Local Plan Soundness Self-Assessment Checklist... · 2 2. Local Plan Soundness Self-Assessment Checklist 2.1 This checklist has been adapted from that which was prepared by AMEC and

Northumberland Local Plan

Local Plan Soundness Self-Assessment Checklist

May 2019

1

1. Introduction

1.1 The Northumberland Local Plan has been formally submitted to the Secretary of State. lt will now be formally examined by an independent Inspector to assess whether the Plan has been prepared in accordance with the legal and procedural requirements as set out by the Town and Country Planning (Local Planning) (England) Regulations 2012 ("2012 Regulations") and whether the Plan is "sound".

1.2 Examinations into Plans such as this can be lengthy and complex, especially for those who are unaccustomed to such processes. Regulations and good practice require the Council to complete and submit a range of statements as part of the Examination 'bundle' and invariably, participants at Examinations will refer to a myriad of their own documents to support their own viewpoints. lt will be for the independent Planning Inspector to consider all of the material prior to reaching a conclusion on the Plan's soundness and compliance with the legal requirements.

1.3 To facilitate the examination process and for the benefit of the Planning Inspector and other Examination participants, local planning authorities are encouraged to submit a Soundness Self-Assessment Checklist and guidance issued by the Planning Advisory Service (updated March 2013 by PAS, and May 2019 by Northumberland County Council in respect of the NPPF 2019).

1.4 This completed checklist provides succinct reference points which demonstrates how the Local Plan is sound. lt further signposts the reader to a range of other supporting evidence that has been prepared and the processes undertaken to get the Plan to this point.

1.5 The Council reserves the right to bring forward additional information through the examination process.

1.6 Table 1 summarises the key stages in preparing the Local Plan to the point of submission. It will be referred to within the following Checklist. Unless otherwise stated, references to chapters, policies and paragraphs will be drawn from the Northumberland Local Plan Publication Draft Plan (Regulation 19).

Table 1 : Key Stages in preparing the Northumberland Local Plan

Northumberland Local Plan Publication Date

Spring 2018 Consultation (Interactive Spatial Survey) March 2018

Local Plan: Draft Plan for Regulation 18 Consultation July 2018

Local Plan: Publication Draft Plan (Regulation 19) January 2019

Local Plan: Publication Draft Plan (Regulation 19), Proposed Minor Modifications

May 2019

2

2. Local Plan Soundness Self-Assessment Checklist

2.1 This checklist has been adapted from that which was prepared by AMEC and URS on behalf of the Planning Advisory Service to update the tool against the NPPF 2019.

2.2 In summary – the key requirements of plan preparation are:

Has the plan been positively prepared i.e. based on a strategy which seeks to meet objectively assessed requirements informed by agreements with other authorities?

Is the plan justified?

Is it based on robust and credible evidence?

Is it an appropriate strategy when considered against the alternatives?

Is the document effective?

Is it deliverable?

Is it flexible?

Will it be able to be monitored?

Is it consistent with national policy?

The Tests of Soundness at Examination 2.3 The starting point for the examination is the assumption that the Council has submitted what it considers to be a sound plan. Those seeking changes

should demonstrate why the plan is unsound by reference to one or more of the soundness criteria.

2.4 The tests of soundness are set out in the National Planning Policy Framework (NPPF) (para 35): “Local Plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound.” Plans are ‘sound’ if they are:

1. Positively Prepared: providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development. This means that the Development Plan Document (DPD) should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development. The NPPF, together with the Marine Policy Statement (MPS) set out principles through which the Government expects sustainable development can be achieved.

2. Justified: an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence This means that the DPD should be based on a robust and credible evidence base involving:

3

Research/fact finding: the choices made in the plan are backed up by facts.

Evidence of participation of the local community and others having a stake in the area; and

The DPD should also provide an appropriate strategy when considered against reasonable alternatives. These alternatives should be realistic and subject to sustainability appraisal.

The DPD should show how the policies and proposals help to ensure that the social, environmental, economic and resource use objectives of sustainability will be achieved.

3. Effective: deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground This means the DPD should be deliverable, requiring evidence of:

Sound infrastructure delivery planning;

Having no regulatory or national planning barriers to delivery;

Delivery partners who are signed up to it; and

Coherence with the strategies of neighbouring authorities, including neighbouring marine planning authorities.

The DPD should be flexible and able to be monitored.

The DPD should indicate who is to be responsible for making sure that the policies and proposals happen and when they will happen. The plan should be flexible to deal with changing circumstances, which may involve minor changes to respond to the outcome of the monitoring process or more significant changes to respond to problems such as lack of funding for major infrastructure proposals. Although it is important that policies are flexible, the DPD should make clear that major changes may require a formal review including public consultation. Any measures which the Council has included to make sure that targets are met should be clearly linked to an Authority Monitoring Report.

4. Consistent with national policy: enabling the delivery of sustainable development in accordance with the policies in the NPPF. The NPPF is considered to be the government’s explanation of what sustainable development means for planning policy therefore compliance with the NPPF is key unless a locally justified departure is clearly evidenced.

2.5 The following table sets out the requirements associated with these four tests of soundness. Suggestions for evidence which could be used to support

these requirements are set out, although these have to be viewed in the context of the plan being prepared. Please don’t assume that you have got to provide all of these, they are just suggestions of what could be relevant.

2.6 In addition, the Legal Compliance checklist (a separate document, see www.pas.gov.uk) should be completed to ensure that this aspect is covered. 2.7 The Duty to Co-operate will also be assessed as part of the examination process.

http://www.pas.gov.uk/

4

Soundness Test and Key Requirements Possible Evidence Evidence Provided

Positively Prepared: providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.

5


Vision and Objectives

Has the LPA clearly identified what the issues are that the DPD is seeking to address? Have priorities been set so that it is clear what the DPD is seeking to achieve?

Does the DPD contain clear vision(s) and objectives which are specific to the place? Is there a direct relationship between the identified issues, the vision(s) and the objectives?

Is it clear how the policies will meet the objectives? Are there any obvious gaps in the policies, having regard to the objectives of the DPD?

Have reasonable alternatives to the quantum of development and overall spatial strategy been considered?

Are the policies internally consistent?

Are there realistic timescales related to the objectives?

Does the DPD explain how its key policy objectives will be achieved?

Sections of the DPD and other documents which set out (where applicable) the vision, strategic objectives, key outcomes expected, spatial portrait and issues to be addressed.

Relevant sections of the DPD which explain how policies derive from the objectives and are designed to meet them.

The strategic objectives of the DPD, and the commentary in the DPD of how they derive from the spatial portrait and vision, and how the objectives are consistent with one another.

Sections of the DPD which address delivery, the means of delivery and the timescales for key developments through evidenced infrastructure delivery planning.

Confirmation from the relevant agencies that they support the objectives and the identified means of delivery.

Information in the local development scheme, or provided separately, about the scope and content (actual and intended) of each DPD showing how they combine to provide a coherent policy structure.

Chapter 2 “Spatial Portrait” sets out the high level thematic issues and challenges with respect to the Local Plan (pages 13-33). The chapter also identifies the more specific issues and challenges by Delivery Area (paragraphs 2.41 – 2.88). These issues are summarised at page 33 paragraph 2.89.

The vision and objectives for Northumberland for 2036 are set out in Chapter 3 “Spatial Vision, objectives and outcomes” (pages 34-42). This also explains in further detail how the vision and each of the eight objectives will be achieved and identifies key outcomes for each objective.

