Agenda item

Context:

           

To outline the purpose, key findings and conclusions of the Local Development Plan (LDP) second Annual Monitoring Report (AMR).

 

The Planning Committee was invited to attend the meeting alongside the Select Committee to scrutinise the report.

 

Key Issues:

 

The Monmouthshire LDP 2011-2021 was formally adopted by the Council on 27 February 2014.  As part of the statutory development plan process the Council is required to prepare an Annual Monitoring Report (AMR).

 

The Annual Monitoring Report

 

The AMR provides the basis for monitoring the effectiveness of the LDP and ultimately determines whether any revisions to the Plan are necessary.  It aims to demonstrate the extent to which the LDP strategy and objectives are being achieved and whether the Plan’s policies are functioning effectively.  It also allows the Council to assess the impact the LDP is having on the social, economic and environmental well-being of the County and identifies any significant contextual changes that may influence plan implementation or review.

 

This is the second AMR to be prepared since the adoption of the Monmouthshire LDP and is based on the period 1 April 2015 – 31 March 2016. 

 

LDP Monitoring Framework

 

The LDP policy and sustainability appraisal (SA) monitoring frameworks form the basis for the AMR, assessing how the Plan’s strategic policies, and associated supporting policies, are performing against the identified key monitoring targets and outcomes and whether the LDP strategy and objectives are being delivered.  This has enabled the Council to make an informed judgement of the Plan’s progress in delivering the targets / monitoring outcomes and policies during this monitoring period.

 

Key Findings

 

Section 5 of the AMR provides a detailed assessment of the Plan’s performance.  The results of the monitoring process demonstrate that many of the indicator targets and monitoring outcomes are being achieved.  Some of the most significant findings in relation to these are:

 

·         Progress continues to be made towards the implementation of the spatial strategy.

 

·         Affordable housing policy targets set out in Policy S4 are generally being met in relation to planning permissions granted in the main towns and main villages.

 

·         The County has a total of 41.8ha of employment land available, indicating that sufficient employment land is maintained to meet the identified take up rate.

 

·         There has been progress in terms of employment permissions within the County, with permissions granted for a range of employment uses on identified business and industrial sites (SAE1), protected employment sites (SAE2) and non-allocated sites (totalling 4.48 hectares). These were predominantly in Severnside.  Permission was also granted for 3.72 hectares of land at the LDP strategic mixed-use site at Wonastow Road Monmouth. 

 

·           A number of rural diversification and rural enterprise schemes have been approved (10).

 

·           The Council approved proposals for a total of 10 tourism facilities, 8 of which related to tourist accommodation.  There were no applications permitted involving the loss of tourism facilities.

 

·           Vacancy rates in the central shopping areas in all of the County’s town and local centres remain below the national average.

 

·           The proportion of A1 retail uses within the towns’ Primary Shopping Frontages generally accord with the thresholds identified in the Primary Shopping Frontages SPG.

 

·           A total of 5 community and recreation facilities have been granted planning permission and no applications were permitted involving the loss of community / recreation facilities.

 

·         There has been no loss of listed buildings or historic sites and no development permitted which would have an adverse impact on the historic environment.

 

·         Progress is being made towards the total waste management capacity for the LDP period and there has been no reduction in the minerals land bank.

 

·         A total of 8 schemes incorporating on-site renewable energy generation were permitted (excluding householder, change of use and agricultural use).

 

·         There were no developments permitted in C1 / C2 floodplain areas which did not meet TAN15 tests.

 

There are, however, several key policy indicator targets and monitoring outcomes relating to housing provision that are not currently being achieved.  The most significant findings in relation to these are:

 

·         A total of 234 new dwelling completions (general market and affordable) were recorded during the current monitoring period. This, coupled with the 205 completions recorded during the last monitoring period, equates to a total of 439 completions since the Plan’s adoption. This is significantly below the identified LDP target of 488 completions per annum.

 

·         A total of 63 affordable dwelling completions were recorded during the current monitoring period. This, together with the 17 affordable dwelling completions recorded during the previous monitoring period, amounts to a total of 80 affordable dwelling completions since the Plan’s adoption. This is significantly below the identified LDP target of 96 affordable dwelling completions per annum.

