Part 1
REPORT OF THE DEPUTY DIRECTOR OF HOUSING AND PLANNING
TO THE LEAD MEMBER FOR PLANNING
FOR DECISION ON 16 SEPTEMBER 2008
TITLE: CORE STRATEGY ISSUES AND OPTIONS REPORT
RECOMMENDATIONS:
That Lead Member for Planning:
1. Approves the Issues and Options Report, and the accompanying
Sustainability Appraisal Report, for public consultation
2. Approves the publication of a determination that the Core Strategy is likely to
have significant environmental effects and therefore must be subject to a
strategic environmental assessment
3. Endorses the proposed consultation arrangements for the Core Strategy
EXECUTIVE SUMMARY: The Core Strategy will form the central part of Salford’s
Local Development Framework. The Issues and Options Report is the first major
consultation stage of the Core Strategy production process. It sets out a spatial
vision, a series of strategic objectives, and four strategic options for delivering the
vision and objectives. Option 1 is based very much around the current policy
approach, with Options 2 and 3 seeing a moderate evolution of that approach. Option
4 proposes significant greenfield release in Salford West, including some Green Belt,
in order to deliver more family housing, but raises concerns around sustainability,
compliance with national and regional policy, and whether it would fully deliver the
proposed vision and objectives. The Issues and Options Report is accompanied by a
Sustainability Appraisal Report.
BACKGROUND DOCUMENTS: None
ASSESSMENT OF RISK: In order to minimise the risk of the Core Strategy being
found to be ‘unsound’ when it is subject to an independent examination later in the
process, it is essential that the city council can demonstrate that all reasonable and
realistic options have been considered given the evidence available.
SOURCE OF FUNDING: LDF budget
LEGAL IMPLICATIONS:
Contact Officer and Extension No: Richard Lester (0161 793 2129)
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Date Consulted: 22 August 2008
Comments: Production of these documents is a statutory requirement. There are no
adverse legal implications arising out of this report.
FINANCIAL IMPLICATIONS:
Contact Officer and Extension No: Nigel Dickens (0161 793 2585)
Date Consulted: 22 August 2008
Comments: Whilst the implications can be managed from the LDF budget, the
consequence is such that this is now fully committed for the current year and in all
probability next year as well.
COMMUNICATION IMPLICATIONS: Press release required; summary leaflet to be
sent to every address in the city (see section 4 of this report for further details)
VALUE FOR MONEY IMPLICATIONS: N/A
CLIENT IMPLICATIONS: N/A
PROPERTY: The Core Strategy will provide the strategic planning framework for the
city, and therefore could have some impact on the city’s property portfolio
HUMAN RESOURCES: N/A
CONTACT OFFICER: David Percival
Extension No: 3656
WARD(S) TO WHICH REPORT RELATE(S): All
KEY COUNCIL POLICIES: Local Development Framework
DETAILS:
1.
Background
1.1
It is a statutory requirement for the city council to produce a Core Strategy.
Government guidance states that the Core Strategy should set out the long
term spatial vision for the authority’s area and the strategic policies required
to deliver that vision. It will effectively provide the main framework for all of the
city’s planning activities, particularly in terms of the determination of planning
applications and the production of other planning documents.
1.2
It is important to note that the Core Strategy should be a high-level document.
It should not repeat national or regional guidance, but must be consistent with
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such guidance. Additional detail would be provided in the Allocations
Development Plan Document, a range of Supplementary Planning
Documents, and other strategies, masterplans, etc.
2.
Process for producing the Core Strategy
2.1
The process for producing the Core Strategy is governed to some degree by
primary legislation and statutory instruments. Recent changes to The Town
and Country Planning (Local Development) (England) Regulations 2004 have
provided more discretion for local authorities, particularly in the early stages of
the process, although Government Office for the North West, the Department
for Communities and Local Government, and the Planning Inspectorate have
all offered strong advice as to what they consider are the minimum
requirements. Such advice has informed the process set out below.
Initial work
2.2
A significant amount of work has been undertaken assembling and analysing
baseline evidence, and assessing the results of other recent public
consultations undertaken by the city council. In addition, three strategic spatial
planning questions were included in the recent Big Listening survey to help
inform the development of the Core Strategy.
Issues and Options Report
2.3
Government guidance emphasises that the Core Strategy must be properly
justified, in terms of being founded on a robust and credible evidence base,
and being the most appropriate strategy when considered against the
reasonable alternatives1. It states that:
Being able to demonstrate the plan is the most appropriate having gone
through an objective process of assessing alternatives will pay dividends in
terms of an easier passage for the plan through the examination process [see
below]. It will assist in the process of evaluating the claims of those who wish
to oppose the strategy2.
2.4
The purpose of the Issues and Options Report is therefore to summarise the
key issues that the Core Strategy needs to address, having regard to the
evidence available and the contents of other plans and strategies, and to
identify what are considered to be the reasonable and realistic alternatives for
addressing those issues and delivering an agreed vision. Government
guidance is clear that: “There is no point inventing alternatives if they are not
realistic”3, but equally it is important to consider all options that could be
appropriate and deliverable in order to ensure that the document is as
effective as possible.
2.5
This is the first opportunity in the Core Strategy process for widespread
stakeholder involvement, and an 8 week consultation period on the Issues
and Options Report is proposed starting on Friday 17 October 2008. It is an
opportunity not only for people to comment on the options that are being
considered, but also to propose alternative options and identify other issues
and evidence that needs to be taken into account. Details of the contents of
‘Planning Policy Statement 12: Local Spatial Planning’ – DCLG (2008), paragraph 4.52
‘Planning Policy Statement 12: Local Spatial Planning’ – DCLG (2008), paragraph 4.38
3 ibid
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2
3
the Issues and Options Report and the proposed consultation arrangements
are set out later in this report.
Identification of the option to be taken forward
2.6
Following an analysis of the results of the Issues and Options consultation, a
further four week consultation is proposed in April/May 2009. The purpose of
this second stage consultation will be to:

Publicise the main issues raised during the Issues and Options
consultation, and in particularly any alternative options that have been
suggested

Set out the option, or combination of options, that the city council is
intending to proceed with (this will be in outline, rather than consisting
of detailed policy wording)
Draft Core Strategy
2.7
The chosen option will then be worked up into a full draft Core Strategy, which
will be published in October 2009. It is important that this is the version of the
document that the city council would ultimately wish to adopt, as there is no
scope for making ‘pre-inquiry changes’ as was done with the UDP without at
the very least repeating this stage and delaying the independent examination.
2.8
There would be a period of at least six weeks following publication for people
to make representations on the draft Core Strategy.
Submission of the draft Core Strategy
2.9
The draft Core Strategy then needs to be submitted to the Secretary of State
for an independent examination. All of the representations received on it,
together with a summary of the main issues they raise, also need to be
submitted. As a result, there is some delay between publication and
submission, with the latter not taking place until March 2010.
Public examination
2.10 The public examination into the draft Core Strategy will be overseen by an
independent inspector appointed by the Planning Inspectorate. They will seek
to test the legality and soundness of the document.
2.11
In terms of legality, the Core Strategy will need to:

Have been prepared in accordance with the Local Development
Scheme, the Statement of Community Involvement, and Government
regulations

Have been subject to a sustainability appraisal

Conform generally to the Regional Spatial Strategy

Have regard to Salford’s Sustainable Community Strategy
2.12
In terms of soundness, the Core Strategy will need to be:

Justified (see paragraph 2.3 above)

Effective (deliverable, flexible, and able to be monitored)

