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Broxtowe BC, Gedling BC and Nottingham City Council

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Broxtowe BC, Gedling BC and Nottingham City Council Greater Nottingham - Broxtowe BC, Gedling BC and Nottingham City Council — Aligned Core Strategies (ACS) Examination Inspector’s Matters, Issues and Questions Matter 7: Infrastructure and Delivery (Policies 1, 2, 10, 18, 19) Main issues: (I) Whether the spatial strategy is capable of being delivered given the infrastructure, community facilities and services, and standards for development which are required to support it; (ii) Whether sufficient attention has been given to viability and funding in line with national policy bearing in mind the likely cumulative impact of the above requirements including affordable housing on developments; (iii) whether the monitoring arrangements are fit for purpose, giving clear targets, measurable indicators, and an indication as to when review or intervention will take place because policies are not delivering. Questions: 1. Does Policy 18 satisfactorily reflect the introduction into national policy of the Community Infrastructure Levy and the three tests for planning obligations set out in CIL Regulations and the NPPF, paragraph 204. Ashfield District Council Response 1.1 Ashfield DC does not have any specific issues with Policy 18 Points 1, 2 and 4. The Policy sets out that new infrastructure will be sought from new development to provide for new infrastructure. The National Planning Policy Framework in paragraph 175 identifies that where practical, Community Infrastructure Levy should be worked up and tested along side the Local Plan. However, this is not a definitive requirement and there are practical difficulties in achieving this particularly in relation to an aligned Core Strategy where a number of Councils are working together. The three tests for planning obligations are set out in the Community Infrastructure Regulations 2010 and repeated in NPPF, paragraph 204. Consequently, the statutory instrument forms the context for the consideration of any planning obligation and the Council does not consider that it is necessary for these requirements to be repeated in Policy 18. 1.2 Policy 18, Point 3 identifies that “for strategic sites which are strategic allocations, the IDP identifies what where and when and how critical infrastructure will be provided”. The key aspect is what is identified as critical infrastructure? The Greater Nottingham Aligned Core Strategy (ACS) Policy 2 allocates strategic sites at North of Papplewick Lane (600 homes) Top Wighay Farm (1,000 homes) and a strategic location at Bestwood Village with up to 500 homes through new allocations and 79 homes on existing commitments. This development is focused adjacent to and around Hucknall and is in addition to the development proposed under Ashfield Local Plan. The Council has specific concerns that the IDP and ACS Appendix A, Strategic Sites and Schedules and Plans does not identify the “what where and when” of the impact on the Gedling's proposed sites upon the infrastructure of Hucknall. Theses concerns are set out in more detail in the response to Question 5. 2. The Infrastructure Delivery Plan (IDP) was updated in May 2013. It refers to related policy, investment programmes and strategies, to joint working arrangements, and considers a range of infrastructure. It reflects the strategic and non-strategic sites in the ACS (Tables 4.2, 4.3 and 4.4) and details stakeholder engagement and consultation (App A) before dealing with each main infrastructure topic area. Does the IDP provide a sound base for the ACS and is it consistent with the NPPF’s paragraph 177? If not, what are its shortcomings? Ashfield District Council’s response 2.1 The Infrastructure Delivery Plan (IPD) sets out that Ashfield District Council is not included in the IDP but the council remains closely involved in the Joint Planning Advisory Board and supporting joint officer group. It also identifies that as the Hucknall wards of Ashfield have a close functional relationship with the area covered by the IDP, broad assumptions regarding the future levels of growth and potential strategic sites within Hucknall have been made (in consultation with Ashfield District Council). 2.2 Ashfield DC is on the Joint Planning Advisory Board and officers do meet on a regular basis. The Council in general has no issues with the IDP and it is recognised that the IDP has made broad assumptions regarding levels of growth in Hucknall in its background studies. It is also acknowledged that not all infrastructure issues can be determined through an IDP and the IDP will change over time as more definitive information becomes available. However, given the substantial development is focused on a small town outside the principle urban area of Nottingham, Ashfield DC has specific concerns that the IDP and the ACS does not identified the full impact that this development will have upon the infrastructure of Hucknall. 