(Information report of the Joint Policy Unit Manager enclosed.)
The Joint Policy Unit Manager presented a report, which summarised the review of the emerging South East Lincolnshire Local Plan carried out by consultants (POS Enterprises) appointed by the Planning Advisory Service (PAS). The consultants’ draft report on the review was attached as Appendix A.
During debate, the main points made by Members were:
· It was essential to receive responses to consultation with neighbouring authorities in order to satisfy the ‘duty to cooperate’ with relevant public bodies.
· Plan preparation to date lacked sufficient evidence and might not have a firm enough link between housing and economic development and how economic development could be delivered.
· The plan’s evidence base had to be robust and defendable; it would prove challenging to prepare a credible ‘Plan B’ in respect of housing provision.
· The review stated that there should be consultation with the Highways Agency, yet it was considered that the agency had ‘abandoned’ Lincolnshire and no longer had any input.
· In response to the concern about the nature of “plan-wide viability”, Officers commented that a response had been sent to the report author to say “we have commissioned consultants to undertake a whole plan viability assessment. A draft report was produced last November but further work is needed on land values”. This point had been made at the previous workshop, but the review’s report author had missed it.
· The plan had to be robust enough not to concede housing requirements to neighbouring authorities to the disadvantage of South East Lincolnshire.
· One Member considered that South Holland was totally dependent on one developer and that, if neighbouring districts were to be considered as locations for meeting the area’s housing needs, it may not deliver,
· Public transport provision in the fens was very poor and this point appeared not to have been properly appreciated in the report.
· The ‘Annual Review’ would enable identification of whether the main urban areas were unlikely to deliver their proposed levels of housing development and it could suggest that other settlements make a more significant contribution to housing delivery if this were to be the case.
· Basing housing provision on migration-led demographic projections and not historical building rates might result in inappropriate housing for the area’s long-term needs; Eastern Europeans were now settling in the area instead of returning home so it was even more important to have a better understanding of the area’s housing needs to create the right type in the right location.
· If housing growth was overestimated, South East Lincolnshire could end up giving housing stock to other areas, and create issues such as people living in Peterborough but working in South East Lincolnshire.
· Holbeach had a substantial housing development planned, but it depended on road improvements that had not yet come forward. Councillor Davie commented that this was on the Greater Lincolnshire Local Enterprise Partnership’s (LEP’s) agenda.
· There was doubt about the viability of a Community Infrastructure Levy (CIL) and how it could be delivered. In respect of South Holland District, it was considered that if a CIL was viable and deliverable, but meant the affordable housing requirement had to be watered down, then that would be acceptable.
· Housing was the most politically-sensitive issue and the PAS report’s comments on satisfying the duty to cooperate in respect of the location of housing raised a concern that this may undermine the Councils’ position.
· There was not much understanding of flood risk in the PAS report; numbers were not being capped in the plan for the sake of it, but because of knowledge of the issues involved. This had to be made clear or otherwise work might have to be revisited because of lack of understanding.
· There was a need to address the skewed age demographic caused by net inward migration and the Councils needed to consider what effect this would have on such matters as health-service provision in the area (given its funding being dependent on the numbers registered at GP surgeries).
Officers commented that there were a number of people to co-operate with, not purely in relation to housing. The PAS report was fair to make the point about consultation with neighbouring authorities; this work was not complete as the results of the consultation had been awaited. However, it was in hand and a number of meetings had already been held. There was a flood risk /housing provision blind-spot in the report; however, by the time of the examination, the Inspector would have a broad understanding of all of these issues. Local Plans were being challenged for not being expansive enough; flood risk was key and needed strengthening.
Councillor Davie commented that the Government’s agenda was ‘growth’ and the plan’s housing numbers, which were ambitious, had to be linked to jobs and infrastructure. The LEP Board had accepted four road schemes put forward by the Lincolnshire Strategic Transport Board for consideration for funding support, one of which was the Spalding Western Relief Road. The LEP would distribute significant amounts of funding in accordance with its strategic priorities for economic growth, but projects requiring funding had to be well-evidenced. Water management, which needed sizeable investment, was one of four strategic priorities in the LEP Growth Strategy.
Members made the following points with respect to the LEP:
· Information was needed on the LEP’s direction and aims, and what could be gained from it; this could be the subject of a separate report.
· The LEP was “Lincoln-centric” and needed to extend its area of influence. It only had one District Council representative. Skegness would get a relief road but not Boston, despite efforts made to get one.
· The LEP looked at Lincolnshire as a unit rather than individual areas.