The Strategic Objectives (refer diagram page 35) are the guiding principles for delivering the plan vision. There is a direct relationship between the identified issues, the vision, the objectives and key outcomes. For example issues page 33:

Improve the quality of jobs and skills to attract new businesses in high value sectors, improve economic activity in the south of the county and improve access to jobs in rural areas. (Paragraph 2.89 bullet 1)

Ensure that the County’s many natural and built heritage assets are carefully protected, enhanced or managed to ensure that their vulnerability to development and human activity is minimised. (Paragraph 2.89 bullet 5)

Relate directly to Local Plan Objectives:

Economy & Jobs:

6


To grow and diversify the Northumberland economy by making it an attractive and competitive place to start, grow and invest in a broad range of businesses, attracting more and better jobs, and attracting and retaining working age people.

To drive improvements in education , training and skills to enhance the employability of Northumberland residents.

Environment:

To conserve and enhance Northumberland’s distinctive and valued natural, historic, water and built environments, ensuring that these assets continue to be experienced and valued by residents and visitors to the County and protected from inappropriate development.

These in turn relate directly to the outcomes of the plan. For example:

Economy and Jobs:

Land and buildings will have been identified in sustainable locations to meet demand, allow for choice and to provide for an additional 15,000 new jobs between 2016 and 2036, (paragraph 3.5 bullet 1)

A diverse range of interconnected sites around the Blyth Estuary will have been provided and will have supported growth of strategically important

7


sectors. (paragraph 3.5 bullet 4)

Environment:

Wherever possible, development will have been directed away from our most sensitive and valuable natural assets, habitats and species, towards less sensitive locations and no net loss to biodiversity will have been experienced (paragraph 3.9 bullet 2)

Tranquillity and Northumberland’s dark skies will have been protected (paragraph 3.9 bullet 6)

It is clear how the policies will meet the objectives and achieve the outcomes sought since they address these matters explicitly in many instances for example:

Economy and Jobs:

Paragraph 4.16 explains the strategy in brief, and Policies “STP1 Spatial strategy”, “STP3 Principles of sustainable development”, “ECN2 Blyth Estuary Strategic Employment Area”, “ECN3 West Hartford Prestige Employment Area”, “ECN4 Round 2 Enterprise Zones” address the objectives and seek to achieve the outcomes cited above.

Environment:

Policies : “STP1 Spatial Strategy”, “STP3 Principles of sustainable development”, “STP6 Green infrastructure”, “ENV 1 Approaches to assessing the impact of development on the natural, historic and built environment”, “ENV 2 Biodiversity and

8


geodiversity” and Policy “ENV 4 Tranquillity, dark skies and a sense of rurality” address the objectives and seek to achieve the outcomes cited above.

The package of policies will contribute to achieving the Vision, Objectives and Key Outcomes. The approach is comprehensive and addresses the issues identified. The Vision, Objectives and Policies within the Local Plan are therefore internally consistent. For each stage of the Local Plan, the sustainability appraisal has considered the cumulative impacts of the policies and objectives including how they relate to each other.

Reasonable alternatives to the quantum of development and overall spatial strategy have been aired, tested, and resolved during production of the Local Plan at key stages. The “Growth Strategy Technical Paper” December 2018 and “Spatial Strategy Technical Paper “ December 2018 explain this clearly. These options are tracked through the Sustainability Appraisal documents. In particular Section 5.3 of the “Northumberland Draft Local Plan Draft Plan for Regulation 18 Consultation Sustainability Appraisal Report” (pp122-132), and Section 5.3 of the “Northumberland Local Plan: Publication Draft Regulation 19 Sustainability Appraisal Report” (pp132-143).

Evidence supporting the Local Plan sets out the range of options for the overall quantum and distribution of new housing and employment growth that were examined to inform the preferred quantum and spatial distribution of development. All evidence was made available to view in tandem with the respective consultations. This is considered in more detail under

9


the ‘Justification’ test below.

The timescales related to the objectives of the plan span twenty years. This is a realistic overall time period to be able to assess impact. The Monitoring Framework details the information that will be monitored through the Council’s Authority Monitoring Report. This establishes the criteria that the Council will use to undertake the required five year review of policies, and trigger earlier review if necessary. With specific regard to housing the SHLAA is updated annually and is based on information from land owners and developers. The position regarding employment land take up and availability is also monitored annually. The housing trajectory is found at page 319 and 320 of the Local Plan.

Chapter 4 ‘Delivering the Vision for Northumberland’ explains the manner in which the vision will be delivered.

Chapter 14 ‘Infrastructure and Delivery’ (page 286 onwards) also deals with delivery and explains how infrastructure should be delivered in the County. This is informed by and in turn informs the Infrastructure Delivery Plan which sets out the implementation and delivery mechanisms and key agencies and partners involved. There are no critical infrastructure requirements required to deliver the plan proposals although there are infrastructure pressures. The IDP is a live document that will continue to be updated as new information emerges.

The presumption in favour of sustainable development (NPPF para 11 )

Plans and decisions need to take local

An evidence base which establishes the development needs of the plan area (see Justified below, that the needs of the wider area have been

The gathering of evidence has been an open process in terms of exploring all opportunities to achieve the most sustainable development approaches possible.

10


circumstances into account, so that they respond to the different opportunities for achieving sustainable development in different areas.

Local Plans should positively seek opportunities to meet development needs, with sufficient flexibility to adapt to rapid change.

Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless

- the application of policies within the NPPF that protect assets of particular importance provide a strong reason for restricting the overall scale, type or distribution of development in the plan area; or

- any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

taken into account and includes a flexible approach to delivery (see ‘Section 3 Effective’, below).

An audit trail showing how and why the quantum of development, preferred overall strategy and plan area distribution of development were arrived at.

Evidence of responding to opportunities for achieving sustainable development in different areas (for example, the marine area)

This has included inviting public and community representative organisations, interest groups, landowners, developers and individuals to suggest opportunities through processes such as the SHLAA, Employment Land Review and Calls for Sites. The Council has worked with partner organisations who have an interest in the environmental conservation, the local community and the economy to ensure the most sustainable solutions from the opportunities available.

The Council has ensured this evidence remains up to date. This evidence has established the development needs for the County and has informed the development of the strategy as well as the detailed policies, including site allocations and proposed Green Belt alterations.

The “Growth Strategy Technical Paper” December 2018 and the “Spatial Strategy Technical Paper” December 2018 both explain how the growth and spatial strategies were developed. During the production of the withdrawn Core Strategy and this Local Plan, each of Northumberland’s main towns and service centres were examined to consider their potential to accommodate the level of development proposed, and the capacity of smaller settlements and rural areas was also examined to accommodate a level of development.

Sustainability appraisals have been undertaken and used alongside the evidence base and consultation responses to support the options chosen for detailed policies and site allocations and Green Belt alterations as well as the alternative options.

11


Policy “STP1 Spatial Strategy (Strategic Policy)” explains how the plan will deliver sustainable development across Northumberland. Policy “STP2 Presumption in Favour of Sustainable Development (Strategic Policy)” and “STP3 Principles of Sustainable development (Strategic Policy)” set out the principles that will be applied to the assessment of development proposals to deliver sustainable development and sustain the vitality of local communities across Northumberland.

The start point for the assessment of housing need is the governments Standard Methodology, however, the Council proposes a significant uplift in this regard and this is justified by the evidence base. The “Housing and Economic Growth Options Findings Report” (June 2018) examines alternative economic growth scenarios and the corresponding levels of housing that would be required to support the growth, thus identifying the housing needs. The Sustainability Appraisal explains the options considered and tested.

