15:20
Okay. Well, good morning everybody. It's now half past 9, so it is time for me to open uh today's hearing session into the
15:27
examination of the South Tinside uh local plan.
15:32
Um hopefully uh just to introduce myself for those who haven't attended previous sessions. My name is David Spencer and
15:39
I'm an independent planning inspector appointed by the Secretary of State to conduct the examination into the
15:45
submitted local plan uh for the benefit of those uh with an interest. This is
15:50
the plan that was published by the council uh in January 2024. Uh and
15:56
obviously representations were made on that plan at that time through to March of 2024. uh and it's those
16:02
representations that are before me as part of this examination. Can I just
16:08
check first off, can people hear me? Am I necessarily see me? Okay, that the microphones are working. Yep.
16:15
Good. Thank you. Um can I please ask at this point that people ensure that mobile phones are switched off or on
16:21
their silent settings, please? Uh and can I at this early stage just
16:27
turn to the council please for the usual uh daily housekeeping matters including
16:32
what we do in the event of the fire alarm going off. Okay. Good morning everybody. Uh we're
16:38
not expecting a fire alarm this morning. So if the alarm does go off, please can you make your way to the nearest fire
16:43
exit was just on the far side of the room and then proceed to the far side of the hotel car park and await instruction
16:48
from hotel staff. Toilets are just across the corridor opposite this room.
16:54
Um, please note that there's cables um, taped to the floor. Uh, so please be careful as you're moving around the room
16:59
not to to trip on those. Um, also the hotel operates a parking eye system. So
17:05
if you have parked in the car park, please ensure you've entered your registration number at the devices at
17:10
the hotel reception. Thank you. Thank you for that. Now these events are
17:17
being recorded and I think livereamed as well by the council. Um, but can I check
17:22
at this stage? Does anybody wish to make their own recording of today's session?
17:30
No. Can I check? Is there anybody here this morning from the local press?
17:37
No. Okay. Uh just to remind everybody that this examination is being supported
17:42
by an independent program officer. That's Annette Feny who's sitting at the the side back of the room to my left. Uh
17:49
just to remind everybody that uh Annette works for the examination. She's your
17:54
kind of first port of call if you need any uh assistance with examination documents or procedural matters relating
18:02
um to the examination and sort of uh Annette works as the independent goet between myself the council uh and or
18:10
those who've made representations on the plan. Annette is based here whilst we're sitting, but if you need to contact her
18:16
at any other point, her contact details are on the examination um website. Uh as
18:23
I've said at previous um sessions, these are public meetings. They're held in public, but it is only the persons
18:29
seated around the table who may uh who are uh uh permitted to speak and want to
18:35
exercise their right to be heard. Um if I can remind people that uh
18:43
obviously at various points I I'll throughout the hearings I will ensure that people can exercise that right to
18:49
be heard. You will be heard uh on the relevant points that link back to your um representations.
18:55
I'll either bring you in directly at a point of the discussion uh relevant to your representations or if you've got a
19:02
particular point that's um uh you think is critical for me to hear at a
19:07
particular point of the discussion the conventioners we've used is to upend your name plate and that will then
19:12
signal to me that you want to come in at a particular part part of the discussion. Can I please remind
19:18
everybody that contributions to these hearing sessions should be relatively um brief and succinct and to the point uh
19:26
and related to your original um representations. Previously submitted statements have been read. They're
19:32
before me, so I don't necessarily need them read out verbatim uh at this hearing session. What I'm particularly
19:38
interested in uh on the one hand is to hear from the council in terms of how
19:43
they've gone around about the plan making uh process and why I should be considering that um sound but from those
19:50
of you who are who have made representations that they're either soundness or legal compliance matters. I
19:57
do want to understand what you are seeking in terms of how the plan should be modified or changed or whether issues
20:03
are so fundamental uh that we you know the conclusion I should draw is that
20:08
this isn't the right uh plan going forward uh for the burough uh over the
20:13
plan period to 2040. uh in terms of just reminding everyone
20:19
we are going to probably hear views that we don't agree with maybe even profoundly disagree with but there
20:25
should be respect and courtesy to all around the table that everybody can freely make uh their contributions
20:31
um it is important that I hear what people are saying so it's difficult if people are speaking simultaneously for
20:37
me to follow um the conversation
20:42
in terms of uh being able to follow the conversation uh this room did get relatively warm yesterday. Uh and I
20:50
think for the sake of comfort uh we're going to uh see if we can persevere with the air con. Uh what I
20:57
think that will mean is that we will need to use we we will need to use the microphones and where possible please
21:04
speak as close to the microphone. They are reasonably flexible. appreciate some people are sharing them or they're
21:11
between you, but please for uh being able to hear in the room and for those
21:16
watching the recordings um use the microphone.
21:22
If at any point the room does get kind of uh oppressively warm, please let me know. Please ensure that you kind of
21:28
think about your comfort. Uh if you're wearing a jacket or whatever, I won't be offended if you want to take that off.
21:35
There's plenty of water, etc. So please ensure your own uh comfort during these
21:40
uh during these hearing sessions.
21:46
And then just finally in terms for me for intro uh sort of uh introductory
21:52
remarks today I mean ordinarily the life of an inspector is a very lonely and solitary one. Uh, and I'm not allowed to
21:59
speak to anybody outside of this room other than the program officer, but I am being observed by a fellow colleague uh
22:06
at some point today. Uh, I don't think he's with us yet, but if you do see me speaking to another gentleman, it's
22:12
likely to be a fellow planning inspector. Um, we will not be discussing the soundness of this plan. And I want
22:19
to reassure the council and other participants that I alone carry the
22:24
burden responsibility of examining this plan. and I will come to my own conclusions on the soundness and they'll
22:30
not be fettered by a uh by another colleague. So, uh just uh if you if you do see me talking to somebody, it's very
22:37
likely to be another another inspector. Okay, that concludes um the
22:42
introductions that I wanted to make uh as part of the just the general uh outline. Are there any brief questions
22:49
around how this hearing sessions work?
22:54
No. I see councelor Taylor, you've now joined us on behalf is it on behalf of the Green Party?
23:00
Yes. Thank you.
23:06
I think at this point I would like to uh turn to the council in the first instance as we have on previous sessions
23:13
uh to introduce who I'm likely to hear from uh this morning. Hopefully everybody's here for matter four which
23:18
is green strategic approach to green belt uh and the overarching approach to
23:24
kind of site selection. So Mr. Shadowavian please. Yes. My name is Paul Sheddderee Casey
23:30
acting for the council. Okay. I'm Deborah Lamb. I'm the operations manager for the spatial
23:37
planner team at South Tai Council. I'm Rachel Cooper, one of the senior
23:42
planning officers with South Tai Council. I'm Matt Clifford. I'm also one of the
23:48
senior planning policy officers for South Tinside Council. Thank you. And then working round from
23:53
my rights, please. Morning all. Lee Fulture, principal at DPP Planning representing Stormbridge
24:00
Homes. Uh I'm James Thompson, a development planner at Banks Group.
24:06
Neil Westwick from Lichfields representing Avant Homes. Chris Smith from Lichfields representing
24:13
Helens Land. Neil Morton Saviles representing Lavric Hall Farm Limited. Um Chris Martin,
24:21
Pegasus Group. I'm representing Belway Homes Limited and Belway Homes Limited Northeast.
24:30
Morning. Kevin Eton from ELG Planning representing Story Homes. Karen Hunter, Felgate Green Belt.
24:37
Uh Dave Greeny of the Felgate Green Belt Working Group. Good morning. I'm Geraldine Kilgawa,
24:44
labour counselor for the Felgate and Headworth ward and supporting the Felgate Green Belt uh group. Thank you.
24:50
Good morning. My name is Dave Hutchinson from East Bland Neighborhood Forum. Mvin Butler, Clayton East Neighbor
24:57
Party. Good morning, councelor Rachel Taylor representing South Tai Green Party.
25:05
Thank you. So just to check I refer to you as is it councelor Kilgore? There's a counselor. Yeah. Okay. Thank you.
25:14
Okay. Thank you for those um introductions. Um I'm going to
25:20
follow uh the agenda that was previously um circulated for this session. It links
25:25
back to my matters issues and questions which were based on the representations that were submitted uh and the council's
25:32
evidence uh provided alongside in support uh of the plan. I just wanted to
25:38
sort of briefly set out how I see this session going and some of the ground that we need to cover uh in terms of
25:44
setting some of the context for the discussion. Just want to remind everybody that this is a plan that is
25:50
being examined in sort of transitional uh circumstances. Uh and for the test of consistency with
25:56
national planning policy, uh I am working to the September 2023 version of
26:02
the national planning policy framework. Uh I appreciate there's been a lot of change recently in terms of national
26:07
planning policy and green belts, but I'm still working back to that version of the national planning policy framework.
26:14
And as such, the national planning policy at that time said that um that
26:19
the time that this plan was prepared that green belt boundaries should only be altered where exceptional
26:25
circumstances are fully evidenced and justified and that should be through the preparation of a local plan.
26:32
And before concluding whether exceptional circumstances exist to justify changes to the green belt
26:37
boundary, there is in my view a stepwise process. It set out at paragraph 141 of
26:43
the national planning policy framework and it's to look at whether plan making has made or sought to make as much use
26:50
of suitable brownfield um sites and underutilized land. That there's been
26:55
consideration of optimizing densities particularly in town centers and other locations well served by public
27:01
transport. And thirdly, that there's been discussion with neighboring authorities demonstrated through a
27:07
statement of common ground whether some of the identified need could be accommodated elsewhere.
27:13
As part of today's discussion, I'm not looking to discuss in detail the individual proposed changes to the green
27:19
belt boundaries in South Tinside that starts tomorrow when we start looking at some of the individual um sites. So I'm
27:26
looking at the more kind of strategic approach that's been taken and whether at a high level there are the
27:32
foundations for exceptional circumstances uh existing
27:42
in terms of some of the interrelated matters for the benefit of those who haven't attended previous sessions. I've
27:47
already discussed over two sessions this week the amount of development that's
27:52
needed both in terms of employment and housing and also have to come to a view on that. I note that some of the
27:59
representations on the plan have referred to case law. Um and I've tried to clarify through my guidance or sorry
28:05
through my matters issues and questions. Uh there are differences uh for plan
28:11
making the test is exceptional circumstances and when you get planning applications within the green belt the
28:18
test is very special uh very special circumstances. I know people have
28:23
referred to case law in relation to Hunston. That was in relation to the latter test in terms of very special uh
28:31
circumstances. In terms of whether exceptional circumstances exist, I've referred to
28:37
case law in my um Massachusetts questions. It's often referred to as the Calverton case or the Calverton test.
28:46
I'm not aware that that's been superseded or replaced by any further um
28:52
case law in terms of setting out the principles uh or what the court has set
28:57
out as some of the parameters for looking at exceptional um circumstances.
29:04
Once we've been through those um three steps of or the the kind of the three steps that lead us um to considering a
29:11
conclusion on exceptional circumstances and then in the second part of today want to look at how uh the method the
29:18
methodology of looking at the green belt has been reasonable uh justified and consistent with national policy. So this
29:25
is the green belt review evidence. Uh and then thirdly uh I think this is
29:30
always a matter for local plan examinations is just generally how sites have been selected and looked at whether
29:37
that process has been robust uh transparent and all reasonable options
29:43
uh that have been identified either through the strategic housing land availability assessment which is undoubtedly going to be short-handed to
29:49
the schlar uh and the employment land review uh have kind of assessed have
29:56
kind of identified the reasonable options s and then those have been looked at comparably through the
30:02
separate sustainability uh appraisal uh process. I appreciate there are those
30:07
around the table who are promoting sites that are not in the plan. My remmit is
30:12
to look at what is in the plan but I understand today and today's session and
30:17
how the council has gone around particularly site selection process is uh probably for you for for those
30:26
promoting those representations a key a key opportunity to uh question the
30:31
soundness and validity uh of that approach. So I don't want to discuss in too much detail sites that are not in
30:37
the plan. is the general approach and methodology to how sites have been um selected.
30:43
So that's my general um introduction um to today's session.
30:49
Um we're due to sit for all of today. Whether we'll need all of today, I don't know. We'll review where we are. We will
30:55
have a mid-m morninging break. There's obviously a program uh break for uh lunch and we'll see uh how much of the
31:02
afternoon uh we need. So without much further ado and turning
31:08
to my agenda for uh today's uh session, I want to turn in the first instance to
31:14
the council. I think it's picking up my uh matters and issues questions 4.1 and
31:21
it may then flow into um 4.2 uh as well but focusing initially on
31:27
masses issues question 4.1. Uh and it's that sort of first step, the
31:32
fundamental step of whether all reasonable site options for housing and employment within the main urban area in
31:38
the existing builtup areas have been considered uh and where such sites have been
31:45
assessed as suitable, available and achievable, whether they've been allocated or identified within the plan.
31:53
So I don't know who's going to kick off for the council, please. Thank you. Um
31:58
yeah, so as we've set out in the site selection topic paper, the council confident we've undertaken a
32:03
comprehensive assessment of reasonable options. A total of 515 sites were
32:08
considered as reasonable options and then they went on to be assessed through the schlaw and the ELR.
32:15
Um over 50 reasonable options were considered in the builtup areas of the villages and over 300 reasonable options
32:22
were considered in the main urban area. So the council consider that to be comprehensive.
32:28
Um and just the final part of that question, yes, where sites were assessed as suitable, available and achievable
32:34
that have been identified in the plan either as potential allocations or commitments um or sites on the
32:42
Brownfield register. Thank you for that. And there are
32:48
various figures um that are before me and I just want to just kind of get my
32:53
head around some of these and hopefully the council can assist on this. Um you
32:58
said there Miss Cooper from the sort of the high the highest level 515 sites um
33:04
have been assessed. Uh there are then references to other um figures as I go
33:11
through the council's matter for statement in terms of I think that uh mim issue
33:18
question 4.2 you say looked at 250 brownfield sites
33:24
and then finally you've looked at 176 sites without planning permission.
33:32
My logic would be that so the 515 is everything from the strategic housing
33:38
land availability assessments everything from the employment land review processes whether they're greenfield
33:44
brownfield got planning permit or got some kind of consent it that's the totality
33:50
that's yeah that's correct so that 515 covers everything every site we've looked
34:05
And then ultimately through the strategic housing land availability assessment process, there are then
34:12
ultimately about 176 sites that weren't in the planning pipeline.
34:18
So they're kind of new sites that have been kind of presented to the council that didn't have at that time the
34:24
benefit of a uh an extent planning consent. Yes. Yeah, that's correct.
34:36
Thank you. And in terms of just establishing that kind of baseline um figure um and getting to the 515,
34:45
the starting point is is often the kind of the call for sites or a call for sites. Can the council just briefly
34:51
explain how how and when you've kind of done that done those processes or done
34:56
those calls, please? Yeah, so an initial call for sites was
35:02
undertaken I think it was in 2020 the first one. Um and we've obviously invited um sites to come forward through
35:10
the um local plan consultation process. Um we also after the initial call for
35:18
sites kind of did a civ of brownfield sites and where we didn't have ownership
35:23
information for those sites, we then wrote to undertook land registry searches and wrote out to the owners
35:29
just to establish could this site come forward reasonably. Um, we didn't get
35:35
any response to that, but yeah, we did try to to reach out to those owners.
35:42
I see. So, where people had not positively responded to the call for sites, but nonetheless, the council
35:48
thought, well, we've got some underutilized land or some brownfield land, you proactively
35:55
tried to kind of see if those Yeah. So when we've kind of gone through you know looking for sites ourselves if
36:02
there's been sort of disused land in the urban area then yeah we we've undertaken
36:07
land registry searches for that
36:33
Thank you. But and a logical um ultimately out of that there will be
36:38
some sites that just were not presented to the council were not promoted by
36:43
anybody to say I've got a site here. I'll be interested in some development
36:48
on that site. There will be some of those that are that are kind of left. Yeah, obviously we're aware through um
36:55
representations through the local plan there are sites that people have identified could be or seemingly are
37:01
suitable for development but we just haven't been able to establish their availability.
37:10
Thank you. And in terms of obviously there are kind of various call for sites but could sites come through in other
37:17
processes. I mean if somebody had made a representation at the uh earlier regulation 18 stages or
37:25
ultimately the regulation 19 stage would the council have taken those into
37:30
consideration? Yes. Yeah. So any sites that have kind of been put forward to us at any point have been then added into the FL
37:37
database and considered. And in terms of the strategic housing
37:43
land availability, the schlar various people reference 20 the 2023
37:49
schlar. Is that correct? Because I think the document that's before me in the examination is dated 2024. Has there
37:56
been a an update? Yeah. So the 2024 SHAR was published just as part of the sort of submission
38:03
package of documents and the 2023 supported the the reggg 19 consultation.
38:13
I see. So would the 2024 schlar be an opportunity would that have
38:18
been an opportunity to respond to anything that kind of came in through the regulation 19 process?
38:24
Yes. Yeah. And obviously an update to commitments and completions at that point.
38:55
Thank you for that. I mean I think I think in terms of just turn to other anybody else around the table I think
39:00
looking at various kind of representations there is we'll come on to some of the
39:06
potential alternatives under matter under uh my matter initiative question
39:13
uh 4.3 which I think is at item um
39:24
yep sorry item six of my my agenda. But in terms of just the general approach that the council has taken, I think most
39:30
representations I've read have kind of complemented the council's thoroughess of looking at
39:36
over 500 sites uh as part of the kind of assessment process. Um
39:48
Oh, Mrs. Is it Mrs. Hunter? Yes.
39:57
Can I ask of the non-responses? Do we have a geographical area of the burough
40:03
of the non-responses and also um owners request that it should only be used for
40:10
employment and not housing? Do we have a great geographical area? Is it is it more in South Shields?
40:18
Is it in Jarro? Is it in Witburn? Is it in Cleon? Where are the non-responses
40:24
coming from? I don't know if the council can assist on that. I presume it's mainly within
40:29
the main main urban area, but yeah, that's correct. So, those sites were mainly in the in the main urban
40:35
area that we wrote out to.
40:42
Thank you. Uh thank you for that. If I can move on in terms of the um uh
40:49
the agenda, please. Uh and uh
40:56
item
41:02
so item uh three. Um I think it's probably not
41:10
strictly linked to one of my MIQs, but kind of a a a sort of a subsequent thought when kind of reading um the
41:17
statements. Um I mean in terms of looking at sites and particularly within the sort of the
41:22
main urban areas and the village area the v village areas um did the council
41:28
kind of apply kind of reasonable kind of thresholds sites above a certain size
41:33
and then subsequently particularly there's then been an allowance made for
41:38
kind of unanticipated sites particularly smaller sites which we often refer to as windfall.
41:44
Uh yeah that's correct. So the schlaw initially looked at sites over 0.5
41:50
hectares or sites that were capable of delivering five dwellings. Um there will be some sites in the schlaw that fall
41:57
under that threshold. So where sites have specifically come forward through the council's asset management team or
42:03
regeneration team. We've looked at those sites. So there's a sort of general threshold but it wasn't like a strict
42:10
cut off. Um and yeah we have applied a windfall allowance. So it's set out in
42:16
the efficient use of land paper which recommends an allowance of 10 small sites and 27 well sorry 10 dwellings on
42:24
small sites and 27 dwellings on larger sites from year six of the plan period.
42:33
Thank you. I'll come on to we'll look at uh windfall allowances in more detail uh
42:39
as part of of um stage uh stage two. Um
42:44
before I move on to um how the council has looked at um employment land because
42:49
I appreciate that's the other part of the equation in terms of uh exceptional circumstances.
42:54
Uh Mr. Green please.
42:59
In relation to the the schlaw uh if you go to page it's about developable sites
43:04
and not presently developable sites. uh appendix B page 44 uh related to
43:11
brownfield sites. There's an abundance of brownfield sites there and there's one in particular SBC84
43:18
which is the former milit mod bunkers. Uh now that's been excluded uh from
43:26
uh the local plan. Yeah, it's a site of in total uh 83.6
43:32
hectares I believe. It's, you know, 20 acres is
43:38
the is this the sole area. Then you've got the army camp of 16 acres and then I
43:43
believe 35 acres are owned by others. And I'm just wondering whether that has been thoroughly looked at and why it was
43:49
actually excluded from being put forward as a with it being a brownfield site,
43:54
why it was excluded from being put forward in the first place. But there is an abundance of uh if you look at the
44:00
map, there's there's a stack of brownfield sites which haven't been put forward.
44:05
Uh yeah, this Lord says yeah, if you could sh about that please.
44:12
Thank you Mr. I'll probably come on to that when we look at um item six but I
44:18
just wonder on the general point from the council's approach. I mean, I'm mindful there's obviously very kind of
44:24
clear guidance when looking at sites. You are they achievable, suitable, available, and those are kind of the
44:31
three kind of key um criteria. The council
44:37
uh can do so much to kind of make people kind of bring sites to the table um but
44:43
it can't compel them to put their land um forward.
44:48
But is there a general um uh picture or an extensive kind of
44:55
picture that the there are kind of various sites across the burough that people might sort of look at and think
45:02
well why hasn't that come forward but there might be reasons that aren't obvious because of ownership or
45:08
suitability that kind of explains why why they're not uh put forward
45:14
within the plan. Yeah, I think as we touched on earlier, availability is probably the main factor as to why
45:21
there's so many brownfield sites that appear in the shaw but then are not taken forward in the plan. Um, and yeah,
45:28
like I touched on, we tried to kind of proactively look at those sites and look at their
45:34
ownership details and availability. But yeah, there's a lot of sites in the shaw that maybe operational businesses,
45:41
operational schools that were just kind of looked at as, you know, a really comprehensive look at
45:48
sites across the burough, but yeah, they're ultimately not available.
45:58
Thank you. We'll come back. I think Mr. Green, you're not alone. I think other people I think have referred to as the bunker site. So, I think it's probably
46:04
something we'll come back to in terms of whether um any potential sites have been
46:11
not looked at or or potentially overlooked. I'm not sure if that's the case for that site, but we'll come back to it uh in due course. Um so, on this
46:19
issue uh in terms of uh what the council's looked at within the urban
46:25
areas and and the villages, is it Mr. Hutcherson next and then councelor Kilgore, please?
46:31
Yes, thank you, sir. Um, now that we're talking about the specific uh built-up
46:36
areas in B Cleon and Witburn, I think it's worth us pointing out that in the
46:42
site assessments, the Clean Lane site um which we spoke about yesterday, which
46:48
may may be approved when the appeal is conducted. Um that was a Brownfield site
46:55
and when it was assessed it was judged as being able to be released from employment use. Um that site would
47:04
provide 202 houses which would meet the whole identified housing need for the
47:09
East Ben area um as set out in the neighborhood plan and that would be over
47:15
a 17-year period and that was agreed by the examiner for the neighborhood plan.
47:27
Thank you councelor Kore. Thank you sir. Um with regards to the bunker, we um have carried out further
47:34
investigations even only yesterday. Um we understand that that site was put forward um that we are very aware of a
47:42
partial owner of the site um and they were able to come back to us yesterday
47:47
and give us some more detail around the parcels of land on that site. So we are
47:53
aware that that was put forward.
48:00
Thank you. I think I kind of want to avoid too much site specifics at the
48:06
moment. We'll come back to this under item uh six of my agenda because there may be
48:12
other reasons the council can draw on around that particular particular site.
48:18
Um but it is one that kind of freak is clearly in it's clearly in sort of the
48:23
the public psyche as a why isn't that kind of an option that's been been
48:29
looked at or taken forward. Um, and I may I may need some assistance
48:34
just kind of geographically pinpointing that for my own benefit or reference.
48:40
Uh, other contri M is Mr. Butler next please.
48:46
Uh, thank you sir. Notwithstanding what you've just said, I feel I have to respond immediately to to the two
48:51
submissions uh by colleagues on the left. uh draw your attention to the site selection topic paper submitted uh by
48:59
the council. Um and uh that gives significant reasons as to why the mod
49:06
site uh was not considered suitable at regulation 19 uh and also draw your
49:11
attention that it's outside the settlement boundary uh for the East Bowl neighborhood plan.
