NDP Regulation 14 Consultation
Following the Allensmore Parish Council’s approval of the draft Neighbourhood Development Plan at their meeting on 23rd May 2019, it was submitted to Herefordshire Council and other “statutory consultees” for formal public consultation under Regulation 14 of the Town and Country Planning, England, Neighbourhood Planning (General) Regulations 2012. The consultation period was from Monday 27th May 2019 to Friday 12th July 2019 – the period being 6 weeks and 5 days.
We had a total of 23 responses, 7 from the statutory consultees and 16 from the public. Here are some key points from the responses:
- Herefordshire Council commented: “overall the plan is well written and well researched … it is clear that the plan takes a positive approach towards identifying settlement boundaries and allocation of housing in line with the Core Strategy”. All our draft policies are deemed to be in conformity with the Core Strategy.
- There were further positive comments from Welsh Water, Historic England and Kilpeck Parish Council.
- The Environment Agency commented on the surface water flooding risk.
- Responses from Natural England and the Coal Authority made no specific comments.
The majority of public responses were extremely supportive which is very pleasing to report.
Several responses commented on the draft settlement boundaries, suggesting three amendments to extend the boundaries to include land owned by the respondents.
All the responses were discussed at length by the NDP Steering Group at their meeting on July 15th 2019. A couple of minor changes to the NDP were agreed at this meeting:
- In response to comments from Herefordshire Council and the Environment Agency, flood risk maps have now been included in the NDP.
- We agreed with the Herefordshire Council advice to add the following statement to policies A4 (Criteria for development) and A6 (conversion of former agricultural buildings): “Consideration should be given to the possibility of encountering contamination on sites as a result of former uses and specialist advice be sought should any be encountered”.
The Steering Group made a unanimous decision not to enlarge any of the settlement boundaries. There are several reasons for this decision:
- The draft settlement boundaries were originally drawn up in discussions with Kirkwells and Herefordshire Council consultants and are endorsed by Herefordshire Council in their Regulation 14 consultation response.
- We wish to retain the character of the settlements and reject any “double depth” development – policies that are supported by a significant majority of respondents in previous consultations.
- One of the sites that was suggested for inclusion came forward during the call for sites process and was deemed to be unsuitable by the independent assessors AECOM, whose report was formally and unanimously accepted by the Steering Group.
- None of the other suggested areas came forward during the call for sites process.
- The draft NDP preferred sites already deliver the minimum growth target with additional contingency.
- The draft settlement boundaries were overwhelmingly supported by local residents in previous consultations.
- There are considerable drainage challenges in some of the areas where respondents have suggested changes.
A full report of all the responses together with the Steering Group’s considerations is published on the Allensmore Parish Council website www.allensmore.org.uk.
The next stage is to prepare the final version of the NDP and supporting documents for approval by Allensmore Parish Council at their next meeting. It will then be submitted to Herefordshire Council for them to carry out the Regulation 16 Consultation and organise the referendum for local residents.
Recent Planning Applications
Although the draft NDP has now completed the Regulation 14 stage and therefore carries some increased importance in planning decisions, it can still be overridden by the Planning Committee.
We are very disappointed that this happened during a recent planning application when a site, deemed unsuitable in the draft NDP (as recommended by our independent assessors AECOM), was given outline planning approval. This was also despite the strong representations of our Parish Council at the decision-making meeting.
This underlines the importance of completing the NDP as soon as the necessary lengthy processes permit and bringing it before residents to ratify in a referendum. Until this happens, the NDP will not have full legal authority when any future planning decisions are made.
Nick Chapman, Allensmore NDP Steering Group – July 2019