The “Northumberland Strategic Housing Market Assessment” 2015 and partial update June 2018 set out the detailed needs of different groups in the County in respect of housing such as those of elderly persons, those seeking custom and self build housing and needs for affordable housing. The “Housing Distribution Technical Paper” (December 2018) explains the choices made in the distribution of housing development in the County and that this reflects sustainable patterns of development.

The “Northumberland Gypsy and Traveller and

12


Travelling Showpeople Accommodation Assessment” (October 2015 December 2018), identifies the needs for these groups.

Needs for employment development are identified in The “Housing and Economic Growth Options Findings Report” (2018) and adjusted as a result of a great deal of fine grained analysis contained within the following documentation: “Employment Land and Premises Demand Study” 2015 and selected data update 2019, Employment Land monitoring undertaken by the County Council included in reports such as the “Employment Sites Schedule 2016/17” March 2018 and analysis reports. The need for employment land is identified as 40 ha over the plan period. The employment provision is set out in summary in paragraph 5.12. This exceeds the overall need identified for the plan period and is well justified by the evidence in respect of local market demand.

The housing requirements are set out in Policy “HOU 2 Provision of new residential development (Strategic Policy)”, whilst affordable housing need is set out in paragraph 7.35 for the 5 year period 2017-22. Need for Travellers Accommodation is set out in Policy “HOU 12 Provision for Gypsy, Roma and Traveller Communities”.

The “Regulation 22 Consultation statement” provides details of the consultation and co operation that has influenced the development strategy. This includes highlighting selective engagement with key partners and is supported by the Duty to Co-operate Statement of Common Ground and Statement of Compliance.

The audit trail demonstrating the process of

13


formulation of the preferred strategy through the Regulation 18 consultation and leading to the conclusions on the spatial development strategy in the Regulation 19 Local Plan is documented through the sustainability appraisal reports and technical papers.

The Local Plan allocates sufficient land to meet needs identified. The audit trail for site selection is found in the following documentation:

“Housing Site Selection and Appraisal Technical Paper” 2018 and the “Northumberland Strategic Housing Land Availability Assessment 2018-2036 including Five Year Housing Land Supply of Deliverable Sites 2018 – 2023”.

“Employment Land Site Option Appraisal for Selected Towns” July 2018, “Employment Land: Strategy Considerations and Assessment of Sites Technical Paper” December 2018.

“Aggregate Minerals Allocations Selection and Appraisals Technical Paper” December 2018.

Policies in Local Plans should follow the approach of the presumption in favour of sustainable development so that it is clear that development which is sustainable can be approved without delay. All plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally.

A policy or policies which reflect the principles of the presumption in favour of sustainable development (see model policy at www.planningportal.gov.uk)

Policy “STP1 Spatial strategy (Strategic Policy)” explains how the plan will deliver sustainable development across Northumberland. Policy “STP2 Presumption in favour of sustainable development (Strategic Policy)” is in line with the model policy. Policy “STP3 Principles of sustainable development (Strategic Policy)” set out the principles that will be applied to the assessment of development proposals to delivery sustainable development and sustain the vitality of local communities across Northumberland.

http://www.planningportal.gov.uk/

14


Efforts have been made to ensure that policies are positively worded and encourage sustainable development subject to certain criteria rather than discouraging development unless criteria are met.

Objectively assessed needs

The economic, social and environmental needs of the authority area addressed and clearly presented in a fashion which makes effective use of land and specifically promotes mixed use development, and take account of cross-boundary and strategic issues.

Note: Meeting these needs should be subject to the caveats specified in Paragraph 11 of the NPPF (see above).

Objectively assessed need is informed by agreements with other authorities

Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy, in particular, where additional infrastructure is necessary (26)

Background evidence papers demonstrating requirements based on employment projections and community needs. Standard Methodology for Local Housing Need used as a minimum start point for assessing housing requirement.

Technical papers demonstrating how the aspirations and objectives of the DPD are related to the evidence, and how these are to be met, including from consultation and associated with the Duty to Co-operate particularly in respect of meeting development needs.

The Local Plan is supported by a robust and proportionate body of evidence which has been available for public scrutiny. The Council has ensured this evidence remains up to date. This evidence has established the development needs of Northumberland within the context of a strategy that seeks ambitious growth to counteract the negative impacts of a ‘business as usual’ approach, and population trends.

The “Growth Strategy Technical paper” (2018) explains how development needs were established through plan making. This has been informed by a wide range of evidence including the studies and technical papers cited above in The presumption in favour of sustainable development (NPPF paras 11) section (please refer).

Examples of background papers demonstrating the use of evidence in respect of needs include the “Growth Strategy Technical Paper” 2018, “Joint Local Aggregates Assessment for County Durham, Northumberland and Tyne and Wear” 2018, “Gypsy Traveller and Travelling Show People Accommodation Assessment” update 2018. The promotion of efficient use of land and mixed use development is evidence in policy including Policy “STP 3 Principles of Sustainable Development”, Policy

15


“ECN 11 Employment uses in built up areas and home working”, Policy “TC3 Maintaining and enhancing the role of centres (Strategic Policy)”, Policy “HOU 1 Making the best use of existing buildings (Strategic Policy)”, and Policy “HOU 2 Provision of new residential development (Strategic Policy)”.

The Duty to Co-operate Statement of Common Ground and Statement of Compliance explains how the Council has worked and continues to work effectively with neighbouring authorities. This includes a memorandum of understanding regarding the accommodation of housing and employment needs.

NPPF Principles: Delivering sustainable development

Delivering a sufficient supply of homes para 59-79

A sufficient amount and variety of land can come forward where it is needed and the standard method for assessing the number of homes required has been used as a minimum unless exception circumstances justify an alternative approach. (59 - 60)

Any needs that cannot be met within neighbouring authorities has been taken into account in establishing the amount of housing to be planned for. (60)

Evidence for housing provision based on up to date, objectively assessed needs.

As noted above the start point for the assessment of housing need was the governments Standard Methodology, however, the Council proposes a significant uplift in this regard and this is justified by the evidence base. The “Housing and Economic Growth Options Findings Report” (June 2018) examines alternative economic growth scenarios and the corresponding levels of housing that would be required to support the growth, thus identifying the housing needs. The “Growth Strategy Technical Paper” 2018 explains how the evidence informed this strategy.

Policy HOU 2 sets out the scale of provision in the minimum housing requirement for the plan period at

16


17,700 net additional dwellings. There are a significant level of existing commitments in the County coupled with high levels of recent delivery of housing. Table 7.2 page 128 of the Local Plan demonstrates that the level of commitments and completions outstrips the minimum requirement. However, a number of the County’s Main Towns, Service Centres and Service Villages have little committed development and net additional dwellings are required to meet future needs of these communities, help balance the housing market and supply specific needs such as those of the older population. The approach also allows for flexibility in supply to address any lapsed permissions, although lapse rates are low.

The distribution of proposed housing in respect of localities is identified in Policy “HOU 4 Housing development site allocations”. This sits within the spatial strategy and is explained in the “Spatial Strategy Technical Paper” 2018. The “Housing Distribution Technical Paper” (December 2018) explains the choices made in the distribution of housing development in the County and that this reflects sustainable patterns of development.

It has not been necessary to provide for neighbouring authorities housing needs although Durham County asked NCC if it could accommodate some need in the south of Northumberland. Given Green Belt constraints here Durham County has revised its Green Belt in the publication local plan.

The size type and tenure of housing needed for different groups has been assessed and is reflected in policies (including for those wishing

SHMA

Identification of the size, type, tenure and range of housing) required in particular locations,

The “Northumberland Strategic Housing Market Assessment” 2015 and partial update June 2018 set out the detailed needs of different groups in the

17


to rent homes) (61)

reflecting local demand.