49:18
But as you say, we'll have more detail on that later on.
49:33
Thank you. Appreciate it. There's probably a lot of interest in the housing uh situation uh in relation to
49:39
how housing sites have been looked at in terms of housing potential. Just turning to the other sort of the other uh part
49:47
of the exceptional circumstances consideration for this uh examination. I think it's also part of my masses issues
49:54
question 4.1 in terms of employment because obviously this is a plan that is looking to alter
50:01
the green belt in in relation to employment land provision. We'll come on
50:06
to that specific site tomorrow. But in terms of how excuse me the council's
50:11
process through the employment land review call for sites uh process has kind of considered all
50:19
kind of options particularly within the main urban area prior to looking at the need for uh a
50:26
green belt alteration. Is it Mr. Clifford? Thank you sir. Yes. The council's
50:32
principal source for developing an understanding of employment land
50:39
is the employment land review that was undertaken in 2023.
50:45
The baseline consisted of the portfolio of existing employment sites and those
50:51
sites promoted by land owners and agents.
50:57
So they were then grouped together under various headings such as general employment land,
51:04
specialist employment land such as the port of time
51:10
and they were assessed under sustainability and market assessment
51:16
criteria through that process. So through that process, we determined
51:23
what we consider to be a robust baseline for the employment site selection
51:29
process. And that's further detailed in in the topic paper, site selection topic
51:35
paper.
51:48
Thank you. And are you able to advise Mr. Clifford or recall I mean obviously the employment land review as you say
51:54
was 2023. I'm probably anticipating that there was always more uh interest or pressure in
52:01
relation to housing um sites or people looking for options for housing. But
52:07
have there been any kind of subsequent kind of sites, potential areas
52:13
identified since the employment land review that have needed to go into the
52:19
um site selection process or into sustainability appraisal potentially or have things remain after the employment
52:26
and review. Has it kind of been reasonable to kind of draw a line that those were the kind of reasonable kind
52:32
of pool of sites for employment use uses?
52:38
I think it's reasonable to draw a line. We've not had any sites promoted
52:43
um which change the overall picture.
53:04
Thank you. uh unemployment land for Mr. Green please.
53:11
Yeah, there's two questions really. Uh have the sites that's you know that
53:17
haven't now come forward have they been revisited? You know when when they were originally asked whether they'd put the sites forward has have have any of them
53:23
been revisited and again I think it's a time to mention you know within the town centers but I'm not sure whether this
53:29
will go on to number six in the agenda. Uh you know there's Ramen House and there is other sites but will that come further on or is it best to do it now?
53:36
Ramen House will definitely be item six. So so we'll leave that one as well as other sites in the town as well as other
53:46
I mean thank you. I mean just just picking up a point Mr. Green made there and for the benefit of people around the
53:52
table maybe also for myself in terms of you know is this uh is a potentially a kind of an an
53:58
iterative or an ongoing process. I mean, I'm assuming from what the council was saying earlier, particularly through the
54:04
strategic housing land availability assessment process, you have been continually updating that
54:11
document, including as recently as 2024, and that's pretty close to when the
54:17
council intended to submit the plan. Um, obviously, I'm mindful it's it's is the
54:23
plan as the council was intending to submit. Is that was that sound? And was that accompanied by sound evidence? I
54:29
appreciate things can always potentially change. We live in kind of very fluid times and sites change ownership etc.
54:37
But I mean as we sit here now I mean was the the 2024 sort of schlar update
54:44
picking up Mr. Green's point an opportunity to just kind of look again at
54:49
site capacities are sites has anything changed in terms of availability things
54:54
like that? Yeah. So, so like you say, the schlaw is an iterative process and it's updated
55:00
every year and um yeah, sites are relooked at through that process. Um we
55:05
invite site submissions at any point through our website. There's a form on the website. Um and yes, it's it's
55:12
updated regularly. Um and as we mentioned earlier, we've got that windfall allowance built into the plan
55:17
to allow for sites to come forward that have not been identified specifically through the plan process.
55:25
And sort of parallel to that, some people might be aware of it, but presumably the council is running or has a brownfield register. So there's
55:33
potentially another source of information. Yeah. So the brownfield register is
55:38
updated alongside the schlaw um yearly and that's published on our website as well.
55:46
Thank you, Mr. Green. The local plan was initially rejected by
55:52
full council on the 5th of September 2024. It was again put to uh full
55:58
council on the 27th of February that exact same local plan. Why? Between when it was initially rejected on the 5th of
56:04
September between the 27th of February 2025 but did nothing change. There was
56:10
nothing added. It was exactly the same local plan. And I feel that when it was rejected in uh in September 24, it was
56:18
actually rejected by all parties, the Green Party, the independence, members of the Labor Party for for specific
56:25
reasons that would have been given the council the ideal opportunity to revisit it to maybe perhaps revisit some of the
56:32
the Brownfield sites that had been initially excluded, but nothing was done, you know, and then by then the
56:39
time table was running out. would have had to be in for March the 12th uh you know to to go on the schlaws it's sorry
56:45
the uh the old NPPF framework but that would have been that would have given the council the ideal opportunity to
56:52
relook make some slight adjustments and perhaps it might have been accepted on the 27th of February 2025.
57:00
I mean, I think as I indicated on day one at the start of this, I mean, we are
57:06
where we are. I understand the background um to this plan um examination. I mean, I've got a focus on
57:13
and my remit is on the plan that's been submitted and the evidence that accomp accompanies it that has followed a
57:19
secretary of state intervention. Um um so I can't really sort of go too much
57:24
back into uh the decision making um process. So I think it's looking at the
57:31
kind of the soundness of what is um before us. I just wonder Mr. green. I
57:36
mean, as you say, I mean, I said at the start of this kind of process, um,
57:41
thinking about you, what are the potential changes that people would like to see to this plan? And you say there
57:47
might have been some, you looked at Brownfield sites, some slight changes or slight amendments. I think, can't
57:53
remember your exact phrase, but slight was in there. Is that is that your case or do you think actually it's more
57:59
fundamental because there could be you know significant kind of untapped kind of brownfield
58:05
previously developed potential that's you know fundamentally changes the plan. It's it would be a different plan. It's
58:11
not a slight thing. Yeah. Quick answer. Yeah. Yeah.
58:16
Thanks. Thank you councelor Kore.
58:22
Thank you sir. uh ju just to come back very very briefly and and I know we're going to discuss the Roman house site in
58:27
full um at item six I understand that I just think with regards to the aloca the the allocation and the investigation
58:35
around the Roman house site there has been additional um work carried out with
58:40
regards to the AAP for the IMP and um offering and I know that's not confirmed
58:45
as yet that hasn't um entirely been um satisfied with regards to general employment land so we see very very
58:53
recently that the Roman House site after um laying empty and and dormant for 15
58:59
years is now allocated for general employment use with regards to the port.
59:06
So given the work that has been going on with the port and the history of allocating land to that and also linking
59:13
that with the AAP um on the AMP, I just find it um unusual that it has has come,
59:21
you know, forward just now. the Roman House paper has been put forward and and and I accept that you accepted that for
59:28
for transparency reasons and and for completeness, but I just think that there seems to have all of a sudden been
59:36
um an interest in securing Roman House under the the guise of general
59:41
employment um linked to the port and I just wonder why that wasn't done previously. Thank you.
59:48
Thank you. We'll come on to the Roman househ site and I think I'll give the council an opportunity. I mean I'm not
59:53
going to discuss the topic paper right now. Um we'll come on to that into item six but the council can obviously
1:00:01
uh explain to me in the examination you know some of the content of that paper and when you've kind of looked at sites
1:00:08
here in the submission it's you know it's suddenly come forward but I'm sure the council will set out some of the
1:00:14
background and the kind of the chronology of when you looked at this site that particular site thinking back
1:00:20
to the 2023 employment land review and other evidence
1:00:25
it doesn't the topic paper doesn't doesn't uh raise any new assessment. Um all it does is um identify um
1:00:35
um documents which are in the evidence base and available publicly available information in order to bring um some
1:00:42
clarity over that particular site. That's all it does. Well, we'll come on to it in matter six
1:00:49
and I appreciate people have got, you know, very kind of different views on um the the treatment or how that site
1:00:55
should be uh looked at.
1:01:01
In terms of then just moving on um to my um agenda, I thought I wanted to ask the
1:01:07
question it was my MIQ 4.4 four. But just sort of generally in trying to unpick this kind of first part of the
1:01:14
national planning policy framework in terms of looking at um you know using as
1:01:21
much possible uh suitable brownfield sites and underutilized land as possible
1:01:27
whether there are other factors or particular factors that also need to be borne in mind. I think I referred
1:01:33
yesterday planning doesn't necessarily start with a blank piece of paper. there are various things going on, various
1:01:39
issues um in relation to how land um could be used. I thought it'd be helpful
1:01:45
to me perhaps to others uh in this room if I just invite the council
1:01:50
uh it's item five on my agenda in terms of whether there are kind of constraints
1:01:55
or other factors that need to be borne in mind. People might be looking at the burough and thinking there are all these
1:02:01
sites or potential sites but there could be other things could be flood risk or other factors
1:02:07
that are uh influencing or having a sort of a
1:02:13
bearing on how much kind of development can actually be yielded and delivered
1:02:19
within the main urban area and the villages or the built up part of the villages.
1:02:25
Yeah. So, as we've already touched on, we've we've looked at a lot of sites throughout the main urban areas. Um,
1:02:32
there are constraints in the main urban area um that the council have looked at throughout the plan process. Obviously,
1:02:38
we've looked at the strategic flood risk assessment which has impacted some sites. Um, heritage assets throughout
1:02:44
the main urban area. Um, and the council are also conscious of green
1:02:49
infrastructure deficits throughout the main urban area. Um the green and blue infrastructure strategy identifies that
1:02:57
there are pockets of high socioeconomic deprivation in the main urban area which tends to overlap with inadequate access
1:03:04
to green space and nature. So that's been that's sort of been factored into the the plan making process as well.
1:03:23
Thank you. And then I sort of followed up in uh sort of second part of my agenda or third part of my uh agenda
1:03:30
item five. There are kind of these direct things we can see whether it's kind of green spaces or um heritage but
1:03:39
then sort of I described them as less observable factors. There are other things that have a bearing and I think
1:03:44
Miss Cooper you referred to some of them earlier in terms of just genuine availability people haven't but afford
1:03:51
the council an opportunity if it wishes to in terms of whether there are other things and it was mentioned yesterday
1:03:56
when we're looking at um uh housing need and delivery things like viability
1:04:03
um land ownership constraints people who for whatever reason are just
1:04:10
simply not putting and uh forward for for consideration whether those are
1:04:16
there kind of other factors we need to bear in mind. Yeah, I think obviously I've touched on
1:04:22
the availability issues throughout the main urban area. Um there's also, you know, a lot of issues throughout the
1:04:28
main urban area such as the Ty tunnel. Can't build on top of that. There's the um health and safety executive zones
1:04:35
around um some sites in Jarro which constrains development around there.
1:04:42
So yeah, there are obviously a lot of constraints
1:04:47
and of course the site selection topic paper appendices deal with this on a more micro level on a site by site and
1:04:53
we'll identify those constraints and if they acted as true constraints to potential development.
1:05:18
Thank you. And as sometimes there's a perception that there is a never- ending kind of supply of previously developed
1:05:24
land, underutilized land. Um I mean it's been a focus of the planning system now
1:05:29
for some time over the last certainly the last two or three decades to kind of
1:05:34
make the most of kind of previously developed land encourage the reuse of brownfield land. I mean, has that been a
1:05:41
an observable trend situation within South Tinesside
1:05:46
that a lot of brownfield sites have already come forward or already within might
1:05:53
have the benefit of planning permission to already accounted for within the um the consented supply.
1:06:00
Yeah, I think that's definitely the case in South Tide. A lot of former employment sites have already come forward for housing. Um and yeah, just a
1:06:08
lot of the brownfield sites in the urban area are already have permission. Um we don't have the numbers to hand of the
1:06:15
sort of percentages that have come forward over the years, but there is definitely a decline of available brownfield land.
1:06:24
Thank you. And I think I picked that up from the other end of the spectrum through the employment land review paper uh identified a number of sites have
1:06:31
been gone from employment to residential through through that evidence.
1:06:37
Uh Mr. Erton, please. Yeah, just to add to that point, I guess
1:06:43
a lot of the brownfield sites, they could come forward now. They're not constrained by the green bell and
1:06:48
haven't done so in a time where there's been low housing delivery and perhaps demand for housing. They haven't come
1:06:54
forward in a time where policy and a lot of sites would allow them to do so, which is quite telling.
1:07:03
Thank you, Mr. Martin, please. Thank you, sir. I I'd just add to what
1:07:08
Mr. says. Um, if they haven't come forward through development management
1:07:14
process, um, the fact that they're going to get allocated, I don't think would make it
1:07:20
any more likely that they're going to come across are going to come forward. And I think what the important thing to
1:07:25
emphasize there is brownfield sites it's getting harder and harder to bring them forward because of things like
1:07:31
biodiversity net gain and on site on brownfield sites if you end up being
1:07:36
unfortunate for instance to have open mosaic habitat on there it becomes a very expensive thing to do to get a
1:07:42
brownfield site being brought forward in a viable way. It also doesn't help in
1:07:48
South Tinside as in the main urban areas. I think I mentioned yesterday the areas of the lower residential value. So
1:07:54
they already have viability challenges. Um so from our point of view um if
1:08:01
anything we think the council have probably been overly generous in an allowance in the main urban areas and it
1:08:07
would just further strengthen the argument that actually there are exceptional circumstances to look at
1:08:12
Greenbell.
1:08:26
Thank you. I'll come back to that item seven on my agenda because I appreciate the various representations who've
1:08:34
uh query or have issue with how the strategic housing land availability assessment has looked at kind of densities and what can be achieved
1:08:40
within um the urban area. So we'll we'll come back to uh
1:08:45
come back to that uh point before I move off agenda item five and we kind of look
1:08:52
into some of the uh other potential sites.
1:08:58
uh there any other observations or comments on the kind of the general approach that the council has taken in
1:09:05
terms of the existing settlements and their their ability to accommodate or
1:09:10
sustainably accommodate further growth. I think it's the council's outline there's various kind of competing
1:09:17
demands for land whether it's employment green space housing whether the council's kind of got the balance right
1:09:23
as part of this plan I'll hear from Mr. Green and then councelor Taylor please.
1:09:28
Yeah, it's just it's just two items. It was related to what Mrs. Cooper had said. There was actually uh you know
1:09:34
when when you kind of build out around the tunnel that is correct but there was actually uh you know brownfield sites
1:09:41
available in an old woodyards which is just outside of the urban area which I believe has now gone to the port of T
1:09:48
but that was available during the period when the when the plan uh was being put together. Uh and also with brownfield
1:09:55
sites which has just been mentioned uh does biodiversity again apply to brownfield sites as well? Can you just
1:10:02
clarify or are brownfield sites still the first choice for uh consideration?
1:10:09
Thank you. I mean there is a a uh an encouragement to use brownfield uh land.
1:10:16
I'm not aware that it's exempt from biodiversity net gain and whether it can
1:10:21
be delivered onsite offsite. Um
1:10:29
Mr. Yeah, it applies to brownfield sites and
1:10:35
as Mr. Martin mentioned earlier, it makes a lot of them unviable because the hierarchical approach with B&G is to
1:10:41
provide it on site first. So that's both a spatial impact on the
1:10:46
site delivery and also a cost. And if you can't provide it on site, which that's the first target is you have to
1:10:53
purchase credits and they're not cheap. So it it's made a lot of brownfield
1:10:58
sites which are marginal uniable. So it's a direct consequence on that
1:11:03
priority to deliver brownfield has been harmed by the BNG as introduced.
1:11:12
Okay, thank you. Well, we'll be looking at viability as part of the stage two um
1:11:18
hearings sort of more in the rounds. Councelor Taylor, please.
1:11:23
Thank you, sir. I just wanted noted the green belt loss already felt in South
1:11:28
Tide recently. Um obviously you know about the AMP and the removal of the green belt there and we lost two and a
1:11:35
half thousand linear meters of hedge and the effect that had on biodiversity and um Epne school which is of course
1:11:41
brownfield and everything and when um the football pitches at the back were all built on green belt land and of
1:11:48
course that's then being used for the 106 agreement to justify the college relocation and all that development. So
1:11:54
all this is just more green belt we're losing bit by bit. I wanted that noted. Thank you.
1:12:12
Okay, thank you for that. I'm going to move on then in terms of my agenda to uh item six. Um we'll probably start this
1:12:20
discussion and then have a midm morning break somewhere through it. But my general question and it goes back to my
1:12:26
MIQ 4.3. Um we've touched upon this at various sessions already and already this morning um the theme through the
1:12:35
representations that plan making has either missed or overlooked or not taken into or unreasonably discounted uh
1:12:42
potential uh options or sites particularly within the main uh urban area. And as a consequence, there wasn't
1:12:50
the need or the the exceptional circumstances don't exist to alter uh
1:12:55
the green belt to the extent that's proposed within the submitted plan. Probably going to focus first on the
1:13:02
particular example because this is a a um a site that is uh repeatedly referred
1:13:09
to uh I hope I'm pronouncing it correctly as the Ramen Hass site. uh I
1:13:14
believe now owned by DAO or in the ownership of DAO um chemicals site in
1:13:21
Jarro um it's one site appreciate the council's prepared a topic paper but I
1:13:26
think I'm going to hear about other sites or potential themes around other uh sites uh as well but if I can just
1:13:33
invite the council first it was my matter issues question 4.3 whether it's kind of applied a
1:13:40
reasonable approach more generally when kind of um discounting sites or
1:13:46
concluding that sites are not appropriate in this case to allocate for housing.
1:13:53
Yeah, as we've sort of picked up on earlier, the site selection topic paper looks at each of the reasonable options
1:13:58
um individually and sets out why they have or haven't been taken forward through the plan process. Um obviously
1:14:05
there's quite a comprehensive evidence base that sits behind that. So the council are confident that a reasonable
1:14:12
approach has been taken and then by by I'm assuming by then
1:14:19
association if they've if they don't fall at that hurdle or they're not one
1:14:25
of the is it the category one sites where there's a fundamental kind of constraint they then will go
1:14:31
into sustainability appraisal would have been looked at had on day one the
1:14:37
significant appendices of sites that have been appraised. So things that have
1:14:43
passed through that kind of site selection process have then gone into sustainability appraisal as reasonable
1:14:49
options.
1:14:58
Thank you. So if we can turn if we deal with the Roman house site first as I indicated the council has produced a
1:15:05
topic paper. um it did arrive at a relatively late stage for this kind of
1:15:10
examination process. I've taken the view that it is pulling together existing
1:15:16
evidence that's either contained within the employment land review paper
1:15:21
uh and elsewhere in terms of the site selection um uh process. Uh it's clearly
1:15:28
a site that several if not many people think has development potential
1:15:33
particularly um for housing. Uh and I just wonder if I can invite the council in the first instance to just give an
1:15:40
overview of how this site has been looked at. It's obviously been looked at as part of the employment land review,
1:15:47
but also coming back to what we've been discussing this morning. Is this a site
1:15:53
where the owner has positively kind of put it forward and said, you know, I
1:15:59
have this site, I would like it considered for housing. So, give the council the first
1:16:06
uh opportunity on this and then I'll open up to others. Thank you, sir.
1:16:12
The site is allocated in the plan for employment.
1:16:18
Um, and it's been a long-standing employment site.
1:16:25
The site owners have never promoted the site for housing. On the contrary, they have made
1:16:33
very, very clear that they are resistant to it ever being redeveloped for
1:16:38
housing. The company has particular reasons to do with um its activities. It does not wish
1:16:47
to see that site redeveloped for housing. The company has only ever promoted it
1:16:53
for employment and the council's business development team are working with the company to
1:17:01
bring the site forward for employment. So the site is not and has never been
1:17:08
available for housing.
1:17:15
Thank you. Um Mr. Clifford, from my reading of the kind of background material, this is a site that ceased its
1:17:22
um its last use in around about 2015 2016. So we're looking at getting on to
1:17:29
around
1:17:45
voted for employment use. Um that continues to be the case and the
1:17:51
council's business development team are working proactively with the site owners
1:17:57
to bring it forward and um
1:18:02
the council very much supports it coming forward for employment and there is that ongoing proactive joint working
1:18:10
relationship to deliver it for employment.
1:18:18
And in terms of its kind of potential for employment, we all we will come on to the kind of detail of the employment
1:18:24
al allocations as part of stage two, but just a very sort of high level now. Now
1:18:31
at this stage, I mean I think it's referenced by uh councelor Kilgore earlier about it being a general
1:18:38
employment um use site. Is that the case or does it have
1:18:43
potential for kind of some other specific uses given its kind of river?
1:18:50
Does it extend it extends down to the river has a river frontage? Does it have
1:18:55
other potential and does the plan reflect provide some flexibility?
1:19:03
Yes sir. As you rightly state, the site has an extended river frontage and
1:19:09
that's a major advantage of the site. We did previously identify it
1:19:15
specifically for sort of port and river related use which we would still very
1:19:21
much support it coming forward for that use but we've provided um the flexibility in terms of general
1:19:28
employment use.
1:19:34
I would also point out sir that in terms of the
1:19:39
sorry excuse me in terms of the site being delivered for
1:19:45
employment use. The site owners have been proactively
1:19:52
working to um remediate the site so they are
1:19:58
to a standard that is compatible with employment uses which will obviously
1:20:05
assist in the marketing of that site.
1:20:22
Thank you. Um, if I can turn to those who have an alternative
1:20:27
view or consider that the council hasn't been sufficiently thorough or proactive
1:20:32
in looking at this particular site. Um, I can start with can I start with
1:20:38
councelor Kilgore then Mr. Green and then councelor Taylor please.
1:20:44
Thank you sir. Um I live in relatively close proximity to the Roman house site.
1:20:50
Um it has been disused for one of a better word for at least 15 years. Um
1:20:58
the remediation that we talk about was carried out some years ago and I believe
1:21:04
um nothing or very little has has been done since. Now certainly uh speaking in
1:21:11
a counselor capacity and receiving information in that regard um we were
1:21:16
advised that the owner was deeply concerned around any um comeback if
1:21:23
houses were were built on that land. And then very recently the mention of flooding um has been uh put forward as a
1:21:31
reason as well. But in my submission, and I I certainly won't go over it again, there is um significant material
1:21:39
around the site from some years ago where the council state that the
1:21:45
authorities environmental experts say that they have examined the land and insist the soil is safe. The council's
1:21:52
environmental officer raised no objection in regard to contaminated land. Now, I think would be foolish to
1:21:59
think that there isn't anything to remediate. I think it's absolutely clear that there is now my particular concern
1:22:07
is that only since um the rush of you know the failure of the plan to go
1:22:13
through uh council on two occasions that this site there has been a for sale sign
1:22:18
outside of that site for as long as I can remember and I've lived in that end of Jarro for 26 years so you know while
1:22:27
it was operational admittedly and I miss my calendar every year um But th this is
1:22:32
not a site that has been overly promoted and I absolutely do believe that the you
1:22:39
know if there's flood risk um with housing potentially there's flood risk
1:22:44
with employment. If there is contamination risk for housing then there's contamination risk for
1:22:50
employment. I don't see that one can be one and one for another. Um the joint
1:22:56
working doesn't appear to have occurred until around this time. Um and I'm not
1:23:03
um minded or convinced that I think I'll be really honest. I feel that this site
1:23:09
has been allocated because we're on to it. You know, we we've now kind of really progressed with
1:23:16
our investigations around the site. Um there is there are detailed papers on the site that that goes without saying
1:23:23
and we have all of them in front of us. But I absolutely do and I also think you
1:23:28
know we talk about communities. I think this would be a huge uplift to the community of Jarrow because that area of
1:23:36
Jarrow um is also some of um our most deprived areas um where we see great
1:23:42
poverty um in that end of Jarrow and I do think it would be it has accessibility for the tunnel which as
1:23:49
you know is now two lane both ways. We have the metro, we have the bus station,
1:23:54
you know, a stones throw away. It is in my opinion um a very appropriately
1:23:59
situated uh site and I think we're absolutely missing a trick if we do not
1:24:06
develop that for housing. There has been housing uh recently developed along um
1:24:12
the um I think it's called is it the Fraser site um further along uh the riverfront where there has been funding
1:24:19
provided for some remediation. I'm not saying that it's going to be easy, but there has been some remediation and this
1:24:26
report overridingly I think the difficulty we've got in um in
1:24:32
comprehending the information that we have in front of us is that the views
1:24:37
and the expertise view the expert views have differed over the years and and
1:24:43
which is it is the soil contaminated is it not because you know I've got a raft
1:24:49
of information that says it's developable able and I would say um it's
1:24:54
available it's developable it's deliverable and and we have identified
1:25:00
sites that um you know the level of detail that has gone into this hasn't
1:25:06
gone into how do we know we know with this site it actually can come forward because it's now been allocated as part
1:25:13
of the port but what disturbs me is that the the element for the port that has
1:25:18
been categorized as general use with regard to the AAP um is also designated
1:25:25
in the same way that Roman H has. So how much of that land do we need given the
1:25:31
other is already you know in a an enterprise zone whereby certain benefits
1:25:37
can be brought and we talked about that yesterday around national insurance you know benefits for local and small
1:25:44
businesses. This site is not in that zone. So why would we um you know want
1:25:51
businesses to go into something that that isn't as advantageous as the AAP?
