Structure Plan - Panel Report

1.2 Links between this policy and the rest of the Plan are illustrated in paragraphs 2.8-2.14 of the explanatory memorandum by showing how each of the seven objectives in Strategy Policy 1 relate to specific strategy and topic-based policies. As was made clear by the Structure Plan Authorities during the EIP, these were not intended to be comprehensive; indeed some specific policies are not even referred to.

Scope and Content of Strategy Policy 1 and its Role within the Plan.

1.3 Most participants considered that there was broad consistency between the overall strategy and policies in the Plan and national and regional guidance. However, it was felt that the scope and content of Strategy Policy 1 could be improved to clarify its role, iron out a number of inconsistencies and make the ‘cross-cutting’ links with the rest of the Plan clearer and more explicit.

1.5 The Panel agrees that there is a need to review the role of Strategy Policy 1. In our view it sets an important context for the whole of the Plan rather than standing as a policy in its own right. We understand the concern of the Structure Plan Authorities that taking it out of the list of policies and putting it into the explanatory memorandum might weaken its formal position as part of the written statement. However, we do not think that any apparent loss of status would be prejudicial in any planning proceedings. Presentationally its role would, in our view, be enhanced rather than downrated by removing it from the policies and giving it greater prominence as a clear set of objectives within the explanatory memorandum in Chapters 1 or 2. We note that the same approach is adopted by Draft RPG, which contains a highlighted set of objectives (in paragraph 3.5) to which the policies in the rest of the document relate. We are aware that similar methods for the identification of overriding objectives have been followed in structure plans elsewhere.

1.6 This would also enable a number of confusing overlaps and repetitions between Strategy Policy 1 and other statements in Chapters 1 and 2 to be resolved. In particular there is reference in paragraph 1.6 to the ‘Vision’ of the Plan: ‘to create a vibrant and attractive area with a rich cultural and natural environment, enabling residents to enjoy environmental, social and economic well-being’. This statement could provide an introduction to the list of objectives in the Structure Plan. We consider that the reference to an ‘Overall Aim’ (paragraph 1.4): ‘to secure the most appropriate development in the most appropriate locations, while taking into account environmental, social and economic well-being’, is a statement of the obvious and could be omitted or absorbed into the explanatory memorandum supporting the list of objectives.

1.7 In paragraph 2.2 of the Structure Plan is another reference to a ‘key aim’ of the Plan, ‘to integrate development with transport’. This statement would also be better transferred to the explanatory memorandum in support of the list of objectives. Finally, in paragraph 2.3 there are a series of objectives-like statements supporting the above key aim which are more specifically land use oriented than the statements in Strategy Policy 1 itself. These are more relevant to the locational strategy set out in Strategy Policies 2 and 3 since they are concerned with the advantages of locating new development in existing built-up areas.

1.8 As to the wording of the objectives contained in Strategy Policy 1, we agree that this would benefit from being refined and clarified. A revised version of the objectives is put forward in our recommendations at the end of this chapter, taking into account the views of participants. In particular, we have sought to:

(a) include reference in the opening statement to the promotion of sustainable ‘development’ as well as ‘living’;

(b) relate the objectives to the four sustainable development aims contained in the UK Strategy and replicated in the Draft RPG;

(c) include specific reference to regeneration and to flood protection, in line with Draft RPG and PPG25;

(d) strengthen the scope of the objectives in respect of economic development;

(e) integrate some of the clauses of the policy which seem to us to be inter-related, notably clauses (d) and (e) concerning protection, enhancement and replacement of environmental assets;

(f) make specific reference to the integration and phasing of infrastructure provision with development; and

(g) relate the resource objectives in clause (f) of the policy more explicitly to the land-use purposes of a structure plan.

1.10 Finally, we endorse the Structure Plan Authorities proposal that terms such as ‘replaceable’ and ‘irreplaceable’ assets of the environment should be clearly defined in the glossary to the Structure Plan, with an explanation of how these relate to other terms used in the Plan such as ‘constant capital’, ‘tradable capital’ and ‘critical capital’. The Structure Plan Authorities agreed that paragraph 1.23 which employs the latter terms should be clarified and brought into closer proximity to Strategy Policy 1.

Linkages with the rest of the Plan.

1.11 The Panel agrees that the Structure Plan could do more to demonstrate how the objectives in Strategy Policy 1 are related to the policies in the rest of the Plan. Various suggestions were made during the EIP for achieving this. Some participants suggested a chart or matrix showing how each policy or group of policies addresses the objectives in Strategy Policy 1. Others put forward their own grouping of the objectives and policies along thematic lines.

