Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 5651

Received: 28/08/2025

Respondent: ATP

I&O_6023
We would encourage that the Regulation 19 iteration of the Local Plan itemises the various sites identified to be suitable for allocation in the Local Plan (perhaps with a lower threshold to be adopted such as 10 for a major development). This should include sites such as ID1182 which is comprised of the Total Fitness unit accessed off Liverpool Road to the north of the city centre. This is an eminently suitable brownfield site close to public transport nodes and employment uses such as the hospital and university. We would also note that the identified yield for that site (32) would reflect a family housing typology whereas the site (by virtue of topography and existing volume and massing) could straightforwardly accommodate an apartment-led typology and a yield of circa 100 units. Evidence has previously been provided in terms of feasibility layouts which would align to these statements.

Comment

Representation ID: 5671

Received: 28/08/2025

Respondent: ATP

I&O_6043
No. This does not appear to align to earlier policies in terms of spatial strategy which would appear to support opportunities for infill development or PDL areas in the vicinity of smaller settlements (which would presumably comprise Green Belt land). We argued that this should be extended to also provide opportunity for other contiguous extensions to settlements subject to consideration of locational sustainability and relative Green Belt harm. This policy as worded would appear to prevent even the development opportunities already promoted under other policies. The approach requires clarification as it is inconsistent and in any event it would be unduly restrictive.

Comment

Representation ID: 5676

Received: 28/08/2025

Respondent: ATP

I&O_6048
No. We note that the extent of a sustainable area is identified through the proxy of an 800m walk distance. However, this fails to have regard to the locational sustainability credentials that can be provided by proximity to bus services or simply being adjacent to established settlements which have existing services and infrastructure. We would also note that the 800m radius reflects a very arbitrary construct and fails to reflect the practical empirical evidence provided via the National Travel Survey in terms of the distances people will actually travel to destinations such as train stations and bus stops in connection with completing journeys for various purposes. It advises that the preferable metric is the 85% figure (so neither the mean nor the maximum figure provided by the empirical survey data). It states:  “When considering the potential walking catchment of a new development, to bus stop or railway station, the 85th percentile distance should be used.” On the basis of the above research 1610m represents an acceptable walking distance to a train station and 800m to a bus stop. That being the case, the 1610m threshold should be used instead of the 800m distance currently shown on the scenario mapping. In addition it should be noted that there will be a reasonable quantum of people (15%) who would find longer walk distances acceptable in practice. Where development sites would be located within 1610m radius of a train station they would therefore be within tolerance of that threshold. This represents an acceptable pedestrian journey on the basis of empirical data which should be relied upon rather than the current and entirely arbitrary 800m distance. Adoption of a more effective acceptable walk distance from train stations and genuine recognition of locational sustainability in the context of bus routes and proximity to existing services in settlements would provide a greater opportunity to meet Plan-led housing requirements. That and a more flexible approach to identifying their typology (which would currently be restricted to infill or PDL sites) would allow other sites close to or adjoining settlements to be properly considered on their merits. 

Comment

Representation ID: 5705

Received: 28/08/2025

Respondent: ATP

I&O_6077
As we set out under the consideration of Local Plan versus the adoption of Sustainability Appraisal objectives, the Council will inevitably take forward a hybrid approach including the use of  bespoke DM policies. However, it will be important that the imposition of these policies are properly assessed in terms of whether they might impede delivery of Plan-led requirements. This will include whole Plan viability assessment, which cannot be left to the DM stage. If this suite of policy requirements did render housing tpyologies undeliverable, then the suite of policy requirements should change accordingly. The policy as worded implies that it is necessary for all infrastructure to be provided, without having any evidence base to establsih whether that is feasible to achieve alongside other planning objectives such as affordable housing.  Our experience of other Local Plan processes is that the whole Plan viability assessment is inadequate and leaves difficult decisions to DM stage which can include discussion on relative provision of planning obligations which therefore increases the risk with the relative dissatisfaction of all stakeholders in the planning and delivery of new development.  

Comment

Representation ID: 5716

Received: 28/08/2025

Respondent: ATP

I&O_6088
It is generally the case that policy obligations such as affordable housing or education contributions have a threshold and that this aligns with the definition of major development. Our view is that this threshold should be maintained unless there is credible evidence to demonstrate why it should be applied at a lower threshold.  Certainly in the example that the Council would seek any mitigation to be delivered on-site, then it would be important as part of the Plan-making exercise to model how that would impact yield. This would presumably require considerably more land to be released from the Green Belt, and the planning ramifications of that strategy would need to be assessed. In practice, we do not feel that it should be obligatory to provide full mitigation on-site.

Comment

Representation ID: 5734

Received: 28/08/2025

Respondent: ATP

I&O_6106
As a point of principle, there is a logic to suggest that new developments should mitigate any impacts that result from them. However, this is not always feasible and we are of course aware of numerous examples where there has been public sector intervention to pump-prime development to allow the re-use of brownfield sites and/or to deliver additional affordable housing. In addition, there have been examples of strategic investment in highways and other transport infrastructure to unlock development opportunities. If one were to ignore those scenarios where there is public sector intervention, it is then necessary to establish what the cost of the various infrastructure requirements would be relative to the general viability position of delivering new housing or employment uses. Put simply, it would not be appropriate to place requirements on developers to deliver infrastructure which would render new development unimplementable by virtue of viability. That is the purpose of the whole Plan viability assessment and that work is incomplete or at least unpublished. In the event that this would show that the full suite of infrastructure sought would render development undeliverable then the proper resolution is to reconsider that suite of infrastructure ambitions to something which was genuinely necessary and would not prejudice deliverability. It is too simplistic to ask to agree/reject whether developers should pay for the "full cost of infrastructure" without confirming what those costs are and to ascertain whether that can be achievable.

Comment

Representation ID: 5739

Received: 28/08/2025

Respondent: ATP

I&O_6111
That might well be appropriate, but any such assessment would need to go through a rigorous SA process and establish what is genuinely necessary and appropriate for each location.

Comment

Representation ID: 5750

Received: 28/08/2025

Respondent: ATP

I&O_6122
No. This is inconsistent with the NPPF or online practice guidance. The key deteminant is whether there are more centrally located sites that are otherwise suitable, available and viable. The fact that a competing site could be previously developed or have a main town centre use permission may be relevant to suitability, but it does not overide whether it is more centrally located. In addition, if a site is concluded out of centre in policy terms then the NPPF has regard to its relative accessibility.  This approach would be unsound and should not be progressed.

Comment

Representation ID: 5765

Received: 28/08/2025

Respondent: ATP

I&O_6137
We would note that strong positive weight should be afforded to proposals which could provide and commit to delivering affordable housing in excess of policy requirements. That should be given proper consideration as part of the planning balance exercise for future DM proposals.