1:25:57
Are we not overp providing and and failing to release this for housing and yet in that case releasing land into the
1:26:05
green belt? So I don't see exceptional circumstances because of partly this site sir Q.
1:26:13
Thank you. Can I just before I bring in uh anybody else councelor Kilgore I think
1:26:18
If I understand you correctly, um you're uh questioning the degree of
1:26:26
contamination on that site, but I think you said you you'd accept when we look at the kind of the history of activity
1:26:33
that's taken place on that site. You know, some of those types of uses
1:26:38
are, you know, the kind of the heavier end of kind of industry uh in terms of types of activities. But there's that,
1:26:45
you know, that that cannot can that reasonably be discounted as an issue that's something that has to be dealt
1:26:51
with. No, absolutely not. But but again, um countering that, the environmental
1:26:57
experts of our local authority some years ago determined that the soil is
1:27:02
safe. They are the words of the article. Um so for me as I've said and I don't
1:27:08
want to to kind of labor the point that if it's suitable and acceptable and can be remediated for um employment use
1:27:16
where you will have people on the site um then I don't see and certainly for
1:27:22
flood flood purposes I don't see um any reason unlike the Felgate uh SP8 site
1:27:30
that that flooding would be a you know a significant factor. there and and I really do think this is this is an
1:27:38
absolute perfect example of a site we're not utilizing and I think that would be
1:27:44
um it would let us down actually. Thank you. Thank you. I will bring in bring in
1:27:51
others. Sure. I'll come back to the council on some of the points, but just councelor Kilgore, I mean part of the
1:27:57
council's um evidence and submissions to me are this is a site owned by uh a
1:28:03
private company that doesn't want to see housing on this site is never is not
1:28:09
promoted this site for housing. One of the key tests and things I'll be
1:28:14
thinking about when looking at all housing sites is are they deliverable? And if they're in a private ownership
1:28:20
that's saying to the council, we do not want housing on this. We we're we're
1:28:26
okay with employment. It could be a variety of employment uses, but but not housing.
1:28:32
Isn't that fairly sort of compelling evidence that this this won't come forward or would not come forward as
1:28:37
housing? What would be the alternative? Who would step in? Who would make that happen if a private company is saying we
1:28:43
don't want this type of land use on our sides? Sir, in my opinion, I haven't um
1:28:49
I haven't seen anything that compels me to understand that that is the absolute
1:28:56
arbitrary decision of of the um owner. I accept the local authority um have been
1:29:02
um or or are advising us of that and I'm not disputing that that is their understanding but we have never been
1:29:09
afforded any communication um with that owner and and I would like to understand
1:29:15
in greater detail much greater detail as to why that is and I think potentially
1:29:22
you know why now why has it been allocated to the port now this plan and
1:29:28
and the warning, you know, kind of 2016 18. Why now? And and I just I genuinely
1:29:35
think that given the constraints that we're under the the small burough that we reside in and the difficulties with
1:29:42
the coastal area that this is ever more important and we we need to speak to that that owner and we need to negotiate
1:29:49
with the owner and I think with the greatest respect if it if it does if it's handy to allocate it to um the port
1:29:57
we need to be more creative around that and we need to to have those detailed discussions that we've not been
1:30:03
afforded. Thank you. Thank you. I can bring in Mr. Green next and then councelor Taylor. Thank you.
1:30:10
Yeah, thanks. Councelor Kilg touched on a lot of that. Again, I've wrote down on here, why are they now proactively
1:30:16
looking at it? You know, is it a coincidence? Well, I'm not going to say, but the
1:30:22
thing is with with Roman H, uh, you know, there is the it's it's heavy it's
1:30:29
been heavy industry in Jeran all the way up to town. Now one of the one of the council arguments is that you know there
1:30:35
will be a cleanup operation. Uh now previous sites uh you've got uh the old
1:30:41
Hullburn site in South Shields which is ship ship building. uh that that was given grants of uh well I I'll go into
1:30:48
all I'll go into all uh South Pain Council was given between 2020 and 2024
1:30:54
I'm not sure when during those periods it was allocated it's almost8 million pound in funding to clean up brownfield
1:31:01
sites now 1.85 95 million went on old Hullburn which is the old shipyard site
1:31:06
where there's a it's it's riverfront. Uh the the council held a balance of
1:31:12
483,000 and the remaining 5,475,000
1:31:17
was spent on South Shields Town Center. Now you know what other funding is available further further up uh you've
1:31:24
got the Hawthorne Leslie site which again is an old ship building site. I believe it might have been contaminated
1:31:30
from the northeast combine authority southside council access 1.945 million
1:31:36
which cleaned the site up. Now what what I'm trying to say is yeah Romanh could have contamination on it even though the
1:31:42
soils deems it hasn't. Why isn't South Tate Council act act actively seeking
1:31:48
brownfield funding I believe. I mean I'll go back into something else from the northeast uh convey authority. This
1:31:54
is going back to uh you know during the period between the the local plans. Uh
1:32:01
we do not have any requests for Brownfield housing funding which are being put forward for funding approval
1:32:06
at this time but we're working with South Tide and Homes Homes England to develop a pipeline projects which can be
1:32:13
put forward for funding. Now, what I'm asking is, you know, in and I mean, uh, Roman House is in private ownership,
1:32:21
but why, if you're trying to prove exceptional circumstances to release green belt land, why in exception
1:32:28
exceptional circumstances are you not going for a compulsory purchase order on Roman House? Now, I don't know how that
1:32:34
works. are not, you know, deemed but it's it's actually been empty uh for 18
1:32:39
years and it I believe it was cleaned up by funding from Southside Council uh in
1:32:45
2018. Now, why didn't they actively promote that during the build up of the local
1:32:50
plan? You know, why didn't they put in place compulsory purchase orders? Again, I don't know how it works, but it's just
1:32:56
all what as council says, why now? I I believe we know that why now, but uh it
1:33:04
it I put it to the council. I'll put it yourself to determine why now. Yeah. Thanks.
1:33:10
Thank you, councelor Taylor, please. Thank you, sir. Um regarding the topic
1:33:18
paper, as you see, it came in at the 11th hour. Um, and I did contact Annette Feny for information to ask if the data
1:33:25
was available to because after reading the report to see if the I wanted to see the data to show it was contaminated
1:33:32
from me, you know, um, and I know that then got in touch with the council and they sent two application numbers in
1:33:39
response to prove this is why it's contaminated. So of course I've read through both M papers and this might be
1:33:46
as well where council Kilg has read it because it then goes on to say um so the second page of the planning
1:33:53
reference ST 00618 and FUL
1:33:58
um from associate planner at AEOM to the principal plan officer states
1:34:04
this following soil samples taken at 32 locations on the Roman site. I quote,
1:34:09
"The majority of compounds were reported as concentrations below the method reporting limit where concentrations
1:34:16
were detected above the MRL. These did not exceed the sight specific assessment criteria. Therefore, the material is
1:34:23
considered unlikely to pose a potential risk to controlled water or human health
1:34:28
because I'm aware that the site's contamination is a big reason why people have been, you know, told or um for a
1:34:36
long time now that that's why it's not getting developed. So to read that in both papers that were being used as evidence was I thought quite stark. Um
1:34:46
now contamination can be remediated. UK plan and environmental law requires
1:34:51
contaminated land to be made suitable for its proposed use. Standard proven remediation methods are available. Clean
1:34:58
up, soil capping, protective measures are available. Now, dozens of former
1:35:03
industrial sites in the northeast have been safely redeveloped for housing already.
1:35:08
Um, now the flood risk as well affects only a small portion. I believe it's 7% of the site. The Environment Agency
1:35:15
flood map shows 7% of Roman site is in flood zone two and three. I'm I think
1:35:20
I'm not 100% sure on that, but 7% um and that's a small manageable proportion
1:35:26
that does not preclude development. Site layout can be designed to keep homes out
1:35:31
of high-risisk areas or mitigate risk through engineering. A precedent of this is the whole bone riverside development
1:35:38
in South Shields which has already been touched upon. um a portion of that was also in the flood zone and by raising
1:35:44
the level that's all able to be developed. Um so the whole bond site was partially in flood zone three but was
1:35:51
successfully engineered out of the functional flood plane through site raising and flood defenses.
1:35:59
So in summary, um it's the area is not recognized as contaminated under part
1:36:07
um I don't know if it's IA or 111A. Um the council position is a soil currently
1:36:14
deemed safe with no formal health objections. Um developers requirements must conduct
1:36:21
thorough contamination investigations, remove cap hazards, install protections
1:36:26
and then it could be developed. Um risk to residents is low if remediation is carried out correctly.
1:36:36
Now um I looked into it and for the size of Roman I believe if it was high
1:36:41
density housing you could get 700 or more houses on that site. um and the location of it where yeah, it does
1:36:48
mention in the council's topic paper that it's in a you know already a a site
1:36:53
that's being developed for industry but I think it's worth noting that and this was within the council's proof of why it
1:36:59
can't be developed funnily enough it says the nearest residential properties are 10 mters from the Roman site so it's
1:37:07
a heavily residential area anyway as well as it being you know also for for industrial use it's 160 mters of the
1:37:15
north of Javo Town Center, 360 m from Palmer's Community Hospital, 380 m from
1:37:22
Javo Community Center, and 310 m from Dun Street Primary School. It seems like a perfect place to have homes. Thank
1:37:29
you. Thank you. I'm mindful I'm being
1:37:37
referred to, I think, material that's not before me. Um it's obviously been shared by the council in terms of those
1:37:44
planning application references. Um I'll look to the council now if there's any
1:37:49
objection that I should be provided with those or is um no not at all. They're they're in the
1:37:54
public domain. Um and uh they've been referred to so you should have a look at them. Um my instructions are that the
1:38:02
the application one of the applications referred to um is was for the removal of
1:38:08
a soil burn and so the um pollution assessment contamination assessment
1:38:14
didn't relate to the whole site. That's my my instructions.
1:38:22
Um so um is this an opportunity to address the general point? It is just before we
1:38:30
move I'm going to record an action point. I think reference to two application references if they can be provided to me as links then I can
1:38:38
follow through the application references that councelor Taylor referred to just I'm for completeness.
1:38:45
Yeah we'll make sure that happens. Okay. I think yes this is now Mr.
1:38:50
Shadow. Yes. The council's opportunity to kind of rebut or I can deal with this very shortly. um
1:38:59
we don't know what the true um theoretical capacity of the site is
1:39:04
because we don't know what kind of mitigation might be required if it were made available for housing.
1:39:10
Um but before we get there, let let's just first of all remind ourselves um
1:39:18
what this examination is about. is about soundness and in determining whether or not the
1:39:24
plan is sound and the decisions which have been made in relation to the plan are sound.
1:39:29
Um, one has to have regard to the fact that it involves an exercise of planning judgment and that planning judgment has
1:39:36
to be exercised reasonably having regard to the available evidence.
1:39:42
In that context, the first point to note about this site is that it is not available for housing development.
1:39:50
So short of the local planning authority using its um powers of compulsory
1:39:55
acquisition, it is not available.
1:40:03
Secondly, um judgments have to be made about the context of the site
1:40:09
and what development is likely to be acceptable on the site. exercising that
1:40:16
reasonable planning judgment. And so you can go along and have a look
1:40:21
at the site and look at the surrounding land uses and come to your own view about the council's assessment of its
1:40:28
suitability for anything other than um employment development.
1:40:39
Thirdly, in terms of contamination, um, one has to have regard also to the
1:40:46
fact that residential development is highly sensitive. You're talking about families living
1:40:53
there 24/7, children playing in back gardens or in green spaces.
1:41:03
It's a highly vulnerable land use.
1:41:09
and should be distinguished from um the kind of measures needed to make a
1:41:15
site acceptable for continuing industrial or other employment uses.
1:41:32
So having regard to those matters, um it's quite understandable why the
1:41:40
site has been since 2019 allocated for employment uses and not residential.
1:41:48
In fact, were the decision to be the other way round, we would be accused now of exercising our planning judgment
1:41:55
unreasonably. I don't think I need to say anything more.
1:42:01
Thank you, Mr. Clifford. So, I'll just reinforce a point which
1:42:07
has just been touched upon which is it seems to be being put from the other
1:42:12
side of the table that the site is sort of suddenly now being promoted for
1:42:17
housing. Um it was actually as you're probably aware we had two regulation 18
1:42:25
um consultations through this process and the first of those goes back to
1:42:31
2019. So the site has been identified through this process
1:42:36
for employment land continuously since 2019.
1:42:43
So it's not something which is suddenly before the uh before this process.
1:42:57
Thank you. And just in terms of background context presuming when the council last did a site allocations documents was it 2012
1:43:06
was that the site allocations plan?
1:43:12
So the L LDF site specific allocations document
1:43:17
that was 2012. Is there a consensus or view that this
1:43:23
site was operational at that time? I mean the I've heard various figures
1:43:30
sort of presented this morning about how how long this kind of site has been around and and available but my reading
1:43:36
of the evidence is it was generally coming to a conclusion around about nine years ago. 2015 2016.
1:43:47
Yes, we would probably have to look back. Obviously, that document is some age now. So, we would have to look back
1:43:52
to see what the the status of that site was at that time.
1:43:58
I think the point on laboring probably quite badly and long- windedly is the
1:44:04
previous kind of uh plan making this site possibly wasn't an option. It was
1:44:10
probably seems to me from the evidence I've got in the topic paper it was in use. So it has been this local plan has
1:44:17
been sort of the first opportunity to look at what could happen on this site. And as Mr. Clifford said if I go back
1:44:26
through all the various stages to the first regulation 18 I'll find there that it was kind of presented as an employ an
1:44:33
employment land option. So it's yeah
1:44:38
okay before we take in a German and sort of move away from the Roman house sites
1:44:44
um any further brief submissions from either councelor Kilgore or Mr. green.
1:44:53
Go. Sir, thank you. Um I I don't accept the argument that um around the uh the works
1:45:00
that would need to be carried out um on the site. Um I've been fortunate enough to be a planning committee member for 11
1:45:06
years. I'm not currently, but I have been. Um and I would consider that to be um a building control matter. it it's
1:45:15
not a matter that you would hear uh with regards to the allocation of a site that
1:45:21
can be dealt with um afterwards. But um and I and I really don't think that's a
1:45:26
consideration. What I think we meant just to to kind of um summarize
1:45:32
with Mr. uh Clifford submission there is that we're not saying that the council
1:45:38
haven't proactively marketed it because quite frankly that is for the owner to do. But if we're looking even from 2022
1:45:47
to now even if we look at that period nothing's been put forward. It doesn't
1:45:52
have to be or form part of a local plan framework in order that a site is
1:45:59
encouraged to come forward if there's a need for the land particularly with the development of the port but it's only
1:46:06
now. Thank you Mr. Green please. Yeah, just just very
1:46:13
quickly, I mean, you know, you've got a lot of people here who've lived in Jerro all of their lives and for, you know,
1:46:19
for it to be stated that family homes, the residents would be highly vulnerable is pretty insulting to Jarro. I mean,
1:46:25
yeah, it is a high poverty area, but there's been estates built further up the road which are which are in exactly
1:46:31
the same position. Uh and also uh Jarro Town Center's currently going going through a six million pound
1:46:36
refurbishment and the area could be developed and this would be an ideal opportunity to to develop that area for
1:46:42
families. Thank you, Mr. I'm sure no insult was intended. I think the point the council
1:46:48
was trying to or was in seeking to make was when you look at the past use of
1:46:53
that site and looking particularly at the more recent kind of chemical use of that site.
1:46:59
I think the point they're the council making is you know there'll be a particular sensitivity about you know
1:47:06
people living where there's previously been herbicides and other kind of activities production on that particular
1:47:12
site which might be different from uh former shipyard ship building sites.
1:47:17
So I don't think there was an insult um intended. Uh Mr. Butler next and then Mrs. Hunter
1:47:24
and then we probably will go into the um morning break. Thank you sir. You did say uh earlier
1:47:29
that we would come back to the mod site under item six. Do you want to do that now or after the break?
1:47:34
Can I do that after the break and I think there will be other sites potentially other than the mod uh bunker
1:47:40
site. Okay. Okay. It's just gone 11:00. Uh I'll take a midm morning uh break.
1:47:46
It's normally about 15 minutes, but to kind of make it easier on ourselves for maths, I'll break till 20 11. So people
1:47:53
can be back in this room, please, at 20 11. Thank you.
2:04:52
Okay everybody, it's just come up to 20 11. So it is time for me to resume uh
2:04:57
this session and matter four of the the examination. uh before we took the lunch
2:05:03
uh the midm morning at German we've been discussing uh the Roman house site I have had uh I should have said at the
2:05:09
start I have visited the site the area uh so I've seen its relationship to uh
2:05:14
adjoining surrounding uses uh I'll reflect on what I've heard um this
2:05:20
morning whether I'll I'll go back and have another look uh at uh some of the issues um that have been raised but I
2:05:26
think that's something I can do on a uh unaccompanied basis in terms of Just widening out then matter six. I
2:05:33
appreciate the Roman house site has been a sort of a key one in people's minds in terms of whether there's uh the council
2:05:40
has uh looked or may sought to make as much use as possible of suitable brownfield sites
2:05:47
and underutilized um land within uh within the burough. Uh other sites have
2:05:54
been mentioned. I'm sort of keen we keep the debate reasonably high level so I'm not sort of getting into sort of too
2:06:00
many sort of small bitty pieces of land but whether they're sort of genuine other sites and other um choices. Uh and
2:06:08
one of the other sites that has been referred to is the I think described as the former mod
2:06:14
uh bunker sites or bunk the former bunkers. Um, I'm probably going to need
2:06:20
some help in the room in terms of just geollocating where that is uh for my my reference,
2:06:27
but I know Mr. Butler could probably assist on on that point and just more
2:06:32
widely. I mean, I think I'm correct. This is a site that is in the green belt.
2:06:39
Yeah, Mr. Butler. Uh, thank you, sir. Yes, this this is a
2:06:45
isolated site. um the former mod bunkers, medical stores, and associated
2:06:51
land. And uh it's isolated uh from the
2:06:56
village of East Balden, and it lies to the uh southeast of of the village. Um
2:07:04
it's been a a long history site in terms of its uh problems with its uses uh with
2:07:13
its um uh ability of the land owner to to try
2:07:19
and do something with it. As early as 2013, there were proposals to remediate
2:07:24
the site and bring it back into uses more appropriate for the green belt. There have been other proposals to make
2:07:31
it into a uh a military museum uh uh etc.
2:07:38
To come to the the point matter, I would submit that this site has not been unreasonably discounted. Uh it's a site
2:07:46
uh which the council say at paragraph 4.57 of their statement on matter 4 that
2:07:52
they confirm the site was identified in the green belt study 2023
2:07:57
as having a high impact for green belt purposes.
2:08:03
Um strong representations were made by the uh Labour party uh during the regulation 18 process. Uh amongst many
2:08:11
others there were a considerable number of objections made uh to the uh site at
2:08:18
regulation 18 over 50 objections. Um the representation centered around uh
2:08:26
the importance of the site uh in terms of the wildlife corridor network study
2:08:32
by Burton Reed associates in 2020. uh that study identified the mod site as
2:08:40
a core site in the wildlife corridor network and that was in our view the key
2:08:45
reason as to why it was rejected uh as a potential allocation at regulation 19.
2:08:52
Uh other factors that were brought into play I reckon to that was the importance of the site in relation to the green
2:08:58
infrastructure uh situation. This sustainability appraisal said it had negative impacts
2:09:05
on the green infrastructure objective and also the strategic flood risk assessment considered that was
2:09:12
considerable surface water flood risk. In our view uh the point that we made at
2:09:17
regulation 18 was is that if there was an allocation there uh it would have a
2:09:23
significant impact on adjoining land which joins the the village and would
2:09:29
call into question other parcels of land uh which have a strong green belt
2:09:34
purpose. And for all of those reasons, um, we were very pleased that the site
2:09:40
was withdrawn. Uh, and therefore, uh, we support the fact that it's not allocated
2:09:45
in in this examination. And finally, I would say, sir, the owners of this site
2:09:50
are not represented at this examination and as far as we know, have not actively promoted the site recently to the
2:09:56
council. Thank you. Thank you for that. Um,
2:10:03
any other further points? Is this Mrs. Hunter on in relation to this this particular site, the bunker site? Yes.
2:10:09
Yeah. From what's been said, I cannot see any any just justifiable reason why it's
2:10:18
classed as an exceptional circumstance to disbar it from um potential building.
2:10:23
When you look at the you look at the green belt in Felgate and the the what
2:10:29
what we'll be going on to later on, i.e. flooding, wildlife. Um, generally the
2:10:37
whole community absolutely embraced this this this piece of land. Um, and I
2:10:43
cannot understand why you've got something that originally in the first consultation presentation, a resident
2:10:50
from the surrounding area asked why that hadn't been placed in there. I think
2:10:56
that given this beautiful idea of what this this bunker looks like, it's actually been in the the surrounding
2:11:04
area. They've got motorbikes. They've got druggies there. They've got al kids
2:11:09
drinking alcohol. They've got motor there motorbikes. It's covered in dog feces when you're walking around. And it
2:11:17
is not an idyllic historic site. When you compare that with the Felgie
2:11:24
Green Belt, it's it's the difference is, you know, day and night.
2:11:33
Thank you, Mr. Green. Just just very quick just for clarification, uh, it's down as a brownfield site. Is that Is it a
2:11:39
brownfield site within a green belt? So, is that it?
2:11:47
Because it's down here as as brownfield and all around it is green field. So, I'm just wondering why it's classed as
2:11:53
green field. Sorry. Uh, it is brown brownfield.
2:12:07
Yep.
2:12:12
Thank you, councelor Kgo. Next, sir, I think I think my comments um are
2:12:20
really broad comments. Um this isn't, you know, virgin land. This
2:12:25
is land that has been developed, albeit, you know, um an MOD building that, you
2:12:31
know, you may consider of of historic value, but as as um Mrs. Hunter has said, it isn't cared for. or it is in a
2:12:39
state of disrepair. What I do want to say though is that um
2:12:46
on a sorry an inspection of this nature unfortunately pits communities against
2:12:52
each other. So we have you know great colleagues, great relationships and
2:12:57
we're all vying for our own pieces of land to do with the requests of our
2:13:03
residents for the right reasons. And I just want us to be really mindful of that. And I do want to say to to
2:13:09
colleagues there that um whenever we are um speaking about a site that isn't the
2:13:15
one that we're looking to particularly protect, it is not with any disrespect to them. This is site related and I and
2:13:23
I just want them to know that because we are literally bartering, aren't we,
2:13:28
between one another and and I don't like that. But thank you.