Evidence and policy on planning for a mix of housing includes but is not limited to those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their homes (61)

County in respect of housing such as those of elderly persons, those seeking custom and self build housing and needs for affordable housing. The “Northumberland Gypsy and Traveller and Travelling Showpeople Accommodation Assessment” (October 2015, update December 2018), identifies the needs for these groups.

Policy HOU 5 deals with housing types and mix and indicates that development proposals will be considered in relation to how well they meet the needs identified in up to date SHMA and local needs assessments. The range of needs including that for community led housing and self and custom build housing are included in this policy.

The approach to housing for older and vulnerable people is set out in Policy HOU 11 which supports a range of housing in accessible locations and provision for Gypsy, Roma, and Traveller communities is made by Policy HOU 12 in relation to the most up to date GTAA. It also provides criteria against which proposals will be assessed.

Where need for affordable housing is identified the following matters have been addressed:,

Other than in designated rural areas affordable housing is not sought for non major development (63)

10% of the affordable homes are affordable home ownership products subject to exemptions at paragraph 64

Policy on affordable housing and consideration for the need for on-site provision or if off-site provision or financial contributions are sought, where these can these be justified and to what extent do they contribute to the objective of creating mixed and balanced communities. (62)

The latest SHMA (2018) identifies net affordable housing need as the equivalent of 151 dwellings per annum 2017 – 22, equivalent to 17% of the County’s overall annual requirement of 885 dpa.

Affordable housing policy in the plan accounts for the variation in the viability of development across the County and applies a requirement of between 10% and 30% depending upon the location of the site in Policy HOU 6. Tenure split is applied to these requirements in line with available evidence and this addresses the NPPF requirement regarding 10% of

18


affordable housing products. The Council expects that the primary form of affordable home ownership will continue to be discounted market sale.

In addition, alternative off site provision and financial contributions in lieu are considered only where clearly justified.

Within the Northumberland Coast Area of Outstanding Natural Beauty the 5 unit threshold will apply to affordable housing requirements.

Neighbourhood Plan areas have an identified housing requirement figure (65)

Evidence of Policy for Neighbourhood Plan areas Policy HOU 3 identifies the housing requirements for neighbourhood plan areas. These are based on the spatial strategy, future sustainability of communities, and the scale of commitments in each area.

Identify and maintain a rolling supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements; this should include an additional buffer of 5% , 10% or 20% (moved forward from later in the plan period) to ensure choice and competition in the market for land. 10% buffer is used where an annual position statement is used, 20% buffer applies where there has been significant under delivery of housing over the previous three years (73)

Identification of:

a) five years or more supply of specific deliverable sites; plus the buffer as appropriate (73)

Where this element of housing supply includes windfall sites, inclusion of ‘compelling evidence’ to justify their inclusion (70)

A SHLAA

Annual position statement

The Council updates its monitoring on sites at least annually and publishes the Northumberland Strategic Housing Land Availability Assessment including 5 Year Housing Land Supply of Deliverable Sites annually. The most recent publication is 2018-2036 SHLAA and 2018-2023 for 5 Year Housing Land Supply. This reports that there was equivalent to 15.6 years housing land supply at September 2018 measured against the standard local housing need calculation.

Identify a supply of developable sites or broad locations for years 6-10 and, where possible, years 11-15 (67).

Identification of a supply of developable sites or broad locations for: a) years 6-10; b) years 11-15

As above

Measures to bring small and medium sites forward are taken and windfall sites supported including 10% of housing requirement is supplied on sites no larger than 1 ha, subject to

Evidence of portfolio of sites and size of allocations

Evidence of measures to bring forward small and medium sites including Brownfield registers,

A small sites windfall allowance has been made in the calculations for housing delivery based on past delivery as evidenced in the Northumberland SHLAA and Five-Year Housing Land Supply of Deliverable Sites

19


caveat in paragraph 68

LDO’s and area wide design assessments and work with developers to subdivide large sites (68)

(December 2018).

The Council considers that it is unrealistic and impractical for the residual allocations in this Local Plan to meet the 10% of housing requirements to be delivered on sites no larger than 1ha (refer paragraph 7.25 -7.26). Nonetheless, of the completions over the past 5 years 27% have arisen from sites of 1.0 ha or less.

Entry level exception site measures are in place unless need is already being met (71)

Evidence for and approach to entry level exception sites.

The approach of the Plan to entry level exception sites for first time buyers or renters is found in Policy HOU 7 which adopts a practical approach to the local circumstances, and is rooted in evidence of local provision and need.

Illustrate the expected rate of housing delivery through a trajectory. (73)

A housing trajectory

Monitoring of completions and permissions (73)

Updated and managed SHLAA. (73)

The housing trajectory included in the Local Plan at page 319 illustrates the expected delivery of new homes throughout the plan period.

Housing completions and permissions are monitored throughout the year and these are reported through a variety of reports including the ‘Net Additional Homes’ reports and the ‘Northumberland Strategic Housing Land Availability Assessment including 5 Year Housing Land Supply of Deliverable Sites’ reports which keep the trajectory and the supply position under review. This report also includes the expected housing trajectory over the 15 year timeframe of the SHLAA. The SHLAA is therefore updated at least annually and managed as a live database that is updated as information changes.

20


In rural areas be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites where appropriate (77).

In rural areas housing should be located where it will enhance or maintain the vitality of rural communities. (78)

Consideration of allowing some market housing to facilitate the provision of significant additional affordable housing to meet local needs. (77)

Consideration of the case for resisting inappropriate development of residential gardens. (This is discretionary)(70)

Examples of special circumstances to allow new isolated homes listed at para 79

The majority of the area of the County is rural in nature and therefore the housing policies in the plan are relevant to rural housing.

The approach to small scale rural exception sites for affordable housing is set out in Policy HOU 7 for sites that are within adjacent or well related to existing settlements and this includes self build, custom build and community led housing if they meet the criteria within the policy. Provision for a proportion of enabling market housing is made subject to certain conditions. The policy approach is based upon local evidence of need and provision.

The Council has not set policy for special circumstances to allow new isolated homes in rural areas. However, Policy HOU 8 deals with residential development in the countryside, setting clear criteria for the circumstances under which it will be supported including in relation to rural workers dwellings.

Where larger scale development is being proposed this has considered infrastructure, access to services and employment, expectations regarding the quality of development, delivery rates and the necessity for new Green Belt designation (72)

Evidence supporting the delivery of large scale development

Infrastructure delivery plan

site trajectory

Development of the scale envisaged by the NPPF is not proposed within the Local Plan.

Building a strong, competitive economy (paras 80-84)

Set out a clear economic vision and strategy for the area which positively and proactively encourages sustainable economic growth having regard to Local Industrial Strategies and other local policies for economic development and regeneration.

Articulation of a clear economic vision and strategy for the plan area linked to the Economic Strategy, LEP Strategy and marine policy documents where appropriate.

Portfolio of sites and policies to encourage

The strategy of the Local Plan sits within the context of the national industrial strategy, North East Strategic Economic Plan, North of Tyne combined Authority aspirations and alongside the Northumberland Economic Strategy (2018). This is explained within the following Background Papers to the Local Plan:

21


Set criteria or identify strategic sites for local and inward investment to meet needs over the plan period (81

investment

Regulation 19 “Growth Strategy Technical Paper” and “Employment Land Strategy Considerations and Assessment of Sites Technical Paper” section 1.2.

The Local Plan sets the overarching vision for the County including “The economy will be thriving and competitive, and deliver more and better jobs. Supported by investment and infrastructure, building on existing strengths whilst diversifying and realising the potential of the rural and visitor economy “ (page 34).

