August 2018 | LB | BIR.4073 LICHFIELD DISTRICT LOCAL PLAN ALLOCATIONS DOCUMENT MATTER 12 – ARE THERE ANY OTHER MATTERS OF SOUNDNESS WHICH THIS EXAMINATION SHOULD COVER? ON BEHALF OF DRAYTON MANOR PARK TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004 Pegasus Group 5 The Priory | Old London Road | Canwell | Sutton Coldfield | B75 5SH T 0121 308 9570 | F 0121 323 2215 | W www.pegasusgroup.co.uk Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester ©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited Drayton Manor Park Matter 12 CONTENTS: Page No: 1. INTRODUCTION 1 2. OTHER SOUNDNESS ISSUES – DRAYTION MANOR PARK 1 3. SUMMARY 5 August 2018 | LB| BIR.4073 Drayton Manor Park Matter 12 1. INTRODUCTION 1.1 This statement has been prepared by Pegasus Group on behalf of Drayton Manor Park who has land interests within Lichfield District in relation to Drayton Manor Park. This statement provides a response to question 12.2 and should be read in conjunction with representations submitted to the ‘Publication’ Site Allocations document [CD1-13] and the ‘Focused Changes’ Site Allocations Document [CD1- 11]. These representations can be provided if requested. 2. OTHER SOUNDNESS ISSUES – DRAYTON MANOR PARK 2.1 Drayton Manor Park, as the most popular tourist attraction in Lichfield District with around 1.2 million visitors per year, has, through previous representations, raised significant concerns, through representations, that the Local Plan Allocations (LPA) document fails to act as the intended ‘delivery vehicle’ for the Local Plan Strategy (LPS). Notably, it omits to replace Policy Emp.5 ‘Major Developed Sites in the Green Belt’ with a suitable alternative, in relation to Drayton Manor Park, that is in line with current national policy. This is considered in detail below. Q.12.2 Are there any soundness issues which this Examination should cover? 2.3 Appendix J of the Local Plan Strategy (LPS) [CD1-32] sets out which saved policies of the 1998 Local Plan were replaced by policies in the Local Plan Strategy and which were proposed to be replaced by the Local Plan Allocations document. Of the policies to be replaced, Appendix J includes saved Policy Emp.5: ‘Major Developed Sites in the Green Belt’, stating that it will be replaced by the Local Plan Allocations document. 2.4 The Council sets out the scope of the LPA [CD1-1-] at paragraph 1.3 and includes within this ‘A review of any remaining Local Plan (1998) Saved policies’ and at paragraph 1.4 it states that the primary purpose of the LPA is to assist with encouraging appropriate development in the District which will contribute to sustainable and economic growth. In addition, the scope of the LPA identified by the District Council also rightly recognises the need to consider Green Belt boundaries through the Local Plan Allocations document. This aligns with Core Policy 1 of the LPS [CD1-32] which states that: August 2018 | LB | BIR.4073 Drayton Manor Park Matter 12 “changes to Green Belt boundaries that do not have a fundamental impact on the overall strategy may be appropriate for all settlements within the Green Belt, with the precise boundaries of these changes being determined through the Local Plan Allocations document.” 2.5 However, despite paragraph 1.3 of the LPA stating that its scope is, in part, to consider changes to Green belt boundaries, the extent to which the LPA actually executes this is very limited. It is noted that paragraph 1.3 of the LPA includes within the consideration of Green belt boundaries, the integration of the developed area of the former St. Matthews hospital into the built-up area of Burntwood, with the LPA proposing to remove the site from the Green Belt via Policy B1: Burntwood Housing Allocations. Under the Lichfield District Local Plan 1998 (Saved Policies) [CD1-34] St. Matthews Hospital is identified as a ‘Major Developed Site in the Green Belt’ under Policy Emp.5, along with Drayton Manor Park. The LPA is, however, silent on Drayton Manor Park and thus, it is contended that the Local Plan Allocations document fails in fulfilling its identified scope, in that it does not properly consider changes to Green Belt boundaries to ensure delivery of the spatial strategy within the Plan period. 2.6 Further evidence in relation to establishing a suitable Green Belt boundary for Drayton Manor Park was submitted to the Council via a Landscape and Visual Statement, which can be provided if requested. This was appended to representations made to the ‘Focused Changes’ Site Allocations Document [CD1- 11]. It is also noted, that at the ‘Focused Changes’ consultation stage no assessment of Drayton Manor Park was included within any of the Green Belt Reports or Assessments undertaken by the Council, listed within the evidence base supporting the LPA. However, in light of the LPS, it is considered that there is no justification for the LPA not to consider amending the Green Belt boundary to ensure that Drayton Manor Park is not subject to the full weight of Green Belt policy moving forward. Therefore, it is contended that the LPS is not justified in this regard. 