· It was surprising that the Spalding Western Relief Road was a LEP project rather than a County Council project. The LEP had been poorly publicised and this should be remedied, as it remained a mystery to Councillors at ground level.
Officers commented that the LEP was in its infancy and would grow. LEP representatives had met recently with South Holland District Council officers to discuss local aspirations for economic development.
Councillor Davie commented that it was unfair to say the LEP was centred on Lincoln. Of the four road schemes receiving its support, two were in Grantham and the other two were in Spalding and Skegness. He would be focusing on building links between Lincoln, other growth areas and the coast. LEPs also had a duty to co-operate with each other.
Members made the following points concerning the ‘agri-food’ business:
· It was hoped to put money into the agri-food business. In Boston Borough, much of it was located off the A52, almost into East Lindsey, which meant it was isolated and could not easily link with similar businesses, e.g. in South Holland; there was a ‘gap in the middle’.
· Agri-food businesses and other industries should be consulted. It would be useful to know what the plans of agri-food businesses were, particularly in respect of their labour requirements.
· A Boston Distributor Road was needed to open up the transport of produce to the east.
Councillor Davie commented that future growth in the agri-food sector was needed and that the LEP had laid down the challenge. An action plan was needed and its preparation would be commenced; Members should await developments. It was correct that they could not leave a gap; it was a barrier to growth.
In response to questions, officers confirmed that ‘all relevant matters’ in paragraph 17 was a catch-all phrase and that Regulation 22(1)(c), referred to in paragraph 18, related to the process and outcomes of community involvement..
During Members’ debate of Neighbourhood Development Plans (NDPs), there was some concern that the lack of NDPs might result in gaps in delivering the Local Plan strategy. Most parish councillors were wary of NDPs because few would be able to do what was expected of them. The lack of NDPs had to be defended; based on their experience of preparing village plans, parish councils had few resources and little expertise to undertake this new type of plan. However, Members would work with those that wished to develop them, but thought that creation of an officer team dedicated to such work might prove to be an ineffective use of resources.
Officers commented that it was not thought that any NDPs would come forward as parish councils had, to date, shown no interest in them, but the mechanism existed if any did wish to do so. An alteration to the Local Development Scheme, setting out how any NDPs would relate to the Local Plan and how the Joint Committee would support NDP preparation, was required. The reference to “non-land use” in the review could be the management of existing facilities and how they were organised. NDPs would have to conform with the Local Plan strategy. Officers had responded to the report author advising him that there had been no real interest shown in preparing NDPs.
Members concluded that the review lacked a full understanding of the area, but also contained some serious warnings that should be heeded. The Steering Group would have been the correct forum to consider the review. Whilst it was considered that the strengths of the work on Local Plan preparation to date were a given, the review had been helpful in confirming the good progress that had been made and that there was no fundamental problem in what had been done so far.
The Environment Agency (EA) representative agreed with a comment that the organisation was now more transparent. It had some concerns about the comments in the review relating to flood-risk matters but was hopeful that all parties would agree a way forward. The EA was putting £90m into the flood barrier for Boston; that was its commitment to sustaining Boston and its future growth.
Councillor Davie commented that the review had revealed many strengths in the work undertaken to date and the identified concerns should be addressed in good time before the examination. The LEP would be a very important consideration. If Members did not feel informed about the LEP it could be that their representative on it was not adequately reporting back to them. The LEP Growth Plan would be going to every authority for consultation in October.
Officers commented that the meeting had inevitably focused on the risks not the strengths raised in the review, but this was purely a timely health check. Housing was key to both District Councils and the Spalding Western Relief Road was also important. They had to ensure ‘Plan A’ was delivered. They would need to convince the Inspector that they could successfully bring forward proposals for major development and provide evidence of this. The LEP was a key consideration, but it was still in its infancy and was not properly understood. If they addressed the points raised in the review positively, the Local Plan would be in a good place.
Many authorities had left this type of review until after the preparation of the ‘submission draft’ document. In South East Lincolnshire’s case, it was hoped that by identifying key plan-preparation issues at the ‘preferred options’ stage, sufficient time would be created to address such issues before the preparation of the submission draft.
Representatives of local businesses had been interviewed and an Employment Land Review had been undertaken. Work with the County Council on the Spalding Transport Strategy, to create a context for the Spalding Relief Road, had commenced and there would be an opportunity to refresh Boston’s Transport Strategy in the future.
It was then requested that the response to the PAS report be submitted to the Steering Group in due course to ensure that the issues raised had been addressed.
That the report be noted.