The first strategic objective: Economy and Jobs sets the framework for policies. It reads: “To grow and diversify the Northumberland Economy by making it an attractive and competitive place to start, grow and invest in a broad range of businesses, attracting more and better jobs, and attracting and retaining working age people. To drive improvements in education, training and skills to enhance the employability of Northumberland residents”.

The key outcomes in this respect are listed at page 36 and address locational, sectoral and cross boundary aspects of the strategy. The strategy for sustainable growth across Northumberland is expressed at paragraphs 4.7 -4.21 whilst Policy STP 1 explains the associated spatial strategy. Policy “ECN 1 Planning Strategy for the economy” outlines the approach and Policy “ECN 12 A strategy for rural economic growth” explicitly addresses rural areas.

Strategic sites are identified in key locations and to support specific sectors. These are identified in Policy “ECN 2 Blyth Estuary Strategic Employment Area”, Policy “ECN 3 West Hartford Prestige Employment

22


Area” and “ECN 4 Round 2 Enterprise Zones”. In addition Policy “ECN 5 Large Scale windfall employment development” sets criteria for such provision. The remaining suite of policies with prefix ‘ECN’ identify sites or criteria for economic development across the County.

Recognise and seek to address potential barriers to investment, including poor environment or any lack of infrastructure, services or housing (81)

Be flexible in approach and address specific requirements of different sectors including making provision for clusters or networks of knowledge and data driven, creative or high technology industries; and for storage and distribution operations at a variety of scales in suitably accessible locations. (82)

Enable sustainable growth and expansion of all types of business in rural areas, development and diversification of agricultural and other land based rural industries, sustainable rural tourism and leisure and retention of accessible local services and community facilities, recognise that local business and community needs in rural areas may need to be located outside settlements (83-84)

Support sustainable economic growth in rural areas. Planning strategies should promote a strong rural economy by taking a positive approach to new development.

A criteria-based policy or allocations which meets identified needs and is positive and flexible in planning for specialist sectors, regeneration, infrastructure provision, environmental enhancement.

An up-to-date assessment of the deliverability of allocated employment sites, to meet local needs.

Background evidence and Flexible rural policy for business

Where relevant include a policy or policies which support the sustainable growth of rural businesses; promote the development and diversification of agricultural businesses; support sustainable rural tourism and leisure developments, and support local services and facilities.

The ECN prefix policies provide criteria based policy that protects employment allocations whilst providing clear criteria regarding flexibility of use. In addition the policies allocate further new land for economic development in response to identified need (Employment Land and Premises Demand Study 2015 and 2019 selective update).

The employment land allocations are based on a qualitative assessment undertaken using a range of evidence. This included a marketability assessment based on the information available. This is explained in the Regulation 19 Background Paper: “Employment Land Strategy Considerations and Assessment of Sites Technical Paper”.

The County economy is characterised by a diversity of small business located across even the most remote areas. This is evidenced by the “Housing and Economic Growth Options Report” 2018 (page 8 contains a useful map). The Plan explicitly addresses rural economic growth in its suite of policies “ECN 12 A strategy for rural economic growth”, “ECN 13 Meeting rural employment needs” and “ECN 14 Farm/ rural diversification”. In addition, the policies for tourism and visitor development “ECN 15 Tourism and Visitor Development” and “ECN 16 Green Belt and the tourism and visitor economy” expressly seek to

23


support rural economic growth.

Ensuring the vitality of town centres (paras 85 - 90)

Policies should be positive supporting the role of town centres at the heart of local communities, and take a positive approach to the management, adaptation and growth of centres, allowing a suitable mix of development (85)

The Plan and its policies may include such matters as: definition of networks and hierarchies; defining town centres; encouragement of residential development on appropriate sites; allocation of appropriate edge of centre sites where suitable and viable town centre sites are not available; consideration of retail and leisure proposals which cannot be accommodated in or adjacent to town centres.

Policy “STP 1 Spatial strategy” highlights the importance of the Main Towns, Service Centres and Service Villages as key to the strategy. The Local Plan defines a hierarchy of centres in policy “TCS 1 Hierarchy of centres” and Policy STP 1 (e) identifies the relationship between clusters of villages. The suite of prefix ‘TCS’ policies support the vitality of the centres, seek to provide for a wide range of uses and enable them to adapt to changing patterns of retail expenditure. For example town centres and primary shopping boundaries are set in Policy TCS 2 to guide the location of Main Town Centre uses whilst Policy “TCS 3 Maintaining and enhancing the role of centres” identifies opportunities for development and renewal. This includes the role of residential development in towns and proposals outside centres (TCS 4). Frontage policy in “TCS 5 Keeping high streets vibrant” seeks a flexible approach to uses whilst maintaining key frontages. In addition, policy INF 2 and INF 3 seek to protect community facilities and services, and local village shops.

The Local Plan approach is grounded in a range of evidence including benchmarking reports and explained in the Regulation 19 Background Paper: “Policy Approach for Northumberland’s Twelve Main Town Centres based on Evidence Technical Paper” 2018.

24


Allocate a range of suitable sites to meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community services and residential development needed in town centres (85)

An assessment of the need to expand (the) town centre(s), considering the needs of town centre uses.

Extent of town centres and primary shopping areas identified.

The “Town Centre and Retail Study” (2011, updated in 2013 and 2016) has been used to evidence whether there is capacity for additional town centre related developments beyond those in the development pipeline. These, together with neighbourhood plans have established the Town Centre Primary Shopping Area boundaries referenced in Policy TCS 2 and the areas identified for development and renewal within centres.

Policies support change of use to residential in town centres such as “HOU 1 Making the best use of existing buildings”, and “TCS 3 Maintaining and enhancing the role of centres” (sections 1c, 2a and 7).

Promoting healthy and safe communities (paras 91-101)

Policies should aim to design places which: promote social interaction, including through mixed-use development; are safe and accessible environments; and support and enable healthy lifestyles (91).

Inclusion of a policy or policies on inclusive communities.

Promotion of opportunities for meetings between members of the community who might not otherwise come into contact with each other, including through mixed-use developments which bring together those who work, live and play in the vicinity; safe and accessible environments where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion; and support healthy lifestyles for example through provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling (91)

The health and well being of the County’s people and communities features in the Local Plan Vision and the strategic objective: ‘Community Health and Wellbeing is “To support sustainable communities across Northumberland; working to improve the quality of services and facilities to support physical and mental health, social and cultural wellbeing for all including responding to the needs and opportunities created by Northumberland’s population”.

The key outcomes relate to the protection of accessible services, green infrastructure and open space and recreational provision, healthcare and education. A range of policies support the Community Health and Wellbeing objective and seek to achieve the outcomes. These include the suite of design policies noted above. For example:

25


“STP 5 Health and Well Being” which identifies requirements of development and introduces Health Impact Assessment

“STP 3 Principles of sustainable development” where consideration will be given to how proposals will support and provide health, social and cultural wellbeing and ensure infrastructure for quality of life of individuals and communities.

“QOP 1 Design principles” which among other provisions seeks comfortable, user friendly and legible environments, supports positive social interaction and a safe and secure environment.

“QOP 3 Public realm design principles” which seek vibrant buildings and spaces and legible access supporting a range of public activity.

“STP 1 Spatial strategy” recognises that Northumberland’s remote areas include relatively isolated hamlets that can act as clusters and share facilities. The plan builds in flexibility for new households to establish in small villages and hamlets, boosting these communities which may otherwise see continued decline.

“HOU 5 Housing types and mix” and “HOU 6 Affordable housing provision” seek to ensure an appropriate mix of house types and sizes and tenure in considering new housing proposals to create and maintain balanced and sustainable communities.

