We (local Liberals) have submitted an objection to the Core Strategy on the basis that it's not a 'sound' plan.
The Barlick specific detail is towards the end of the post. The first parts deal with industrial land, greenbelt and general housing numbers.
Response to the Pendle Core Strategy Pre-submission Report by Pendle Liberal Democrats.
The Core Strategy is not consistent with national policy in relation to the Green Belt and the proposal to take Green Belt land for industrial land for the proposed Lomeshaye Industrial Estate extension in the vicinity of Fence/Wheatley Lane.
The National Policy Planning Framework (NPPF) states (paragraph 79) (our italics):
79. The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.
83. Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.
We agree that if Green Belt boundaries are to be changed, the new Local Plan is the process by which it should happen. We suggest however that there are no “exceptional circumstances” to warrant this change, and that a change at this stage drives a coach and horses through the idea that “the essential characteristics of Green Belts are…their permanence.”
The proposal to take this Green Belt land is based on a flawed or at the very least debatable assessment of the future need for industrial land, and a failure to consider adequately other options. It does not amount to “exceptional circumstances”. We do not think that merely by designating the land a “strategic site” amounts to exceptional circumstances in the absence of other compelling evidence.
The NPPF also states:
84. When drawing up or reviewing Green Belt boundaries local planning
authorities should take account of the need to promote sustainable patterns
of development. They should consider the consequences for sustainable
development of channelling development towards urban areas inside the
Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary.
We submit that the proposed extension into Green Belt adjacent to the village of Fence/Wheatley Lane is not a “sustainable pattern of development” and that the other options have not been fully considered.
We consider that the housing completion numbers that underlie the policies in the Core Strategy are fundamentally flawed. They are not deliverable over the period of the Local Plan and therefore the strategy fails on the criterion of Effectiveness.
The Council’s Development Viability Study of December 2013 shows quite clearly that this is the case. It states in its Conclusions and Recommendations that
6.9 It is clear that most…residential development in the parts of the M65 Corridor…is not viable in the current market. …this is reflected on the ground with the lack of actual development coming forward.”
It makes it clear that this is not due to current Council policies, but
6.10 […] It is more the case that weak development viability stems from low property values associated with limited demand inPendle.
It then goes on, illogically, to support the policies in the Core strategy, without any explanation of how or why the “limited demand” is going to change to any significant extent.
It is our view that the figure of 5,662 net dwellings (298 per annum) from 2011 to 2030 is hopelessly unrealistic, and the proposal to stagger this figure from 220 to 353 is just whistling in the wind, hoping for something to crop up on the basis of no evidence.
The actual figures for net dwellings in the last five years are:
2009/10 +29 -96 net -67
2010/11 +62 0 net 62
2011/12 +122 -61 net 61
2012/13 +69 -39 net 30
2013/14 +90 -27 net 63
TOTAL +372 223 net 149
The net number for 2011-14 (the first three years of this Local Plan) is 154, an annual rate of 51, which is already 514 dwellings behind schedule, even on the dubious annual phasing proposed.
It should be noted that many of the completions last year and those expected this year are from the Council-sponsored PEARL developments and not from the private sector, whose performance is even worse than that suggested by these figures.
The annual figures proposed are therefore hopelessly unrealistic and there is no evidence put forward that granting large numbers of additional planning permissions will make much difference. We therefore suggest that the annual figures of housing completions should be substantially reduced.
In line with this we suggest that the following sites should be deleted from the Strategic Land Availability Assessment (SHLAA) which provides supporting evidence for the housing numbers in the Core Strategy:
• Off Skipton Road, Barnmoldswick
• Behind Raikes Cottage, Barnoldswick
• Off Gisburn Road, Barnoldswick (Lane Ends Farm and Foster Road)
• At Wapping
• At Windermere Avenue/The Rough, Colne
• Lidgett Triangle, Colne.