HILPERTON NEIGHBOURHOOD PLAN Hilperton Parish 2017 – 2026 CONSULTATION STATEMENT Contents 1.0 Introduction and methodology 4 2.0 Early community engagement 8 3.0 Overall summary of findings of initial community engagement 15 4.0 Reg. 14 formal 6-week consultation 19 5.0 Reg. 14 Consultation – summary of issues and themes 54 6.0 Changes to Vision, Objectives and Policies 57 Appendix 1 Community Engagement: Public Meeting 26th November 2015 Appendix 2 Community Engagement Formal questionnaire and Analysis Appendix 3 Community Engagement: comments from website response form and Facebook. Appendix 4 Community Engagement: Business Survey – November 2016 Appendix 5 School Council: children’s responses / suggestions Appendix 6 Older people’s responses Appendix 7 HRA and Discussions with County Ecologist Appendix 8 Revised Area Application and Parish Area before and after Boundary Review Appendix 9 Neighbourhood Plan Team - 2 - GLOSSARY OF TERMS USED Term Definition DPD (HSAP) Development Plan Document (later known as the Housing Site Allocations Plan or HSAP) HNS Housing Needs Survey HRA Habitat Regulations Assessment LDF Local Development Framework LPA Local Planning Authority (Wiltshire Council) NDP Neighbourhood Development Plan NPPF National Planning Policy Framework - 'The Framework' sets out planning policies for England and how they are expected to be applied. It provides guidance for local planning authorities and decision-takers, both in drawing up plans and making decisions about planning applications. Qualifying Body Body authorized by law to create a Neighbourhood Plan. Normally the Parish Council. Reg. 14 / 15 Regulation 14 of the Neighbourhood Plan (General) Regulations 2012 requires that a formal 6-week Consultation be carried out. Regulation 15 Requires a Consultation Statement to be submitted. SA Sustainability Appraisal – A wide-ranging appraisal of the impacts of policy (such as this plan) to include socio- economic as well as environmental factors. SEA Strategic Environmental Assessment – European legislation requiring all plans to be assessed for environmental effects. In the UK compliance with the SEA Regulations can be achieved through SA or Sustainability Appraisal which takes into account socio-economic as well as environmental factors. WCS Wiltshire Core Strategy * In this Consultation Statement, the term ‘Sites DPD’ refers to what has since become known as the Housing Site Allocations Plan or HSAP. - 3 - 1.0 Introduction and Methodology 1.0 This Consultation Statement has been created primarily to demonstrate compliance with regulations 14 and 15 of the Neighbourhood Planning (General) Regulations 2012, but also as an analysis exercise that has been of great value to the evolution of the Hilperton Neighbourhood Development Plan (NDP). Specifically, the Statement has been the means by which the Steering Group has been able to collect, analyse and make sense of all community engagement and consultation data. These inputs have then been used to directly shape the Plan in response. How this happened is described below. 1.1 It can be seen from this report that engagement with the community has effectively steered and guided the Plan from the start, and in order to reach all sections of the community a range of methods were employed. Additionally, responses from the Regulation 14 consultation led to changes in the plan. 1.2 The Consultation Statement acts as a record of all of community engagement and formal consultation, including early informal meetings and an online questionnaire, as well as formal Regulation 14 Consultation that has been carried out during the course of the preparation of the NDP. It also records the most significant interactions with the LPA – for example the Area Application and SEA / HRA Screenings. 1.3 The first Area Application took place in June and July 2016 and was managed by the LPA in accordance with the Regulations. A decision notice was issued on 20th September 2016. The Area was the whole Parish Area at that time which was approved. The draft Plan was submitted to the LPA for SEA and HRA screening on 1st December 2016. 1.4 Unfortunately, following this, an unrelated and county-wide boundary review was conducted in Autumn 2016 by Wiltshire Council. This resulted in a small portion of land and population (264 homes on part of the Paxcroft Mead estate) being transferred from Hilperton to Trowbridge with effect from 1st April 2017. On the advice of the LPA, Hilperton Parish Council decided to re-apply for its Neighbourhood Area based on the new smaller, post-review boundary. This application required a separate 6-week consultation run by Wiltshire Council. 