Reigate and Banstead Inspector ‘significant concerns’ on DTC and Housing #NPPF

The papers can be found here – exploratory meeting 29th August.Probably the most important bellwhether findings under the new regime yet as it involves a SE LPA with large amounts of Green belt.

From the Council’s ‘Cross boundary issues and co-operation statement’ it is not clear to me that meaningful cross-boundary working has taken place. The statement summarises the consultations that have been undertaken with neighbouring planning authorities and other agencies, and purports to demonstrate how co-operation and joint working has helped inform the development of CS policy. There is also comment on joint development plan preparation and
reference to two mechanisms which currently involve joint working arrangements. But the statement fails to draw out the main strategic cross-boundary issues and their outcomes….

The section 33A duty relates only to strategic matters, defined as  sustainable development which would have a significant impact on either (i) at least two planning areas or (ii) a county matter. In the case of Reigate & Banstead, it seems to me that the main strategic matters with potential cross-boundary implications are the scale and distribution of housing development, Gatwick airport, and the provision of key infrastructure. For each of these matters the result of consultation and discussion with neighbouring authorities is required, including a comment on whether or not they are fully meeting their own assessed needs and if not, the arrangements that are in place for cross boundary provision.
Other key issues might include the approach to transport/travel, meeting gypsy/traveller accommodation needs and the role of Redhill/Reigate town centres…

My main concern is over the robustness of delivery of the housing development proposed in the CS and the lack of certainty about “Broad Locations” in the later part of the plan period. The Annex to this Note sets
out in detail my questions about the housing strategy. The main points are:
• What evidence base has been used to determine the need for market and affordable housing? Is continued reliance on the SEP housing requirement appropriate in light of more up-to date population and household forecasts?
• Housing delivery to meet the CS target in years 1-10 seems to be dependent on implementation of all the sites identified in the SHLAA and the trajectory – how realistic is this?
• The CS appears somewhat ambivalent about the need for Sustainable Urban Extensions (SUE), whereas the evidence points clearly to a gap in supply for which SUEs are the only option proposed. So as to provide a strategic framework for future DPDs, the CS should identify the broad geographic location of SUEs and their likely scale and timing.
• In identifying some types of Broad Locations, the Council appears to be quantifying windfalls which would be expected to come forward throughout the plan period; if this is correct, there will be a significant gap in supply in years 11-15.

The CS fails to grapple properly with the approach to be taken to the Green Belt. The proposed minor modifications (BP14) are an improvement on the submitted CS, but do not go far enough. Given the
strategic nature of the CS and the importance of Green Belt as a policy tool, the policies of the plan should acknowledge the need for Green Belt releases and give guidance on their implementation. It seems to me that, as a minimum, the principles under which Green Belt releases would be considered, including reference to the important ‘exceptional circumstances’ test required by NPPF paragraph 83, should be clearly set out in a CS policy.
11 It may be, for example, that Green Belt releases will be contemplated only for large scale SUEs, or they may also be considered appropriate for small scale boundary adjustments which would produce
boundaries which better meet the criteria of NPPF paragraph 85. Other circumstances may also exist. The role of the CS is to give clear guidance about the considerations to be taken into account when deciding at later DPD stage whether, and where, Green Belt releases can be justified.

The CS falls significantly short of what is necessary to satisfy the recently published “Planning policy for traveller sites” (PPTS). There is no identification in the CS of the scale of the local accommodation needs of
gypsies/travellers or travelling showpeople. It is not sufficient merely to state in the CS that need will be assessed by reference to the latest GTAA; PPTS is clear that pitch/plot targets should be set in Local Plans. Whilst it may be appropriate to adjust the need over time as future GTAAs become
available, the current requirement for the Borough is a strategic matter which should be explicitly addressed in the CS.