1.12 Another suggestion was that the Plan could include cross-references in the margins showing how each policy is related to the objectives. A number of participants preferred an expansion of the approach currently adopted in the explanatory memorandum, which describes how each clause in Strategy Policy 1 is related to key policies in the rest of the Plan. As indicated above, however, this is only done selectively and some policies are not referred to at all. We agree with those who felt that there are dangers in such an approach, in that important policies may thereby appear to be devalued.

1.13 We do not have a strong view on which of these options would be best. Each has its attractions and they are not necessarily mutually exclusive. A single matrix or chart which attempted to show the relationships between the objectives and all 80 policies in the rest of the Plan would be far too large and unwieldy. It would be preferable to produce a series of separate charts or matrices, firstly in the Strategy chapter and then in the introductory sections of each of the topic-based chapters, showing the relationships between the particular policies in that chapter and the overall objectives of the strategy.

1.14 Irrespective of whether charts or matrices are employed, however, it is essential in our view that there is a brief description in the introductory text of each chapter explaining in a little more detail how the various policies seek to address the objectives, recognising that some policies will be related to more than one objective. This approach should be clearly explained in the explanatory memorandum to the list of objectives, emphasising that the Plan must be seen as a whole and that in applying the objectives and policies in local plans and in dealing with development proposals, the aim should be to find integrated solutions to meeting the objectives. This will enable the common strands provided by the objectives to run through the whole of the Plan and for cross-cutting themes to be more clearly brought out, thus aiding the transparency and overall coherence of the document.

1.15 Paragraphs 2.4-2.6 of Chapter 2 of the Structure Plan deal with the role of the Central Leicestershire Policy Area (CLPA). The Structure Plan Authorities accepted that this is now in the wrong place. With the introduction of a new policy (Strategy Policy 2) for the CLPA, this passage should be moved to that part of the explanatory memorandum supporting the new policy. We deal in more detail with the CLPA in Chapter 2 of our report.

1.16 Blaby District Council drew attention to the absence from the Structure Plan of any policy covering energy generation. Resource Management Policies 2 and 3 deal with energy efficiency and renewable energy respectively, but the Plan provides no specific guidance on non-renewable energy development. We note that Draft RPG Policy 67 indicates that development plans should provide a framework for the development of new energy installations and combined heat and power schemes. The absence of such a policy from the Plan, therefore, does seem to be a significant omission and one which the Structure Plan Authorities should consider rectifying as part of the final modifications to the document. This could be done either by introducing a new policy into the Plan or by widening the scope of Resource Management Policy 3.

Monitoring.

1.17 Monitoring plays an increasingly important role in development planning, especially with the greater emphasis now being placed on plan, monitor and manage. With three strategic planning authorities involved in the production of this Structure Plan the importance of having a robust and effective mechanism for joint monitoring of the Plan cannot be over-stressed.

1.18 At the EIP we heard that formal data collection mechanisms were in place involving the various local planning authorities. A Land Report, drawing upon this information, is produced annually by Leicestershire County Council. At the more informal level there is a Development Plans Forum involving all the local planning authorities and the Government Office for the East Midlands. The Structure Plan Authorities confirmed that it was their intention to produce a regular monitoring report on the Structure Plan, though no decision had been made as to its frequency.

1.19 In our view the Structure Plan should explain more clearly the joint arrangements which will be in place to ensure effective monitoring of the Plan. A monitoring report ought to be produced at least every two years. We also agree with those participants, notably the Government Office, who suggested that special arrangements might be needed to monitor and manage development within the CLPA. With six district planning authorities and Leicestershire County Council involved in development matters in the CLPA, it is imperative, in our view, that there is close liaison and co-operation to ensure that decisions are being made in line with the provisions of the Structure Plan, notably in applying the sequential approach to new development.

1.20 Turning to the technical aspects of monitoring, the Structure Plan’s approach to listing Key Indicators and Targets in Chapter 10 was generally supported by participants. We agree that it is helpful to relate the indicators and targets to the objectives and key policies in the Plan and to indicate possible sources of data and the relationship to other indicators. Some specific points related to the key indicators and targets in Chapter 10 were drawn to our attention. We consider that these should be addressed by the Structure Plan Authorities in finalising the Structure Plan.