2:13:35
Thank you, Mr. Hutcherson, please. Thank you, sir. Just to uh add to what
2:13:40
Mr. Butler was saying earlier um in the East Ben neighborhood plan. This site
2:13:46
was outside the identified settlement foundry and was did discount as an
2:13:52
appropriate site for new housing on that basis. U I would echo the points that
2:13:57
Mr. Butler's made earlier about the if this site was used for housing, it would
2:14:03
open up the possibility for a lot of surrounding sites to to the same issue.
2:14:10
So we strongly support its uh retention within the green belt.
2:14:18
Thank you, Mr. Westwick. So this is about a different site. Do you want to finish off the discussion or
2:14:24
can I move on to um Yeah, I just I will finish on this site.
2:14:30
Are there any further point councelor Kilgore briefly? So just just a very quick comment in
2:14:36
that whilst I understand Mr. Hutchinson's concerns, we can't in in my
2:14:42
understanding consider precedent. we are looking at a site and and I believe you
2:14:48
know we shouldn't be applying the methodology around this site to the roll
2:14:53
on or knock on effect to others in that area who which may have completely different components and an identity.
2:15:00
Thank you. Thank you. I mean, I think in terms of
2:15:06
this item uh of the agenda, I was kind of really sort of wanted to kind of unpick or find if there are particular
2:15:14
sites or particular um locations that haven't at any time been um assessed by
2:15:22
the council. I think the the issue probably with the former mod site, it is a site that the council has looked at.
2:15:28
It's not something that the council's kind of overlooked. There might be differences of opinion about how the council's considered it, but it's um
2:15:35
it's it has been looked at as part of the site selection process, and I'll I'll look at that that evidence. In
2:15:42
terms of other sites or other uh locations, Mr. Westwick, sir, this is just a a very quick point.
2:15:48
We've heard a lot about uh land at Clean Lane, uh East Balden. Um it is uh Schlaw
2:15:54
reference SBC010. Um I think this is more of a housekeeping matter for the council. Um
2:16:00
it is featured in the commitments. The 202 uh units is featured in the commitments. Um it doesn't feature in
2:16:07
SP4 uh because at the time when the council were drafting the plan, it was had a minded a grant. It then um went to
2:16:15
committee and got a refusal on uh drainage matters in relation to matters we heard yesterday from NWL around
2:16:20
Witburn. Um but my understanding is as you heard from other residents, the development of this site is supported. So my view is that that should feature
2:16:27
in um as an allocation in the plan and removed from the commitment section.
2:16:36
Thank you. And for my benefit, I mean am I correct in understanding that that site is not in the green belt?
2:16:42
It's not in the green belt and it's a brownfield site. Okay. I think for the purposes of the
2:16:47
council and looking at capacity had factored this site in
2:16:54
uh albeit under at that time commitments. It's not a site that the council's overlooked or not not
2:17:01
accounted for. No sir. Yeah. Okay.
2:17:10
Thank you. Is there anything further the from uh councelor Taylor please?
2:17:16
Thank you. This is referring very very briefly to the Ramen House site and the chemical issue. I just want to bring to
2:17:22
your attention a former site called Compton and Turnell that's on the very
2:17:28
coast of South Tinside um just before you get a little Haven Hotel on Sea Road
2:17:33
it may be but that was actually a um chemical plant and um it was highly
2:17:39
contaminated and that's all now residential housing and so just because I know you said that we were talking
2:17:45
about former shipyard area and the ramen site's different and I just thought it was important to mention that I know
2:17:51
there's others, but this is a one in South Townside that has been developed with possibly very similar um
2:17:58
circumstances. So, thank you.
2:18:04
Thank you. Before I move on the agenda, is there anything further council wish to say under item six and no? Okay.
2:18:13
I have made a note of 515 sites that have been looked at as part of the plan
2:18:18
making uh process in total. If I can then move on please then to
2:18:24
item seven. Uh I think this is the other side possibly uh the other side of the
2:18:30
same coin. So for those who I've heard from who think that the plan making process has not uh looked at all
2:18:38
potential uh opportunities or sites or to make as much use as possible of suitable brownfield lands under utilized
2:18:45
sites. Uh it was my MIQ 4.2 Two is whether the council's made kind of
2:18:50
reasonable um assumptions or approaches in terms of um optimizing the density uh
2:19:00
and suitability of land particularly within mentioned at
2:19:05
the start of this session around town centers uh and locations
2:19:11
uh close to public transport in terms of I think ultimately I think the council's evidence is identified opposing
2:19:19
on top of uh commitments to allocate 27 sites within the kind of builtup areas
2:19:26
to give a just I think just short of 1,200 new homes and I think we're going to
2:19:31
hear from others who think that may be an overestimation but I'll
2:19:38
give the council the opportunity to talk to MIQ 4.2 and the density and uh
2:19:43
optimization work that you've done. Yes. So the density report is kind of
2:19:49
our main base of evidence for the the densities that have then been carried over into the schlar assumptions. Um so
2:19:56
the density report recommends higher densities around metro stations and town
2:20:02
centers. Um and yeah those assumptions have been carried over into the slot. It
2:20:08
is important to note that they were used as a sort of starting point, but where there's further evidence from site
2:20:14
promoters or from the council's own regeneration team, then alternative
2:20:19
densities might have been used. Um, as we set out in the efficient land use paper, there are quite a few council
2:20:25
loan sites that were proposing for higher density than the sort of standard
2:20:31
density calculations. And that's based on what internal work that we've done with our regeneration and asset
2:20:36
management teams.
2:20:43
Thank you. So in terms of as I've read you've kind of leased with the regeneration team. So is that
2:20:48
specifically or exclusively on councilowned sites or have you kind of cast the net a bit wider to look at
2:20:55
other other sites? Um in terms of the work with the the regeneration team that's on council owned sites. Um in terms of other sites
2:21:03
where obviously you know promoters have put their sort of master planning work forward as part of the consultation
2:21:10
process and we have taken that into account allocating other sites.
2:21:28
Thank you. And just to say with the council before I potentially uh widen or open this out, I mean in terms of
2:21:33
optimizing and higher density can tend to mean sort of one of two things or two
2:21:39
things either development increases in heights potentially or um smaller kind
2:21:45
of units to kind of um maximize or optimize the potential of sites. Is that something that's
2:21:52
um established within South Tinesside? Would this be kind of entering into kind
2:21:58
of new territory for the market? Are there any kind of initial viability
2:22:04
kind of signals that um so we have seen some higher density
2:22:09
planning applications coming forward and one of which is being built out currently at Hullbborne um and I would
2:22:16
draw your attention to table 6.3 in the schmar which based on sort of evidence
2:22:22
of speaking to residents and the surveys that the done it recommends a tenure mix
2:22:27
of 15 to 25% flats and then an additional 15 to 20% one to twobedroom
2:22:33
homes. So I think that signals that the market is there for higher density dwellings whether that's sort of smaller
2:22:39
homes or flats.
2:22:51
Thank you. Thank you. And is the council able to advise? I mean, are there any sensitivities around the height of buildings within the kind of the urban
2:22:59
pattern or grain of the burough, particularly within the urban areas in terms of potentially going up? Is that
2:23:05
not is that something that's potentially sensitive?
2:23:12
High high builds aren't typically a feature of South Townside. We don't have
2:23:17
a large number of high-rise um buildings in the burough. Um so obviously any
2:23:22
application that came forward for higher density would have to take into account the character of the local area and that would be determined basically at an
2:23:29
application stage.
2:23:39
And then finally for the council before I sort of open it this out from sort of the various representations and
2:23:44
statements from others um who have a view that potentially the
2:23:50
capacity of the urban areas is being overestimated which would then be a uh a
2:23:56
platform to consider further potentially further sort of green belt um alteration
2:24:02
is this kind of use of the kind of the yield ratio the 75% um net developable
2:24:09
area in terms of the uh through the strategic housing land availability assessment and whether given the various
2:24:17
kind of competing demands and requirements on development whether that's a reasonable kind of approach to
2:24:23
kind of inform what the capacity of some of these sites um could deliver. Yeah, we're confident that is a
2:24:30
reasonable approach. I mean a lot of the sites within the main urban area are council own sites. Um and like I said
2:24:36
earlier, we've worked closely with teams internally to ensure that the site capacities that were proposing in the
2:24:43
plan are realistic.
2:24:58
Thank you. I said I would move away from the council but one final promise. This is the final final point and then before
2:25:03
I open out and in terms of that work with the council regeneration team
2:25:09
would it be reasonable to assume you you know that took account of the kind of various policy requirements including
2:25:16
things like biodiversity net grain open space provision or the kind of types of things we would
2:25:23
expect to see on most developments. Yes. Yeah. Um yeah, we have undertaken
2:25:28
quite comprehensive conversations with those teams and obviously they're aware of the policies we're proposing in the
2:25:33
plan and national policies. Thank you. So probably bring in others
2:25:40
on this point. I know various uh people probably on the back of the room to me uh have raised uh question marks around
2:25:49
uh the realism of kind of what's being identified through particularly the 27
2:25:55
sites. um and the the yield of just just short of of 1,200 homes within the main
2:26:01
sort of urban area and whether that's a kind of a realistic uh and robust
2:26:07
figure. Uh I'll start with Mr. Martin from Pegasus first, please.
2:26:16
Thank you. Uh sir, yes. Um I think it's alluded to in our uh hearing statement.
2:26:23
Um, we don't personally doubt the veracity of the council's data, but it's useful
2:26:31
to highlight it's from 2015 to 2023. The risk has sound like a stuck record.
2:26:37
Statutory BNG came in in 2024. And to say it's had a
2:26:42
an a large impact on how uh house builders plan for their sites is is a is
2:26:49
an understatement basically because um I cannot see how um sites of 04 to two
2:26:58
hectares and over two hectares are going to get to the net to gross ratios that are shown in the density which is 90%
2:27:05
for 0.4 4 to2 hectares and 75% um to two hectares and over and the
2:27:12
reason for that is because the statutory BNG that's come in requires first of all
2:27:17
a sequential approach to BNG so that's um needing to provide it on site in the
2:27:23
first instance and you'll be well aware sir that it's a
2:27:29
competing interest with open space and it's often the case that you cannot simply stack the two and have them on
2:27:36
the same um same area simply because BNG itself needs its own management plan. It
2:27:42
needs to be taken care of. If you've got things like species rich meadows, you don't want people trampling over them.
2:27:50
Uh you know, they need to be managed and maintained carefully. So having that be
2:27:55
on-site BNG requirement as well as the open space requirement, you'll then have
2:28:00
elements such as, you know, which I'm imagine we'll go on to later on in the examination, things like M42 and M43
2:28:07
requirements and houses which tend to have larger footprints. Um and all of this adds up to the fact that our recent
2:28:15
experience and looking at sites you're looking at more 50 to 60% net to gross
2:28:22
um on often on development sites. So I do think that that the net to gross area
2:28:28
is is overly overly optimistic in in nature. Um
2:28:34
there is obviously the option uh if you can demonstrate sufficiently that
2:28:41
biodiversity net gain for whatever reason cannot be met on the site you can go offsite habitat bank or statutory
2:28:47
credits from the government. However again and I think Mr. um alluded to it earlier. these are um
2:28:54
you you effectively monetarily get punished for that in terms of instead of
2:28:59
a you know one for one biodiversity unit I think it's if you go to habitat bank that's um in the adjacent authority for
2:29:06
instance it's one and a half I think statutory credits it's twice as much so then that puts as I said if you're
2:29:13
looking at sites in the urban area that have lower residential values arguably
2:29:19
in some degree maybe less attractive to some uh people who want to move into the
2:29:25
area, it starts to become an ever more squeeze on viability and the
2:29:30
deliverability of those sites. So, it's really two things. It's it's to do with the deliverability of them given the
2:29:36
increasing policy requirements and also it's whether actually realistically that net to gross ratio can be achieved. And
2:29:44
I'd be interested to know from the council as to whether that they seem quite confident about those. Have they
2:29:50
have any sort of testing layouts or framework plans been done on any of these sites to actually verify whether
2:29:56
that would be the case or is this just a general assumption that's been made?
2:30:03
Thank you. Thank you for that. We'll come back to the the council on that. I mean just as
2:30:09
a a general point, Mr. Martin, I appreciate biodiversity net gain starts
2:30:15
from a baseline position. So it's it's what's there already. Uh I'm not going
2:30:20
to kind of get into too many sort of generalities, but I mean in
2:30:26
uh thinking about some of the sites within the main urban area of South Tide,
2:30:34
is it likely that the biodiversity baseline is going to be significant in terms of thinking about a proportional
2:30:42
kind of improvement on what may or may not be there? Um yes it is and it unfortunately it's a
2:30:51
quirk of how the biodiversity net gain system works as in often you will get
2:30:56
penalized on brownfield sites more than green field sites and the reason for this is unless the site is a complete
2:31:04
sealed surface and there's no cracks or anything like that you're fine as soon
2:31:09
as it becomes anywhere near sort of neglected and you start getting species
2:31:15
of plants and stuff that's classed as an open mosaic habitat. Now that in itself is difficult to
2:31:22
replace. Now the trading the the metric requires you to um and it's getting a
2:31:27
bit techy but it requires uh you to adhere to trading rules. So if there's an open mosaic habitat within a
2:31:33
brownfield site, the metric would point to you replacing that with other open
2:31:39
mosaic habitats, which is actually very difficult to achieve on a site.
2:31:44
um and which often means for brownfield sites it becomes really difficult to
2:31:50
establish that 10% net gain um and if then if you have to go as I said on the
2:31:55
to an offsite route or statutory credits it becomes very expensive
2:32:00
so in terms of the soundness issue um and what potentially you may be inviting
2:32:07
me to consider Mr. Martin, is it is it effectively a rerunning of the strategic housing land availability assessments
2:32:15
to apply different kind of density ratios? I think it I think it would be to look
2:32:23
at the assumptions they've made for the net to gross ratios and rather than
2:32:28
taking it as a retrospective exercise and looking back since 2015,
2:32:34
they need to be um considering what the latest policy requirements are in terms
2:32:40
of um in terms of uh what's required when you put a planning application in because it has radically changed in the
2:32:46
last few years and it's become a real big challenge for the development industry more generally. So yes, it's
2:32:52
it's more about revisiting that methodology.
2:33:00
Thank you. I'll hear from Mr. Eton next, please. It's just to add on some of the points
2:33:06
already raised by Mr. Martin. Um the housing density study, there's one
2:33:12
previously done as well. So the most recent version targets 66 donnies per
2:33:17
hectare identifies that in their in their assessment. The the previous 2018 density study and it had 40 per hectare.
2:33:26
So much lower compared to the more recent one. However, it's the more recent one which has informed policy 14
2:33:32
which is the density policy in the local plan which targets I think minimum 35 dwellings up to 60
2:33:40
per hectare on development sites and that density is also informed and been applied to the draft allocations in the
2:33:47
main urban areas and now in our submissions we kind of identified quite high densities that's resulted in being
2:33:53
expected to be delivered on those 25 sites and a lot of those sites the relative
2:33:59
small. So I think you can sometimes increase density in large regeneration
2:34:04
schemes, but with these smaller scale sites, it's very much dictated by the surrounding context. You can't really
2:34:11
jar with that. You can't reset that context. Um, and it's not just so it's
2:34:17
also neighboring overlooking access points, site constraints, and they all
2:34:22
eat away into limit how much you can put on those sites ultimately. And it's not
2:34:27
clear from my assumption my my understanding is that those capacities were based just on that indicative
2:34:34
densities from the density study not from sight specific considerations
2:34:40
where those sight specific considerations have been applied on the larger sites in some of the framework um
2:34:46
strategies and thereforities and I think that's probably because they've looked at more detail in those
2:34:52
site constraints and recognized that those higher densities can't be achieved on
2:35:01
Thank you, Councelor Taylor. Thank you, sir. Um, regarding the
2:35:08
density within the town center, South Shields Town Center specifically, you've got like Queen Street, Salem Street, all
2:35:13
these sites which to the naked eye without a full report certainly don't look like they're a species rich. The
2:35:19
they're the quite especially the Queen Street ones just got buildings at the minute. So I can't imagine there's going to be much biodiversity net as a the
2:35:27
baseline like you already touched upon. Um so I would love to see and I know that the center for cities think think
2:35:33
tank report calls for authorities to focus on developing homes in central locations to revive alen town centers
2:35:40
and I would love to see like much higher buildings with much higher density in
2:35:46
those specific sites which a council have raised. I think that's a a fantastic idea and you know to to get as
2:35:53
many people in as possible in just within the the town centers I think specifically
2:35:58
um and um I know there's a site the old clinic on Ben Lane site um which is it's
2:36:04
only a small site and I know you say I didn't want to focus on tiny little parcels I appreciate that but um maybe
2:36:11
possibly that site could possibly be used for some high density housing as well but unfortunately that's actually being not counted and it's not including
2:36:18
the local plan. Um it was looked at but there's no in my view valid reasons for
2:36:24
taking that out. It was noted in it was because it was too close to the an air monitor which is hundreds of meters
2:36:30
away. I didn't understand why that it would be taken out for that reason which it's prime land for for some houses. Um
2:36:36
but yeah, so just um just to to sort of
2:36:42
to mention again that because I know the Green Party you're really um really adamant on um high density houses in
2:36:50
town centers, Heaven Town Center, South Shields Town Center, Jaro Town Center to
2:36:56
um to help alleviate the the need for green belt development. Thank you.
2:37:02
Thank you, Mr. Butler. and then I'm going to come back to the council and then back to Mr. Martin.
2:37:10
Thank you, sir. Um, we heard evidence yesterday relating to SP2 and the street
2:37:15
housing market assessment uh about the uh need for older person's housing uh
2:37:22
within within the burough. And um as part of uh stage two, we'll be looking
2:37:28
at policy 19 where we've made a modification suggesting uh that the plan addresses this matter more clearly. But
2:37:36
it is an issue quite clearly of density. Uh we have many examples in uh in our
2:37:41
area of special accommodation which is largely threetory and therefore of a higher density and these properties are
2:37:48
should be well located to public transport. So I would suggest that there is uh in terms of addressing the the
2:37:55
issue the character of housing market uh there is clearly the need and therefore one hopes uh the ability to deliver much
2:38:03
higher density for accommodation for older persons. Thank you.
2:38:12
Thank you. I'll come back to the council. Um Miss Cooper, I wonder if the council can specifically pick up the
2:38:18
point raised by Mr. Martin in terms of whether the council's kind of look at this was a kind of a theoretical kind of
2:38:25
approach or whether you kind of did or undertook you know more specific kind of
2:38:30
analysis of the capacity of some of these sites. Yeah. So similar to our approach to
2:38:37
density we used that as a sort of starting point and then like I picked up
2:38:43
earlier most of the sites in the urban area are council own sites. So we have done a lot of work internally looking at
2:38:49
the um capacity of those sites um and a
2:38:55
lot of those we are sort of proposing to deliver a higher yield and that's an aspiration of the council to deliver
2:39:00
those higher yield sites.
2:39:06
Um sorry again I'll just pick up um table three in the efficient land use paper sets out those sites where we have
2:39:11
looked at higher densities. Thanks.
2:39:17
Thank you. So the council has done quite a bit of work on this. Um is it presented as part of the uh density
2:39:25
report or the uh efficient use of land paper? Is it something that
2:39:31
could be provided to the examination?
2:39:39
Um I think yeah something that we can look at. Okay. I'm mindful you did sort of you
2:39:44
have produced obviously site framework documents. We got document how to which is quite helpful in terms of some of the
2:39:49
site allocations. I wonder if there's somewhere in all of the evidence that sits behind
2:39:55
a local plan something that's captured a bit more your kind of um
2:40:01
scrutiny and sort of examination of these particular sites in a format that could be shared or disclosed with the
2:40:08
examination. um not in terms of those smaller urban area sites. Yeah, that process was just looking at the the
2:40:14
green belt sites, but yeah, it's something we can we can look at.
2:40:21
Okay, I will record that as an action point. I'll try and articulate or capture a bit more what
2:40:27
I'm looking for, but I'm I'm assuming there is some whether they're proformers
2:40:32
or records of discussions about how some of these sites were
2:40:40
I'm getting nods to my right. So, um there might well be something.
2:40:49
Thank you. And I'm sure Mr. Martin and others probably want to see that as well in due course and it might be something
2:40:54
we come back to as part of um stage two and considerations around density um
2:41:01
more generally. I just wonder if the council would want to also briefly comment on this kind of uh point around
2:41:09
whether there is an issue of looking back over a certain period of time and what past trends have told us about
2:41:15
density versus what has changed quite recently
2:41:20
particularly biodiversity net gain whether there's a potential issue there.
2:41:27
It's certainly a legitimate issue. Um and something which we can have regard to. I actually do um
2:41:36
believe that when we come to stage two and we examine the individual sites, it
2:41:44
might be more profitable to have regard to that issue having regard to sight specific characteristics.
2:41:52
And then you might say, well actually I've looked at this and I think there would be a deficit over the plan period
2:41:59
of this kind of range between this and this. Um or you may come to the view
2:42:06
that actually the assessments are are broadly okay. Um but that that is the time I think rather than looking at it
2:42:12
in an abstract way now and applying what might be a multiplier to to it. uh we
2:42:20
ought to be saying well hang on let's have a look and see how the individual sites perform because that's going to be
2:42:25
a major issue for stage two. It it will be I mean that does um it
2:42:31
will hang on whether there are soundness issues with it may be that some of these sites when we come to the detail they're
2:42:39
not controversial people may not have raised soundness issues particularly around them so I think there is I
2:42:47
appreciate the point you're making Mr. shadow ra enough about let's look at the detail of some of these sites but I
2:42:53
still think there's a legitimacy around just looking at the the overall methodology are we starting broadly from
2:43:00
the right place is there something I need to flag and have in my mind either
2:43:05
now or as you say let's look at this in a bit more detail when we come to stage two and some of these specific sites
2:43:12
because maybe then that crystallizes actually on such and such a site
2:43:17
council's assuming being 80. Yes, I think when we looked at that in more detail that does look about right, but I
2:43:24
think there's still a valid issue now about the overarching approach. I I I don't I don't doubt that for one
2:43:31
moment. What I'm suggesting is when you come to do that particular exercise at the second stage um that will act as
2:43:40
some kind of indicator as to whether or not the overall methodology adopted was reasonable because if you identify sites
2:43:47
and there are serious misgivings about the capacities assumed for those sites then of course it could raise issues in
2:43:54
terms of the number of houses which are being provided over the planned period and also the appropriateness of the
2:44:01
trajectory. uh and that's where it becomes important and where soundness really bites. But
2:44:08
you're not going to be able to make a judgment from um looking at overall methodologies at this stage to say
2:44:13
whether or not the plan is sound or the or the exercise is sound without that confirmatory approach.
2:44:20
That's the point I'm making. Having said that, we will provide you with what information we have at this stage.
2:44:29
Thank you. I'm looking at a soundless jigsaw. There are many pieces, Mr. Chavian. So, uh um
2:44:38
but you're right. There'll be there'll be areas where I won't draw a conclusion till I've looked at the the complete
2:44:44
picture, but this is an appropriate time to just look at the general approach and
2:44:49
whether we're starting now with some kind of things to think about. So, Mr.
2:44:55
Martin, your opportunity to come back in on this. Thank you. I do think it's important
2:45:01
that um it's shown in that additional work that the c you've asked the council
2:45:06
to do that they do show that BNG has been fully taken into account because I I remain to be convinced that those net
2:45:12
ratios can be achieved and it is fundamental to the plan because it's all about actually how do you need to be
2:45:18
actually looking at more green belt release and it is fun that is for my mind fundamental. The other point I
2:45:25
wanted to raise was there's been a lot of talk about densities, higher buildings in town centers, etc. And
2:45:33
again, it's probably a question for the council, but has any of that been
2:45:39
factored into the plan viability? Because once you start building up, hous
2:45:45
the buildings tend to get a lot more expensive to build because of various engineering works that you need to do
2:45:51
once you start building higher. The other point is once you get to a certain height with buildings, you fall under
2:45:57
the remit of the building safety act and you have to then make specific design changes to a building which can make it
2:46:04
more um expensive to address uh fire regulations in you know following the
2:46:10
Grimfell disaster they've been tightened up a lot more. Um, so it's really just
2:46:15
if we if you are talking about building up higher, has any of that been taken into account in the evidence base?
