Plan for Fylde - Plan for the Future Fylde Borough Council Text of Regulation 20Economic Development Representations in Policy OrderStrategy and Action Plan December 2016 Consultation Responses – Policy Order: General Comments on the Publication Version OC/MISC/08/00833 Thank you for notifying National Trust of the above consultation. – National Trust Having reviewed the consultation documents, including the report in respect of earlier relevant consultations the Trust has no comments to add to those submitted previously. OC/ACT/13/02036 – I am responding to your letter dated 9th August re the above and would be grateful if you would provide the Inspector dealing with the Local Plan Minority Group - Liz with copies of the two Minority Reports, prepared by councillors who are not members of the Conservative administration. I would be obliged if Oades you would confirm, in writing that this will be done. Most of the points my colleagues and I wish to make are contained in the two Minority Reports so I do not see any reason for repeating them. Since the Minority Reports were published submission documents have been prepared which were not available at that time, I then briefly outline below some comments and concerns in relation to some of the documents: Open Space Study Update and Playing Field Strategy. These are poor documents as much of the information within them is inaccurate, I think they are lazy studies and should be redone ensuring that the information is fully accurate. The education figures seem to be inaccurate and I believe that this needs to be revisited. At the Planning Policy meeting held in June there was a discrepancy noted in relation to the population figures within the documents, this should perhaps be looked at again? I look forward to receiving your response. SCB/SCB/16/02321 – We have reviewed the above consultation document and can confirm that National Grid has no comments to make in response to this consultation. National Grid Further Advice National Grid is happy to provide advice and guidance to the Council concerning our networks. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us. To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect our assets. Please remember to consult National Grid on any Development Plan Document (DPD) or site-specific proposals that could affect our infrastructure. OC/ISP/08/00692 – Thank you for your consultation on the above Canal and River Trust Only a small part of the Lancaster Canal passes through the Borough, in generally rural locations not subject to significant development proposals. We therefore have no comments to make on the soundness or legal compliance of the document. SCB/SCB/08/00355 – Thank you for your consultation seeking the views of United Utilities as part of the Development Plan process. United Utilities United Utilities has commented on previous versions of the emerging Local Plan. We submitted comments (UU Ref: DC/13/3885) to the first ‘Preferred Options Local Plan and IDP’ consultation in November 2013, and also submitted comments (UU Ref: DC/14/3747) to the subsequent ‘Development Sites’ consultation on 19 November 2014. More recently, we submitted comments (UU Ref: DC/15/1940) as part of its ‘Revised Preferred Options Local Plan and IDP’ consultation. We now write to submit representations (UU Ref: DC/16/3418) to the Council to its emerging Local Plan ‘Publication Version’ consultation in accordance with the deadline of 22 September 2016. Please note that representations submitted previously by United Utilities to the Local Plan and IDP still stand. This letter is therefore supplementary to comments submitted to the above mentioned consultations. United Utilities has met with Policy Officers from Fylde Borough Council previously and made comment on the individual proposed site allocations. We understand from discussions with the Council’s Policy Team that no additional sites are proposed for allocation as part of the ‘Publication Version’ Local Plan, therefore we do not provide additional comments on the individual sites as part of this letter response. GENERAL COMMENTS United Utilities wishes to highlight that we will seek to work closely with the Council during the Local Plan process to develop a coordinated approach for delivering sustainable growth in sustainable locations. New development should be focussed in sustainable locations which are accessible to local services and infrastructure. United Utilities will continue to work with the Council to identify any infrastructure issues and appropriate resolutions throughout the development of the Local Plan. OC/AGCN/13/01729 This section summarises our Client’s representations to the Publication Draft Document of the Fylde Local Plan 2032. – Story Homes Ltd. In these representations we have considered whether the strategy, policies and allocations proposed by the Council are consistent with the policies Barton Willmore of the NPPF, commenting on their deliverability, effectiveness