Finally, Policy “TCS 6 Hot food takeaways” seeks to

26


control their location and proliferation.

Policies should plan positively for the provision and use of shared space, community facilities and other local services (92).

Consider the benefits of estate regeneration (93)

Ensure schools are able to be altered or expanded (94)

Promote public safety and take into account wider security and defence requirements. (95)

Inclusion of a policy or policies addressing community facilities and local service.

Positive planning for the provision and integration of community facilities and other local services to enhance the sustainability of communities and residential environments; safeguard against the unnecessary loss of valued facilities and services; ensure that established shops, facilities and services are able to develop and modernize; and ensure that housing is developed in suitable locations which offer a range of community facilities and good access to key services and infrastructure, and that schools are able to expand.

Consideration given to estate regeneration where applicable (93)

Public safety and defence requirements are addressed (95)

Infrastructure policies seek to ensure that any new development is accompanied by the necessary physical, community, social and green infrastructure through Policy INF 1. The retention and enhancement of community facilities providing for health, and well being, social, spiritual, recreational, leisure or cultural needs of the community is addressed by Policy INF 2 which includes support for shared use. The protection of village convenience shops and public houses is sought (Policy INF 3) whilst Assets of Community Value are afforded protection as far as is possible (Policy INF 5).

Housing policy for older and vulnerable people seeks to provide accommodation in appropriate sustainable locations where there is access to existing local services and facilities including health, leisure education and transport facilities. (Policy HOU 11).

Policy “ECN 17 Military establishments” seeks to protect operation defence installations.

Identify specific needs and quantitative or qualitative deficits or surpluses and opportunities for provision of open space, sports and recreational facilities; and determine what provision is needed. (96).

Identification of specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area. (93)

A policy protecting existing open space, sports and recreational buildings and land from development, with specific exceptions. (97)

Protection and enhancement of rights of way and access. (98)

Appropriate designation of Local Green Space (100)

The Local Plan contains a specific policy “INF 5 Open Space and facilities for sport and recreation”. This seeks to protect such facilities and seeks new provision, as necessary to support new development and its ongoing maintenance. The Local Plan identifies protected open space and there is ongoing work to produce a Planning Obligations SPD that will provide further detail.

In specific respect of the environment of residential development policy “HOU 9 Residential development management” requires multi functional spaces where

27


appropriate.

The policies have been informed by a series of studies that have been recently updated and are being developed into live databases. These include the “Northumberland Open Space, Sport and Recreation Provision Assessment” (2011 selectively updated 2018), “Northumberland Playing Pitch Strategy” (2011 – currently being updated), and “Northumberland Sports Facilities Strategy” (February 2019). The approach to allocating open space in built up areas in the plan is explained in Regulation 19 “Review of Open Space in Northumberland Technical Paper” (2018).

In addition, the Local Plan contains policy in respect of natural green space in its policies on green infrastructure i.e. STP 6 identifies consideration of a range of criteria for development proposals regarding the inclusion, and protection of green infrastructure in development, its multifunctional role and contribution to the health and wellbeing of communities. In addition design policy addresses this matter in QOP 2. The policy is informed by the “Northumberland Green Infrastructure Strategy” (2011) and the “South East Northumberland Green Infrastructure Strategy” (2011) and ongoing work with the objective of securing green infrastructure.

Finally, the policies contained in the Environment chapter of the plan also seek protection for natural assets.

Enable local communities, through local and neighbourhood plans, to identify special protection green areas of particular importance

Policy enabling the protection of Local Green Spaces. (Local Green Spaces should only be designated when a plan is prepared or reviewed,

The Local Plan relies on the NPPF for this aspect of policy. Neighbourhood Plans identify Local Green

28


to them – ‘Local Green Space’ (99-101). and be capable of enduring beyond the end of the plan period). The designation should only be used when it accords with the criteria in para 100. Policy for managing development within a local green space should be consistent with policy for Green Belts. (101)

Space in the County.

Promoting sustainable transport (paras 102-111)

Facilitate sustainable development whilst contributing to wider sustainability and health objectives. (29)

Actively manage patterns of growth and offer choice to:

address the impacts of development on transport networks

realise opportunities from transport infrastructure and changing technology and usage

identify and pursue opportunities to promote walking cycling and public transport

identify and account for environmental impacts of traffic and transport infrastructure, including mitigation and net environmental gain

recognise that patterns of movement and transport considerations are integral to design and making high quality places. (102)

Focus significant development in locations which are or can be made sustainable whilst recognising that opportunities to maximise

Joint working with adjoining authorities, transport providers and Government Agencies on infrastructure provision in order to support sustainable economic growth with particular regard to the facilities referred to in paragraph 31.

Policies encouraging development which facilitates the use of sustainable modes of transport and a range of transport choices where appropriate, particularly the criteria in paragraph 35.

A spatial strategy and policy which seeks to reduce the need to travel through balancing housing and employment provision.

Policy for major developments which promotes a mix of uses and access to key facilities by sustainable transport modes.

If local (car parking) standards have been prepared, are they justified and necessary? (39)

Identification and protection of sites and routes where infrastructure could be developed to widen transport choice linked to the Local Transport Plan.

Transport policy has been co ordinated through the work at a regional level on the North East Combined Authority Joint Strategic Transport Plan for the seven north east authorities and, more recently, early work on the ambitions of the North of Tyne Combined Authority.

The transport policies, and site allocations, have been informed by a body of evidence including: “Northumberland Strategic Road Network Infrastructure Study” (Highways England 2016), “Northumberland Transport Assessment” December 2018 and “Northumberland Transport Assessment Mitigation Report” published in 2019 (produced in 2018).

The key transport requirements of the Local Plan have been derived from consultation with key partners including Highways England.

The spatial strategy includes the ‘Connections’ strategic objective “To improve connectivity and movement utilising existing infrastructure and securing the delivery of new and necessary infrastructure upgrades in order to meet the changing needs of people and places. “ The key outcomes are noted on page 39 including “A range of viable,

29


sustainable transport solutions will vary between urban to rural areas. (103)

Do policies:

Support an appropriate mix of uses, and within larger scale sites, to minimise the number and length of journeys

Align strategies and investments for supporting sustainable transport with development patterns having been prepared with local highways authority and other transport infrastructure providers and operators

Identify and protect sites and routes which may be critical to widen transport choice

Provide for high quality walking and cycling networks and supporting facilities

Provide for any large scale transport facilities that need to be located and the infrastructure and wider development required to support them

Recognise the importance of maintaining a network of general aviation airfields, their need to adapt over time and economic value (104)

The setting of local car parking standards for residential and non residential development including provision for charging plug in and other ultra low emission vehicles (105):

Maximum standards are clearly and compellingly justified

Town centre parking is convenient safe

efficient sustainable transport alternatives will have been provided to reduce reliance on the private motor vehicle, although it is recognised that in rural areas reliance on the private car will remain extensive” and “Improvements to transport and communications infrastructure and the County’s Main Line and Tyne Valley Railways, the Ports of Blyth and Berwick, passenger services on the Northumberland Line, and links to Newcastle International Airport. “

The spatial strategy in Policy STP1 directs most development to the most sustainable locations in terms of accessibility to services and facilities and provide the best opportunities to maximise and encourage the use of more sustainable transport modes such as walking and cycling, linked trips and shorter journey distance. In addition, Policy “STP 3 Principles of sustainable development” includes reference to making best use of infrastructure (k.) and accessibility to reduce reliance on the private car (j.). Most importantly Policy “STP 4 Climate change mitigation and adaptation” has a focus on reducing the need to travel by measures relating to location, layout and pattern of development.