 

·         The Monmouthshire Joint Housing Land Availability Study (JHLAS) for the 2015-16 period demonstrates that the County had 4.1 years housing land supply (based on the residual methodology prescribed in TAN1).

 

·         There has been limited progress with the delivery of allocated strategic housing sites. With the exception of the Wonastow Road site, none of the strategic sites have obtained planning permission since the Plan’s adoption. Progress on the delivery of the LDP strategic housing sites is provided in the policy analysis section for Policy S3.

 

·         Permissions and completions in Severnside settlements were considerably below the identified LDP targets. 

 

This indicates that the LDP’s key housing provision policies are not being delivered as anticipated and the subsequent lack of a 5 year housing land supply is a matter of concern. The fundamental contributing factor to this shortfall is the slower than anticipated progression of allocated strategic housing sites, albeit that progress is being made in bringing these sites forward and there is no evidence to suggest that the allocations are not deliverable (as detailed in Section 5 of the AMR). Nevertheless, the slower than anticipated delivery rate does suggest that there is a need for additional site allocations.

 

Contextual Information

 

Section Three of the AMR provides an analysis of the relevant contextual material that has been published since the adoption of the Plan at a national, regional and local level, along with general economic trends.  This concludes that the changes identified to date do not suggest the need for an early review of the Plan.

 

Supplementary Planning Guidance (SPG)

 

Progress has been made in the preparation and adoption of SPG to help to facilitate the interpretation and implementation of LDP policy.  This is detailed in Section Three of the AMR. SPG preparation and adoption will continue in the next monitoring period.

 

Sustainability Appraisal (SA) Monitoring

 

Section Six of the AMR expands on the assessment of LDP performance against the SA Monitoring Objectives, providing a short term position statement on the performance of the Plan against a number of sustainability indicators. There is an overlap between some of the LDP and SA indicators helping to demonstrate how the two monitoring processes are interlinked.

 

Conclusions and Recommendations

 

Section Seven sets out the conclusions and recommendations of this second AMR.  The 2015-16 AMR concludes that while good progress has been made in implementing many of the Plan’s policies and that overall the strategy remains sound, a number of key housing provision policy targets are not being met which indicates that these policies are not functioning as intended. The lack of a 5 year housing land supply is a matter of concern that needs to be addressed if the Plan’s housing requirements are to be met.  

 

An early review of the LDP is therefore considered necessary because of the housing land supply shortfall. As there are no concerns with other Plan policies at this stage the AMR concludes that it is not considered necessary to review other aspects of the Plan at this time. Accordingly, the AMR recommends an early review of the Monmouthshire LDP as a result of the need to address the shortfall in the housing land supply and facilitate the identification and allocation of additional housing land. This will involve the production of a Review Report which will set out and explain the scope of the Plan revision required. The Plan revision is likely to involve the identification / allocation of additional viable and easily deliverable sites to boost the land supply. 

 

It is further recommended that this AMR be submitted to the Welsh Government in accord with statutory requirements.  The AMR will be published on the Council’s web site and publicised via the Planning Department’s Twitter account.

 

Next Steps

 

The Plan will continue to be monitored on an annual basis through the preparation of successive AMRs, with the broad structure of the AMR remaining the same from year to year in order to provide ease of analysis between successive reports.

 

Given the importance attached to the land supply issue an early review is considered necessary, as set out in the AMR. This would also assist in seeking to avoid ‘planning by appeal’ and ad hoc development coming forward outside the development plan system and not in accordance with the Plan’s strategy. However, it is also recognised that adopting a pragmatic approach to the determination of departure applications for residential development sites will assist in this context. 

 

The Regulations allow for a ‘selective review’ of part (or parts) of an LDP. Such a provision would allow for a partial review of the LDP to cover issues associated with the housing land supply and site selection, in accordance with the recommendation of the AMR. The Council, however, is required to commence a full review of the LDP every four years.  This would mean that a full review to meet statutory requirements would have to commence in February, 2018. It is considered, therefore, that it would be more appropriate for a review to be commenced to consider all aspects of the LDP at this stage in order to fully assess the nature and scale of revisions that might be required. An early full review will also assist in meeting the 2021 deadline for having an adopted revised LDP in place to avoid the local policy vacuum that the new Regulations threaten to create.

