4 February 2019 Newsbrief 44 CLOUD Commentary on Evidence and Additional Information
In Newsbrief 43 we promised to provide a commentary on the evidence and additional information provided by Lancaster City Council. This is the material which the Council proposes as supportive of the Local Plan. Public consultation runs up to 15 February. Our assessment and comments on this new material is set out below. We will be submitting the response on behalf of CLOUD next week.
We know that CLOUD members have spent a vast amount of time over the last couple of years commenting on successive versions of the Local Plan. It was particularly galling to learn (as reported in Newsbrief 43) that the previous consultation in October 2018 had been suspended by the Planning Inspector as contrary to planning law and may yet prove to have been a waste of the time and effort we put into commenting on it. Nevertheless we would encourage all CLOUD supporters to respond to this latest consultation - if only briefly and to register the point that your previous objections to the Local Plan still stand.
In framing your response the following statement from government guidance on Local Plans https://www.gov.uk/guidance/plan-making#statutory-duty-and-the-role-of-plans
might be useful in informing your comment:
Authorities are expected to be mindful of the need to produce concise, visual evidence, written in plain English to help ensure that it is easily accessible to local communities, to avoid them becoming disengaged with the process.
Do you feel that this obligation was met in this set of consultations? Were you easily able to download documents especially if a tablet or phone user? If not you should say so in your comments.
Here is the link to the evidence and additional information on which Lancaster City Council is now consulting:
There are indeed many pages of evidence, but our reading so far has found nothing that changes the views we have already expressed on the soundness or otherwise of the Local Plan. However we are still working our way through the evidence and there may be valuable ‘nuggets’ we have yet to unearth! If we find evidence that needs challenging we will do so. We will follow this Newsbrief with our full response to the consultation.
The main topics are :
Transport assessments - These are very much interim assessments. They recognise that the absence at this stage of the Strategic Transport Model is a major limitation. These assessments take no account of the proposed Bus Rapid Transit scheme, nor the proposed reconfiguration of Junction 33 on the M6 (a crucial requirement for Bailrigg Garden Village), nor the city centre movement strategy (currently under preparation by Lancaster County Council).
Viability assessment - the stage 2 assessment states that Bailrigg Garden Village will be developed through a separate Area Action Plan and so there is no coverage of it here. This assessment concentrates on smaller scale developments (it defines ‘large’ as 150 houses or more) which are not on the scale of the garden village with its 3,500 houses. There is also an interesting comment in the assessment. Referring to the 13,000 to 14,000 new houses and 9,500 new jobs as envisaged in the Local Plan, it describes this as a ‘step change’ with ‘levels of growth not previously seen in the district’.
Infrastructure delivery - the Schedule here includes Junction 33, but at the lower end of the cost estimate range and with the qualification that ‘developers will need to ensure that the new development (ie Bailrigg Garden Village) connects with the public highway’.
Open spaces and playing pitches - The proposals here are certainly commendable, but there is nothing on Bailrigg Garden Village and nothing to change previous criticisms of the Local Plan. This report also makes recommendations for Community Infrastructure Levies and Section 106 to provide funds - but no indication that such funds will be forthcoming or other demands on developers such as BGV infrastructure.
Landscape reviews - check - does it cover BGV?
Identified sites assessments
Air Quality - gives the impression of being a preliminary report, this position statement is totally inadequate on its own.
Housing land monitoring report - overview of house building delivered 2003-18 and 5 year land supply.
Lancaster growth report - A report prepared by Hall Aitken lacks any reference to the exceptional job growth projected in the Local Plan for South Lancaster.
Strategic housing & employment land availability report - this is (or appears to be!) a largely technical report listing all land in Lancaster suitable for housing or employment. However it is only land included in the Local Plan which is scheduled for development (once the Plan is approved) so the key document is the Local Plan and not this report.
There is some good news in that the City Council issued summary guidance on these 2,000 pages on 17th January (do check your SPAM box as it may be there). It seems unfortunate that, whilst the evidence and additional information was published on 7th January, the summary was delayed by more than a week. Here is the link to the summary :
The date of 1st April 2019 for the start of the examination hearings into the Local Plan remains “provisional”. We will be asking when it is going to be confirmed.
For those who respond you can use the form supplied by the City Council, but you may find it easier to submit your comments by email or post. You don’t have to use the form.
Post: Planning and Housing Policy Team, Town Hall, Marine Road East, Morecambe LA4 5AF