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Craven Local Plan Examination

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Craven Local Plan Examination Craven Local Plan Examination Summary of Representations on the Main Modifications and Craven District Council Responses Where Required 09/05/2019 1 Note: This document lists the representations received for each Main Modification during the consultation for the Main Modifications to the draft Craven Local Plan, arising from the examination of the local plan by the Inspector in October 2018. The document includes a summary only of each of the representations on the proposed Main Modifications to the local plan, and provides a response to them where required. All the full original representations received during the consultation period have been sent to the Inspector for his review and consideration of the points raised within them. 1 2 Representor Summary of Key Issues Identified in the Representation CDC response MM Ref ID No (where required) MM1a Historic Supports modification, which introduces reference to Settle’s No response required. England intimate feel and distinctive character. 017 MM3 Skipton Civic Support modification to revise numbers to reflect current No response required Society situation. 044 MM3 S Wilton This is a sensible modification as it ensures the Plan reflects Whilst the plan itself cannot be a ‘live’ online document, 118 the current position. It would be even more helpful if the net the Council will publish, in its annual Authority additional dwelling figure could be continually updated on Monitoring Report, up to date figures on housing any on-line version of the Plan to ensure it always contained completions and housing supply requirements. the up-to-date figure MM5 HBF, J Supports modification, which introduces full table from SHMA No response required. Harding Update 2017, recognises other sources of evidence and 028 refers to flexibility in part (c). MM6 Gladman Supports deletion of percentages in part (a) of policy, but These issues were raised and addressed during the 012 changes do not go far enough. Consideration of housing examination hearing session on Matter 8. The resulting market demand indicators should be taken into account in modification ensures that the policy is now clear and determining housing mix. Broadly supports changes to part effective with respect to those issues. In considering (b), but they do not go far enough. Higher density should be whether to change the proposed modification in acceptable in town centres and highly accessible locations. response to this representation, the Inspector’s Lower density should be acceptable in lower order attention is drawn to the Council’s view that no change settlements in response to their form and character. This 2 3 would reflect Government’s approach and changes to Design is required. in the 2019 NPPF. MM6 J Adams In part (b) ’regard to local and site-specific circumstances’ is The reason or need for the proposed change is not 204 non-specific and should be replaced with wording more in clear and the suggested wording appears to be less keeping with SP12 and INF7. ‘Regard to local’ should be clear and effective than the proposed modification. The followed by ‘sustainability issues, infrastructure requirements, policy, as modified, should ensure clarity and safety and inclusivity’. effectiveness and no further modification should be necessary in the interests of soundness. MM6 S Coetzer In part (b) ’regard to local and site-specific circumstances’ is See response to representation 204 on MM6 above 226 non-specific and should be replaced with wording more in keeping with SP12 and INF7. ‘Regard to local’ should be followed by ‘sustainability issues, infrastructure requirements, safety and inclusivity’. MM6 F Hall Coetzer In part (b) ’regard to local and site-specific circumstances’ is See response to representation 204 on MM6 above 227 non-specific and should be replaced with wording more in keeping with SP12 and INF7. ‘Regard to local’ should be followed by ‘sustainability issues, infrastructure requirements, safety and inclusivity’. MM7 CPRE North CPRE North Yorkshire welcomes the clarity that the No response required Yorkshire additional text provides at paragraph 4.40 in relation to Tier 5 009 settlements. This clearly describes the service role as being limited to the residents of the settlements – for settlements which have 15 or more closely grouped residential properties. This helpfully distinguishes between those settlements in Tier 4 and those considered to be within the ‘open countryside’. 