2:46:22
Because again, it's it you once you build higher, it starts to get a lot lot more expensive.
2:46:28
Thank you. I'm going to pick not going to sort of gloss over it but I am going to pick it up as part of stage
2:46:34
two and when we look at the kind of cumulative kind of cost implications of all all the policies of the plan and
2:46:40
obviously being directed to uh to other policies particularly around around density so we will I will want to come
2:46:47
back back to that. Um is it Mr. Green next please? Yeah, just very quickly, uh
2:46:54
there's another urban footprint in uh in South Shields. Uh it was where the old library was and uh it was going to be
2:47:02
originally what I've been informed was it was going to be student accommodation for the marine students from the college
2:47:08
uh but they're now going to be moving into the old BT building which is right on the seafront and so on on the river
2:47:14
side and I'm just wondering exactly what's going to happen to where the old library is in South Shields because it
2:47:20
is quite an an area uh and whether that's going to be allocated to uh
2:47:26
employment or that's going to be allocated to housing. Can the council assist briefly? Is this
2:47:32
something we will pick up as part of stage two? Is it a site that's either within the South Shields regeneration
2:47:38
area or uh No. So, at the time of writing the plan, that site was sort of earmarked for student accommodation as it's being
2:47:44
picked up. Um, and that's the type of site we would envisage coming forward as a windfall.
2:47:51
Well, we look at windfall rates, windfall allowance uh as part of stage two. Mrs. Hunter
2:48:01
rest really when we talk about, you know, keeping reducing the the footprint. I think we've gone from a
2:48:08
twostory house to a skyscraper. I don't think that's what we're advocating that we want. I think it's just if you if
2:48:15
you're going to build twotory, build four story. We I don't think it's expensive. It doesn't come into all
2:48:22
those building rags and it reduces the footprint. It it doesn't create a slum
2:48:28
area or anything like that. It just it gives you an extra accommodation on on the footprint.
2:48:35
That's I just I just need to put it straight that we're not going for multi- um skyscraper
2:48:42
um options. I think we need to see what what we need to see, Mrs. turn to is what the council's kind of what their assumptions
2:48:49
and sort of analysis has been in terms of some of these these sites as to what
2:48:54
they can accommodate and whether there kind of been considerations in terms of the scale uh and massing of those those buildings
2:49:02
um very briefly Mr. Martin did you have skyscrapers in mind? I did not know but what I would say is
2:49:10
that the building safety act comes in actually at a fairly low threshold. just once you get over 18 mters in height.
2:49:17
So, it's not we're not talking about super tall buildings here. We're we're talking about things that could be four or five stories. Okay.
2:49:29
Okay. I'm going to move on please now in terms of the uh the agenda for today. Um
2:49:36
um recorded the action point for the council to assist the examination on.
2:49:42
Um, I appreciate a number of people made similar submissions to Mr. Martin in terms of concerns around um
2:49:50
uh the uh
2:49:56
yield uh ratios that have been been applied. So, uh they don't need to
2:50:01
necessarily be echoed. But if I can just point to or turn to sort of the final
2:50:07
part of um the national planning policy framework and um demonstrating or
2:50:13
starting the case for demonstrating exceptional circumstances. Um
2:50:20
it does have significant overlap I feel with our discussions previously on the duty to cooperate. Obviously it's raised
2:50:27
specifically in relation to national policy and green belt and exceptional circumstances. I asked at uh MIQ
2:50:35
4.5 around the discussions with neighboring authorities and whether the council's kind of reached the evidential
2:50:42
threshold to kind of pass through point C of paragraph
2:50:47
141 of the MPPF is it Mr. Clifford. Thank you sir. As we've set out in the
2:50:53
duty to cooperate statement, once it became clear that the council
2:50:59
was unable to meet its objectively assessed need for housing without the
2:51:05
alteration of green belt boundaries. We wrote to neighboring authorities
2:51:12
asking whether they would be able to assist in meeting housing needs.
2:51:18
Gates, Sunland and Northinesside councils all responded
2:51:25
to state that they would not be able to assist. We wrote again
2:51:31
and subsequently in 2022 and again we
2:51:37
received the same responses. they would not be able to assist in meeting either
2:51:42
our housing requirement or our economic development needs. And this evidence is
2:51:49
set out in the duty cooperate statement appendices and also
2:51:58
in an addendum to the duty to cooperate statement which are all available as part of the document library for the
2:52:05
examination. Um, I would further make the point that
2:52:11
all four of our neighboring authorities, Newcastle,
2:52:17
North Tinesside, Sunderland, and Gates Head are themselves Green Belt authorities. They
2:52:24
have their own challenges in in meeting their development needs. While we've not
2:52:30
seen it as necessary for us to interrogate
2:52:36
their land supply situations because we feel they are professional planners,
2:52:42
they know their areas better than we do. The fact that they are green belt
2:52:47
authorities and informal discussions with them have always indicated they have their own challenges in terms of
2:52:54
meeting their own needs. So I feel that we have um very decisively
2:53:02
and and comprehensively demonstrated that that is not a reasonable option from a plan
2:53:10
making point of view for this council.
2:53:20
Thank you for that. I appreciate there are people at the table who have an alternative view. Some of that has been
2:53:25
aired as part of the duty to cooperate um
2:53:30
uh discussions. But in terms of um
2:53:36
the council's approach, there are statements of common ground before me with those
2:53:42
uh three uh adjoining authorities and now fourth one with Newcastle City Council.
2:53:52
Um I appreciate a lot of people have made submissions under the duty to cooperate discussion on the first day
2:53:57
about the the extent and efforts to which the council has sought to engage
2:54:02
um with others. Is there anything further people want to raise at this stage? Councelor Kilgore, is that on this point?
2:54:08
So I'm really sorry um I kind of was um playing a game there with this. I wasn't
2:54:14
um sure whether it was relevant, but just to go back just one step if I may. um can we look at particularly the um
2:54:21
high-rise element and the higher density element with regards to the proposal for Felgate as well and I know we'll come
2:54:27
into that in more detail um but I do want to look at the positioning of that
2:54:32
proposal um not that I'm wanting to entertain it but I do think that needs to be addressed as well but but coming
2:54:40
on to this matter I think um Mr. agree mentioned yesterday with the duty to
2:54:45
cooperate in the council submission um at 4.30
2:54:51
it states that the responses from each council state that they will not be able
2:54:56
to assist comprehensively. So what what does that mean? Um does it mean in some
2:55:02
way does it mean not at all? Because the language that we're hearing is that they cannot assist, but it specifically says,
2:55:09
and I'm basing it on that word comprehensively. What does that mean? Have they offered us something, but not
2:55:16
a lot? Q. Thank you, Mr. Clifford, you over to
2:55:21
assist on that point. Yes, I can assist. Uh, apologies if that phraseology isn't clear. Um, but their
2:55:30
responses are part of the evidence base. They're in the document
2:55:37
library and it's quite clear they're not able to assist at all.
2:55:45
Thank you for that. Just before I move away on this this issue, I want to clear
2:55:50
in my mind. I think it's Mr. Martin. and it was in your statement and uh response
2:55:56
to MIQ 4.5. I can't recall which hat you were
2:56:01
wearing, whether it was Belway Homes or Belway Northeast,
2:56:07
but my note to myself here because I thought it was an interesting phrasiology
2:56:12
was that you describe South Tinside as an outlier in terms of what's
2:56:17
potentially happening more widely. I didn't know that was in a positive way in terms of where we are with plan
2:56:22
making or whether there's something else I need to No, so it was more just an observation.
2:56:28
Um, Southside is an outlier in respect that all the other constituent
2:56:34
authorities that make up the northeast combined area have had adoptive plans in
2:56:40
place over the last few years and where you did Northside for instance. So they're all at a stage now where they're
2:56:47
either about to or are in the process of reviewing their plans and it all forms
2:56:55
together in terms of the um SDS the spatial development strategy that will
2:57:01
be coming forward for the area and I'd imagine it will be through that process
2:57:07
where any sort of sharing of housing numbers will come through. So it was
2:57:14
really just an observation that I if there are going to be sharing of housing numbers, it's probably not for
2:57:20
this plan. It would be for a review because they're somewhat outst of the rest of the the region, so to speak.
2:57:36
Thank you. That's that's helpful. I was just wondering if there was something else to that uh to that phrase.
2:57:44
Okay. So, in terms of this kind of first issue and kind of the uh as I say the sort of the foundations for um for
2:57:51
demonstrating uh exceptional uh circumstances in terms of strategic
2:57:57
pro approach um to the um uh
2:58:10
to the green belt. Um I think it's sort of pulling it together into sort of my uh MIQ 4.6. It's item nine uh of the um
2:58:20
agenda. uh having looked at all the various kind of factors
2:58:25
um does there remain a residual unaccom unaccommodated need for development that
2:58:32
would comprise exceptional circumstances and I referred to the Calverton
2:58:38
test and case law uh at the start of this morning I think used the word there acute or the the acuity of need is a a
2:58:47
consideration as part of the judgment of whether exceptional circumstances exist.
2:58:52
And I think I was quoted the figure yesterday that once the council's been through all of this kind of looking at
2:58:59
available supply within the main urban areas optimizing it is still around in
2:59:05
the council's figures at the moment 2 thou around about 2,250 houses
2:59:12
uh short of meeting your minimum housing need figure. So I'll invite the
2:59:18
council first uh obviously I've read your your your statement but um your kind of conclusion and how you arrived
2:59:25
at um that position of feeling that there was or that there are the
2:59:30
exceptional circumstances to consider green belt alterations.
2:59:36
Yes, thank you. I think um as set out in our response to question 4.6 Six. Um the
2:59:43
council does consider that there are exceptional circumstances at a strategic level for green belt release through
2:59:48
this local plan. Um this information is brought together through the green belt
2:59:54
exceptional circumstances paper which DRB2. um that doc that that paper documents
3:00:01
that there are inherent constraints in the supply of reasonable non-green belt
3:00:06
resources to meet the minimum requirements for our housing need in the short and long term. And therefore it's
3:00:12
considered um within the do the exceptional circumstances paper that the
3:00:18
social and economic environmental and health implications of not meeting our housing need have also been explored
3:00:23
through that paper as well. And as a result, the council considers that to
3:00:28
enable to meet our the housing need is going into the green
3:00:34
belt would be the most sustainable approach for this version of the local plan.
3:00:59
Thank you. Now I'm assuming from the back of the room, if I start from Mr. Eton across to Mr. Fulture, there's
3:01:06
probably no dissenting voices that exceptional circumstances
3:01:11
um exist here. And in terms of modifications to the plan, it's not looking at a terms of a fundamentally
3:01:17
different strategy. It's probably the extent to which there is a need
3:01:23
um to go into uh or to consider green belt alteration and probably from a view
3:01:29
that the 2,250 or so houses um it's the figure is likely to be be
3:01:36
greater than that. So you're not disputing that the council's demonstrated exceptional um
3:01:42
circumstances. But I appreciate if I turn to my left. There are those who do
3:01:48
uh dispute that exceptional circumstances or the basis for exceptional circumstances to consider
3:01:53
altering uh the green belt uh have not been um made out.
3:02:00
And presumably from those those of you on that side of the
3:02:05
room, it's in terms of what you would be seeking me to do. Is it is it as um significant as
3:02:15
saying this is not the the plan? It's it's the wrong it's the wrong plan or it's a plan
3:02:22
uh that could be addressed through alternative or different green belt alteration green belt different level of
3:02:29
green belt alterations. If I can start with councelor Kore then
3:02:35
Mr. Green then Mr. Hutchinson please.
3:02:40
Thank you, sir. Um, no, I absolutely don't think that exceptional circumstances can be demonstrated. Um,
3:02:47
and of course, I'm going to, um, refer to, uh, Felgate Green Belt in particular. So, as it was discussed
3:02:54
yesterday, um, Sunderland local authority do include the AMP in their
3:02:59
local plan. I went and checked that again um, last night. We don't. Um I
3:03:05
think that the allocation for Felgate is not only um inappropriate, it it doesn't
3:03:12
demonstrate exceptional circumstances, but it's also significantly disproportionate
3:03:17
um to the other allocations. Um when you look at the AAP coming online as well,
3:03:24
um it takes further green belt from that area in the plan. um and it simply isn't
3:03:31
enough of a robust argument. I think we also learned yesterday um an affirmation from the local
3:03:38
authority that the flood risk etc. um we've always maintained that it has a
3:03:44
significant flood risk. Um I know as a local authority member that we have looked to progress small schemes for
3:03:52
residents with regards to some hard standing um on the Felgate estate and that has been rejected. um because of
3:04:00
the scheme that was put in place on Felgate that it really does um hold it
3:04:05
in highstead for safeguarding the estate as it is but without any further
3:04:10
adaptation or hard standing built um in in any direction. Um, I also think that,
3:04:18
you know, I read quite a bit last night around uh bridal ways and bridal paths
3:04:23
and Sunderland note the um the actual um establishment of them of new ones. We're
3:04:30
looking to take this one away. Um we are um you know it's a site with a bridal
3:04:36
path in you know certainly in our opinion that we can support um has been for for over 20 years. Um so where the
3:04:45
provision within the Sunderland plan um provides holistically for the green belt
3:04:52
um I feel that our plan and separating it um does not include it and therefore
3:04:59
um is is not proportionate at all. I also wanted again to mention about the
3:05:05
um the density. It it doesn't demonstrate um appropriate land use, the farming
3:05:13
use, the flood risk, the traffic, the infrastructure etc. that we have
3:05:18
submitted and we'll submit further um next week. But I don't think at all um
3:05:24
that it demonstrates exceptional circumstances. And I think you know those of us around this table have
3:05:30
studied this for a great number of years and cannot find and what I would um
3:05:36
refer to is that it didn't come under exceptional circumstances
3:05:42
in the last iteration of the plan. In fact, quite the opposite. and the
3:05:47
arguments are quite or or not quite they're very very robust. Again, we're
3:05:52
looking at um information that is contrary to what has
3:05:58
come before. What I don't understand is is how one consultant can render this um
3:06:05
not suitable and not exceptional and yet another can. uh it it is so inconsistent
3:06:13
and you know we're lay people um you know noting this but I think sometimes it's really good that we're lay people
3:06:20
in order that we can um look at it with a fresh pair of eyes and understand what's gone before and I think the
3:06:26
arguments that you use before you simply can't turn them on the head I know planning is subjective but I don't think
3:06:32
it stretches this far you thank you councelor Krueger we'll come on to uh is part of today's discussion
3:06:39
about how the council has looked at kind of reviewing the green belt uh in terms
3:06:45
of its overarching methodology and I think I have a specific question around obviously there have been um uh various
3:06:52
green belt uh studies undertaken but obviously the final one is the one by LU
3:06:58
which is before me uh in support of this plan but we'll we'll we'll look into that probably be um
3:07:06
uh very shortly in terms of on the agenda I just want to clear in terms of um sort of the
3:07:15
starting point for exceptional circumstances and we will obviously look at Felgate in more detail next week
3:07:22
in terms of I've I've got to come to a view and a conclusion as to whether the
3:07:28
housing need is as the council say it is around about you know 5,000 or so
3:07:33
houses. If I were to arrive at that view, that's that is the figure. The
3:07:39
council telling me through its evidence though when it's looked at every what it
3:07:45
thinks are reasonable options within the main urban areas, there's still a shortfall for h houses for people in
3:07:51
need. Is it your view that that's still not the point? Or if I were to arrive at
3:07:57
those that conclusion, you're still not in exceptional circumstances, you still wouldn't change the green belt. what
3:08:04
potentially there would be a a shortfall of housing. Some housing would just go go unmet.
3:08:10
Yeah. So, sir, I wouldn't I wouldn't want us um falling behind certainly as a local authority and certainly not
3:08:15
wanting to stem any advancement. However, I think as we've discussed this
3:08:20
morning, there are other sites that I think um need to be revisited or certainly looked at in the first
3:08:26
instance and and the methodology applied there. Um I think we do very much with
3:08:32
Felgate and I don't want to sound like a nimi but I think we have just caused um with regards to the proportionality and
3:08:39
the loss um the buffer has been squeezed. It was mentioned yesterday um
3:08:45
by um another colleague of mine that it is you know we're encroaching on those
3:08:51
boundaries from the opposite side with the AMP and then to squeeze that
3:08:56
boundary and the buffer between various local authorities is just improper. You
3:09:02
know I I don't think anyone can negate um the need for housing but it also has to be appropriate housing. You know, I
3:09:08
use the word and I know we're using the word um affordable, but affordable to who, you know, um I much prefer, and I
3:09:16
know it's not within MPF um September 23, but um it's social housing that we
3:09:22
need. We see that we need um one-bedroom dwellings, and we got some figures yesterday from the local authority about
3:09:28
just how many single household dwellings there are. There are thousands. and that I think there's about 1300 um on the the
3:09:36
ward that I represent. So it's it's about what is appropriate in what
3:09:42
proportion. Um and because I think we have taken up our proportion to be fair
3:09:48
um with the development of the AMP that has been justified which is a you know it's a further um investment zone with
3:09:56
with the the the goodies that that brings I don't think the necessity to develop further housing on on that um
3:10:03
area is appropriate. I think as well I read the sister um account and the um
3:10:10
the assessment there as well again last night and it very it actually clearly states that it would not be safe. So I
3:10:18
think that speaks for itself and it and it says it's not safe with the projections of even the 1,200 um let
3:10:26
alone uh what the developer would like that to multiply into the infrastructure
3:10:32
is not there. it's not going to be there and the funding of that minimizes I'm sorry sir to go on but it minimizes the
3:10:38
availability and the very option and I've seen this a million times of um the
3:10:44
affordable housing and the 106 agreement it is a tradeoff and it's not an acceptable trade-off I'm afraid
3:10:51
thank you there is probably a lot there councelor Kilgore that we're going to come on to next Tuesday I think are you
3:10:57
are you joining us for that session yeah okay so I think you I'll uh you'll be able to make those points points again
3:11:03
at that at that session. Um, now I've forgotten what order I said I'd hear
3:11:08
people from. So, I hear from Mr. Green next and then we'll work away. Yeah, council council kos, you know, touched on a lot of the points where I
3:11:14
was going to make. I just think that's uh except exceptional circumstances don't apply here in relation to the
3:11:20
green bell boundaries because there's an abundance of you know as were previously stated this this morning of brownfield
3:11:27
sites still available uh which I think is counced.
3:11:33
Uh I don't think I can sort of say that there isn't except exceptional circumstances without doing so.
3:11:40
Yeah. Thank you. Um
3:11:46
we'll work that way down the table and then we'll come back to Mrs. Hunter. Do you want can I hear from you next or
3:11:53
please? Uh I'm going back to what council Kilgawa has alluded to in the fact that
3:11:59
the housing need for South Tinside. I would like the council to tell us what
3:12:05
they think the housing requirement is in South Tinside broken down by
3:12:12
affordability, social housing and what houses are going to be built on this green belt. Will that serve the
3:12:20
residents of South Tide? Okay. I'm just mindful we obviously had
3:12:26
session yesterday on on housing needs. So I'm clear what the council's telling me is the housing need and requirements.
3:12:32
We will we'll come on to uh specific issues around housing mix
3:12:38
and the proportion of affordable housing that's being sought particularly on the felgate site. I think it's essential that we do
3:12:44
because breaking the back of green belt to give to give housing that is not going to service the needs and
3:12:51
requirements of the residents in the areas does not denote exceptional
3:12:56
circumstances. These houses will not be available to the residents of South Einside which that council our council
3:13:05
is supposed to be serving. That's all. That's fine. Mr. Hutchinson, please.
3:13:12
Thank you, sir. Um, the point that we were going to make was around whether or not exceptional circumstances have been
3:13:19
made to justify the the alteration to the green belt boundaries. And the point
3:13:25
was essentially the same point that we made yesterday about the housing need.
3:13:30
Um you've just said that you you don't want to talk about that now. Is that
3:13:36
correct or I mean we we discussed the housing need in some detail yesterday. I'm aware of
3:13:43
people's kind of respective kind of positions that and those who say you know the housing need at the figures
3:13:50
that are put forward in the plan are not justified. there are alternatives and those alternatives should be used and where I
3:13:57
to go down the path of those alternatives you don't get the kind of the housing numbers
3:14:04
that um the council say at the moment would would comprise the shortfall.
3:14:10
Well, that that's correct. And um the I think the figure we quoted yesterday was
3:14:17
very similar to the uh the number of homes that are proposed within Green Belt Land within South Tside. So, you
3:14:25
know, we we rehearsed the uh the information that we'd had from the Secretary of State confirming that the
3:14:31
use of the standard method wasn't mandatory for the council and they could consider other bases for assessing their
3:14:39
own housing need. Um and we go just go back to the point that uh
3:14:46
they've used the 20 thou they dis discredited 2014 base for calculating
3:14:52
that whereas a much more upto-date basis would be the 2021 census. Um
3:15:00
so really that's the point we're wanting to make.
3:15:06
Thank you. Uh Mr. Butler next please. Thank you sir. Um in terms of the
3:15:13
importance of the green belt, I think the communities uh particularly within Clean and East Balden, but I think
3:15:20
across all of the green belt uh really hold the green belt in in in great
3:15:26
support. And uh just like to uh quote uh the letter that was sent by the chair of
3:15:33
East Balden Neighborhood Forum to the Secretary of State in June 2022 where she said the green belt here in South
3:15:40
Tide makes up over one-third of the Burough's area and has made a significant contribution in protecting
3:15:46
the identity of the villages and providing habitat for wildlife. And of course I've made evidence earlier that
3:15:52
the wildlife corridors network report that was then uh commissioned and by the
3:15:57
authority u evidenced that going forward it will play an important role in combating climate change and providing
3:16:04
food security. We believe that it must be protected for future generations. And I think this is
3:16:10
a very strongly held view by the communities and the importance of the
3:16:15
active participation in the green belt particularly its use for footpaths and
3:16:20
bridal ways and just the ability to to use uh those areas which was highlighted
3:16:27
during the COVID pandemic. we saw uh uh a greater use of the green belt uh as a
3:16:34
result of people taking exercise ability to get out out. So those factors I think
3:16:41
are are important factors that have to be measured in terms of uh the uh
3:16:47
assessment of whether exceptional circumstances have been given. And just to go back on uh one point uh in terms
3:16:54
of uh of the evidence given yesterday about uh population
3:17:00
uh Dr. Bulock referred to uh the 2022 ONS population figures. Um we're not
3:17:07
clear uh at this stage you know what the household projections would be for that. So I would again submit that that at
3:17:14
this stage we don't have uh the detailed evidence uh to to take forward his
3:17:19
suggestion that the number of uh households might be higher. Thank you.
3:17:26
Thank you councelor Taylor please.
3:17:31
Thank you sir. Exceptional circumstances are not met in my view. Failure to
3:17:37
justify green belt release NPF demands exceptional circumstances must prove no
3:17:43
alternative brownfield sites. Failure on housing need to lower target
3:17:49
can get plans found unound as we know but overallocating green belt when they are brownfield options is also unsound.
3:18:01
It undermines planled systems and public trust. National policy stresses the
3:18:06
importance of plan-led approach. NPPF paragraph 15. Green belt review should
3:18:12
be part of an evidence-based consultive local plan process. Ad hoc or
3:18:17
unjustified allocations undermine the credibility of the plan process and public participation.
3:18:24
Climate change commitments. South Tai Council has declared a climate emergency and ecological emergency with net zero
3:18:31
ambitions. Building on green belt or green field land is typically car
3:18:36
dependent, increasing transport emissions, loss of vegetation and reducing carbon sequestration potential.
3:18:43
Green belt release runs counter to local climate commitments. Risk of precedent and cumulative loss.
