Revised National Planning Policy Framework Consultation (July-Sept 2024):
To receive a report.
Minutes:
The Chairman welcomed Phil Norman, Assistant Director for Planning and Strategic Infrastructure, Paul Jackson, SHDC Executive Programme Manager and Pranali Parikh, Director of Economic Development to provide Members with an update.
The Assistant Director for Planning and Strategic Infrastructure presented Members with a report on the Revised National Planning Policy Framework Consultation which highlighted a summary of the proposed changes in the published consultation on the revised National Planning Policy Framework (NPPF, 2024), pages 15 to 20 of the Agenda refer.
The key considerations related to the revised National Planning Policy Framework were highlighted as follows:
· Housing Supply and Targets
· Affordable Housing
· Design
· Economic Development
· Climate Change
· Agricultural Land
Members were advised that the new housing target was currently proposed at 1091 dwellings per annum in comparison to the current Local Plan target of 558 and that questions were being raised on how East Lindsey could deliver the level of growth and provide the infrastructure to support the significant increase.
In relation to agricultural land, the Assistant Director for Planning and Strategic Infrastructure further advised Members that the removal of the inclusion in the NPPF for high grade agricultural land to be protected had been influenced by the government’s increasing support of renewable energy schemes.
Members were invited to put their comments and questions forward.
· At the indulgence of the Chairman, Councillor Ruchira Yarsley queried the practicality of the changes in the NPFP and whether there was a demand and need for such high numbers of housing in the district and how this would affect farmers and rural areas in East Lindsey. In response, the Assistant Director - Planning and Strategic Growth explained to Members that the housing figure was a 150% increase and that it was essential that the Council made strong representations to the government on the proposed changes to highlight concerns on adverse impacts. The Assistant Director – Planning and Strategic Growth further assured Members it was the government’s responsibility to obtain feedback through the consultation process and that the final position may change when they examined how the proposals would work in rural areas.
· The Chairman commented on the challenges that would result from a significant increase in housing numbers including the impact from the lack of demand, lack of skilled workers or from shortages in building materials. The Chairman further commented on concerns with meeting the proposed housing targets and the removal of taking agricultural land used for food production into account.
· A Member queried the possible penalties for not achieving the government’s targets and commented on whether more focus was needed on building renewable energy on flood risk areas rather than on high quality agricultural land. In response, the Chairman advised Members that further discussion on the Local Plan would be undertaken during the following Agenda item and that the availability and allocation of land for market housing was significantly constrained in East Lindsey by the Area of Outstanding Natural Beauty (AONB) and inland and coastal flood risk areas.
· A Member referred to an example in Stickney where 205 applications had been approved and had not been built out which suggested there was a lack of demand in certain rural areas in East Lindsey. In response, the Chairman informed Members that ELDC had exceeded its build out targets and commented that the proposed increase was disappointing when the Council had already achieved more than had been asked.
· A Member made reference to provisions in the NPPF for identifying preferred sites for renewable energy and queried whether policy could be developed to identify areas which could be allocated to mitigate concerns.
· Members expressed further concerns with the implications from increased housing targets and the potential increases in housing density.
· A Member queried whether settlement proposals were fit for purpose. In response, the Interim Planning Policy Service Manager advised Members that the Committee had previously reviewed the settlement proposals and that further revision was not currently necessary. Members were further advised that following the Regulation 18 consultation, approximately 800 sites had been identified on the strategic housing land availability assessment and that East Lindsey district was not short on sites for development. The Interim Planning Policy Service Manager concluded that the 800 sites previously identified would form as a consideration in the emerging Local Plan and it was to be determined which of those sites were suitable and sustainable for delivering the housing that was needed.
The Assistant Director – Planning and Strategic Infrastructure further explained to Members that considerations on what areas needed reassessment could change and that the challenges from revisions to the NPPF were being experienced nationally and that East Lindsey was not the only district in the country to have been presented with high housing targets.
· A Member queried the timeframe which had been given for completion of the review of the Local Plan to ensure that the Council was fully prepared. In response, the Assistant Director – Planning and Strategic Infrastructure advised Members that an exact date could not be provided and that the next stage was to update the local development scheme. The Assistant Director – Planning and Strategic Infrastructure further advised Members that the government had outlined a schedule for transition arrangements which was subject to change and that the Council were committed to ensuring its work fed into the governments timetable.
· The Chairman further assured Members that the Council was in a stronger position for reviewing the Local Plan than it had been in 2016 and that the current Local Plan was relatively up to date pending revision.
