With an admittance of having little knowledge of the Local Plan process, we fear that the Castle Point Local Plan2016 may have already come across some major difficulties.
One of the very first stages pre-examination is for the local authority to gather and submit evidence on how they have attempted to cooperate with neighbouring authorities.
“Local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before they submit their Local Plans for examination.
Local planning authorities must demonstrate how they have complied with the duty at the independent examination of their Local Plans. If a local planning authority cannot demonstrate that it has complied with the duty then the Local Plan will not be able to proceed further in examination.”
It appeared apparent to us, during the Local Plan Task and Finish group meetings that little evidence of cross local authority cooperation work had been published.
Now we learn of the Planning Inspector’s letter to cpbc, expressing an opportunity for cpbc to offer an explanation on the missing gaps in the required work.
It appears to us that the letter underlines the chasm between the level of commitment to the Local Plan2016 between officers and members.
At the recent Council meeting the council leader made light of the issues, but unless a united effort is made by officers and lead group members, the Local Plan2016 may have hit stormy waters less than one calendar month after it being submitted to the Planning Inspectorate!
The Inspector wrote on 22nd September;
1. As an initial matter the PPG makes reference to the submission of robust evidence by authorities of the efforts they have made to co-operate on strategic cross boundary matters (ID 9-012-20140306). This should include details about who the authority has co-operated with, the nature and timing of co-operation and how it has influenced the plan. Whilst some information is given at Section 4 of the DtC Report precise details are scanty. Future work through the South Essex Strategic Members Group and the completion of a written Strategic Planning Framework appear to be broadly in line with co-operation principles but clearly have no bearing on the preparation of the New Local Plan. In responding subsequently I therefore request that the Council provides specific detail of actions taken to seek the co-operation of key partners in relation to the preparation of the New Local Plan.
2. Section 4 of the DtC Report indicates that officers have come together since mid-2014 to consider strategic planning issues affecting South Essex. Prior to that was there any constructive, active and on-going joint working linked to the preparation of the New Local Plan? If so, what form did it take?
3. Section 4 also includes a list of cross-boundary planning issues. Compared to the topics identified in Appendix 1 communications infrastructure is omitted. Having regard to paragraph 156 of the NPPF and the PPG (ID 9-013-20140306) could the Council confirm the full list of strategic matters that, in its view, fall within the definition in Section 33A? Having done so it would be helpful to have a short resume of the steps taken to meet the DtC and to deal with questions 6, 7 and 8 in respect of each of these matters.
4. The PPG refers to the important role of Councillors in the DtC process (ID 9-0003 & 004-20140306). To what extent have Councillors been directly involved in any specific DtC activities?
5. Has the Council considered any more formal arrangements in terms of joint working on plan preparation as set out in the PPG (ID 9-01620140306) and as required by Section 33A(6) of the 2004 Act? If so, why have any such approaches including the use of formal agreements not come to fruition?
6. How have any DtC actions maximised the effectiveness of plan preparation?
7. How have any DtC actions influenced the preparation of the New Local Plan and what have been the outcomes?
8. What solutions have emerged to achieve effective strategic planning policies?
9. Regulation 34(6) requires details of action taken in co-operating with other bodies under Section 33A to be given in a monitoring report. Have any such details been provided in monitoring reports throughout the plan preparation period?
10. Paragraph 13.22 of the New Local Plan recognises that the housing target of 2,000 new homes by 2031 does not represent objectively assessed need but reflects the capacity of the Borough to accommodate growth. Paragraph 179 of the NPPF indicates that joint working should enable local planning authorities to work together to meet development requirements which cannot be wholly met within their own areas. In the light of the strategy proposed for Castle Point what specific steps have been taken or mechanisms are in place to distribute unmet housing need elsewhere in the Housing Market Area (HMA) or beyond?
11. What is the rationale for reducing the housing requirement from 4,000 in the Draft Local Plan to 2,000 in Policy H1 as referred on p12 of the Consultation Statement (CP/05/013)?
12. When were neighbouring authorities within the HMA made aware of the Council’s intention not to meet its full objectively assessed needs and of the reduction referred to above?
13. Has the Council considered whether it should meet any unmet housing requirements from neighbouring authorities?