Consistent with national policy
2.13
It is anticipated that the public examination will take place in June-July 2010.
The inspector may invite some of those who have made representations to
appear at the examination, as well as other stakeholders who have not
commented.
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Adoption
2.14 The recommendations of the inspector will be binding on the city council. It is
anticipated that the inspector’s report would be received in October 2010, with
adoption taking place in January 2011.
3.
Contents of the Issues and Options Report
3.1
The Issues and Options Report includes a ‘spatial portrait’ that sets out the
main spatial issues currently affecting the city. This is followed by a ‘spatial
vision’ for how Salford should be in the year 2027, and a series of strategic
objectives for delivering that vision. The strategic objectives are generally
target-based and locally specific. They are intended to be headline objectives,
rather than comprehensively covering every aspect of the Core Strategy.
Broader and more generic objectives are included in the accompanying
sustainability appraisal.
3.2
The majority of the report focuses on setting out four strategic options for
delivering the spatial vision and strategic objectives. These are summarised
initially, and then set out in detail in a series of topic-based tables. Some of
the elements of the options are potentially interchangeable, meaning there
are effectively options within options, but the different elements have been
packaged together to help people understand the overall strategic decisions
that need to be made as well as the choices on individual issues.
3.3
The four strategic options can be summarised as follows:
1)
Where we are heading = essentially takes forward current policy
approaches, with a general emphasis on high density development
within the urban area
2)
Moderate change in approach = involves slightly higher levels of
redevelopment and change within the urban area, with the Regional
Centre and the rest of Central Salford not dominating quite as much
as in Option 1, and effectively offers a compromise between Options 1
and 3
3)
Maximising opportunities across the city = involves a greater level of
investment and change across the whole urban area, with more
development opportunities in Salford West and more investment in
new transport infrastructure
4)
Major greenfield release = involves significant release of greenfield
land in Salford West, including some of the Green Belt, to provide
more opportunities to build houses rather than apartments
3.4
Given that they are all seeking to deliver the same spatial vision and strategic
objectives, there are many similarities between the options. For example, they
all seek to deliver a net increase of 38,600 dwellings over the period 20072027, they all include major proposals such as MediaCityUK and Irwell City
Park, and they all support ongoing regeneration in Central Salford.
3.5
However, there are also some significant differences, which essentially fall
into two categories:
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a)
The overall spatial approach – the distribution of housing in particular
varies between the four options. All of them have very similar levels of
additional housing in Central Salford outside the Regional Centre, but
the balance of the remaining housing between the Regional Centre
and Salford West varies significantly with the proportion in the latter
increasing from Option 1 through to Option 4. This is achieved in
Options 2 and 3 by releasing more of the existing employment estates
for housing redevelopment, but in Option 4 it also includes the release
of around 35 hectares of Green Belt and 50 hectares of other
greenfield land for housing. The spatial distribution of new
employment opportunities also varies, with Option 2 supporting the
Cutacre proposal, and Options 3 and 4 also proposing the release of
around 40 hectares of Green Belt at Barton for employment use, with
replacement Green Belt being designated around the western edge of
Little Hulton
b)
The strength of the policy approach – there are some exceptions, but
generally the strength of the policy approach proposed increases from
Option 1 through to Options 3 and 4. For example, the proportion of
affordable housing sought increases, the space standards for new
dwellings increase, and the approach to renewable and decentralised
energy strengthens. However, many policy proposals are common to
all four options.
3.6
Option 4 has been included because of concerns expressed by some
stakeholders that the supply of new dwellings is dominated too much by
apartment development within the Regional Centre, and that there need to be
more houses provided particularly in Salford West in order to attract and
retain families, and to improve the overall housing offer to support economic
growth objectives. Option 3 already involves the loss of a considerable
number of Salford’s existing employment areas to housing, and the only way
more sites for a significant number of additional family houses could be made
available without potentially compromising the city’s economic base would be
to release relatively large areas of greenfield land, including Green Belt,
around Walkden, Boothstown/Ellenbrook, Worsley and Irlam (with some much
smaller areas around Swinton/Wardley).
3.7
This approach would help to deliver a more equal balance between
apartments and houses in the new dwelling stock, but it comes at the
expense of a number of other important objectives. In particular,

It begins to water down the strong prioritisation given to the Regional
Centre and the rest of Central Salford, and therefore risks falling out of
line with Policy RDF1 of the emerging Regional Spatial Strategy

It would result in the net loss of Green Belt land, contrary to the spatial
vision and one of the strategic objectives (xx)

It would result in the proportion of new dwellings that are provided on
previously-developed land falling below the 90% target in the
emerging Regional Spatial Strategy

