TAG Response to the Publication Draft Wyre Local Plan 2017

Part C requires the following format

Q3a Do you consider the Local Plan “sound”? TAG’s answer No

Q3b Which part is not sound - section/ para/policy/allocation/other?

Q3c Please specify on what grounds - not positively prepared/ not justified/not effective/not consistent with NPP. (can tick more than one ground)

Provide details why

Q3d What modifications are needed?



This requires 8 representations from TAG to cover 8 topics (sections etc)

Rep 1 The spatial approach (The concentration of Development in the Fylde Coast Peninsula)

Policy SP1 Not justified/ not consistent

Great stress was laid on the options for development in the Issues and Options Document (2015) and residents were asked to choose which of the Options, given the evidence set out, would best meet the needs of Wyre over the Plan period. 755 responses were received of which well over 50% selected Option 2 which concentrated development along the A6 corridor with only moderate development in the Fylde Coast peninsula (FCP).

However, the Local Plan has ignored the results of the consultation (p52 4.1.1), proposing that 48% of housing in the LP period (2011-2031) be built in the FCP compared with 30% on the A6 corridor. This is not sustainable because there are more limited opportunities for employment in the FCP because of its problems of accessibility and consequently will lead to even more residents commuting to work outside the Borough. That outflow of residents to work already has increased in the 2001-2011 period by 3%.

In the LP it is admitted (see para 2.6.2 and Figure 2.6) that very little open space is left in the FCP. To put the amount of development proposed gives little consideration to the problems after 2031 when the needs of the local population will still have to be accommodated. Sustainability means looking to the future beyond 2031.

Modifications

The spatial approach to development should be one which concentrates development where it is most economically viable and sustainable i.e. along the A6 Corridor



Rep 2 Housing

Section 7.2 not justified/ not effective

The recognition that the OAN (Objectively Assessed Need) for 9580 dwellings to be built during the plan period is NOT achievable is to be welcomed. The target is now set at 8224 which amounts to 411 houses per year to 2031. Given that 1646 houses were built in the first 6 years (274 houses per year) there is a shortfall of 820 houses. Wyre has recognised that to spread this shortfall over the next 5 years is unrealistic (see para 7.2.2) but spreading the shortfall over the remaining plan period amounts to 59 additional houses per year. Thus the requirement for new houses is 470 rather than 411 per year.

The LP is not sound in this respect because that amount of new housing cannot be delivered in the time period. This is illustrated by the proposals for Lamb’s Hill where 437 houses are proposed but the developers indicate that only 360 can be delivered. The reasons for this are a combination of the finite limit to resources available and the number of new houses the market can support.

The amount of new housing in Wyre is also unjustified. The LP states that the population of Wyre will increase by 6% between 2011 and 2032. (para 2.3.3) In 2011 there were 47281 households in Wyre. The LP will increase the number of houses (= households) by 8224, an increase of 14.8%. Thus there is no correspondence between population growth and expansion of housing. This is made all the more obvious when the plans for adjacent LPAs are looked at. Using the 5 year housing target 2015-2020 the figure for Blackpool is 1540, Fylde 1850, Preston 2535 and Wyre 2350. The increase in the number of houses in Wyre cannot be justified in terms of overspill from neighbouring boroughs, since all boroughs are rapidly increasing their supply.

Modifications

The number of additional houses to be built in Wyre in the Plan period needs to be reduced to match the projected increase in population.



Rep 3 Development and the Risk of Flooding

Section 2.9.15 not consistent with NPP

For many of the proposed developments, areas within Flood Zone 2 and 3 are to be avoided for building. E.g. regarding Lamb’s Road “Housing will not be acceptable within Flood Zone 2 or 3.” Yet in the Hillhouse mixed zone it is proposed to build 250 houses in Flood Zone 3. At Pilling Area SA10 also lies in Flood Zone 3. It is not sustainable to permit housing to be constructed in Flood Zones 2 and 3, given the likelihood of those areas being flooded.

Modifications

Areas in Flood Zones 2 and 3 should not be allocated for new housing



Rep 4 Affordable Housing

Section 7.4 not effective

The LP stresses the need of the local population for affordable houses and smaller homes for both older and younger people. The affordable need (para 7.4.2) is assessed as 134 p.a. from 2017-2022 and 189 p.a. 2023-2031. Without taking into account any shortfall, 33% of all new housing needs to be affordable 2017-22 and 46% in the rest of the plan period. Given that only 30% of housing in new developments of over 10 houses needs to be affordable, the figures of 33% and 46% are unrealistic. The track record shows that nothing like these percentages has been achieved. As an example of the 100 houses on Bourne Way, 10 are affordable and 47 are 4 bedroom detached houses.

