocations DPD’ with ‘Site Allocations and Policies Development Plan Document’ 91 5.264 – 6th/ 7th/ 8th lines Replace final sentence of paragraph with ‘Further guidance on the Borough Councils requirements for affordable housing can be found in its Affordable

24 Housing SPD.’ 92 5.266 – 2nd line Delete ‘by 2012’ 93 5.268 – 5th/ 6th/ 7th lines Replace with ‘An arrangement exists between English Partnerships and the Land Restoration Trust to ensure the long term management of the void and disposal area at the former Silverdale Colliery site once they have been restored.’

Core Strategic Policies

94 6.8 – 9th line Delete ‘(Appendix 2)’ 95 6.9 – 1st line Replace with ‘Policies CSP1 and CSP2 will seek to deliver the following key principles:-‘ 96 6.16 – 1st line Hyphenate Newcastle under Lyme 97 6.17 – 4th bullet point Hyphenate Stoke on Trent and Newcastle under Lyme 98 6.22/ 6.23 Insert line break between 2 paragraphs 99 CSP3 – page 96, 3rd line of point 1 Replace ‘onsite’ with ‘on site’ 100 CSP3 – page 96, 6th line of point 1 Move comma to before instead of after ‘then’ 101 6.34 – 4th/ 5th/ 6th lines Replace 2nd sentence of paragraph with ‘A screening exercise was carried out to identify any potential significant effects and therefore the need to carry out a full Appropriate Assessment of the Core Spatial Strategy. As a result of this exercise, it was determined, in consultation with Natural England, that a full Appropriate Assessment of the Core Spatial Strategy was not necessary. The process and outcomes of this exercise are set out in the Screening Report for Newcastle-under-Lyme and Stoke-on-Trent Core Spatial Strategy (July 2008).’ 102 6.37 Replace entire paragraph with ‘The identification of specific natural assets – SSSIs, SBIs, Local Nature Reserves etc, and detailed criteria based policies for their protection, will be included in future

25 Development Plan Documents, and Proposals Maps. Further details are available in each authority’s Local Development Scheme.’

103 6.43 – 1st line Hyphenate Newcastle under Lyme 104 6.43 – 13th/ 14th lines Replace final sentence of paragraph with ‘The findings will be taken forward through future Development Plan Documents as set out in each authorities Local Development Scheme.’ 105 6.44 – 3rd line Hyphenate Stoke on Trent 106 6.44 – 4th line Hyphenate Newcastle under Lyme 107 6.45 – 3rd/ 4th lines Replace ‘Development Control Policy documents and supplementary guidance’ with ‘future Development Plan Documents and in the case of Newcastle, the Developer Contributions Supplementary Planning Document.’ 108 6.56 -1st/ 2nd lines Replace with ‘Sites will be identified in future Development Plan Documents, as set out in each authorities Local Development Scheme, that satisfy the criteria set out below –‘ 109 6.57 – 2nd/ 3rd / 4th lines Replace 2nd sentence of paragraph with ‘Where necessary additional sites will be identified in future Development Plan Documents that include site allocations. Further details can be found in each authority’s Local Development Scheme.’ 110 6.60 – 2nd line Hyphenate Newcastle under Lyme 111 6.61 – CSP8 Replace ‘Minerals’ with ‘Minerals in Stoke-on-Trent’

Implementation

112 7.1 – 2nd/ 3rd lines Hyphenate Newcastle under Lyme 113 7.1 – 7th/ 8th lines Replace last sentence of paragraph with ‘Detailed implementation programmes will be set out in future DPDs that include site allocations. Further details are provided in each authority’s Local Development

26 Scheme.’

Monitoring Framework

114 8.1 – 3rd line Hyphenate Newcastle under Lyme 115 Page 114 - 119 Insert referencing into table for each Indicator & Measure.

Next steps

116 9 Delete

Appendices

117 Appendix 2 Needs to be updated to reflect all the agreed documents within the finalised Core Documents list presented at the Hearing Sessions.

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