3:18:51
Approving development on green belt in one location. risk setting a precedent for further erosion. The strength of
3:18:58
green belt policy lies in its permanence and clear boundaries, allowing incremental loss weakens future policy
3:19:04
protections. The environmental act 2021 requires attempts on biodiversity net gain for
3:19:11
most developments. Destroying functional ecosystems and habitats, particularly those on green belt land makes achieving
3:19:18
net zero nearly impossible. Net gain, sorry, nearly impossible. Biodiversity
3:19:24
is not enhanced by removing mature trees or building over natural green field land. These are irreplaceable natural
3:19:30
capital assets. Follow the framework, not the bulldo bulldozer. South timeside
3:19:36
needs housing, but the MPPF requires a more balanced approach, not blind expansion into green belt and vital
3:19:43
green infrastructure. Now exceptional circumstances for the
3:19:48
AMP were met and were lost a huge amount of green belt land there and it was
3:19:53
disastrous for mature trees hedge and the only breeding barn owl site in the whole of South Tinside
3:20:01
now discounted small parcels of land for poor reasons
3:20:08
and larger sites like the ramen house without evidence to show why is wrong
3:20:13
and I'm hoping the inspector sees that as we see that the council
3:20:19
chose to go with high building figures and I know that was discussed yesterday
3:20:24
but the teams wasn't working yesterday so I don't know if you know that but um so I think that that really needs to be
3:20:30
fed into all this and um lastly the college site on St. George's Avenue um
3:20:36
in the local plan which it's now going to it's all officially going to be built
3:20:41
on that's 100 houses over what the target actually was in the local plan. So how you know um we need to factor
3:20:48
that in as well. Thank you.
3:20:58
Thank you for that. I'm not going to get into this the specifics of particular sites, but we will look at the kind of
3:21:04
the housing land kind of tables and calculations as part of stage two if
3:21:10
there's any kind of additionality we need to factor in um versus any other uh
3:21:16
other adjustments. I'd obviously um at the start of this invited the council um to talk to MIQ my
3:21:24
MIQ4.6 six. Um I think the council's referred
3:21:30
me in terms of I mean one of the things to think about as part of exceptional circumstances around securing s patterns
3:21:36
of sustainable development and I heard the council's view that
3:21:42
having considered the main urban areas and other settlements the way to achieve that is going to have to require looking
3:21:50
at altering um the green belt as part of this this local plan. Um, is there
3:21:55
anything further the council wishes to pick up or come back on as part of that that last exchange? No.
3:22:01
No sir. Okay. In which case, okay, we've got um it's
3:22:06
been a relatively long morning session. We will have a lunchtime in German, but I want to kind of make the most of today
3:22:13
and maybe uh take some of the balance off this afternoon. So, I want to just continue with some of the green belt
3:22:19
discussion. So mainly focused this morning on what I'm seeing in my mind is the kind of the bit the higher level
3:22:25
picture around exceptional circumstances. As I indicated, I'm not going to get drawn too much into the the
3:22:31
the detail of specific sites and whether uh the circumstances exist for those
3:22:36
sites. We'll come on to those as part of the individual um site discussions. But I did want to start sort of the
3:22:43
discussion on kind of the how the council's looked at the green belt. And I I think Mr. Shadow and you're going to
3:22:50
bring on some subs from the bench. Yeah, the subs are coming on now and um
3:22:55
we're going to give you an overview of the methodology employed. Okay. If that's helpful,
3:23:00
it is and you'll have picked up from my agenda and I think it's already been referred to by councelor Kilg Gore. I'm
3:23:07
very mindful the document I have in front of me to demonstrate the soundness of this plan is the 2023 green belt
3:23:15
review prepared by LU. But obviously through the process of plan making that
3:23:21
was brought in as a a sort of further piece of evidence in 2023. So obviously
3:23:26
people have got in their minds or there was an earlier uh green belt review and I wondered if
3:23:34
as before we get into kind of the introduction or whether it's part of the introduction to this session where
3:23:40
there's just a very brief overview of why it was felt necessary for the to do
3:23:46
the 2023 um green belt review
3:23:52
miss will deal with that and just the generalities of you know is this a formul ic process. So if you do
3:23:57
it once you'll get and do it again you'll get the same answer or whether it's you know it's an inherently
3:24:03
judgmental kind of process when you're looking at the kind of the various factors.
3:24:08
So maybe a bit of history and context Mrs. Lamb. Okay no problem. Um I think up until um
3:24:15
LU undertook the green belt review in 2023 that the council had undertaken
3:24:21
those assessments inhouse ourselves. Um I think um that process had started from
3:24:29
the the first regulation 18 that we did back in 2019.
3:24:34
Um and it was we we kind of felt it was an iterative process because I think we
3:24:40
were learning as we were going through um and and doing those assessments. Um
3:24:46
after the regulation 18 consultation in 2022 and in response to representations
3:24:52
made at that point um we undertook a a peer review and that's when we brought
3:24:58
LU in to to review the documents that we'd done up until that point. Um so
3:25:03
that was the stage one stage two green belt papers. Um and then as a result of
3:25:10
that peer review um and to ensure that the council had a robust and up-to-date evidence base to support the plan going
3:25:16
forward uh we commissioned LUC to undertake a further green belt review at
3:25:22
that point to make sure that the the green belt study was in accordance with the the latest national green belt
3:25:28
planning um national plan policy and also with um in accordance with recent case law as well which probably hadn't
3:25:35
been factored into the the internal studies that the council had done themselves
3:25:42
and I'm mindful as we sit here now I mean we describe it as is it the wider sort of t and wear green belt is that
3:25:48
the kind of appropriate kind of terminology for the for the green belt the metropolitan green belt
3:25:54
it is across the the region yes that's what known as and I appreciate we're obviously looking
3:25:59
at um south tin side but when the council was doing its initial work and
3:26:04
for l we'll probably come up we'll come on to how Luc approached it. Obviously, you've got neighboring authorities where
3:26:11
you know your your part of the green belt will um touch their part of the green belt. Was there any kind of uh I'm
3:26:19
going to use the rword regional or subregional um kind of framework or agreements about
3:26:25
how green belts would be looked at or did you kind of each authority come up with its kind of own approach?
3:26:33
At that point, we took our one approach to assessing those green belt assessments.
3:26:41
Thank you. I think at this point, Mr. Shraven, is it over to I'm going to ask Mr. Allen to introduce
3:26:47
himself, please. Good afternoon, Josh Allen from LU,
3:26:53
responsible for the green belt um study. Um just on that last point with regards to subreional
3:27:00
uh where we did consult on the methodology with with duty to cooperate neighbors before the assessment was
3:27:05
done. So they had opportunity to to comment on the methodology before the assessment took place. Um
3:27:12
I I'm going to cover just a broad broad overview of of item 11. Now um I think
3:27:18
reading through the representations um the main questions asked about the assessment method and its findings uh um
3:27:27
correct me if I'm wrong seem to be around if if we'd have parcels up the land differently if we'd have had smaller parcels
3:27:33
I think actually just to explain the overall
3:27:41
okay um well so our our our our main goal was to assess green belt harm. Um
3:27:49
that the green belt harm of release and of development. Um the approach we we
3:27:55
took is tried and tested uh and reasonable. Um it's one that we've um done up and down the country for for
3:28:02
many years and and been found sound to date. Um the the way that we we do the
3:28:07
assessment is that we we don't uh prepar.
3:28:13
Um so what we do is we we look at all the different factors in the round.
3:28:19
They're outlined in the methodology. We can go into them if you'd like. Um we consider um the function of the green
3:28:26
belt land, the relevance of each individual green belt purpose of which there are five. Um we look at the
3:28:32
distinction of the green belt land, its relationship with urban areas, its containment. We look at the openness of
3:28:38
the green belt land. Um think about those things all in the round.
3:28:43
um and then uh draw parcels and then we think if you were to release or develop
3:28:50
that land what the impact would be and what would remain of the wider green belt and if we think that that would
3:28:55
have further impact we then we we reduce the size of the parcels and scot the parcels accordingly. So what what that
3:29:02
means is that the the variation of the parcels in the study um are the product
3:29:08
of the assessment um and and as a result um any sites that fall within them or
3:29:17
portions of sites um broadly speaking would rate the same.
3:29:23
Um so that that was the starting point going through that process and and um and drawing out those reviations. Um
3:29:30
that was done at a minimum parcel size of 10 hectares uh which we think is perfectly
3:29:37
reasonable proportionate starting point to give you an initial strategic overview of variations across the plan
3:29:43
area to inform uh plan making. Um but we went further than that. Um once we'd
3:29:49
done that that assessment and we drawn out those those variations, we then
3:29:55
considered the harm that would result from the release of uh specific schlar
3:30:00
sites within each parcel. So all all the schlar sites that fell within each parcel area that had been defined, we we
3:30:08
we asked ourselves the question, would would the ratings for that parcel apply to that site? Um and more often than not
3:30:16
they did where that wasn't the case where the sites were particularly small or particularly contained by the urban
3:30:23
area sometimes part of a site we we added to the proform and said there's
3:30:29
small variations here and these are why um I mean I I would make the the general
3:30:36
point of course the release and development of smaller parts of the green belt regardless of scale would
3:30:42
would be inherently less harmful to the green belt but um based on the
3:30:47
application of the methodology that wouldn't change the ratings that we that we put in the report in any given
3:30:55
location. Um I'm I'm happy to go into more detail on
3:31:00
the methodology if you have any further questions but I'll leave it there. Thank you for that that overview and
3:31:07
obviously people have seen that document at uh GRB1 in the examination um library
3:31:14
in terms of um Mr. is it Mr. Allen? Yep. Um in terms of obviously the approach LU
3:31:21
have taken is to come ultimately to kind of a harm rating scale. It's either kind of got low or no harm, moderate high um
3:31:29
or very high. And that's pulling together that's coming from or looking
3:31:35
at kind of holistically the four factors that you've uh assessed at an earlier
3:31:42
stage that encompass the five purposes of of green belt and is that a
3:31:47
reasonable scale? Is that a scale you've in terms of that gradation of harm that you've applied in other
3:31:55
green belt assessment work? Yes. Just to be clear, we rate harm to each individual purpose and then the we
3:32:02
give an overall harm rating for a parcel based on the highest harm to any given purpose in that location. Um, and yeah,
3:32:09
it's it's reasonable. We we've done it um up and down the country for for a long long period of time. I mean, by way
3:32:15
of comparison, I I know it's it's it's out of the scope of this particular examination, but the go the government's
3:32:21
recent planning practice guidance on on green belt studies um uses a a three
3:32:26
tier rating system of high, medium, low.
3:32:32
And I sort of indicated at the start whether there's kind of like an inherently kind of judgmental you know
3:32:38
application of judgments as part of this process and trying to perhaps
3:32:43
obviously you've started to touch upon already as part of this discussion people are uh curious or interested as
3:32:49
to how you know green belt could have been assessed in in one way and come out with a different uh scoring or outcome
3:32:56
and then the LUC report arrives at a a kind of a different
3:33:02
uh potentially a different assessment or conclusion uh on a particular piece or parcel uh of the land. Do you think
3:33:08
that's a result of the kind of the methodology you've applied or ultimately the kind of the judgments that come from
3:33:14
that uh that process? Is that something you've kind of thought about or applied in terms of previous or you just kind of
3:33:23
solely and exclusively just applied your methodology and that's that's what's
3:33:28
shaken out as the outcomes of that process? Yeah. I mean, we we we're not particularly influenced by previous
3:33:34
previous judgments. We apply apply our method based on um yeah, what we deem to
3:33:40
be appropriate in terms of policy and case law. Um I think it's a combination of the factors that you just described.
3:33:48
Um yeah, nothing further to add on that really.
3:33:55
Thank you. This discussion may well kind of straddle um the lunch period, but obviously I'm mindful that there are
3:34:01
those around the table um who have different views on just the general kind
3:34:07
of method methodological um approach that's being um applied and
3:34:13
I think what I kind want to understand is whether the council's approach and the work of LUC
3:34:21
uh can be considered robust or whether there are when you look at the methodology applied significant problems
3:34:27
that um give give rise to kind of uh significant
3:34:35
soundness concerns uh for the plan and the approach it's taken to reviewing um the green belt.
3:34:43
So if I can start with I think Mr. Green first and then we'll work our way back
3:34:48
up towards uh Balden. Yeah, I'm just looking through this. Is this the stage three green belt review?
3:34:54
Is this the one we're talking about? Is it It will be the 2023
3:35:01
green belt review by LU. Yeah. Doc document GRB1 in the
3:35:07
examination. I think I've got the right one. Uh paragraph 4.29.
3:35:17
I'm hoping I've got the right one.
3:35:23
It makes a brief reference to the the schlaw as well.
3:35:30
Sorry, Mr. Grim, is that paragraph 439? 4.29 29.
3:35:42
If I haven't got the right one, I'll take it after lunch. I'll get the right one. It's just it's got stage three green green green green green belt
3:35:47
review and I'm assuming it's the same one a different one.
3:35:54
I I I don't think that's the same document. No, we don't have a Do you want to have a think about that over lunch and then we'll pick that up
3:35:59
when we come back? Would that report be applicable as well then? Sorry. Would that would the stage three green belt?
3:36:05
I think I need to understand what this this document is, Mr.
3:36:12
Sorry, I think it's the regulation 18 green belt review that you're looking Yes. Uh so that's obviously been updated
3:36:18
and superseded by the the 2023 document.
3:36:25
Okay. Uh councelor Kilgore.
3:36:31
Thank you, sir. Um I think for all of the reasons stated um is it Mr. Allen?
3:36:37
Um I I would um submit that um the the plan is flawed um and it isn't sound. Um
3:36:45
I think if we look at um quite um I
3:36:50
suppose common in a common sense approach that the greater the parcel the greater the harm. So when you're looking
3:36:57
at parcels of 10 hectares and ours is in Felgate is 51 um you know I think that
3:37:04
directly correlates with with far greater harm. Um if I misunderstood
3:37:11
please correct Mrs. Islam. Did you say that the peer assessment said that we were robust the local authority were
3:37:17
robust? No, we undertook uh a peer review to
3:37:23
make sure that the evidence that was supporting the plan was robust and on the back of that LU were commissioned to
3:37:30
undertake a new assessment. Okay. Thank you. So can I just come back? Um I think the it was my
3:37:37
understanding and I will find the document because I've got them. Um that a consultant also carried out a pre the
3:37:45
previous review which resulted in the outcome and the site um specific
3:37:51
allocations as well. It wasn't my understanding that the local authority carried that carried that out themselves
3:37:58
holistically. And I have I do have it and I do have the name of the the consultants that were used which is why
3:38:04
I can't understand um the disparity in them. And I think when we're looking at
3:38:10
um sequential impact as well we're looking at amp we're looking at a much greater impact because it rolls on and
3:38:18
we're also looking at the the developer doesn't want 1200 homes he wants 3,000.
3:38:23
So um in in breaking through that um it's actually sequential as well. So I I
3:38:31
don't think I think that actually really robustly um supports our argument as did
3:38:37
I think Mrs. Nickel was it yesterday um around the flood risk uh because the local authorities documentation if I
3:38:43
recall correctly uh rates it as um 1A or one uh whereas the report carried out by
3:38:50
LUC rates it at 3A and 3B. Thank you.
3:38:56
before I bring in other people just on that particular point um in terms of
3:39:03
looking at the green belt and um other things that are um kind of being sort of
3:39:10
within the within the sort of the planning pipeline I mean does that come in Mr. Allan as part of the kind of the
3:39:16
assessment of distinction a recognition that uh when you're in a particular lo
3:39:22
location um you know there are plans or you know
3:39:28
development is already an area is already taken out of the green belt. Yes. Um so all the factors that were
3:39:34
just summarized there have been taken into consideration in terms of um what what we do and don't take into
3:39:41
consideration in terms of planned growth. we we only take on um take on
3:39:48
what's been allocated or permitted um already. Anything else we we dis
3:39:53
discount because it hasn't actually been committed yet. So I'm sorry my my penny
3:39:59
is slowly dropping that obviously at the time that the LU did your work in 2023
3:40:04
the area of the AMP had already been taken out of the green belt so it wasn't part of the green belt and that would
3:40:09
have been uh reflected as part of that. Okay. Um,
3:40:14
Mr. Hutchinson, please. Thank you, sir. Um, just with regard to
3:40:20
the the green belt study in the for in the views of East Ben forum um and with
3:40:26
specific reference to the sites within the forum area, we would argue that there are flaws in the assessment made
3:40:32
of those sites in the green belt study. Um the study states that the release
3:40:38
release of green belt land would only cause moderate harm to green belt
3:40:44
purposes. We would contend that it would provide significant harm. Um, an example
3:40:50
of this would be the development of site GA2 at North Farm. Um, would reduce the
3:40:57
the gap in terms of distance between the Balden and South Shields areas and would
3:41:02
increase pressure on the remainder of the green belt in in that area. Um, in
3:41:08
addition, the boundary of the green belt is very tightly drawn around the edges of East Balden on three sides and this
3:41:14
has helped to preserve the character and distinctiveness of the village. um which
3:41:20
gives its unique feel in the context of the green belt. Um I mentioned earlier
3:41:26
that the the neighborhood plan had directed development to within the settlement boundary which is contiguous
3:41:33
with the green belt boundary. So you know we we're very concerned that uh the
3:41:39
the assessment of the green belt study isn't correct in that respect.
3:41:45
Thank you. We we'll come on to that in more detail next week when we look at um site GA2. Uh Mr. Butler, please.
3:41:54
Uh thank you, sir. Um I'd like to make a couple of points relating to the
3:41:59
characterization of the Baldens within the study. uh the methodology uh within
3:42:04
the study uh relation to purpose one uh of paragraph 3 uh.36
3:42:12
uh has the description uh that a narrow although a narrow strip of open land along the course of the river dawn
3:42:19
separates the Baldens from the large builtup area of Tinside no green belt land separates them from the connibation
3:42:26
therefore the Baldens are considered to be part of the large builtup area this
3:42:32
is in our view is not correct with regard to East Balden where as Mr. Hutchkins just said there is a lot of
3:42:39
land uh between the village and the southern part of South Shields of the White Leard which is part of the green
3:42:46
belt. Uh and obviously that's our main
3:42:51
concerns about the closure of the gap between South Shields and East and West Balden at that point. And the second uh
3:42:59
observation relates to purpose two uh which in the study at paragraph 3.48 48
3:43:07
uh says for the reasons outlined above for purpose one the Baldens are considered to be part of the town of
3:43:13
Jerro or outer south shields and therefore forming part of a neighboring town. Once again we would uh challenge
3:43:21
that assumption and obviously for reference um the two purposes that
3:43:26
they're referred to there. The first purpose uh purpose one is to check the
3:43:31
unrestricted sprawl from large builtup areas and two to prevent neighboring
3:43:36
towns merging into one another. The characterization seems to be uh that you
3:43:42
can assess the parcels of land um between uh the Baldens and South Shields
3:43:48
in particular uh in a lesser form because the Baldens form part of the
3:43:54
urban um builtup area which clearly is not the case. Uh East Balden uh is a
3:44:01
distinctive village and so is Cleon which are separate from the main urban
3:44:06
area. Thank you. So I think are you saying I think what you're saying to me Mr. Butler is if you
3:44:11
applied different judgments on that you'd arrive at a higher the outcome would be a higher degree of harm would
3:44:18
be identified in relation to those particular purposes. Yes sir. Yeah.
3:44:28
Do you want to respond to that particular point? You may. Yes. And then I see Mr. Fulture has been very patiently waiting but uh
3:44:37
whilst we're live and hot on this this issue, Mr. Allen, if you could just come on back on that point, it'll be helpful.
3:44:42
Thank you. Yeah. Um I think it would actually be the opposite with regards to the relevance of those two purposes. Um we
3:44:50
by by acknowledging that uh the Baldens are part of the large area actually increases the relevance of the green
3:44:57
belt around the settlement to that particular purpose. purpose A uh and by
3:45:04
acknowledging as part of that wider town increases the relevance um to purpose B. So if if if we didn't
3:45:12
acknowledge that relationship, the harm potentially in certain locations to
3:45:18
purposes A and B would actually be lower than is currently the case in the study.
3:45:27
Thank you. Um Mr. Fulture, please. Thank you sir. Um just wanted to note
3:45:34
that we do find the green belt study methodology sound. Um and although
3:45:40
perhaps a subjective matter um we do disagree with the council's assessment
3:45:46
of our sites um that we have promoted and not to labor the point that we
3:45:52
discussed yesterday but in order to meet the true housing need for the area um we
3:45:59
would recommend a reassessment of edge of settlement sites in in the green belt
3:46:05
in clean and balden in order to meet that need.
3:46:11
Thank you. Um I'm going to It's just gone 1:00, so I'm keen to take a break.
3:46:16
I did afford you, Mr. Green, the opportunity because I think you were looking at different documents. I'm assume I'm hoping I'm on the right
3:46:22
report now, but uh if you could go to table 4.2, uh chapter 4, 4.2, please. If I'm not,
3:46:29
I'll look it up over lunch break because there's a lot of green belt reviews there and it should come to a table.
3:46:37
It's page uh 65
3:46:44
and if it is if it is the correct one then uh there's a there's big major concerns
3:46:50
in relation to the to the study.
3:46:56
Okay. The council got I've got table 4.2 in the RU report. Yeah. Yeah. I I mean this brings brings me
3:47:03
back to what were mentioned the very first day of the of the hearings where reports were taken off the websites were
3:47:10
told in March 2024 which highlighted originally highlighted were as very high high and the odd one moderate and then
3:47:19
the uh sustainability report then indicated that we're in flood risk 3A
3:47:24
and 3B. Now to me this totally highlights if if it is the right one it
3:47:30
totally highlights five fellgate is high high very high the odd one's moderate and that raises serious your concerns
3:47:37
once again about the soundness of the local plan and the fact that felgate if this is correct is still in that plan
3:47:44
because it indicates that there is massive flood risks uh I mean this can be backed up with evidence what we've
3:47:51
got I mean and I highlighted this I highlighted this again on Monday. The
3:47:56
fact that all of a sudden the council 2324 come and try and clean drains out 17 times in the entire year. In 2425
3:48:04
when the local plan was being pushed the uh cleaned them 805 times and was still
3:48:10
flooded on April the 4th, but this backs up our arguments. I totally feel that this backs up our
3:48:15
arguments and I would like on these findings fell to be removed from the from the local plan.
3:48:22
Yeah. Yeah. Thank you. And we'll come on to I mean appreciate under that table there are five broad areas under the felgate um or
3:48:32
sort of five broad parcels under the felgate um uh area and we're going to come back and
3:48:38
look specifically at uh the green belt assessment on relation to some of those those parcels. But thank you for
3:48:45
bringing that um to my attention Mr. Green. It's coming up to 5 1. Um, you'd
3:48:51
be pleased to know I'm going to take a lunchtime adjournment now. Uh, I would like to be back in this room at 2:00 and
3:48:56
we'll be continuing discussion on green belt and general approach to site selection. Thank you.
4:46:04
uh into examination of the Southside local plan. We're still on matter four uh approach to green green belt
4:46:11
strategic approach to green belt and then we'll come on shortly to general approach to uh site selection uh
4:46:18
matters. Uh before we took the uh lunchtime break, we were still on item
4:46:24
11 of my agenda uh in terms of the kind of the reasonleness and appropriate kind
4:46:30
of methodology of the 2023 green belt review which uh informs the soundness of
4:46:36
the submitted plan from the council's uh perspective. I think in introducing
4:46:44
um yourself Mr. Allan and the kind of issues that the kind of the work looks at um this
4:46:51
I'm sure it is a word in the English language pastalization or how the sort of the study has pass looked at the
4:46:57
parcels uh of green belt um that's often an issue for plan examinations to kind of
4:47:04
grapple with people having different views about how that should be done and at what sort of scale and level and you
4:47:10
outlined that you used a minimum sort of 10 hectare um threshold to kind of look kind of
4:47:18
more strategically at those those kind of parcels um of the green belt.