2.7 Contrary to Appendix J of the LPS [CD1-32], the submitted LPA [CD1-1-] does not propose to replace saved Policy Emp.5 with a suitable alternative that is in line with current national policy, but instead lists it within Appendix A as a policy to be deleted, with no explanation given. August 2018 | LB | BIR.4073 Drayton Manor Park Matter 12 2.8 As stated above, representations were made on behalf of Drayton Manor Park to the ‘Publication’ Site Allocations document [CD1-13] and the ‘Focused Changes’ Site Allocations Document [CD1-11]. It is considered that the Officer response to Drayton Manor Park’s representation to CD1-11 is totally inadequate and appears to have missed the points made. Contained within “Summary of Representations and Responses to Local Plan Allocations (Focused Changes Consultation)” [CD1-5] the Officer response to the representation (listed as FC256 within this document) states: “Core Policy 10 of the adopted Local Plan Strategy states that existing local and national tourist attractions including Drayton Manor Theme Park will be supported and promoted where they do not conflict with other Core Polices.” 2.9 Additionally, the wrong Core Policy has been quoted here, as Core Policy 9 of the LPS, and not Core Policy 10, refers to tourism within the District. 2.10 As the submitted LPA does not make any reference to Drayton Manor Park and as such, if the submitted LPA is adopted as it stands, deleting saved Policy Emp.5 with no credible alternative in its place, this would mean that the whole of Drayton Manor Park would become subject to the full weight of Green Belt policy as determined by the National Planning Policy Framework (NPPF) and Policy NR2 of the Local Plan Strategy. 2.11 The reality of this for Drayton Manor Park, would be an increased risk associated with bringing development proposals forward at the site, potentially affecting investment in the Park, with inevitable detrimental impacts on the Park’s long- term development and growth. This would have severe implications for the economy of Lichfield District, as currently Drayton Manor Park supports more than 400 full-time equivalent (FTE) jobs, generates more than £140million in visitor spend per annum and over £35million in economic output in Lichfield and the wider economies of Staffordshire and the West Midlands region. With planned investment at the Park, these figures could rise to 500 FTE jobs, £180million in visitor spend and £44.6million in economic output. Appended to representations to the ‘Focused Changes’ Site Allocations Document [CD1-11] were an Economic Benefits Report and a Vision Document which set out future plans for the Theme Park. These documents can be provided if requested. Conversely, the inclusion of positive policy provision for Drayton Manor Park within the LPA would encourage August 2018 | LB | BIR.4073 Drayton Manor Park Matter 12 sustainable economic growth in the area, and would therefore ensure consistency with national policy, namely paragraph 21 of the NPPF, in this regard. 2.12 This omission of any provision for Drayton Manor Park from the submitted LPA is therefore clearly contrary to the provisions of Core Policy 1: The Spatial Strategy of the LPS [CD1-32], which lists Drayton Manor Park amongst the District’s significant tourist assets and states that: “The District’s significant high quality natural and built environment and tourism assets will be protected and enhanced in their own right”. 2.13 Further patronage for Drayton Manor Park is given by the Council in Core Policy 9: Tourism of the LPS [CD1-32]; with commitment being given to the support and promotion of Drayton Manor Park, where there is no conflict with other Core Policies. However, this support is not carried through into the LPA, as the submitted LPA is completely silent with regard to Drayton Manor Theme Park. 2.14 This is in stark contrast to how other tourism assets are dealt with by the Council in the LPA, as for instance, the submitted LPA includes a specific policy on the Lichfield Canal (Policy IP2), Cannock Chase Area of Outstanding Natural Beauty (Policy NR10) and the National Forest (Policy NR11). 2.15 Previous representations on behalf of Drayton Manor Theme Park to the ‘Publication’ Site Allocations document [CD1-13] and the ‘Focused Changes’ Site Allocations Document [CD1-11] have expressed the need for the allocation of Drayton Manor Park and the inclusion of specific policy guidance protecting the sustainable growth and development of the Park from the full weight of Green Belt policy.