3 4 It goes on to clarify at paragraph 4.46 to set out what will be allowed (limited development) in relation to Tier 5 settlements – i.e. 1.5% of total housing growth across the plan period in these settlements. MM7 R Pringle MM7 is unsound, not legally compliant and could breach the There appears to be a misunderstanding over what 036 Duty to Cooperate for the following reasons: these changes mean. The changes proposed in MM7 and MM8 should be read as a whole. Reading these The emphasis in paragraph 4.47 and 4.49 has been modifications as a whole, it is clear that there is no changed from building on allocated sites and significant change to the plan’s overall approach to brownfield sites in settlements to basically ‘building supporting the principle of housing development on anywhere’ and on land outside a settlements main built up area in the countryside. appropriate land within the main built up area of o The new wording is ambiguous with no settlements, and definitions included land adjoining a settlement’s main built up area o These major changes have been made that is unallocated – but only if the settlement’s without being the subject of discussion at the planned growth level is not being met, or it is a examination hearing and the consultation rural exception site in accordance with Policy protocol. H2 , or there are special economic, o The change is in conflict with national environmental and/or social circumstances planning policy. which justify development. The sections about traffic have been deleted. Policy criterion H and paragraph 4.47 both refer to Apart from the inclusion of additional wording regarding the supporting proposals for housing within the built up Council’s regular monitoring of the performance of each area of a settlement. The matter of adding support for settlement in meeting its planned growth levels, which is housing on other appropriate land as well as previously justified, the modification should be deleted and the original developed land within a main built up area was wording re-instated. discussed and agreed at the examination hearing in response to the Inspector’s questions 2 and 3 of Issue 3, Matter 4. The policy support is conditional on proposals being in conformity with all other relevant plan policies. For example, it will not be appropriate to support housing on land protected by Policy ENV10: 4 5 Local Green Space. Supporting housing on other appropriate land within the built up area of a settlement, as well as previously developed land, will assist in minimising the loss of countryside to housing. The changes proposed regarding the wording of the plan on when it may be appropriate to allow housing on land unallocated for housing adjoining a settlement’s main built up area still retain the same approach as contained in the Publication Draft Plan. The plan continues to support the delivery of the plan’s housing allocations and appropriate land within the built up area and, continues only to allow housing proposals adjoining settlements (apart from rural exception sites for affordable housing) if allocated and windfall housing within the built up area are: not able to meet the settlements planned growth, or development is justified by special economic, environmental and/or social circumstances, and proposals are compliant with the criteria in Part I) i), ii), iii), iv), v), vi). The Publication Draft Plan Policy SP4 did not promote a ‘brownfield land’ first approach. This would not have been consistent with national planning policy. During discussion of Policy SP4 at the examination hearing, the Inspector questioned whether the proposed criterion regarding traffic impact was appropriate to include within this strategic policy. The Council agreed at the hearing that this criterion could be deleted from this policy. The issue of ensuring proposals have an acceptable traffic impact is dealt 5 6 with in the proposed new policy INF7: Sustainable Transport and Highways (MM120 and 121). This issue has not been deleted from the plan as a whole. In considering whether to change the proposed modification in response to this representation, the Inspector’s attention is drawn to the Council’s view that no change is required. MM7 Skipton Civic MM7 is unsound and not legally compliant for the following See response to representation 036 on MM7 above. Society reasons: 044 the changes allow random growth at a settlement giving no direction for where a settlement spreads The plan used to encourage sustainable development by using brownfield sites first and to secure growth as planned. Retain the wording previously proposed. MM7 S Wilton MM7 is unsound for the following reasons: See response to representation 036 on MM7 above 118 The introduction of the wording ‘or other appropriate land’ as it stands is vague and provides a ‘blank cheque’ enabling developers to argue that any land is appropriate. The deletions and insertions in paragraph 4.49 detract from the sound principle that any brownfield sites should be considered first and only if there are none available should consideration be given to other land. Delete the word ‘or other appropriate land’ from paragraph 6 7 4.47, and ensure paragraph 4.49 unequivocally establishes ‘brownfield first’ principle. MM7 B Martin MM7 is unsound, not legally compliant or in compliance with See response to representation 036 on MM7 above. 182 the Duty to Cooperate for the following reasons: The change of wording from favouring ‘allocated land previously developed land in tiers 1 to 5’ to favouring ‘brownfield land and other appropriate land’ will allow developers and the Council to build anywhere they want.
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