4:47:23
Uh often the case is put you know should should there have been a more fine
4:47:29
grained analysis or examination of the
4:47:34
green belt i.e. smaller parcels sub subdivision of parcels. I just wonder if you could explain to me into the
4:47:40
examination what you kind of did in terms of having established those parcels. I think you
4:47:46
referred to you then did go and look in more detail at sites that have been put
4:47:52
forward through the strategic housing land availability assessment. Is that correct?
4:47:58
Yes, that's that's exactly correct. So we did that that broad burrowwide view at 10 hectare minimum parcel size drew
4:48:05
out those strategic variations and then taking each uh promoted site in turn we
4:48:11
overlaid them with those parcel variations and as the question if those sites were released developed in
4:48:17
isolation would would the harm ratings identified within those parcels change
4:48:24
and as I said earlier the vast majority of um the ratings wouldn't where where
4:48:29
we thought that uh they would for whatever reason where they were particularly small and at urban edges
4:48:34
and contained by the urban edge. We updated the proformer reports and
4:48:39
explained why in specific site cases uh there might be lower harm.
4:48:46
And in terms of the sites that you looked at as part of that that process from the schlart from the strategic
4:48:52
housing land availability assessment, would I be right to sort of conclude that those are the sites that were
4:48:58
deemed suitable, available, achievable, or be it within within the green belts or was
4:49:05
it kind of reasonable sort of options? That that's my understanding. Yes,
4:49:37
Thank you. As I say, I think parcelization can be an issue for plan examinations. I know Lichfields,
4:49:43
particularly for Buckley Baret Limited and for Cleonen Property Investments, I think raised the
4:49:50
issue about whether there should have been a more fine grained analysis. I don't know, Mr. Westwick whether you're
4:49:56
wearing any of those hats. Um I'm I'm not sir. I think it was um
4:50:01
exactly your point is there is a there is always a debate at EIP about the fine
4:50:06
grain analysis essentially. I'm not I'm not wearing those hats but I understand that stand the generality is that it was a very broad parcels and didn't drill
4:50:13
down into um into the smaller sites. But I think as uh Mr. Allen pointed out that
4:50:19
obviously the smaller sites the lesser harm they have overall in the green belt. So it's a balancing exercise for the local authorities. So, I think that
4:50:25
was the that was the point.
4:50:48
So I'm just asking for further expl
4:50:54
which differ and the reasons why they differ by reference to the figures figure two in in in the report
4:51:05
um sorry Figure four. Yeah. So, if I can draw everybody's attention to figure 4.5, which is
4:51:12
probably the the closest to an overview of uh of green belt harm across the the
4:51:17
plan area. Um, and what that that figure shows is the highest harm uh rating uh
4:51:26
given to a given purpose in each parcel identified. uh and as I explained
4:51:31
earlier um these parcel areas are a product of the assessment. So we've
4:51:36
drawn out all the variations based on all the considerations we consider openness relevance to each individual
4:51:43
purpose uh the distinction or urbanizing influence of of those urban areas um and
4:51:50
the impact on adjacent green land and in combination we then draw the red lines. So some parcels are bigger because all
4:51:58
the land within that area um is the same for all those considerations. Some are smaller because
4:52:04
there's more variations in some areas. You tend to get smaller parcels at urban edges where there's more containing and
4:52:11
urbanizing influences or more development encroaching into the green belt. But as you get further away out
4:52:16
into the open countryside, you get bigger parcels because there are fewer variations and generally higher harm.
4:52:33
Thank you. And just um check check with Luc. I mean that works on even on the
4:52:39
scale that we're looking at here in South Tinside where it's a relatively compact
4:52:45
burough. Uh some might argue the sort of the green belt is I think I heard earlier is about approximately a third
4:52:51
of the the burough sort of area. So that's that still works on that kind of geography or that scale where things are
4:52:58
sort of still reasonably close. Yeah, I think there's a question. All of
4:53:03
these judgments are made in a unique local context. We're not applying a
4:53:08
generalized standardized approach. I mean all the all the principles that we're assessing are obviously um
4:53:14
consistent and robust and we replicate those wherever. But in terms of the application of the methodology, it's
4:53:19
it's purely based on on this local green belt. So depending on how narrow the
4:53:24
gaps are between towns, how close things are to the the areas defined as a large
4:53:29
builtup area. Taking purpose A as an example, purpose one, which is about pre
4:53:36
preventing the spraw of large builtup areas, I think arguably all the green
4:53:41
bot land to some degree is near to the large built-up areas. So is relevant to
4:53:46
some degree. um where the variations lie is where there's a lack of openness or containment by the large builtup area
4:53:53
and that's where you get the get the variations for that one. Thank you. It's and it's a judgment call
4:53:59
as to precisely where those parcels boundaries apply. So if I'm looking at
4:54:05
I'm not going to get too I'm going to get specific but we're going to pick this up next week. So if we look at just more widely at the felgate, if you think
4:54:12
of FE as the Falgate kind of parcel, that's then been subdivided into five
4:54:18
areas. Um what would you say is in terms of why that's a valid approach as
4:54:23
opposed to say well we just look at this as one sizable parcel uh within that
4:54:29
particular location. Yeah. So I mean if if we were taking approach where we were just taking the
4:54:36
the most readily recognizable permanent boundaries in that location um you might draw a parcel that incor incorporated
4:54:43
all of the land from the urban edge of flailgate all the way down to Newcastle road and have that as one parcel. Um if
4:54:51
we were to assess that land um as a whole um then we'd be considering the
4:54:57
loss of all that land and the implications that would have on the wider gap between uh followings B and Gates Head. Um so
4:55:04
the harm of that wider parcel would be greater as a result. We wouldn't be considering all the variations within
4:55:09
that parcel by taking our our approach of considering all these factors in the round and then drawing the parcels as a
4:55:16
product of the assessment. we draw out that variation as a matter of course. Hence you have five parcels within that
4:55:23
gap um rather than just following um following boundaries. So we can go
4:55:29
through specific parcels if you like as to why there are variations there. probably not for today, but when we come
4:55:35
to some of the site specifics, I've got kind of various questions straight off the bat when we're looking at some of
4:55:40
the the green belt uh proposed green belt alterations as to kind of when we're drilling in on specific parcels.
4:55:47
Um we'll pick those up um pick those up there. And can you recall uh for my
4:55:53
benefit and maybe for others in the room, Mr. run and in terms of this kind of um parcelization approach that's now
4:56:00
presented to me in um the LUC report is that more um fine grained or more
4:56:10
segregated than previous uh studies that looked at the green belt
4:56:16
have you kind of assessed more parcels or ended up with sort of a greater degree of
4:56:21
parcelization can you recall uh I think it's it's pretty average. I'd say I mean it it depends on uh the plan
4:56:29
area I I guess as to to how granular we do these things. The the key thing is is coming up with
4:56:35
something that's proportionate and gives you the results you need to inform the plant making in that place. And I think
4:56:41
we've pretty much struck the right balance. I mean I think it's it's it's partly um highlighted in the fact that
4:56:46
when you actually look at the individual site variations where we've drawn them out, there are relatively few of them.
4:56:52
um we haven't found that many more when we consider it considered smaller areas at the individual site level which would
4:57:00
suggest that that 10 hectare minimum parcel size is about right um I mean
4:57:05
we've we've applied this methodology in lots of different places Manchester
4:57:11
Oxford Cambridge we're doing a very similar study for the um uh 18 London
4:57:17
burers at the moment um and they're all within the ballpark of this.
4:57:26
Thank you. Are there any points people wish to bring in in relation to just the general approach to u to paralization?
4:57:33
I've obviously heard from Lichfields obviously got the representations from others in front of me. Can I just ask so
4:57:41
still under my item 11 just as a sort of a generality at this stage because I'm going to pick it up um for specific
4:57:48
sites but obviously the MPPF as you'll be aware Mr. Alan it's paragraph 142 of
4:57:55
the September 2023 version uh presents the um the issue and the
4:58:02
concept of provide making compensatory improvements. Was that part of the remit of the your work for LUC and the the
4:58:11
green belt review? Yes. So yeah, as a an additional task if
4:58:16
you like beyond the the judgments around green belt harm, we we considered
4:58:24
opportunities for a confidential improvement in um in specific um site
4:58:31
areas. So that's addressed in um Let me go to the contents page of the
4:58:37
report. Um,
4:58:44
chapter five, um, which, um, covers green belt harm of specific site
4:58:49
allocations. Um, as part of that assessment, we we looked at the um the
4:58:58
council's green and blue infrastructure work um and all the all the strategic um
4:59:06
opportunities that identified and we we considered compensatory improvements at
4:59:12
two scales. We looked at what opportunities were identified in that report at a strategic level that might
4:59:18
be appropriate for uh things like section 106 agreements or sill. Um and
4:59:23
then we looked at uh individual um compensatory improvement options
4:59:28
within the immediate vicinity of each site allocation um and mapped those um
4:59:34
as almost like a shopping list of things that the council might approach um
4:59:39
developers um to consider as part of those allocations. I mean comp compensatory improvements is
4:59:47
not defined in the national planning policy framework but as a kind of a general consensus building from LU
4:59:53
through your work and from others what type of things would come under that umbrella.
5:00:01
Yeah, I I think that there is there is some planning practice guidance around it that was was available at the time um
5:00:07
specifically relating to enhancement of the green belt which is slightly different um part of the the chapter 13
5:00:14
but I think the the lists of it things that that are referenced in that plan practice guidance are very relevant to
5:00:20
compensatory improvement. So things like improving the access accessibility of the green belt, enhancing biodiversity,
5:00:27
um increasing the the multifunctionality of the recreational offers within the green belt, things like that.
5:00:44
Thank you. Before I move away from the sort of general u methodology approach of the green belt review, is there
5:00:51
anything further anybody wishes to add on this particular point?
5:00:57
No. Sorry, councelor Kilgore. Thank you, sir. Um I'm very grateful to
5:01:04
Mr. Alan for for pointing that out and I think we've looked at par 4.5 as well
5:01:10
which um has regard for the openness um and obviously having visited the felgate
5:01:15
site I'm sure um that you will have seen how very open and large that is and I
5:01:21
think the reiteration of the parcel sizes um is really really um something
5:01:27
that we need to to take very very seriously. Um but just just a moment ago
5:01:32
back a little before lunch um I was aware of um a previous consultant who
5:01:38
had carried out the work for the previous iteration and it was night Cavana and Paige.
5:01:44
So that's the that's where the original report was devolved from Q.
5:01:57
Thank you. I appreciate I mean with every sort of plan preparation over a period of time the evidence base evolves
5:02:04
and develops. Obviously said before previous previous uh parts of this
5:02:10
discussion the green belt review that's in front of me that the council's relying on for the soundness of this
5:02:16
plan is the LU report. But I appreciate there's been iterations and I understand why people have seen previous versions
5:02:23
and Mr. Green and others kind of ask themselves you know why does it say something different at an earlier an
5:02:29
earlier stage Mr. green. It's just uh in relation to the parcels. Yeah. Again, I go back to the you know
5:02:36
the side by side. Some are very high, some are high, some are moderate, but it's such a wide it's such an open area
5:02:43
uh you know that the parcels uh you know one will have, you know, you
5:02:49
could have more nature in this one and they'll be the same in this one. But the parcels, if this makes sense, are so
5:02:55
close together because it's four fields. You've got FE1, FE 2, F3, F4. There's
5:03:01
actually five sections of it and it is all one parcel of the green belt.
5:03:06
That makes sense. Thank you. I think that relates back to the previous point I put to Mr. uh Mr.
5:03:14
Allen on how he how he'd approach that.
5:03:19
Should just clarify, Mr. Alen. I mean, in terms of all the parcels, they are following physical features on the
5:03:25
ground. Is that how they've been where it's at all possible? But yeah, our primary goal is to draw out
5:03:31
variations against all the factors we consider. So we consider more factors than just boundaries. So where that's
5:03:37
the case, sometimes there isn't a clear boundary, but where we can, we do.
5:03:44
Thank you. If there's nothing further then on green belt methodology, I'm going to move on and um we will come
5:03:50
back to parts of the approach to green belt in the next sort of section. But it's issue two on my agenda and it's the
5:03:56
general approach to site selection and indeed green belt um boundaries. Uh I'd
5:04:02
just like to start this part of the discussion by um drawing together I think a number of my questions uh MIQ's
5:04:10
4849 and 410 and I think invite the council I think in the first instance
5:04:17
terms of how it's gone about the approach of selecting particular sites uh and I've used um the phrase probably
5:04:25
on more more than one occasion whether there's a kind of a clear audit trail about how uh sites were assessed
5:04:33
where kind of reasonable sites kind of filter out of the process and then how you've looked at kind of the reasonable
5:04:40
uh options that then are feed into um your preferred sites that have ended up
5:04:46
uh proposed in the plan whether there's transparency um around how that that
5:04:52
work was undertaken. Yeah, that's that's fine. Um so the the
5:04:59
key document to look at in terms of of how our general approach to site se selection um is is set out. It's the
5:05:06
site selection topic paper um unsurprisingly by the the name of the document. Um and that document clearly
5:05:13
sets out the process that the council's undertaken for identifying sites um
5:05:18
included in the plan for both housing and for employment um allocations. Um I
5:05:25
would refer to um figure one in the site selection topic paper which provides a
5:05:31
flow diagram which shows the process that has been undertaken in terms of how
5:05:37
the various um evidence-based documents link um to to result into site
5:05:44
selection. Um so you'll be able to see um in that image that initially it
5:05:50
starts with a call out for sites which then feeds into the schlaw and ELR evidence based documents themselves.
5:05:57
From that point the reasonable options are identified and they are fed into the sustainability appraisal where a site
5:06:04
specific site sight specific sustainability appraisal assessment is undertaken.
5:06:10
Um you'll also see on the left hand side of that diagram where we look through the um case for exceptional
5:06:16
circumstances and um the need to go into green belt which is also informed by um
5:06:22
the green belt review itself. those have sort of come together. Um
5:06:29
also take into account um various evidence-based documents um which the council's produced to
5:06:37
come to a overall conclusion using plan and judgment as to whether those sites should be included in the local plan or
5:06:45
not. Um like I say each site um has been subject to senability appraisal. Um and
5:06:53
that is um each site has been um proportionately and um
5:07:00
clearly audited throughout um appendix I think it's appendix F of the sustainability appraisal sets out the
5:07:07
audit trail for the reasons why sites have been selected or rejected and that
5:07:12
is also um documented in the appendices for the site selection topic paper as well which clearly sets out the reasons
5:07:20
um taking into account all those evidence-based documents what has contributed to why a site has been taken
5:07:26
forward or not. Um this has been an iterative process. So through each stage of the local plan uh preparation we've
5:07:34
undertaken this um assessment both the sustainability appraisal and the se site selection topic paper update and you'll
5:07:41
be able to see um within the appendices where evidence has changed from
5:07:46
regulation 18 to regulation 19 taking in account updated evidence-based documents
5:07:52
which have come to light um since the previous stage of the plan preparation.
5:08:17
Thank you for that. Now I appreciate there are people around the table who have um alternative views about the
5:08:23
transparency uh and kind of appropriateness of the council's approach um around site
5:08:31
selection. Um, obviously I've read representations. There are certain people I might like to
5:08:37
hear from who've made specific points about how the council's gone about um, this process.
5:08:44
Um, particularly in response to my MIQ's 4.8 and 4.9. I was going to afford the
5:08:52
opportunity to Mr. Thompson from from banks because I know you've made representations also Mr. Martin uh from
5:08:58
Pegasus um in the first instance in terms of having heard from the
5:09:05
council obviously evidence base does evolve and does change during the plan preparation
5:09:11
but I think you've got kind of view as to how transparently and how clearly is
5:09:16
it explained perhaps why sites have been either discounted or or not selected as
5:09:23
part of what you think in your view would be an appropriate strategy. Oh, that's right. Um, so our site was
5:09:30
previously allocated. It's then been subsequently deallocated.
5:09:35
Um, and the reason being was for a waiting bird survey. Um, which we have
5:09:42
asked for and not received. Um, so we don't know what that says exactly. Um,
5:09:50
appendix F of the sustainability report.
5:09:55
um suggests it for impacts on the green belt why it was deallocated.
5:10:01
Um but it scores moderately um as does lots of allocate sites.
5:10:10
So yeah, there's there's no audit trail there of why the site was deallocated
5:10:16
and why other sites have been allocated with similar harms to the green belt.
5:10:25
which locks site reference.
5:10:32
Could just clarify the site reference, please. Um, so it's it's WH6 on the green belt
5:10:39
study. It's also SWH
5:10:44
009 in the sustainability appraisal
5:10:49
which is at Wellland's farm in Witburn or Wellland's farm Whitburn.
5:11:03
So can I just pick that up with the council in terms of the first point about if a waiting bird survey has been
5:11:09
used to kind of inform the site selection process and is that something
5:11:14
that's sensitive and people can't see the outcome of that process? You're
5:11:21
you're shaking your head, Mrs. Lamb. No, the the Wade and Bird surveys are actually part of the local plan um
5:11:27
evidence library. Um so the the first study was actually taken to undertook um
5:11:33
in 2019 2020 and that is referenced as um local plan reference pre42 under the
5:11:41
regulation 18 um documents that supported that consultation. Um the the
5:11:46
web page actually referenced that the document was published on the 2nd December in 2020. So that document has
5:11:53
always been available. Um we'll also have a second document which was published alongside the regulation 19
5:11:59
consultation as well which again was uh has been public available since um the
5:12:04
regulation 19 public consultation. Is there a document reference for that
5:12:10
as well? Mrs.
5:12:21
not 20.
5:12:26
Without sort of getting too much into the kind of site specifics, what will be the um the issue that needs to be kind
5:12:33
of borne in mind? Why would that be sort of come to bear on sites being potentially deselected or not taken
5:12:39
forward as allocations? Could I bring Miss Rockcliffe, our
5:12:45
ecologist, to the table if that's okay?
5:12:58
Hi, Claire Roiff, the natural environment manager at South Touncil. Um, So the wading bird survey um I'll
5:13:07
I'll try and be fairly brief. It looked over over two winters of how wing birds use a whole range of fields on the the
5:13:14
kind around the effectively between Whitburn and Cleon or around that whole area because that's close to the coast
5:13:20
and where waiting birds would come and land. Um and effectively sites were studied over a couple of winters to
5:13:26
increase the robustness of the data. One winter's um data wouldn't be considered
5:13:32
completely robust. two is better than one. Um, off the back of that, um, sites
5:13:38
were identified as the most attractive fields for weirders on a number of different criteria. It was done by an
5:13:44
expert ornithologist. Um, and effectively the outcome of the site
5:13:50
fields were then colorcoded based on their relative importance for WERS. There were seven red sites um um
5:13:58
identified because these had peak counts that represented at least 1% of the total South Tinside Wider population. So
5:14:05
those fields are therefore valued as ecologically significant for weirders in the context of South Tinside.
5:14:10
Um and the 1% threshold is is widely used in conservation biology. I can go into that if you need me to do so. But
5:14:17
effectively the Wellins farm site is made up of part of one of these red sites and then three other fields that
5:14:24
were classified as amber. The amber sites have between 0.1 and 1% of the total southside wer population use. Um
5:14:32
so the wellins farm site was the only regulation 18 potential allocation that included a red site and as this was
5:14:39
considered ecologically significant you know that was one of the factors in the decision-m process with regards it
5:14:46
suitability for development. Thank you. I mean I will track back and
5:14:51
look at those documents that the council's referred to. Um I mean Mr. Thompson is your point also too. I don't
5:14:59
know that there's there needs to be more explanation or Well, I think it does. I mean, because
5:15:04
if if we were to go into site specifics on on all the sites, would would
5:15:09
discover issues um and that doesn't mean the site can't be allocated. That there
5:15:15
is possible mitigation um to to overcome these issues um with
5:15:21
with more work, I'm sure. So yeah to to solely weigh an allocation based on one
5:15:29
potential issue um you know I think we can um you know I think
5:15:36
that's unfair um say there'll be every site will have its problems um that need
5:15:42
to be overcome and mitigated in some way. So yeah I'm I'm not totally
5:15:47
convinced by that approach. Mr. Thompson, the second point you
5:15:53
raised was I think in the in the sustainability appraisal it's another reason it's the impact on green belt.
5:15:58
Yeah. So so exactly that's in I think it's appendix F the reason it was discounted is for harm
5:16:06
on the green belt when the harm on the green belts um moderate according to the
5:16:13
green belt study which is pretty much every uh site that's allocated is also
5:16:19
moderate. So, um I guess it's the consistency of reasoning there which
5:16:27
isn't right.
5:16:35
Thank you. I hear from others to see if there's a bigger a bigger picture and then come
5:16:42
back to the council on just whe there's a general kind of consistency uh issue that I need to be um concerned
5:16:49
about. Mr. Martin next please.
5:16:54
Thank you sir. Um feel like we're in a similar position to
5:16:59
how Mr. Tom Mr. Thompson's um raised here. Um my client's land interest is
5:17:06
SBC00004. It is the land directly east to the allocation GA2.
5:17:13
In the previous REGG 18 uh draft, which is 2019 draft, it was actually even a
5:17:20
joint allocation with that piece of land. It's then subsequently been
5:17:25
deallocated um in the later REG 18 and the REGG 19
5:17:32
draft. which obviously has set hairs running for myself because I was wondering why
5:17:37
why would that be the case and I can clearly see the methodology that the
5:17:43
council have described as to how they've gone and assess sites it's then the output which doesn't seem to make any
5:17:49
sense. So my client's land for instance that scores very well in the
5:17:55
sustainability appraisal in fact equal to the adjacent parcel which is allocated. It is formed part of that
5:18:02
green belt parcel with GA2 and again is scores very well again in terms of
5:18:09
minimal impact on the green belt. Uh so this is you know here I'm getting lots of green lights as in this this looks
5:18:15
like it could be a suitable suitable site. um it then is discounted. Uh and
5:18:21
then when you go to appendix F for sustainability appraisal, I start having significant concerns here because um it
5:18:29
tells me that they've discounted because the site's not viable. Now um my client
5:18:35
is a national house builder. They know what's viable and what's not viable.
5:18:40
They wouldn't be paying me to sit here to promote a site that is not viable.
5:18:46
and I haven't seen any evidence from the council that the site is not viable. My
5:18:52
client is satisfied it's viable. Um you go on further um they've told me there's
5:18:57
an unacceptable impact on biodiversity net gain. Again, this is a bit of a
5:19:02
strange one for me because this judgment was made prior to the statutory BNG
5:19:08
being put in place. And again, I failed to see the evidence. they may may well
5:19:14
be buried somewhere and I'd like to scrutinize it in more detail but again the apparently BNG cannot be obtain
5:19:21
cannot be achieved on site which is again without evidence and in fact now
5:19:28
that we're in a regime with statutory BNG I would suggest most sites at some
5:19:34
point if you're willing to have the funds behind it can address biodiversity
5:19:39
net gain thirdly there is talk about uh flood risk. Now, the flood risk is in
5:19:47
the far north of the site, which doesn't necessarily have to be built on. In fact, it could form rather attractive
5:19:53
open space as you're entering into the site anyway. Um it also makes a point
5:19:59
about it being in a wildlife corridor. Now, it's only in a wildlife corridor because the council are attempting in
5:20:06
this plan to put it in a wildlife corridor. Prior to that, in previous drafts, it the wildlife corridor only
5:20:12
ran along where the water course is at the top. So, drawing all this together,
5:20:18
I I'm completely at a loss as to why my client's land, which is clearly
5:20:24
sustainable, clearly has low impact on the green belt, has been discounted. As
5:20:29
I said, the process seems to be clear. The output doesn't make any sense.
