Log in | Register
09/07/2020

PAC critical of some key elements of Belfast LDP

Words: Roger Milne
Belfast / iStock-91766568

The Planning Appeals Commission, which has begun examining Belfast City Council’s local development plan (LDP), has voiced concern that the draft planning strategy may be unsound.

The two commissioners involved – Rosemary Daly and Julie de-Courcey – have carried out an initial assessment of the plan and its evidence base.

PAC programme officer James Bickerstaffe has written to the planning authority saying: “This has given rise to some issues that, both individually and cumulatively, may have implications for its soundness.”

The commissioners have complained that it is not clear whether the LDP was prepared in accordance with the statutory timetable.

They have also questioned the LDP’s reliance in part on zonings and designations in the draft Belfast Metropolitan Area Plan (BMAP) 2015, pointing out that this version of the draft BMAP was declared to be unlawful by the Court of Appeal.

In addition, the commissioners are unhappy that the LDP’s urban capacity study uses the draft BMAP as representing existing policy.

“It is not a local development plan as defined by section 6 of the Planning Act (Northern Ireland) 2011”, and cannot be relied on in assessing likely delivery of windfall housing, argued the commissioners. 

Other issues raised by Daly and de-Courcey relate to the sustainability appraisal carried out for the LDP and lack of data on the capacity of waste water treatment (WWT) infrastructure. The commissioners ask, again rhetorically, how the council could assess the likely environmental effect of the growth strategy given its admission that it is not able to quantify the position in respect of WWT infrastructure capacity.

The commissioners are concerned at the mismatch between NI housing growth indicators published last year and the strategy’s higher figure and the absence of a market review of achieving “a notable uplift in the supply of housing”.

Other issues that concern the commissioners are the deliverability of the LDP’s affordable housing policies and the possibility that this will be covered by supplementary planning guidance.

On infrastructure, clearly a key issue for the commissioners, questions are asked about the council’s proposed use of section 76 agreements to secure infrastructure improvements, as well as a final version of the council’s developer contributions framework.

The letter noted: “As the council is not the statutory provider for the strategic infrastructure improvements required to deliver its growth strategy, please explain why it considers associated policy to be realistic and appropriate?

“How can developers make informed decisions based on the draft plan strategy when it seemingly does not identify required infrastructure improvements, there is no evidence of associated costing, and no indication of when deficiencies therein would be remedied?”

Another area of concern for the PAC rests on cross-boundary matters and the lack of evidence on whether the city has been in dialogue with other districts sharing strong labour force relationships with the capital.

“If it has, the outcome is not clear from the council’s evidence, including the associated implications it has for job growth and housing provision. Please confirm how the council concludes that its draft plan strategy is not in conflict with development plan documents of neighbouring councils.”

The PAC has requested a detailed response from the city council by the end of this month (July).

The letter can be found on the Planning Appeals Commission website.

Image credit | iStock

Tags