ALL 326 local planning authorities in England, councils like Stratford-on-Avon District, need a local plan. The core strategy is a component of that local plan. It contains all the local district wide policies that need to be considered when processing planning applications.
New development needs to satisfy local needs, helping to realise the hopes and ambitions of its communities and protect them from situations they fear. New homes and places to work should provide then with a healthy lifestyle, a pleasant place to live, good recreational facilities and above all the infrastructure that enhances their quality of life. The buzzword to describe this is ‘sustainable’.
The core strategy is the local policy framework to produce sustainable development. It needs to be compliant with higher level planning policy and guidance, currently the National Planning Policy Framework (NPPF).
A core strategy needs considerable preparation and:
Alongside this, when the NPPF was published on 27th March 2012, we learned that the district needs to have an identified supply of land, enough to last five years or more.
An explanation will be given why we cannot just get out a map, lock ourselves in a box one Friday afternoon and close the doors until the document is written. We have to follow detailed regulations. There are no prizes for getting it wrong as careless councils have discovered. Having followed the rules, everything has to be checked and declared sound by a government body known as the Planning Inspectorate, often called PIns. They are intolerant of mistakes and have a well-documented track record of holding up the aspirations of many councils.
Successive government policies have ensured that every crucial element of planning strategy is endorsed by a costly study. This evidence gathering takes time
Every time government policy, or the law changes, the local plan has to be updated to be considered compliant with national and, at times, regional policy. Revisions are made to the core strategy as it is developed. As the goalposts move, the councils themselves can look uncertain. The core strategy has to be developed in the public gaze, with consultation. We are not our own master when we should be leading the public debate.
So rigorous is the process that only 37 councils, out of 326, just 11 per cent have adopted a core strategy since March 2012 that is compliant with the latest government policy.
Other councils are not devoid of a policy base, but will rely on what are known as saved policies from previously adopted plans, where they are compliant with the NPPF.
The government passes laws saying what a council can and cannot do and also likes to influence their decision making. This creates a tension between government drive and local aspiration. We all face up to the extremes of conflicting targets set from above and the emotional resistance to change on the ground.
It could have been so different when the coalition government embraced localism and simplified national policy. Sadly, the NPPF has been implemented in a way that sets communities and their elected representatives apart. Threats to the environment create some of the biggest tensions. The NPPF can act as a ‘one-size fits all’ framework, fine in urban areas with loads of inbuilt infrastructure. Locally, it puts our precious heritage and open landscape under indiscriminate attack.
The referee in all this is the government’s own agency, the Planning Inspectorate. Not only does the government devise procedure, but they use PIns to be the arbiter of the issues that land on our plate. Heads they win, tails we lose.
We are a district that has plenty of land and a variety of communities. It is essential that we develop proper protection with a policy base that preserves that character of local communities and restricts them from being forced to expand beyond tolerable limits.
We need to ensure that there is a thorough assessment of the viability and sustainability of all planning proposals and applications. I have instructed officers to use our saved policies and exploit all the policy we can muster from the NPPF to resist unwelcome development.
What have we attempted to achieve?
I became leader of the district council in 2011 when new government policy, was becoming clear. Most of our local plan policies had been given an extended lease of life. Localism and neighbourhood planning provided an opportunity for a new focus.
The coalition government indicated that local councils would be the powerhouse behind planning policy when our regional spatial strategy (RSS) was withdrawn. With shifting sands, a second core strategy draft in 2010 was not going to satisfy the strategic needs of the district and be upwards compliant.
In 2011, we bit the bullet and refocused our planning policy with a new draft core strategy. I set up an advisory group to help produce a new core strategy based on revised aspirations:
Local plans need to identify sites for sustainable development. The list of approved sites is replenished periodically as it is used up. However, each time new sites are introduced, there is an elaborate process to assess their suitability, accompanied by consultation and inspection, and so new sites will normally be introduced into the local plan in batches.
When assessing potential sites to put into our local plan, NPPF paragraph 173 provides clear guidance. Each development site must be judged to be deliverable by assessing the commercial viability of each site to ensure that it will provide “competitive returns to a willing land owner and willing developer.” We have to rely on developers declaring their sites to include in the local plan, well ahead of any planning application. We cannot just draw lines on a map and say: “Job done.”
Since March 2012, we have been judged to have insufficient approved housing land. As a result, the government has deemed our housing policies to be out of date. This gives developers an opportunity to bypass paragraph 173 by applying for outline planning permission without the site being first included in the local plan. NPPF paragraph 186 then kicks in and we are told to look for solutions to be able to grant planning permission, rather than problems. If we cannot do all the necessary consultation and assessment in 13 weeks, there is the threat that our local decision making powers could be taken away. This is NOT the way to make quality decisions upon the sustainability of new development projects and simply adds to the tension between the council and the communities it represents.
A planning inspector has recently admitted that more time is spent at planning appeals on housing targets and land supply than any other topic. This is a bizarre state of affairs when the focus should be on the quality and suitability of development and recognising that local councils know best when assessing the location and quantity of any development.
I have written to our local MPs to seek their assistance to take steps to get NPPF paragraph 186 amended to give us an opportunity to defend unsustainable sites, especially heritage sites that once used up, cannot be replaced.
On the home straight? Not quite.
We plan to publish our latest core strategy by Easter, but this last year, the council has been told:
We have worked hard to ensure that the plans do not delay the adoption of our core strategy. Once submitted, we have to wait for them to declare the plan sound. This typically takes about six months, but there are examples of much delay:
The only prize for rushing things, as several councils have discovered is delay, upon delay and expense followed by more expense. We cannot afford to take that risk.
The new coalition government in May 2010 gave the council an opportunity to make positive changes. There was a new spirit of localism and plans were underway to revoke the West Midlands RSS. The NPPF was introduced to replace most of the PPGs and PPSs
It is easy to apportion blame on the local administration for what has since happened. If you are tempted along this route, please recall that the coalition government has most of the tricks up their sleeve and two political parties sign off Government policy. Your council has recognised that it cannot take the view that King Canute did of the tide.
Your council, led by me, has introduced a positive new direction for future planning policy. History will perhaps prove that we got a lot right. Remember the days when most new housing was directed to Stratford-upon-Avon town. Your council has spent time changing that, giving choices for other places to grow while preserving their character?
Your council has done its best to produce studies that would realistically assess our housing needs and we have a strong evidence base to resist overdevelopment. Your council has researched and strengthened our landscape protection policies. In the main, you like our emerging core strategy, though many builders do not. With emerging neighbourhood plans, on my watch, I’m with you.
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