 

The commencement of a Plan review will require the preparation of a Review Report. This should set out clearly what has been considered, which key stakeholders have been engaged and, where changes are required, what needs to change and why, based on evidence; including issues, objectives, strategy, policies and the SA, as well as the implications of anticipated revisions on any parts of the Plan that are not proposed to be revised. It must also make a conclusion on the revision procedure to be followed, i.e. full or short form. The LDP Review Report may conclude that the issues involved are of sufficient significance to justify undertaking the full revision procedure. Alternatively, a short form revision procedure is available for circumstances where the issues involved are not of sufficient significance to justify undertaking the full revision procedure. The latter procedure may be the most appropriate in this case, given that the main issue is the shortfall in the land supply but this will be determined through the analysis to be carried out for the Review.

 

A report will be made to Cabinet seeking a formal resolution to commence a review of the LDP. Any comments from the Economy and Development Select Committee will be reported to Cabinet. Should Cabinet agree the recommendation to commence Plan review, a LDP Review Report would be produced for future political reporting, setting out a recommendation for the type of Plan revision (full or short). That decision would need to consider timescales, fit and the relationship with the emerging Future Monmouthshire work, Cardiff Capital Region City Deal work and a South East Wales Strategic Development Plan.

 

Member scrutiny:

 

Having scrutinised the report, the following points were noted:

 

·         In response to a question raised regarding land not coming forward and lack of supply, it was noted that there was a series of factors involved.  Sites have been allocated in the LDP.  However, the reasons are that as follows:

 

-       External market issues.

 

-       Calculation of how housing land supply is calculated.

 

-       Some of the Strategic Sites are a t various stages with regard to planning permission.  Some robust debate has been undertaken with applicants regarding viability issues.

 

-       Therefore, there a number of reasons, many of which are not within the control of the Planning Department.

 

·         The review will look at the policies and identify whether they are working and look at how policies relate to each other.  The review then recommends whether or not a revision takes place.

 

·         In response to a Member’s question regarding judicial reviews on the English sites close to the border with Monmouthshire, it was noted that these are not considered by the Planning Authority.  The housing need there is not within the housing need for our market area or a part of Monmouthshire’s LDP housing need.  Judicial reviews is a risk that the Planning Authority considers, in particular with regard to the bigger schemes.

 

·         The Housing needs review is assessed which looks at the need for affordable housing.  The next review will commence in April 2017. Any outcomes will feed into the LDP.

 

·         The wider housing need is a challenge to catch up on so there is a need to look at extending the plan.  The Welsh Government is making more grant funding available and the Authority will be looking to capitalise on this.

 

·         Concern was expressed by a Member of the Committee in that there were problems with regard to achieving building land and development land for businesses.  Less than 50% of houses have been completed and also less than 50% of affordable houses have been completed. No houses have been built on a strategic site and only one business has gone onto a strategic site. The proposal to provide additional sites could have a detrimental effect in certain areas such as Monmouth as the existing infrastructure and traffic issues would be exacerbated. The Head of Planning, Housing and Place-Shaping stated that there will always be a time lag on the bigger sites coming forward.

 

·         A full review could take in the region of two years to complete.

 

Committee’s Conclusion:   The Committee discussed the Local Development Plan (LDP) and Annual Monitoring Report (AMR) in depth and agreed that the report should be submitted to the Welsh Government.  Members furthermore supported the recommendation to commence the review of the LDP.  The Committee accepted that the review would determine whether there is a need for revisions of the LDP and agreed to await the conclusions of the review which would be reported back to the select committee. The Committee requested that an update report be brought to them in due course on the Community Infrastructure Levy, together with a list of applicable areas.  Members also requested that supplementary planning guidance on affordable housing be brought to a joint scrutiny meeting with Strong Communities and Adults Select Committees at the appropriate time.