2.3 Hucknall is a town to the north of the city of Nottingham which was identified as a sub regional centre in the recently revoked East Midlands Regional Plan 2009. The 2011 census identifies the population of Hucknall as 32,099 people with 14,309 dwellings. Under the provisions of the Structure Plan reflected in the Ashfield Local Plan Review 2002, Hucknall has seen a significant growth in the number of dwellings, which has increased from 12,670 in 2001 to 14,309 in 2011, a 13% increase. The growth currently proposed for Hucknall, in the Greater Nottingham Aligned Core Strategies, together with the agreed level of growth within Ashfield District is as follows:- Hucknall Housing Stock (March 2011) 14309 Ashfield housing requirement for Hucknall (2011 to 2024) 2,253* (to 2024) PERCENTAGE INCREASE IN HOUSING STOCK IN HUCKNALL 16% (ASHFIELD DISTRICT) (at 2024) Top Wighay Strategic Site (GBC) 1,000 North of Papplewick Lane (GBC) 600 Bestwood Strategic Location (GBC) 500 TOTAL ADDITIONAL HOMES IN HUCKNALL (Combined 4432 Ashfield and Gedling sites) (2011 – 2028) PERCENTAGE INCREASE IN HOUSING STOCK IN HUCKNALL 31%** (Combined Ashfield and Gedling development) (at 2028) Table 1. Hucknall housing stock * 2460 dwelling requirement 2010-2024 less 207 net dwelling completions 2010 - 2011 * This is the minimum increase as Ashfield’s Local Plan is to 2024 2.4 The Ashfield Local Plan Publication document reflects Hucknall’s role as part of the Greater Nottingham area setting out Area Based Policies for Hucknall which identifies a requirement for 2,460 dwellings for the period 2010 to 2024. ACS Policy 2 identifies that, by 2028, 2,179 homes will be constructed adjoining or close to Hucknall at strategic sites at North of Papplewick Lane (600 homes), Top Wighay Farm (1,000 homes) and at Bestwood Village up to 500 homes through new allocations and 79 homes on existing commitments. Developments both in Ashfield and on the edge of Ashfield in Gedling would result in a minimum of 4639 new dwellings to 2028. Since 2010, there has been a net increase of 573 dwellings in Hucknall, which leaves 4066 dwellings to be serviced if Gedling’s proposals progress. This does not take account of the 4 years between 2024 and 2028 in Ashfield as the Ashfield Local Plan Publication goes to 2024. As can be seen from Table 1 above, If annual rates of development in Ashfield remained constant it would reflect a 31% increase on the number of dwellings currently in Hucknall. 2.5 The decision by Gedling BC to focus development on Hucknall rather that the urban areas of the borough means that Gedling needs to fully understand the impact on their proposed development on the infrastructure of Hucknall. The practicality of the transport links means that the impacts from the developments at Top Wighay, North of Papplewick Lane and Bestwood Village will be focused on Hucknall. The poor connectivity of these sites with the rest of the Borough makes this inevitable that Hucknall becomes the service centre for an additional housing requirement. 2.6 Whilst acknowledging that Gedling’s Local Plan allocated part of Top Wighay in 2005, this was before National Planning Policy Framework was published. There is now more of an emphasis on infrastructure delivery in the NPPF. 2.7 Given this context, it is considered that the ACS must address the impact that development in Gedling will have upon Hucknall and the delivery of Ashfield’s proposed development in Hucknall. The questions Ashfield DC would like Gedling BC to answer are: Q. What are the broad impacts of the allocated sites in Gedling around Hucknall? Q. Have those impacts in relation to Hucknall been assessed? Q. How will the impacts be addressed? 2.8 Gedling Borough Council has not sufficiently addressed Ashfield’s concerns regarding the impact of development in Gedling Borough on the delivering of development in Hucknall. Although there have been meetings between the two Councils to discuss Gedling BCs proposals on the boundary of Hucknall, Ashfield DC considers that it has not received sufficient information from Gedling BC to address many of the questions raised about the delivery of infrastructure in Hucknall. 2.9 Ashfield has concerns that if development proposed on the boundary comes forward first it will compromise the delivery of development in Ashfield by absorbing existing infrastructure capacity. This would jeopardise Ashfield’s position with regard to meeting the District’s objectively assessed housing needs. 2.10 It was agreed that Gedling Officers (letter from Gedling 26 th April 2012) would set up a series of ‘themed workshops’ to enable Ashfield, Gedling and other Greater Nottingham Local Authorities to specifically tackle issues such as transport. Ashfield DC has attended three meetings to discuss various issues, (3 rd July 2012 and 18 th September 2012) and a meeting was held on 5 th December 2012 to discuss the Habitats Regulation Assessment. While the concerns over the Habitat Regulations Assessment have been resolved the other issues remain outstanding. 2.11 There are a number of specific issues relating to the impact on Hucknall from the Gedling’s development sites These include the following: Education • Developments both in Ashfield and on the edge of Ashfield (at Top Wighay, North of Papplewick Lane and Bestwood in Gedling Borough) total a minimum of (Ashfield’s Local Plan is to 2024) of 4066 new dwellings up to 2028.
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