1.5 The Application for the revised Area was submitted on 21st April 2017, and the consultation, managed by Wiltshire Council, ran from 5pm Friday 28th April 2017 to 5pm Tuesday 13th June 2017. The New Area was formally approved on 27th June 2017. - 4 - 1.6 Coincidentally at this time, the Steering Group was ready to begin its Regulation 14 Pre-Submission consultation. There was significant public interest in the plan and the Steering Group wanted to maintain steady progress. Rather than delay the consultation by two months while the revised area was determined, the Group decided to consult in parallel – that is, on the basis that the area of the proposed plan would be that of the new area, even though it had not yet formally been approved. Risks associated with this process were considered to be low as the application was not controversial and was for the whole Parish Area – effectively the default area for plans led by Parish Councils. It was hard to see how the LPA could refuse such an application. In the event, there were no objectors and just one supporter who responded. 1.7 The plan that subsequently went out to Reg.14 consultation on 20th May 2017 was therefore one based on the new area, even though that was not yet formally in effect, with an explanation as to why this was changing. The Reg 14 consultation ended on 30th June (Appendix 9 includes both the Area decisions and ‘before’ and ‘after’ maps). 1.8 Although unusual, the above circumstances do not breach any Regulations. Consultees were presented with all of the prescribed requirements of the Regulations, including a map of the Area to which the plan policies would apply, and copies of the plan including the polices were made available as required. The population of the entire plan area was consulted and able to comment. The Area was subsequently approved and both plan and area agree. Wiltshire Council agreed in an e-mail dated 4th August 2017 that this parallel process met the requirements on the Neighbourhood Planning Regulations 2012. Further details of the Reg.14 consultation are given in Section 4 of this Consultation Statement. 1.9 SEA screening carried out in early 2017 by the LPA determined that an SEA was not required. The screening decision is given as Appendix 6 of the NDP’s Scoping Report. However, the SEA format seemed to offer a useful and thorough methodology for research. In particular, the creation of a separate scoping report would contain the evidence base in an easily-referenced separate document and would leave the NDP itself free from clutter and hopefully easier to access and use. Accordingly, this separate scoping report was created and all of the research done by the Steering Group and consultant is included therein. 1.10 An HRA was carried out by Wiltshire Council’s Ecologist on 17th March 2017 after a request from the Steering Group. The Report is given here and in the NDP as an Appendix. The Ecologist suggested additional wording for some policies. However, the Steering Group, while they agreed with the objective of the wording, felt that this would be more appropriate in supporting text. The e-mail trail discussing this is also given in the same appendices (Appendix 7 here). - 5 - 1.11 Parish Housing Needs Survey (HNS) A survey of residents was published by Wiltshire Council in partnership with the Parish Council on 17th January 2017. The full Parish Housing Needs Survey is given as Appendix 8. This is based on the earlier, larger pre-review Parish boundary, which may cause it to over-estimate the need for affordable housing if applied to the later smaller area. The survey shows a demand for just 13 affordable homes in the Parish – 8 subsidised rent and 5 by means of shared ownership or discounted market housing. 1.12 The difference in area between the survey and later Neighbourhood Area is not considered to be problematic for the Plan, since the HNS was just one strand of evidence considered in the assessment of the housing issue. Other factors, such as a mixed response from the community, proximity to the Strategic Site at Ashton Park, luke-warm enthusiasm from the community for site allocation, and the emerging Sites DPD were more significant. In any event the Neighbourhood Plan does not directly allocate sites, although it does promote and encourage suitable windfall development. 1.13 The two main stages of consultation recorded by this report were: Early Stages Community Engagement (November 2015 – July 2016), and, Regulation 14 Formal Six-Week consultation (20th May - 30th June 2017). 1.14 The Early Stages Community Engagement was undertaken involving the larger Parish Area (i.e. it includes some residents who will not be covered by the final plan). The Reg 14 consultation on the other hand, in addition to a wide range of statutory consultees, includes only residents included within the reduced post-review boundary. This is not considered to be a problem, since it remains the case that all residents affected by the Neighbourhood Plan will have been involved throughout the entire process in its creation because the area has got smaller and not larger.