· The Chairman highlighted concerns with proposals to increase annual housing targets to 1091 from the current 558 per year and commented that ELDC would be unable to deliver and meet the 5-year supply of deliverable housing sites in those circumstances, page 18 of the Agenda refers.
· At the indulgence of the Chairman, Councillor Ruchira Yarsley queried the process and timeline for providing feedback to the government. In response, the Assistant Director – Planning and Strategic Infrastructure advised Members that the deadline for consultation responses was before the end of September 2024 and that the response would be a Partnership effort which would be reviewed by each of the Partnership’s portfolio holders and would include points relevant to each district. The Assistant Director – Strategic Planning and Infrastructure further advised Members that the government had indicated that a new NPPF could be published by the end of 2024.
· At the indulgence of the Chairman, Councillor Ruchira Yarsley queried whether the government was required to take the consultation responses into account. In response, the Assistant Director – Planning and Strategic Infrastructure advised Members that the government was duty bound to undertake consultations.
· A Member requested an estimate of when the housing target was likely to become mandatory. In response, the Assistant Director – Planning and Strategic Infrastructure advised Members that a new NPPF was expected by the end of 2024 and commented that the government’s intention to motivate Local Plan development was counterproductive when its targets were extremely difficult to achieve.
· A Member queried whether ELDC’s responses to the NPPF consultation could be shared with all Members of the Council. In response, the Chairman confirmed that the responses would be shared with Members.
· In reference to Paragraph 2.4, a Member queried whether the entirety of the emerging plan was open to change or only in relation to housing targets. In response, the Assistant Director – Planning and Strategic Infrastructure explained to Members that it was uncertain until the final transition arrangements had been agreed.
· A Member further queried whether the Council had the opportunity to make changes to the Local Plan until the deadline of December 2026. In response, the Assistant Director – Planning and Strategic Infrastructure advised Members that no further clarity could be provided, and that current legislation and regulations would continue to apply up until that date.
· At the indulgence of the Chairman, Councillor Jill Makinson-Sanders queried whether the revision of the Local Plan could include provisions to limit the spread of caravans on the coast. In response, the Chairman advised Members that queries related to the Local Plan could be addressed in the upcoming Agenda item and examined as part of the Committee’s wider work programme.
· A Member emphasised the importance of Planning Policy Committee Meetings continuing to take place. In response, the Chairman provided assurance that meetings would continue as scheduled and that opportunities would be available to examine the current meeting format and that further avenues for informal debate would be explored.
· A Member further queried whether the Planning and Planning Policy teams had capacity to undertake the anticipated workload for revising the Local Plan. In response, the Assistant Director – Planning and Strategic Infrastructure advised Members that in agreement with new Director of Economic Development, capacity would be assessed across the Partnership over a period of time before any conclusions were made.
· Pranali Parikh, Director of Economic Development assured Members that four new team members had been assigned to working on the task and that capacity within the team was being assessed across the Partnership, and that there was a commitment from Executive Members and the Leaders to drive forward resources and to recruit to bring wider improvements.
· At the indulgence of the Chairman, Councillor Ruchira Yarsley queried whether planning applications would be considered under the current Local Plan until December 2024. In response, the Assistant Director – Planning and Strategic Infrastructure confirmed this was correct.
· A Member queried whether the settlement figures could be revised. In response, the Chairman advised Members that the settlement scoreboard had been comprehensively reviewed following consultation and that for consistency more support had been given to smaller villages. The Chairman further advised Members that the figures were not intended to change and that background papers highlighting how those figures were agreed could be circulated to Members.
· A Member commented on the disadvantages of diverted focus across three authorities when ELDC were primarily concerned with only what occurred in East Lindsey. In response, the Director of Economic Development assured Members on the validity of concerns on the focus of each district and supported the separate understanding of each District and the sharing of resources from across the Partnership to assist East Lindsey.
· A Member further queried whether the Committee could be provided with further information on the distribution of settlement hierarchies and other policies which were due to be reviewed. In response, the Chairman advised Members that settlement hierarchies would not be revisited and that consideration for which policies needed revising could be considered as a future Agenda item, together with a policy tracker which could to be circulated Members.
· At the indulgence of the Chairman, Councillor Jill Makinson-Sanders queried whether the Planning Policy Committee could undertake a review of market towns, particularly in the circumstances where housing numbers were to significantly increase. In response, the Chairman recognised Members’ concerns to protect rural areas and market towns and acknowledged that the proposed target of 1090 houses was not achievable.
The Chairman thanked everyone for their comments.
Following which, it was
RESOLVED:
That the Revised National Planning Policy Framework Consultation (July-Sept 2024) report be noted.
Supporting documents: