The New Dorset Unitary Authority has released its reg 18 consultation on its new local plan.
This is an exciting time for planning in the new unitary authorities like here and Bucks. They are no burdened by the problems of governance and the ‘liberium veto’ unanimity rule that has burdened plan such as for Greater Manchester. But that isnt the real problem. Even when there is agreement many plans with strategic policies have failed – like West of England and North Essex.
The classic problem repeated here again and again and also stated by many commentators at conferences etc. is a lack of meaningful consultation on strategic options (‘early engagement’ in the language of the SEA directive.
I quite looked forward to the Dorset consultation. An opportunity for some fresh thinking. My heart sunk. The documentation is unmanageable, nearly 600 pages, It looks for all the world like documents written by officers from the five predecessor authorities just glued together.
What is worse it is simply presented as a narrative of what the plan is going to say, without any serious discussion of (realistic) strategy alternative options. For example.
I’ll give an example:
In the central Dorset functional area housing growth will be delivered:
at the county town of Dorchester, including through major urban extensions at
Poundbury and North of Dorchester;
at the major coastal resort of Weymouth, including through town centre regeneration and a major urban extension at Littlemoor;
through regeneration within the settlements on Portland;
through the significant expansion of the town of Chickerell and the larger village of Crossways / Moreton Station and the smaller-scale expansion of the larger villages of Charminster and Puddletown; and through windfall and infilling within existing settlements defined by local plan or
neighbourhood plan development boundaries.
Across the central Dorset functional area, employment growth will be delivered through:
infilling and intensification within existing employment sites;
further commercial development at Poundbury;
the development of allocated sites at Littlemoor and Crossways / Moreton Station; and
substantial new development at North of Dorchester
As it says
A major urban extension to the north of Dorchester was identified as a ‘preferred option’ in the review of the Joint Local Plan. Further work has been undertaken to refine this proposal, which is also
taken forward in this local plan.
On the Green Belt it even sets down sites where exceptional circumstances exist without explaining what these are.
The plan clearly states that this is an early stage of the process (obviously reg 18) with only SEA scoping at this stage, the next stage being a draft plan, proferred option sites and SEA.
I don’t think the regs are helpful. Reg 18 was designed to be as flexible as possible and didn’t specify any stage. But it failed to incorporate the SEA directive requirement for early engagement on realistic alternative options. To many reg 18 options are aspatial and a waste of time, seemingly just warming up documents stating we have some tough decisions to make, be scared growth is coming, we arnt saying where and its all the governments fault. In the response to the White Paper submission it should get back to two simple stages with a tighter timescale – draft plan and deposited plan. That approach worked well and we shoul get back to it. The wolly ‘flexibility’ of reg 18 simply allows LPAs to tie themselves in knots and hang by the rope they have made.
Imagine you are Dorhester Town Council. Dorset Council is saying it is an early stage and their is no draft, however it is sticking by a plan for Dorchester which is bolted on from an old preferred option. They are claiming they have to take an ‘unfair share’ of growth with North Dorchester. They may well be wrong but they are right in seeing the process as a stich up. This is not meaningful consultation.
I think Dorset should withdraw the document. It can only end in tears at examination. Either they do a reg 18 document which presents genuine strategic alternatives openly – after all the combined new authority is in no way legally bound by previous no submitted plans and cannot be – or it prepares now a genuine reg 19 draft plan presenting realistic alternatives in the SEA. After all they havnt even done a strategic call for sites yet.
Judicious editing should be able to reduce the size of the document to less than 100 pages.
There are real alternatives here, with the tight Green Belt and AONB constraints the options for strategic scale growth are limited in number.
(By the way I think the North Dorchester proposal is in the right broad area but has a horrible urban design. They make the classic Aylesbury mistake of having a distributor road double up as a bypass and driving it through the middle ensuring the proposal will be car dominated and high carbon. There is no realsitic prioritisation of public transport or cycling on the form)
Pingback: CPRE Agrees with me – at Least on Dorset Local Plan | Decisions, Decisions, Decisions