Modifications

The % of affordable housing in new developments needs to be raised to match the needs identified



Rep 5 Green Infrastructure (GI)

Section 2.9.12 not consistent with NPP

It is noted that a Supplementary Planning Document (SPD) is to be written in relation to inter alia Green Infrastructure (GI). However, GI is a vital area of land use which needs to be addressed as part of the LP. Without this consideration the LP must be considered unsound.

The GI Strategy was designed to guide the LP so that the Strategy would be implemented. Yet the LP refers only briefly to the GIS and nowhere is there reference to how the GIS has been used to justify the provision of existing Open Spaces and the provision of new ones. For example the GIS identifies the FCP as an area where needs of society (Figure 8 p16 GIS) are not being met at present. However, no discussion of this occurs in the LP as to how and where this can happen.

The development maps of the LP identify open space areas with green cross hatching but again there is no examination of why these areas have been included nor the justification for their inclusion. For example, Poolfoot Farm has green cross hatching but is a private facility and not available for public use as are indeed school playgrounds. In order to be sustainable the LP needs to set out where different types of Open Space will be provided for public use in relation to the housing developments being proposed.

The GIS sets out (see p66 of the LP) the Open Space Standards set for Wyre both in quantity (hectares per 1000 population) and access (measured in a straight line). For example, the “Amenity Green Space Standard” is 0.40 ha. per 1000 population and an access of 720m. Nowhere in the LP is there any discussion of whether these standards have been met and if not, how they will be achieved. The statement the “the Council will determine the most appropriate type and means of Open Space provision …” is worthless when it comes to the provision of Open Space.

The GIS (p21 6.10 GIS) identifies a lack of trees and woodlands in Wyre, and the advantages of better tree provision as well as the need to create green corridors for wildlife. Yet there is no overall plan to achieve this in the LP although there are loose proposals for specific sites. Regarding Lamb’s Road SA 1/2, the LP mentions tree planting and on-site Open Space and a “rural transition zone between the development and the wider countryside and coastline…an appropriate buffer is required”. What is an appropriate buffer? Where will it be located? The ecological impact of development on the Ramsar/SSSI site of the Wyre Estuary needs much more detailed analysis to achieve the sustainability required.

From the proposals map it is noted that the football pitch north of Bourne Way (in Flood Zone 3) will remain as Open Space. This is not mentioned in the text and needs a much stronger policy for protection (as do all Open Spaces) than that set out in the LP.

Modifications

A much clearer policy on GI needs to be established.



Rep 6 Schools etc

Section 2.9.5 not consistent with NPP

Wherever development is proposed it is essential that consideration is given to which land needs to be used to provide services for the incoming population. Regarding school provision, 4138 dwellings are planned for the FCP over the LP period. This will require the building of new schools and/or expanding existing schools. This will need land to be identified for this purpose. Yet no land is identified in the LP. The proposal for Lamb’s Road states “the development should make land available for a new primary school….” But there is no consideration of where the school might be located and how this fits in with Stanah School which is surrounded by the development.

The same proposal refers to a Master Plan “covering the whole of the site to be agreed by the LPA prior to the granting of planning permission for any part of the site”. Yet planning permission for the first 160 houses has already been given with no Master Plan even formulated. Thus the LP contradicts what Wyre Council has already permitted.

Modifications

The need for additional schools and medical and other services arising from the proposed developments must be assessed and land allocated in the LP for this purpose.



Rep 7 Transport

Section 2.9.5 not consistent with NPP

TAG was involved in the consultation process and Public Hearing relating to the Area Action Plan (2008). That Plan set out the traffic flows which were predicted as a result of the development and the amount of contributions required from the developers for sustainable transport measures (£10 million) and junction improvements on the A 585 (£10 million). None of this money has been forthcoming.

The LP does not have any transport survey. What increase in traffic will occur as a result of the propose developments? How will the increases in traffic flows be catered for? What improvements will need to be made in terms of both sustainable measures (cycle ways, bus services etc.) and road alterations? How much will this cost and what contributions will be required from the developers? There is a big gap in the LP.

Even where it is recognised that a new road will be needed for a development to go ahead (Lamb’s Road) there is no indication of which route it will take or when or if it will be built (“primary access into the site should be from a new road”).

Modifications

A Traffic Impact Assessment needs to be carried out so that traffic flows can be predicted and necessary road improvements and sustainable measures carried out which includes identifying sources of funding.

Rep 8 Air Quality

Section 2.6.13 not consistent with NPP

This is an important issue which apart from a paragraph stating that air quality is measured at certain locations is not examined in the LP. At present there is no measurement of air quality on Fleetwood Road through Thornton – a route used by too many HGVs and close to two primary schools, There must be a policy on monitoring air pollution in Wyre and addressing the growing problem. What does this omission say about the attitude of Wyre to our children’s health?

Modifications

There needs to be clear policy on tackling the issue of air quality