1.21 Firstly, the target of 50% of new housing and employment development to be located on brownfield sites by 2021 was questioned. The Panel cannot see the value of setting a target so far ahead that it is outside the end date of the Plan. Moreover, it is not in line with PPG3 or Draft RPG both of which which set a target of achieving 60% of new housing on previously developed land by 2008. In Chapter 4 of this report we propose a similar target for the Plan area. We think that any target for employment development should be separate from housing. It should be challenging but realistic in comparison to what has happened in the past and the potential for future employment development on previously developed sites. It should also be clearly defined, that is whether it relates to the area of land developed, the number of jobs or some other indicator. In Chapter 2 we have more to say about other development targets identified in the locational strategy.

1.22 Secondly, attention was drawn to the absence in Key Indicator 4 of targets relating to biodiversity enhancement, although this features, alongside protection of existing assets, in the objectives and policies of the Plan. The Structure Plan Authorities indicated their intention to incorporate targets drawn from a recent Strategic Overview of Biodiversity Targets produced by a consortium led by English Nature. This is a matter to which we refer in Chapter 6 of this report.

1.23 Thirdly, the Housebuilders Federation and others emphasised the need to expand and refine the housing indicators under Key Indicators 13-16, especially in relation to demand factors such as house prices, homelessness and waiting lists, as well as factors under-pinning the Structure Plan housing requirements such as migration, commuting, vacancy rates and the like. Whilst we agree that these are matters that need to be monitored and reported upon, we do not think they need to be listed in Chapter 10, which is seeking to focus upon a limited number of the key development indicators directly influenced by the Plan. For the same reason, we question whether Key Indicator 18: Unemployment is appropriate since it is only indirectly affected by the objectives and provisions of the Structure Plan.

1.24 Fourthly, English Heritage highlighted the lack of any indicators or targets relating to the historic and built environment and agreed to work with the Structure Plan Authorities on filling this gap.

1.25 Finally, it was suggested that the waste management targets under Key Indicator 8 needed to be brought more closely in line with those in the national waste management strategy.

1.27 That Strategy Policy 1 be omitted as a separate policy and transferred to the explanatory memorandum as a highlighted statement of the Objectives of the Plan, amended as follows:

OBJECTIVES OF THE STRATEGY

The Plan aims to promote sustainable development and living by integrating social, environmental, economic and resource objectives, as follows:

Social

Environmental

(c) protecting and enhancing irreplaceable assets of the natural and cultural environment and ensuring that replaceable assets are identified and replaced if lost or increased where there is a deficiency;

(d) enhancing the quality of the built environment by promoting good design in both urban and rural areas so as to make them safe and attractive places in which to live and work;

Economic

(e) providing in a sustainable way for the land use and transportation requirements of businesses already within or wishing to locate to the Plan Area;

Resources

(f) securing patterns of development which integrate land uses and transportation provision, minimise the need to travel, minimise waste and pollution, promote the efficient use of energy and protect against the risk of flooding;

(g) ensuring that development makes the best use of existing infrastructure and that appropriate new infrastructure is provided in phase with new development.

1.28 That other statements related to the vision, aims and objectives of the Plan in the explanatory memorandum of Chapters 1 and 2 should be reviewed and more closely related to the above Objectives or to appropriate sections elsewhere in the Plan.

1.29 That terminology used in Strategy Policy 1 such as ‘replaceable’ and ‘irreplaceable’ assets should be clearly defined, in relation to other terms in the explanatory memorandum such as ‘constant’, ‘critical’ and ‘tradable’ capital.

1.30 That further explanation of the linkages between the Objectives set out above and the policies of the Plan should be incorporated both in the Strategy chapter and in the introductory sections of each topic based chapter, in the form of appropriate explanatory text, possibly accompanied by a matrix or chart.

1.31 That paragraphs 2.4-2.6, dealing with the CLPA, should be transferred to the explanatory text supporting new Policy 2 of the Plan.

1.32 That consideration should be given to introducing a new policy, or widening the scope of Resource Management Policy 3, to cover non-renewable energy development.

1.33 That robust arrangements should be put in place to ensure effective monitoring of the Plan, including special arrangements among the county and six district planning authorities covering the CLPA to monitor and manage development within that area. These arrangements should be outlined in the explanatory memorandum to Chapter 10 of the Structure Plan.

1.34 That the list of Key Indicators and Targets in Chapter 10 should be reviewed and refined, taking into account the points made in paragraphs 1.20 to 1.26 above.