In addition, the suite of transport policies address the range of relevant matters including:

the promotion of sustainable transport choices (Policy “TRA 1 Promoting sustainable connections” c.) the provision of supporting infrastructure i.e. cycle parking, public rights of way and charging points,

safe access and minimisation of conflict between different modes of transport,

30


and secure alongside measures to promote accessibility for pedestrians and cyclists (106)

Adequate overnight lorry parking facilities are provided including for new or expanded distribution centres (107)

Allocation site have been assessed to:

promote sustainable transport modes,

ensure safe access can be achieved for all users,

any significant impacts on the transport network can be cost effectively mitigated to an acceptable degree (108)

mitigation and management of adverse impacts of the network from development and minimising adverse impacts on communities and the environment (Policy “TRA 2 The effects of development on the transport network”)

Routes are safeguarded and planned for improvement and support for lorry parking given through Policy “TRA 3 Improving Northumberland’s core road network”, whilst new passenger rail and protection of improvements to existing services are addressed in Policy “TRA 5 Rail transport and safeguarding routes”. This policy safeguards a number of rail transport routes and rail freight facilities, including the Northumberland Line, the South Tynedale Railway line, the Aln Valley Railway and the former track bed between Newcastle Airport Metro Station and Ponteland. The Northumberland Line is currently progressing through the GRIP process and the extension of the Metro to Ponteland is supported by the Nexus Metro Strategy and the NECA document “The combined future of Metro and Local Rail in the North East”

Further support is given to Newcastle Airport through the allocation of land in Policy TRA 6 whilst aerodrome safeguarding is the subject of policy TRA 7. Ports Harbours and beach launch facilities are protected by Policy TRA 8.

The impact of site allocations on the network have been assessed for their impacts, safety and the promotion of sustainable transport modes. The evidence is contained within the “Northumberland Transport Assessment” December 2018 and

31


“Northumberland Transport Assessment Mitigation Report” published in 2019 (produced in 2018), and the site selection evidence. In respect of the residential allocations, the “Housing Site Selection and Appraisal Technical Paper” 2018 provides the relevant information. For the assessment of existing employment sites and the approach to them the “Employment Land: Strategy considerations and assessment of sites Technical Paper” 2018 explains, whilst the “Employment Site Option Appraisal for Selected Towns Introduction and Methodology” 2018 explains allocations of new sites.

Supporting high quality communications (paras 112-116)

Support the expansion of the electronic communications networks, including next generation mobile technology (such as 5G) and full fibre broadband connections.

Policies should set out how high quality digital infrastructure is expected to be delivered and upgraded over time and should prioritise full fibre connections to existing and new developments. (112)

The number of communications masts should be kept to a minimum, encouraging the use of existing masts, buildings and structures. Where new sites are required sympathetic design and camouflage is appropriate.

Local planning authorities should not impose a ban on new telecommunications development in certain areas, impose blanket Article 4 directions over a wide area or a wide range of telecommunications development or insist on

Policy supporting the expansion of electronic communications networks, including telecommunications and high speed broadband, noting the caveats in para 144.

Support for high quality communications is a thread of the strategy including the ‘Connection’ strategic objective and key outcomes, and its key relationship with the Local Plan strategy for the economy. Within the ‘Connectivity and Movement’ chapter of the plan the Policies “ICT 1 Planning for high quality communications infrastructure” and “ICT 2 New developments and infrastructure alignment” set out key criteria that address key aspects of this critical policy theme in line with the NPPF.

The Local Plan supports the implementation of the Northumberland broadband plan known as the iNorthumberland programme aiming to bring superfast broadband to over 95% of the County.

32


minimum distances between new telecommunications development and existing development. (114)

Making effective use of land (paras 117-123)

The strategy for meeting objectively assessed needs makes as much use as possible of previously developed or ‘brownfield’ land (117)

Evidence and approach to encouraging multiple benefits from land, including mixed use, and the achievement of net environmental gain and habitat creation. (118)

Evidence and approach to remediate despoiled, degraded, derelict, contaminated or unstable land (118)

Evidence and approach to development of under utilised land and buildings including use of vacant space on upper floors

Evidence and approach to upward extension for new homes

Evidence of facilitating land assembly, and bringing forward brownfield sites including the use of Brownfield Registers (119)

The Local Plan includes a strategic objective relating to resources. “Resources: To manage the prudent use of Northumberland’s natural resources, including minerals, energy, land, existing built fabric and water, while providing less waste and minimising adverse impacts on communities and the environment”. The associated key outcomes in paragraph 3.17 include “efficient use of land and existing buildings, with priority given to the development of previously developed land, wherever possible”.

Policy “STP 3 Principles of sustainable development”, applicable to all proposals requires development to adhere to the principle of making efficient use of land including higher densities in more accessible locations and through the re use of brownfield sites.

In addition, Policy “POL 3 Agricultural land quality” seeks to protect the best and most versatile agricultural land.

The multifunctionality of land is addressed in Policy STP 3 as well as in “STP 4 Climate change adaptation and mitigation” and “STP 6 Green Infrastructure” which sets out the criteria that will be applied to consideration of development proposals in this regard.

Mixed use development is encouraged in Town Centres (Policy TC 3) and residential conversions and changes of use are encouraged by Policy “HOU 1

33


Making the best use of existing buildings”.

The approach to remediation of despoiled, degraded, derelict, contaminated or unstable land is outlined in Policy “POL 1 Unstable and contaminated land” which seeks to support proposals that allow for the beneficial remediation of such land subject to criteria to ensure this is safe.

Land allocations and land availability is regularly reviewed (120)

Evidence of supporting alternative uses on sites and reallocation for more deliverable use (120)

Evidence of supporting alternative uses on currently developed unallocated sites. (121)

As part of the production of the plan a review of the employment land was undertaken and as a result a selection of sites that were allocated in existing development plans were deallocated on the basis that they were no longer considered suitable for that use. This is identified in the “Northumberland Employment Land Review” 2011.

Flexibility with respect to uses is built into the policy framework for example in Policy “ECN 9 Additional flexibility in general employment areas” and “TCS 3 Maintaining and enhancing the role of centres”.

Development that supports the efficient use of land is supported subject to the conditions in paragraph 122.

Where there is existing or anticipated shortage of land for meeting identified housing needs building at low densities is avoided and optimal use of sites is made subject to requirements in paragraph 123

Evidence and approach to efficiency of land use (122)

Use of minimum density standards in appropriate locations (123)

The Plan does not contain an explicit policy that considers appropriate densities given that Northumberland is so diverse however Policy “STP 3 Principles of sustainable development”, applicable to all proposals, requires development to adhere to the principle of making efficient use of land including higher densities in more accessible locations and through the re use of brownfield sites.

There is not, nor is there anticipated, a shortage of land for meeting identified housing needs.

Achieving well designed places (paras 124-132)

34


Clarity about design expectations and how these will be tested (124)

A clear design vision and expectations should be set out, and design policies developed with local communities. (125)

Use should be made of visual tools such as design guides and codes with the level of detail and degree of prescription tailored to the circumstances of each place. (126)

Inclusion of policy or policies which seek to increase the quality of development through the principles set out at para 127 and approaches in paras 124- 126 linked to the vision for the area and specific local issues

The Local Plan recognises high quality design as an integral aspect of sustainable development and places great emphasis on high quality design through its vision and ‘Quality of Place’ strategic objective: “To ensure the high quality design of buildings and spaces, in order to create attractive, inclusive places which instil a sense of civic pride and enrich, rather than harm the diverse character of Northumberland.” Key outcomes for Quality of Place are included at paragraph 3.19 and their achievement is sought through policies in the Quality of Place chapter of the plan.

The Local Plan expects design to contribute positively to place making and in response to robust analysis of the character of the site and surrounding area, in addition to the functional requirements of the intended use.

Principles of sustainable design in Policy STP 3 and “STP 4 Climate change mitigation and adaptation” set the context for the rest of the design policies in the ‘Quality of Place’ chapter. These include design principles in QOP 1 which seeks to achieve well designed development and places, the resultant experience of amenity of design and its context in “QOP 2 Good design and amenity”, and the incorporation and relationship to the public realm in “QOP 3 Public realm design principles”. The attention required to landscape and trees is included in QOP 4, sustainability performance in QOP 5 and relevant design tools are addressed by “QOP 6 Delivering well designed places”.

Further detail on the requirements and delivery of

35


high quality sustainable design in Northumberland is to be provided in two Supplementary Planning Documents currently in production: “Design SPD” and “Highways and Transport Design and Delivery SPD”.

Protecting Green Belt land (paras 133-147)

Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Before concluding exceptional circumstances exist to justify changes to Green Belt boundaries the authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development (137)

When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development and set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land (138)

Local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. (141)

Where Green Belt boundaries have been changed the evidence should indicate:

o that all other reasonable options have been examined fully (137)

o that the need to promote sustainable patterns of development has been accounted for

o Evidence of compensatory measures (138)

Where Green Belt policies are included, these should reflect the need to:

o Enhance the beneficial use of the Green Belt. (141)

o Accord with criteria on boundary setting, and the need for clarity on the status of safeguarded land, in particular. (139- 140)

o Specify that inappropriate development should not be approved except in very special circumstances. (143)

o Specify the exceptions to inappropriate development (145)

o Identify where very special circumstances might apply to renewable energy development that is inappropriate. (147)

The preparation of the Local Plan entailed a review of Green Belt boundaries to assist in setting the detailed outer boundary around Morpeth, and inform the assessments for site allocations. This is explained in the Regulation 19 “Green Belt Review Technical Paper” (2018) together with the exceptional circumstances justifying the change of boundary. The exceptional circumstances for releasing some Green Belt land for employment development arise in the interests of the need to promote sustainable development, hence provide for land to meet the needs of local industrial markets in selected market towns. Reasonable options have been examined but are not appropriate.

The approach to Green Belt Reviews was agreed with the North of Tyne Working Group (June 2015) and in September 2016 with Durham, Newcastle, Gateshead and Sunderland Councils where methodologies were shared.

Policy “STP 7 Strategic approach to the Green Belt” explains the principles of the protection that this affords in Northumberland whilst “STP 8 Development in the Green Belt” explains the principles applied to assessing proposals for development in the Green Belt and the criteria for limited infilling. Finally, Policy “ECN 16 Green Belt and tourism and visitor economy” provides criteria for the consideration of such

36


proposals in support of the rural economy in Green Belt locations.

The approach to safeguarded land is included in Policy STP 9.

The Council has considered ways to offset the impact of removing land from the Green Belt but has not been able to identify practical compensatory measures.

Meeting the challenge of climate change, flooding and coastal change (paras 148-169)

Adopt proactive strategies to mitigate and adapt to climate change taking full account of flood risk, coastal change, water supply biodiversity and landscapes and the risk of overheating from rising temperatures and demand considerations. Minimise vulnerability to climate change (149)

Planning of new development in ways that avoid increased vulnerability to impacts arising from climate change and in locations, and ways which reduce greenhouse gas emissions such as orientation and design

Support for measures to ensure future resilience of communities and infrastructure to climate change impacts (149)

Support for energy efficiency improvements to existing building.

Local requirements for a building’s sustainability which are consistent with the Government’s policy for national technical standards (149)

Addressing climate change is a strategic objective of the Local Plan. “Climate Change: To ensure the delivery of sustainable development which mitigates climate change, whilst acknowledging and anticipating the likely impact of a changing climate on Northumberland and adapting to its effects”. The associated key outcomes sought for the plan are noted at paragraph 3.14 and include the pattern of development, renewable energy and heat supply, energy efficiency, sustainable buildings and management of flood risk. A range of policies seek to deliver these outcomes. The following are examples:

The spatial strategy of the plan seeks to reduce green house gas emissions by the location of the majority of new development close to existing services (refer Policy “STP1 Spatial strategy”) whilst the principles of sustainable development set out in policy STP3 identify the range of measures that assist in both reduction of emissions and adaptation to the impacts of climate change in particular parts f - k, and m – o

37


which include matters such as anticipating impacts from climate change, accessibility by public transport walking or cycling and energy reduction in design.

In addition, Policy “STP4 Climate change mitigation and adaptation” seeks to ensure that development directly addresses the range of measures suitable for both mitigation of and mitigation to the impacts of climate change including measures such as sustainable drainage, water demand, green infrastructure provision, and electric vehicle charging points.

Policy “TRA 1 Promoting sustainable connections” supports the spatial strategy and distribution of development, and identify sustainable transport measures that are expected of development proposals.

Further design policy addresses these matters as follows:

Policy STP 6 provides for green infrastructure – a key mitigation and adaptation measure with links to flood risk management as well as biodiversity

Policy “QOP 1 Design principles” incorporates contribution to net environmental gains, response to climatic conditions, mitigation and adaptation to climate change

Policy QOP 3 and QOP 4 seek urban greening to, among other things, support temperature control in urban environments.

38


Help increase the use and supply of renewable and low carbon energy through a strategy, policies maximising renewable and low carbon energy, whilst ensuring that adverse impacts are addressed satisfactorily and identification of key energy sources. (151)

A strategy and policies to promote and maximise energy from renewable and low carbon sources,

Identification of suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources (see also NPPF footnote 49)

Identification of where development can draw its energy supply from decentralised, renewable or low carbon supply systems and for co-locating potential heat customers and suppliers. (151)

The Local Plan includes a strategic objective relating to resources. “Resources: To manage the prudent use of Northumberland’s natural resources, including minerals, energy, land, existing built fabric and water, while providing less waste and minimising adverse impacts on communities and the environment”. The associated key outcomes in paragraph 3.17 include “the need to generate energy is effectively balanced with the need to protect Northumberland’s environment and communities from any significant adverse impacts associated with it”.

The key policies addressing this matter are “ REN 1 Renewable and low carbon energy and associated energy storage” and “REN 2 Onshore wind energy development”. The County is home to a number of renewable energy developments including wind farms, and individual turbines. REN 1 supports the provision of all forms of renewable energy developments subject to certain criteria. REN 2 applies to onshore wind only and is accompanied by the identification of potentially suitable areas. The approach is explained in Regulation 19 “Potentially Suitable Areas for Wind Energy Development Technical Paper” (2018)

To add more detail to the renewable energy policies a supplementary planning document will be prepared, which will provide more guidance on the requirements of the policies.

Minimise and manage the risk of flooding (155) Account taken of the impacts of climate change. ()

Allocate, and where necessary re-locate, development away from flood risk areas through a sequential test, based on a SFRA. (156- 157)

The evidence supporting the allocations of sites includes level 1 and 2 SFRA together with outline and detailed water cycle studies (“Northumberland Detailed Water Cycle Study” 2015, “Northumberland

39


Policies to manage risk, from a range of impacts, through suitable adaptation measures including requiring Sustainable Drainage systems in all major development (155-165)

Level 2 Strategic Flood Risk Assessment” 2015). Sites have been sieved in relation to their associated flood risk in reaching conclusions regarding allocations.

The Co