It would involve major greenfield residential development when
sufficient previously-developed land within the urban area is available
to accommodate the scale of housing proposed albeit at higher
densities
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
3.8
Of its environmental impacts as identified through the sustainability
appraisal (see below and the separate Sustainability Appraisal
Report), particularly when compared to the other three options
As a result, the Issues and Options report includes the following statement:
The city council considers that there would need to be special
justification for Option 4 to be taken forward, and that there would need
to be clear evidence that the other three options were not appropriate
and were unable to deliver the spatial vision.
3.9
A copy of the Issues and Options Report is attached. Maps and diagrams
have been produced as a separate appendix at present, but will be integrated
throughout the document when it is transferred into the published format. It is
also intended that a Background Report should be published setting out the
evidence underpinning the Issues and Options Report and the four strategic
options within it. This is currently in production and will be reported in due
course.
4.
Consultation proposals
4.1
The consultation and publicity arrangements for the Issues and Options
Report are currently being finalised, but it is envisaged that they will include
the following:

6 page summary leaflet, including a questionnaire, sent to every
address in the city (distributed early November)

Letters sent to key organisations and others who have registered an
interest in the Core Strategy (including a copy of the Issues and
Options Report and accompanying documents where appropriate)

A stakeholder event for community representatives (end October)

A stakeholder event for planning professionals (end October)

Salford West business breakfast (mid October)

Drop-in events at libraries and sports centres

Press release

Advert in the Salford Advertiser (16 October and 13 November)

Adverts on Salford Community Radio

Facebook page, and possibly a linked video

Housing and Planning staff event

Articles on the Intranet and in TheOne
4.2
Discussions are ongoing to determine additional measures required to
engage with hard to reach groups.
5.
Sustainability appraisal and strategic environmental assessment
5.1
A Sustainability Appraisal Report (SA Report) has been produced (copy
attached) to accompany the Issues and Options Report, which will need to be
updated at each stage of the Core Strategy production process. It assesses
each of the four strategic options against 21 sustainability objectives, and also
assesses the ‘no plan’ option (which means relying on the existing UDP and
emerging Regional Spatial Strategy, i.e. no Core Strategy, rather than there
being no plans at all).
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5.2
The Sustainability Appraisal Scoping Report published in July 2007 concluded
that the Core Strategy would be likely to have significant environmental
effects, and therefore must be subject to a strategic environmental
assessment and an Environmental Report must be produced accordingly. The
SA Report incorporates the requirements for an Environmental Report under
the Environmental Assessment of Plans and Programmes Regulations 2004,
and the relevant sections in this regard are highlighted at the start of the SA
Report.
5.3
The city council must publish a formal determination that a strategic
environmental assessment is required, in accordance with Regulations 9(1)
and 11 of the aforementioned regulations. It is therefore proposed that the
following should be published on the city council’s website and sent to Natural
England, English Heritage and the Environment Agency, with a similar
statement included in the SA Report:
In accordance with Regulation 9(1) of The Environmental Assessment of
Plans and Programmes Regulations 2004, following consultation with
statutory bodies, the city council has determined that the Core Strategy
is likely to have significant environmental effects, and therefore must be
subject to a strategic environmental assessment in accordance with the
requirements of European Directive 2001/42/EC (the SEA Directive).
5.4
It has been concluded that an appropriate assessment in accordance with the
Habitats Directive, appraising in detail the potential impacts on Natura 2000
sites, would not be required. This conclusion has been reached in part having
regard to the appropriate assessment of the emerging Regional Spatial
Strategy.
6.
Conclusions
6.1
It is recommended that the Lead Member for Planning:
1)
Approves the Issues and Options Report, and the accompanying
Sustainability Appraisal Report, for public consultation
2)
Approves the publication of a determination that the Core Strategy is
likely to have significant environmental effects and therefore must be
subject to a strategic environmental assessment
3)
Endorses the proposed public consultation arrangements for the Core
Strategy
Bob Osborne
Deputy Director of Housing and Planning
Appendices :
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Sustainability Appraisal Report
:
Issues and Options Report
9