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CONTENTS INTRODUCTION - The RPG process OVERALL POLICY
SUB-AREA ISSUES
POLICY AREAS
INTRODUCTION The RPG Process New Planning Guidance for the East Midlands will be published in Summer 2001. It will set the context for County Structure Plans and District Local Plans upto 2021. A Public Examination into the Draft RPG was held over 3 weeks in June in Leicester. Environmental groups working together through East Midlands Environment Link were strongly represented. Some of the major planning issues which emerged are:
The Draft RPG was prepared by the East Midlands Regional Local Government Association (LGA) - i.e. the local authorities (see: www.emrlga.gov.uk). The Public Examination was presided over by a Panel appointed by the Government composed of the Chair Jim Parke and a Planning Inspector Mary Travers, supported by Ken Mafham and Owen Rumbold who are based at the Government Office in Nottingham (details on: www.rpg-eastmids.go-em.gov.uk). The Panel published their report in October 2000 (available on www.go-em.gov.uk/rpg/report.htm). The Secretary of State will now produce a revised RPG in late February 2001. This will be drafted by the Government Office East Midlands (GOEM). There will then be a final consultation lasting 8 weeks. The final RPG will be produced by the Secretary of State a couple of months later. The Panel has recommended an early review of RPG in 2003 to cover at
least:
The purpose of this note is to flag up some of the points of dispute which could be of significance during the consultation. It does not attempt to cover everything of importance in the Draft RPG or the Public Examination. It is put forward as a basis for discussion. The Draft RPG first sets out principles for achieving 'Sustainable Development'. Then it puts forward policies for the built environment, natural and cultural environment, and transport. Finally it discusses policies for the five sub-regional areas. By the time it gets to the sub-areas, the principles of sustainable development have been largely ignored. To a large extent it is policies for these sub-areas which are the most significant and the most controversial. OVERALL POLICY The Draft RPG sets out the four main components of sustainable development:
Another problem is that the sustainable development policy is not adequately followed through into all parts of RPG, particularly policies for the Sub-Areas. For example, a Sustainability Appraisal of the Draft RPG found that policies for economic growth, trunk roads and East Midlands Airport were not compatible with objectives for social inclusion and environmental protection. The Panel Report addresses these problems. It recommends that the four aims should be achieved together as part of an integrated strategy, and also that the whole RPG should be developed in an integrated way. KEY ISSUE:
The 'sequential approach' is perhaps the most important new idea in the RPG. It aims to direct development to the most sustainable locations: where possible on previously developed sites in cities and towns. Where development outside cities and towns is needed, it requires that sites are well served by public transport and if possible on previously developed land. However, the Draft RPG compromised this aim by subordinating it to a policy based on criteria including 'marketability of sites', and by expecting 'different outcomes' in different Sub-Areas (which means more use of greenfield sites in the former coalfield areas). The Panel Report reverses this, subordinating the criteria to the sequential approach, and rejecting different interpretation in different parts of the Region. KEY ISSUE:
SUB-AREA ISSUES Most concerns relate to a projected massive expansion in both passenger and freight services, and lack of restrictions on noise, night-flying, traffic congestion, etc. The Panel Report supports the expansion of the Airport within the context of national policy, but tightens up the requirements for sustainability assessments. It also requires a shift of panssenger and freight access from road to rail in the longer term. KEY ISSUE:
(2) Development around the airport and M1 Junction 24 The developers put forward extensive proposals for business and housing development around J24. The LGA argued that these would undermine regeneration in the cities, overload the road network, and adversely affect access to the airport. These proposals were not pressed at the Public Examination. But the policy in the Draft RPG (para 7.34) in effect would allow in future any development which does not impede expansion of the airport. The Panel Report rejects further significant development around J24, and particularly rejects a prestige business park supported by the LGA. Inward investment should be focused on the three cities. KEY ISSUE:
(3) Greater Nottingham Greenbelt Greenbelts are supposed to be permanent, to prevent coalescence of settlements. The Nottingham Greenbelt has recently been subject to serious erosion as a result of a large amount of greenfield land being allocated for housing. There is almost coalescence along the Derbyshire border, and between Hucknall and Annesley. More land than is needed has already been taken out of the Greenbelt. Government guidance says that boundaries should be reviewed only if there are exceptional circumstances. The policy in the Draft RPG encourages a review even though there is no evidence of exceptional need. The Panel Report supports Government policy. It suggests that no change of boundaries should be needed in the current round of local plans. When structure plans are reviewed, land should be taken out of the Green Belt only if there are exceptional circumstances. However, the Panel ignored arguments that new Green Belts should be considered in Northamptonshire and around Lincoln. KEY ISSUE:
(4) Former coalfields of Notts and Derbyshire Draft RPG sets jobs against environment. It is based on promoting large greenfield sites (to allow for 'son of Toyota') and more roads. It fails to recognise the rural nature of much of the area. The LGA and East Midlands Development Agency (EMDA) argued that brownfield sites are not in the right place (close to where people live and transport infrastructure). EMDA has an option on a large greenfield site without rail connection at Penniment Farm, on the western edge of Mansfield - ignoring a large brownfield site at Shirebrook, just 4km away. They also want to fast-track development of a large site at Junction 29A (Markham Employment Generation Zone) even though this may require widening of the M1. Opponents include local authorities in South Yorkshire who argued that the lax approach in the East Midlands in promoting greenfield development will undermine brownfield regeneration in South Yorkshire using European Objective 1 funding. The Panel Report rejects development of greenfield sites, including Penniment Farm, until alternatives have been considered, in line with the Sequential Approach. It recommends a long term environmental strategy. It would require a full assessment of proposals at Junction 29A. KEY ISSUES:
(5) Northamptonshire and Southern Lincolnshire The main question is whether the South of Northamptonshire will become part of a Greater Milton Keynes. One proposal is for a new town and mainline station at Roade, just South of Northampton. The Panel Report supports a study aimed at targeting development in the Milton Keynes-Bedford-Northampton-Corby quadrangle. It argues that this should be based on the sequential approach and sustainable development objectives. Otherwise, there has been very little consideration of environmental constraints - e.g. shortage of water supply, risks of flooding, or threats to wildlife. In particular the Panel Report supports significant housing development in Corby, with no regard for wildlife sites. It also promotes the growth of Northampton. However, it recommends that Southern Lincolnshire should not be developed as overspill for Greater Peterborough. KEY ISSUES:
(6) Derbyshire Peak District National Park One significant issue in the Peak Park is the South Pennines Integrated Transport Strategy (SPITS). In particular, will the A628 cross pennine route be allowed to increase capacity to carry more freight? This would almost certainly fail the test required in National Parks that environmental benefits should outweigh disbenefits. Reopening the Woodhead tunnel to put more freight on the railways would probably pass the test. The Panel Report would defer these questions for a Multi-Modal Study. But it supports the Mottram-Tintwistle bypass on the A628, subject to the stringent environmental criteria applying to routes through National Parks. KEY ISSUE:
MAIN POLICY AREAS (a) New housing numbers The RPG has to allocate the new housing provision required in each Structure Plan area from 1996 - 2021. The main dispute at the Public Examination was between the LGA, which estimated 350,000 homes will be needed in the region, and the developers estimating 500,000. Most of the difference was due to claims that meeting EMDA's economic growth target will cause in-migration. EMDA sided with the LGA in claiming that any economic effects are included in the 350,000 figure. The Panel Report supports the LGA argument. But it recommends cutting
10,000 off the figure for Lincolnshire, so that South Kesteven should not
have to take more car commuters from Greater Peterborough. The overall
allocation for the East Midlands would then be 340,000 (i.e. 13,600 p.a.
over 25 years), broken down as:
KEY ISSUE:
(b) % of new housing on brownfield land The Government's target is that by 2008 60% of new housing will be on previously used land. The LGA put forward a target for the East Midlands upto 2021 of only 45%. This takes account of large scale allocation of greenfield land already made since 1996. This lax attitude is opposed by local authorities in South Yorkshire because it undermines their policies to promote regeneration on brownfield land. There is a good argument that no more greenfield land should be allocated
because:
The Panel Report recommends:
KEY ISSUES:
(c) Phasing release of housing land Government policy now requires a strategy of 'Plan, Monitor and Manage' instead of the old 'Predict and Provide'. This means that only the land required in the next 5 years or so should be made available for development immediately. Brownfield land in urban areas should be released first. The Panel Report agrees that no more greenfield sites may need to be allocated upto 2021, and in some areas existing greenfield allocations could be deleted. It recommends that Development Plans should ensure that previously developed land and buildings in sustainable locations are developed as a first priority. KEY ISSUE:
(a) Employment land There is a substantial overallocation of employment land (mostly greenfield) which has been made in the past. Much of this should be deallocated, or reallocated to housing land (in accordance with the Sequential Approach). The Draft RPG argues for separate allocation for a number of different
categories of employment land. The main problem areas are:
The Panel Report recommends:
KEY ISSUES:
(b) Major retail facilities The Draft RPG argued there is no need for new regional scale out-of-centre retail development, and such proposals would not be consistent with sustainable development objectives so would not be permitted. The Panel Report argues that the need must be assessed before such a conclusion can be reached. KEY ISSUE:
At the Public Examination, the Panel pointed out the contradiction in the Draft RPG between a policy of avoiding roadbuilding, and a policy of supporting lists of intended road schemes. They also pointed out the lack of adequate policies to address weaknesses in public transport throughout the region. This will become more important as the proportion of elderly people increases. Other issues include:
The Panel Report is to a large extent concerned with setting the context for a review in three years time. It is critical of the lack of transport objectives in Draft RPG - e.g. everyone being able to meet most of their transport needs by walking or cycling, and having access to a non-car mode of high quality and reliability. It is also critical of lack of integration between land use and transportation strategies, and particularly the lack of policies to deal with development pressure around major transport nodes. It recommends that:
KEY ISSUES:
(4) Natural and Cultural Resources (a) Biodiversity The East Midlands has suffered large losses of biodiversity and now
has less than most other regions. Issues include:
The Panel Report recommends priority being given to supporting the objectives of Biodiversity Action Plans, and also a policy to protect and enhance strategic river corridors. KEY ISSUE:
(b) Cultural assets The Panel Report recommends strengthening RPG policy to require the siting and design of new development to be informed by the management of cultural assets and their setting. KEY ISSUE:
(c) Water The Panel Report supports Environment Agency proposals to reduce the risk of flooding, to protect water resources from overabstraction or pollution, and to protect wetland habitats. KEY ISSUE:
Regional policy is delayed, waiting for revised government policy. There will be a shift in emphasis to using more recycled aggregates, with fewer quarries. The Panel Report recommends:
KEY ISSUE:
Regional policy has been delayed until the Environment Agency produces
Strategic Waste Management Assessments (detailing how much waste is being
produced) - due later this year. Some of the issues are:
The Panel Report recommends that:
KEY ISSUE:
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