Inspector’s Initial Questions and Issues ANNEX 1 Chapter 5 Delivering the Vision and Strategic Policies Policy STP1. Spatial Priorities for Sustainable Growth Question 1. Are all the sites that will be required to meet housing needs on previously developed land? The sites that have been allocated through Policy H2 are all previously developed sites. The outstanding commitments, which provide the bulk of the forward supply of land upon which new homes will be built during the plan period, are almost entirely comprised of previously developed land. Notable exceptions include the Allerton Priory appeal site which sits within the Green Wedge (see response to question 121). Of the 25, 978 outstanding commitments referred to in Table 7 of the Submission draft Liverpool Local Plan 91.75% are on previously developed land. While the remaining 8.25% (2,143 dwellings) are on sites that comprise some elements of previously undeveloped land, the majority of these contain in some cases substantial proportions of previously developed land, particularly the 8 former school sites and in the case of the former International Garden Festival site the proposed 1, 374 dwellings are to be built on the sites developed core area. As a general rule if a the curtilage of a site of more than 0.4 hectares contained over 50% open space it has been the City Councils practice to apply an open space policy designation through the City’s existing development plan the UDP. MM Policy STP2. Sustainable Growth Principles Question 2. Despite apparently applying to all development, this policy contains a series of aspirations which cannot be met in every case. It covers a wide range of topics and applies general policy approaches which do not accurately reflect the more detailed policy contents of the individual policies or of the NPPF. This policy was written as an over-arching strategic policy that puts down markers, in the form of key principles to help ensure sustainable development. While detailed policies set out how many of the principles will be implemented, not all the themes within the policy are developed to the same degree. In particular this applies to criterion (i) and (j) which are concerned with low and zero carbon and adaptation to climate change. Liverpool, in common with many other authorities has now declared a Climate Emergency, which lends the objectives of this policy even greater importance to the City and so underlining the significance of its retention. It is accepted that as written the policy has weaknesses, and accordingly the City Council proposed change to address any issues of consistency within the local Plan or in relation to the NPPF, is set out following Question 7. Question 3. The 2012 NPPF encourages the re-use of previously developed land but does not make it a “first priority”. The use of recycled building material may be feasible in some cases but not all, so cannot be regarded as a “first priority”. The City Council considers that it has taken, as required by the NPPF account of local circumstances in the scope and content of the policy. It nevertheless recognises that the term first priority may be too prescriptive and in some cases impractical, but it should be an aspiration. The City Council proposed change, is set out following Question 7. Question 4. The policies on social inclusion and health and wellbeing are too high level to explain to a decision maker or applicant how they will be applied in individual planning applications. Inspector’s Initial Questions and Issues Health and well-being is an extremely important issue to the City Council and accordingly it is important that development proposals should have positive outcomes. However it is recognised that further detail is required. The City Council proposed change is set out following Question 7. Question 5. The concept of “no adverse impact” is not appropriate: many developments have a level of impact and there is a planning balance to be struck. The City Council agrees that there is always a planning balance to achieve but this term implies an impact that is unsustainable. It is a term frequently used, albeit with qualifications in the NPPF. The City Council proposed change is set out following Question 7. Question 6. The criterion concerning the protection of the green infrastructure network is too general. That relating to heritage assets is too general and does not properly reflect the detailed requirements of the NPPF. The same can be said of most of the rest of the policy requirements. It is acknowledged that the policy wording can be improved upon. The City Council proposed change, is set out following Question 7. Question 7. Policy STP2 is therefore ineffective and should be deleted in its entirety. It is in any case unnecessary, since there are individual policies which cover all these items in more detail. If the Council wants to make a general statement about its broad approach to sustainable development it could consider putting it into the background text. The City Council accepts that the policy could be written more effectively. It asks the Inspector to note that it considers this Policy to be one of its key statements about the nature of development proposals that are brought forward. Taking into account the points made in the questions above the City Council proposed change is : 1. New development should seek to avoid negative impacts on the environment through adoption of best practice. Where a negative effect is identified this should be mitigated by appropriate measures. Specifically. To to ensure the sustainable growth of Liverpool, the City Council will support development proposals which address, as appropriate, the following strategic economic, social and environmental principles: Economic Principles a. As a first priority, be located on previously developed land and/or re-use an existing building, seek to use secondary materials such as recycled aggregates and where appropriate aim to secure the remediation of contaminated sites; a. Contribute to delivering economic growth and ensuring a strong, responsive and competitive economy; b. Make effective use of land, including where appropriate underutilised existing land and buildings, to meet the need for homes, employment and other uses; c. Ensure no adverse impact on the operation of existing businesses in the area within which the proposed development is located; d. Make use of suitable brownfield land for new homes and other identified needs in this Plan. The City Council will also support appropriate opportunities to remediate land especially that which is derelict, contaminated or unstable to meet development needs; Inspector’s Initial Questions and Issues b. Make a positive contribution to the delivery of sustainable communities including through the promotion of social inclusion and equal opportunities in the communities in and around the area where the development is taking place; Social Principles d. Make positive improvements to health and well-being across the City e. Create or contribute to the creation, improvement or maintenance of healthy, safe, sociable and inclusive mixed and balanced communities and places; f. Make the public realm attractive as a place to be enjoyed by the whole community, which creates a sense of safety and security and helps to prevent crime and antisocial behaviour inside and outside buildings and in public spaces; g. h. Be located where it is Make the best use of locations that are already easily accessible by sustainable transport or where it that could easily be made accessible by sustainable transport including walking, cycling, public transport and by supporting the use of electric vehicles including electric vehicle charging points h. Facilitate and promote walking and cycling to increase people’s activity rates i. Avoid ‘bad neighbour’ use related problems including for example vacant premises and inactive frontages, and the cumulative impact of A5 uses (hot food takeaways) Environmental Principles j. Achieve net environmental gains, for example net gains in biodiversity, contributing to the recovery of priority species and habitats and new habitat creation; k. Improve public access to open space and sports facilities, including good quality, secure and stimulating play space, informal recreation provision and accessible natural open space which encourages greater participation in physical activity; f. Contribute to ensuring a net gain in biodiversity in the City including, where relevant, contributing to the recovery of priority species and habitats; l. Minimise environmental impact, with sustainability features incorporated into buildings, spaces and neighbourhoods at an early stage of the design process in line with and which results in the efficient use of resources generally including materials, water and energy; reduces carbon emissions and thus contributes to achieving zero carbon buildings; m. i. Deliver high quality contextual design which helps to reinforce the distinct character and identity of the various parts of the City, and results in the efficient use of resources generally including materials, water and energy; reduces carbon emissions and thus contributes to achieving zero carbon buildings; informed by an analysis of local character and the specific attributes of the site, seek to reinforce or create positive local distinctiveness and identity, whilst securing integration and coherence with the local context and which promotes opportunities for physical activity; and minimises waste, light and noise pollution; Inspector’s Initial Questions and Issues k. Avoid areas at risk of flooding and demonstrate it will not exacerbate potential sources of flood risk; n. g. Conserve and enhance the City's heritage assets including for example through development proposals which reflecting, protecting, and enhancinge the area’s historic character and environment; o. j. Is Be well adapted to the effects of climate change by for example including incorporating appropriate climate change adaption measures and meeting the highest feasible environmental standards during construction and occupation; p.