and justification, and providing recommendations how issues identified may be overcome in moving forwards within the Plan. Our Client has significant concerns regarding the overall soundness of the Plan. We do not consider the approach or evidence supporting the Plan to meet the tests of soundness outlined within Paragraph 182 of the NPPF. Fundamental issues with the plan as drafted include: - The approach to defining the objectively assessed housing needs represents a departure from national planning policy and guidance; - The overall housing requirement will not provide for a significant boost to housing land supply and fails to support the opportunity to develop the local economy; and - The Plan is ineffective as the assumptions made by the Council in terms of expected delivery rates of a number of strategic sites are unrealistic given the infrastructure required to deliver these sites. Substantial revisions are required to supporting evidence, proposed policies and proposed site allocations to address the issues identified above. This we consider includes the adoption of a housing requirement of the level required to support projected job growth (440-450 dwellings per annum). The allocation of further sites to deliver housing needs is fundamental in securing a sound and deliverable Plan. Furthermore, given the uncertainties of the Elswick Neighbourhood Plan the Council should be looking to allocate sites within Elswick as part of the Local Plan. Land north of Mill Lane, Elswick has a capacity for up to 100 dwellings, with the potential to contribute to the short term supply. The Site is sustainably located and faces no known technical constraints that would prevent its delivery for housing. Our Client was granted outline planning permission for the development of up to 100 dwellings at Land off Willow Drive, Wrea Green in January 2016. Our Client has subsequently submitted a reserved matters application for 86 dwellings which is currently pending consideration. It is their intention to deliver the site within the next 5 years. Our Client therefore supports the inclusion of this site as an allocation within the Local Plan. We trust these representations will be afforded full consideration by the Council. We also reserve the right to appear at the Examination in Public, on behalf of our Client, on the basis of these representations. SCB/SCB/08/00351 – We have reviewed the Fylde Local Plan to 2032 and the associated documents insofar as it relates to out remit and we wish to comment as follows:- Environment Agency We are pleased to see that our comments in our previous response (dated 5 January 2016, Ref: NO/2012/103893/CS-03/PO2-L02) to the Revised Preferred Option consultation have been taken on board. OC/LPD/13/01646 – 1.1.4 The National Planning Policy Framework (the Framework) sets out four tests that Local Plans must meet to be considered sound at Gladman Examination. In order to provide an appropriate basis on which to plan for the borough’s housing needs and to be found consistent with the Developments requirements of national planning policy, the emerging Local Plan will need to be tested at Examination to ensure that it has been prepared in accordance with the Duty to Cooperate, legal and procedural requirements and to assess whether it is sound. The four tests which the Local Plan must meet are as follows: - Positively prepared - Justified - Effective - Consistent with national policy 1.1.5 The Planning Inspectorate’s “Procedural Practice in the Examination of Local Plan” provides guidance to local authorities on the examination of local plans. It sets out that the Plan that is published under Regulation 19 is the Plan that the Council intends to submit to the Secretary of State under Regulation 22. The Council should satisfy itself that the document is sound prior to undertaking its Regulation 19 consultation. There does however remain an opportunity for the Council to address the fundamental issues that remain following this Regulation 19 consultation through the production of an addendum (including an updated sustainability appraisal where necessary). Any addendum would need to be the subject of a further round of public consultation by the Council prior to the submission of its Plan (together with any addendum) under Regulation 22. This approach can be effective in enabling an efficient examination timetable and can significantly reduce the likelihood of further changes needing to be put forward by the Council as main modifications during the examination. 1.1.6 Gladman requests that it is given the opportunity to discuss the significant objections to the Plan that are contained within these representations at the Examination in Public. OC/AGCN/13/01758 1. INTRODUCTION – Hallam Land 1.1 Pegasus Group are instructed by Hallam Land Management Ltd (HLM) to make representations to the ‘Fylde Local Plan to 2032: Publication Management Version’ consultation, which ran between 11th August and 22nd September 2016.