5:20:38
Thank you. I'll wrap that in with Mr. Thompson's as well and we'll we'll we'll come back to that. Um Mr. Eton next,
5:20:46
please. Thank you, sir. Um a bit of a theme
5:20:51
here. Um we undertook a similar kind of excite and understanding why our client site
5:20:57
hadn't been allocated and other sites had and we looked at the site selection topic paper the sustainability appraisal
5:21:06
and the schlar and to compare the allocated site with our client site. We
5:21:14
noted that the Schlard class site has been moderate impact to the green belt
5:21:20
but concluded it was unacceptable in green belt terms whereas the other site which was allocated was also moderate
5:21:26
impact but it was allocated. So there's a a difference there. Um the
5:21:33
sustainability appraisal for the allocated site highlighted by the being
5:21:39
a red impact and for our client sites being an amber impact and that links to
5:21:45
an extent to the wing bird survey which highlighted both the allocated site our
5:21:51
new allocated site as being an area for wing birds yet the allocated site that wasn't
5:21:58
highlighted as an issue in the site selection topic paper but power client site it was. So it's it was an
5:22:03
ultimately clear understanding how these studies were then used to then decide on
5:22:09
the allocated site when they appear to be comparable sites in terms of impact between between sites and just pick up
5:22:17
on on the wing bird survey I mentioned earlier. One of the notes in there that one of
5:22:24
the limitation of constraints is that more data would be required to look at longerterm trends in field use and
5:22:29
influence of cropping. So whilst it would seem to be an evidence base to help inform site selection, I don't my
5:22:35
read of it doesn't say you can't allocate sites because of the findings in that indeed it includes mitigation
5:22:41
for sites which do have higher value for weight. It identifies how that can be mitigated and sets out criteria for
5:22:48
doing that which can be entirely achieved on our client site. So it's kind of it's
5:22:54
that that process it does seem to be consistent and flawed in terms of how it's decided on its on its ultimate
5:23:00
allocations. Okay. Thank you.
5:23:06
Before I hear from other people because I think there's obviously a um I don't want to say there's a gap between Mr.
5:23:13
and u Mrs. Hunter but there's probably getting into kind of other other themes. There's a kind of demarcation of uh
5:23:19
representations. Can I just come back to the council on this issue of is there a consistency
5:23:25
or a um a continuity issue that this examination needs to be
5:23:31
um concerned about in terms of how the ultimate uh site selection is is
5:23:38
being being determined whe there's a kind of a disconnect between the evidence or is it
5:23:44
down to particular judgments? there's no disconnect uh in the evidence
5:23:50
overall. I think there might have been identified a an error which I'll allow
5:23:58
the council to deal with. Um but overall there's no inconsistency and at the end of the day um the um as
5:24:08
it indicated in the schlar and also the results of the essay um it reflects
5:24:13
issues of of planning judgment about the acceptability or otherwise of a site for
5:24:18
development. And of course we're not here to examine the merits of emission sites. I do
5:24:25
accept however that if the if they are omitted as a result of a poor
5:24:33
methodology that might be of concern but um I'm suggesting to you it doesn't none
5:24:38
of this reflects a poor methodology or any fault in the meth methodological process which has been adopted. I I'll
5:24:46
ask to for an explanation of the inconsistency first of all.
5:24:53
Yeah. Um just picking up on the um site uh at Whipburn in terms of the essay um
5:24:59
where it's ruled out in the appendix F in terms of green belt. Um I think that
5:25:04
is down to to an error in the essay as the site selection topic paper does
5:25:09
reference that the site is a moderate in terms of the green belt study and clearly states that it's ruled out in
5:25:15
terms of um biodiversity implications. So I think that's just a an error that's
5:25:21
that's happened in the essay through that process.
5:25:41
So just to pick up on the wildlife corridor point, the previous wildlife corridors in the in the earlier in the
5:25:49
old LDF were were very much indicative. They were diamonds through a landscape following kind of rough areas. that they
5:25:56
didn't define the wildlife corridor very well and we were very well aware of that which is why we commissioned the study
5:26:03
to undertake a criteria based wildlife corridor network review and that
5:26:08
followed a standard methodology um so it's consistent with national
5:26:13
planning policy um and was consistent with a published nature networks evidence handbook by natural England in
5:26:20
2020 and the network's built on a hierarchy of components identified by the lot report ranked according to their
5:26:26
biodiversity, importance and priority. So you get the core sites which are ranked the highest and their designated
5:26:31
sites and priority habitats and they're followed by secondary features which include semi-natural green spaces and
5:26:38
linear corridors and then stepping stones which are more patches of habitat and features that support species
5:26:44
movements across a landscape where it's not continuous and finally buffer zones which were applied around core sites. So
5:26:52
secondary sites which um the north farm east site was identified as um
5:27:01
they provide their areas of semi-natural habitat providing links for movement between core sites and the north farm
5:27:08
east sites are substantial area of land providing this function. Secondary sites such as this offer
5:27:14
opportunities for meaningful nature recovery through the lot principles of the more bigger better and joined up. Um
5:27:20
and given the size of the north farm site, its location adjacent to core sites and its existing semi-natural
5:27:25
habitats, it's well placed to deliver on those principles and its loss to development would be sign a significant
5:27:30
impact on the wildlife corridor network which could not be ready readily mitigated or compensated for.
5:27:41
Thank you. Can I just be clear from Mr. Mr. Martin and Mr. Thompson, you all
5:27:47
representing sites that were in a previous version of the plan
5:27:52
which kind of comes on to my point 13. So probably wrapping these kind of two
5:27:58
um issues together. I mean I think from what I'm hearing and I think picking up the point from um so Mr. Shadow Ravian.
5:28:05
I don't think anybody's kind of disputing the kind of methodology uh approach and the kind of flowchart
5:28:12
that the council Mrs. Lamb talked to. I mean I'd go as far to say put my neck
5:28:19
out. Now that's probably what I'd exactly expect to see in terms of the site selection process. I do think it's
5:28:26
whether there's an issue about whether whether it's one of you know judgments
5:28:31
are uh finally balanced and there's you know a marginality
5:28:37
between some of the sites that have been allocated and some that haven't or whether there are significant whether
5:28:44
they factual or uh other they're not matters of
5:28:49
potentially judgments. There's there's just something as not quite I use the
5:28:54
word, you know, disconnected. It's whether it's that's more the issue rather than one of of of judgment.
5:29:06
Mr. Martin, I would say no. It's not one of judgment. If you're going around
5:29:12
claiming my site's not viable, I want to see the evidence. That's not a judgment. That is I want to see facts because my
5:29:20
client is of a different opinion. And also I'd like to add um in response to
5:29:26
Mr. Rocliff's points, I fundamentally disagree that it's an important wildlife corridor. If you're developing the site
5:29:33
to the west and you then have a definitive boundary of a railway line to
5:29:38
the the east, how is that going to be a joined up wildlife corridor? It makes
5:29:44
absolutely no sense whatsoever.
5:29:49
Okay. keen not to get kind of too too specific into sites that are currently not in the
5:29:56
plan, but um I'm not quite sure that that was a reason for rejecting the site, but
5:30:02
anyway, that let's um get an explanation.
5:30:07
Yes, I think for the North Farm East site, I think at um regulation 18 stage
5:30:12
um when we were considering sites um sort of it was as BNG was emerging and I
5:30:18
think what we've stated in the site selection topic paper for that site at that point um sort of reflects our sort
5:30:26
of concerns in terms of ecological impact of the site and um and and that's
5:30:33
I think that's clearly stated in in the the assessment ment that's given there. I think it's worth saying that in the
5:30:39
the update that was published at regulation 19 um we do say that it is
5:30:44
noted that mandate BNG has been introduced from January 2024 and is applicable to all non-exempt
5:30:51
applications um and that recognizes the sort of the statements that was said at regulation
5:30:57
18 and it seems to to go some way to acknowledging the fact that that was not
5:31:02
and should not be a consideration in terms of that site. I think what's happened is basically through the essay
5:31:09
and in the appendix F the essay that BNG in terms of viability has been sort of
5:31:15
carried forward. I don't necessarily think that that should have been the case. I think it should have just been
5:31:20
the fact that it was um ecological considerations to why that site was ruled out.
5:31:27
Very briefly, Mr. Martin, I would ask whether the council had any
5:31:33
due consideration to the ecological reports that my client had done on the site because they would clearly show
5:31:39
something different. I just unfortunately, sir, I I just think there's a complete lack of
5:31:45
evidence. It's the audit trail like you said, sir. it it you get to a point and you think that looks like an absolutely
5:31:51
suitable site and then they don't choose to allocate it and come up with very speurious reasons of which I still
5:31:57
haven't seen any evidence.
5:32:03
Sorry Mr. Thompson and then I will come back to the council. Um well on a on a similar theme I would
5:32:10
just like to clarify with the council um that then our site wasn't deallocated
5:32:16
because of harm on the green belt and it was purely because of harm on biodiversity.
5:32:25
Yes that's what's stated in the site selection topic paper.
5:32:31
Sorry just come back to the council on this point. It it seems to me from just this brief discussion this afternoon and
5:32:37
it may be a symptom of having looked at so many sites and the thoroughess of looking at so many sites that there are
5:32:45
now some issues that just need to be double checked. I've heard this afternoon the council saying yes maybe
5:32:53
that isn't the issue the issue is this. So I'm just wondering you know the alarm bells in my mind you know that this
5:33:00
needs to be checked again maybe the council arrives at the same conclusion but for a
5:33:06
different reason or different factors. I think you'll find that the reasons
5:33:12
given for the rejection of the site are legitimate in a sense that for example
5:33:18
Mr. Martin's client site was rejected because of its wildlife implications,
5:33:24
its ecological implications. Um, and we're we're not here engaged in the
5:33:30
discussion about whether or not we should have entered into dialogue about the veracity of the information we had,
5:33:37
the information they had because to do that in relation to every site would be an impossibility.
5:33:43
um we the evidence base we had we applied across the board and there is
5:33:48
inevitable it's inevitable that there will be disputes about that. Um it's not as if there was
5:33:57
a basic factual misjudgment which affected the assessment and that
5:34:02
that misjudgment was repeated across the board. It's nothing like that at all. So we've got to draw the line somewhere.
5:34:10
Um, but we're I'm I'm very happy that we should in relation to the emission sites which are being represented around this
5:34:15
table today do a double check on them.
5:34:21
I It sounds like there are a number of issues just from this brief exchange
5:34:26
that need to my mind need to be to be just checked. I I accept that you you need to be
5:34:33
satisfied in relation to the points being raised today. Um but I would
5:34:39
respectfully reject any contention um that this is representative
5:34:44
of a flawed methodology or assessment process.
5:34:51
it's inevitable that some mistakes do happen and uh in that sense I suppose it's not surprising that where it has
5:34:58
happened if if it has happened it's being alluded to here by those who are making representations
5:35:06
it is but I think when we come to uh where these issues are recorded whether it's in the site selection uh topic
5:35:14
paper or more importantly in the sustainability appraisal paper that there is that kind kind of uh
5:35:22
robustness behind it. So things do need to be updated or amended. But I accept
5:35:28
you know we are looking at kind of um you know sites fit as part of an appropriate strategy. There may be sites
5:35:35
that score very closely. The the council may say as part of an appropriate
5:35:41
strategy for reasons it wants to give. A site that scores poorly on one factor but maybe better on another is still
5:35:48
nonetheless within the wider parameters of soundness a sound approach. I think
5:35:54
what I'm slightly concerned is hearing you know reasons like viability
5:36:00
uh if there isn't yeah where has that been drawn from
5:36:06
and you know other I don't know if that's if that's just a oneoff for Mr. Martin sites or that's been applied uh
5:36:14
more widely for other for other sites. But I think my general action point that I want the council to
5:36:20
kind of reflect on and take away today is having heard that some of the uh uh
5:36:26
assessments need to be kind of just checked again. I accept it's it seems to be within the pool of sites that were
5:36:34
originally uh suggested or proposed for allocation
5:36:39
in terms of those come today. So we'll keep it confined to that for now. But if there is a any
5:36:46
sort of wider uh systemic issue, I'm not aware of it from the representations. So
5:36:53
I think I think that's the point first of all and secondly, I fully accept um that we need to deal with these matters
5:37:00
because they've been raised. Fully accept that and we will do so. Um,
5:37:06
the third point, if I may make it, is that none of this ought to or does draw
5:37:11
a question mark over the actual allocations.
5:37:17
And that's really what we're concerned about apart from the issue of of of their adequacy in terms of numbers.
5:37:24
Yeah. Um
5:37:29
indeed um we are focused on that. Uh I'm
5:37:34
just mindful that sustainability appraisal in particular is a sensitive
5:37:40
area and it can be a root. Uh I've been to the court of appeal on
5:37:45
sustainability. Okay. So thank you. Right.
5:37:54
Well, you've beaten me. I've only been to the high courts
5:38:00
successfully I should add. Um pre pins prepins.
5:38:07
Um so uh slight diversion there. I'm I'm going to leave that part of the
5:38:13
discussion that's raised in the action point recorded with the um the council. I'm now going to move through and I'm
5:38:19
probably going to hear I I don't want to get too kind of sight specific. I appreciate from Balden you've heard from
5:38:24
Mr. Martin and I'm sure you do not agree uh with Mr. Martin's assessment but I
5:38:31
think drawing back to what Mr. Shadow Ravian said it's our primary focus at
5:38:36
these plan examinations is what's in the plan. So that's site GA2. So I think comments should be around sort of the
5:38:42
general site selection methodology rather than sort of getting too too sort of detailed on uh alternative uh sites
5:38:51
that are currently not in the plan. Um but I'll work my way down. So I'm going to start with Mr. Green I think first.
5:38:57
Yeah. Yeah. Ju just to say, you know, uh consistency is essential for these hearings and there's too many
5:39:02
inconsistencies. You know, we've heard it all week in relation to this. In relation to
5:39:08
Felgate, I'm just listening that one of the sites being rejected because it's being, you know, it's it's not in a way
5:39:15
well Felgate's in a wildlife corridor. You know, it's an oasis of bio it's a
5:39:20
biodiverse natural habitat. uh and why
5:39:26
again why is it still w with all the pointers that what you know we're putting forward why is it still in the
5:39:32
local plan uh you know and I'm sorry if I'm going off track here because I had made load of notes but there's a lot
5:39:38
went on since since uh now going on to the uh going on to the site selection
5:39:45
topics am I on the right one this time site selection topic 2024 is that the correct one and uh if you go
5:39:52
to appendix three. And if you start from page 18,
5:39:58
it's just all of the reasons I've just heard. Whoops. All of the reasons I've just heard, the majority of them apply
5:40:03
to Felgate. It's mystique.
5:40:11
There's another one as well. Another question I want to raise is about the habitat assessments and stuff like that. or whether the one's actually been we we
5:40:19
were made aware that started last December and if it's ongoing if Clay's right Mr. brackets right uh it continues
5:40:27
for two years. Uh but if we could go on to the sites the site selection topic uh
5:40:33
starting from page 18 if you look at felgate and the reasons why the majority of the
5:40:40
sites have been rejected because of the exact reasoning what's just been put
5:40:45
forward by those members of the council and members of the panel here. Uh
5:40:52
it's if you just scroll down, if you scroll down, it all applies to Felgate from page uh
5:40:59
from page 18. Uh just keep scrolling, there's one allocated on SP sites SP6.
5:41:06
But if that's the case, how can you have one part here which is rejected because of the wildlife, but you've got one here
5:41:12
which is okay? Uh you know, it doesn't make sense. It's it's it's so
5:41:18
inconsistent. And then if you continue scrolling down, you've got reject site, you've got reject site, you've got
5:41:23
reject site. Why isn't the why hasn't the site been rejected already?
5:41:29
I mean, the evidence is there.
5:41:35
That's assuming I'm on the right topic. I'm on the right page. Yeah. I mean, that that's just a question. It's so
5:41:40
inconsistent. And we have had this that, you know, we've had, you know, the council's going to take reports away and
5:41:45
look at this, look at that, look at this. It's been happening since Tuesday and surely that that points to the fact
5:41:52
that the local plan isn't sound. It's it's flawed. It's got to be flawed and you know these
5:41:58
gentlemen are picking that up now that there's so it's so inconsistent.
5:42:03
It's Thanks. Thank you. I mean obviously we'll come on to Felgates and the reasons behind
5:42:09
that on um Tuesday. So we'll look at that in in more detail um then. Um
5:42:19
just turn to the council just very briefly. I mean the Felgate site has been through the same site selection and
5:42:25
sustainability appraisal methodology um as all the other sites. Yeah.
5:42:36
Thank you councelor Kilgore please. Thank you sir. Um I think you know with
5:42:42
every human being carrying out a role there is a margin of error and I absolutely understand that and I think
5:42:48
what we're probably seeing is um officers being pulled in so many different directions and this has gone
5:42:55
on for so long that I think it absolutely does lack consistency. I think there have been so many different
5:43:02
um officers dealing with this for a very long period of time and it's about one
5:43:07
following the other a different consultant coming in here and there and I think you know overall it possibly has
5:43:14
led to what we're seeing now. Um I I would like to come back to um Mr.
5:43:22
Shavarian on the veracity. I absolutely think it's about veracity. It it
5:43:27
completely is. We've got to be able to validate and verify the methodology and
5:43:34
the narrative around the judgment that's being used. And I think if you can't um
5:43:42
rely on that information, then your judgment skewed. I think I think it it
5:43:47
quite simply follows. Um we're seeing on Felgate um reports and assessments being
5:43:53
carried out. Now I have um an education report where they're looking at school
5:43:59
places. The annex was removed when a second email was sent to the school that I'm chair of governors at. So these
5:44:07
these exploratory um conversations are happening now. This has been in place
5:44:12
since well certainly finalized in September last year when it was it was rejected by uh borough council. So, I
5:44:20
get a very great feeling that this is about making it fit and whatever they
5:44:25
need to do to make it work, to make it viable, to make it solid. And I'm really
5:44:31
sorry that I think we've used this word all week, inconsistent. There is no
5:44:38
linkage in the majority of things where these big decisions have been made. And Felgate has been out of the plan
5:44:46
forever. Felgate is now in the plan for the reasons these developers or these
5:44:53
officers you know representing the developers that theirs is out. So it is
5:44:58
it does not make sense. We can follow a logic. This is illogical and I don't
5:45:03
know where we go from here but I don't think it's appropriate that we expect of the council to go away and very quickly
5:45:11
check this out and check that out. It's adding it's applying more pressure. it's applying more work.
5:45:18
You know, it's just not right. It's absolutely not signed sound and it is
5:45:23
flawed. And I don't think we should put them under any more pressure to attempt to pull this all together because I
5:45:30
think that just creates further errors as well. And I do um have have a great uh deal of respect and consideration for
5:45:36
the officers doing this. Um and I just think it it just doesn't make sense. Doesn't fit.
5:45:41
Okay. Thank you. Um Mr. Hutchinson, next
5:45:47
please. Thank you, sir. Um I just want to talk fairly briefly about um the sites that
5:45:55
were rejected in the East Balden area at uh regulation 18 stage. Um as has been
5:46:02
mentioned earlier in the proceedings, there were 1,887
5:46:07
objections at the regulation 18 plan stage. And following that um two sites
5:46:14
were removed from the East Balden area. Uh those sites were the MOD site which
5:46:21
has been discussed earlier today and Mr. Butler is going to talk in more detail about that in a minute. Uh and also the
5:46:29
um site at St. John's Terrace and Natalie Avenue. I'm sorry I don't have the reference number to hand. Um in its
5:46:38
selection topic paper 2025 the council
5:46:43
um explains that that site was withdrawn due to flood risk impacts. So you know
5:46:50
as far as we concerned there was a a reasonable explanation as to why that site was withdrawn.
5:46:57
Mr. Mr. Uh B is also going to talk about the east field to the east of GA2 site
5:47:04
GA2.
5:47:12
Uh thank thank you sir. I'd like to start by stressing the importance of the wildlife corridor network as a result of
5:47:19
the study uh produced by Burton Reed Associates on behalf of not only South
5:47:24
Tinside Council but Gates Head and Sunderland councils. Um as Mr. Rcliffe said in her evidence, this was a
5:47:32
comprehensive study to try and properly define the impact of wildlife within the
5:47:40
Tanear green belt. uh and as far as uh we are concerned it brought a lot of
5:47:48
clarity to what the communities f feel about the areas that they live close to
5:47:54
and uh participate in uh act actively.
5:47:59
And as you've heard in in the evidence uh this is just not uh something being
5:48:04
imposed on on a site. This is a comprehensive study looking at uh how
5:48:12
wildlife impacts within our area and how valuable that is to the residents and
5:48:18
the community. Um, we've already uh said to you that the
5:48:24
MOD site was uh identified as a core site within the wildlife study corridor
5:48:30
network and and what flows from that um brought about its rejection uh at
5:48:36
regulation 19. Um, we also have made continuing
5:48:43
representations throughout the plan process about uh, North Farm East, the
5:48:48
site that Mr. Martin is is promoting to you. It's an omission site, sir. It's a site that was not allocated at
5:48:55
regulation 18. It was allocated the pre-publication stage. It was rejected
5:49:00
at uh, regulation 18 for the grounds that uh, Mrs. Slamman and Mr. Cliff have
5:49:06
given to you today. It is rejected again at regulation 19 and I would submit to
5:49:13
you uh that it is not a site that you should consider at this point and
5:49:19
clearly um the ecological importance which has been explained to you today is
5:49:24
as far as um we're concerned of utmost importance. This is a piece of land that
5:49:29
has been out of farming use for nearly 30 years. I hope you will visit it. is
5:49:35
next door to the um North Farm West site and it's a site that's been enjoyed by
5:49:40
the community for that period uh and is one that is valued by the community and
5:49:46
was strongly opposed in terms of post development during the neighborhood plan process.
5:49:54
If I sorry um did you want to come back on that because I want to move to another site please
5:50:01
very briefly is this another site that's not in the plan this is a site in the plan oh in the plan okay
5:50:06
yes indeed uh the site at Morain Cleon um this site has gone through the
5:50:13
process uh being about assessment and uh assessment for site selection however we
5:50:20
have a new situation that is occurring we have a major application for a solar farm immediately
5:50:27
to the south of the housing site promoted by Sunderland AFC. This is a
5:50:32
very exceptional very exceptional circumstances case because that field is in the green belt but it adjoins the
5:50:38
housing site. So far in the consultation process on that planning application,
5:50:44
the applicants have refused to engage over the issue that we have a housing allocation immediately across the road
5:50:51
and I would want this raised at this examination. So the we can consider
5:50:57
whether there are any implications on the site selection uh for the housing site in relation to a proposed solar
5:51:03
farm. I'm not sure if that's something I'm going to to uh necessarily entertain in
5:51:09
terms of um when did the proposal for the win uh solar farm or solar proposal
5:51:14
come in? Is that is that a formal application? Yeah.
5:51:23
Yes. It's a a plan application and it was um submitted post regulation 19.
5:51:29
It remains undetermined. Yeah. Okay. Thank you. I think what I would say in
5:51:35
relation to what I've just recently heard is it won't be my role as part of this examination to say to the council
5:51:43
where I to think that more uh sites were needed for housing to say you will put
5:51:49
in site X or site Y. If I come to a conclusion that uh the plan is not sound
5:51:56
on housing numbers and more land is required that will go to the council and
5:52:02
it'll be for the council to assess and determine what it can do and how it can do it. Uh I'm sure their position will
5:52:09
be we've identified the sites that we think are the most or an appropriate strategy to um meet their uh meet the
5:52:17
housing need. I think what I do want to just be uh assured on from this exchange and what I've heard from Mr. Martin uh
5:52:24
from Mr. Thompson and from others is that the the evidence base neatly t kind
5:52:32
of ties in and ties up. And if there's been any kind of uh oversightes or
5:52:38
there's you know things that just haven't quite sat in the correct place then now is an opportunity to kind of
5:52:44
look at that reflect and obviously there'll be an updated I'll be looking for I will be looking for a uh
5:52:52
sustainability appraisal addendum uh if we get to the stage of you know proposed modifications. So there was an
5:52:59
opportunity to to kind of look at this Mr. Martin briefly. It's uh yes, it is very briefly. It's just in
5:53:05
response to Mr. Butler's point. Uh and it's just a statement of fact. The site is privately owned. If anybody does go
5:53:12
on it, it's trespassing. Um and part of the flaw in the wildlife corridor work
5:53:17
is the fact that they it seems to be on the basis of a secondary feature which it thinks is able to be accessed by the
5:53:25
public, but it's not. It's private land. Okay. For the benefits uh of the examination, I do not go on to private
5:53:32
land at this stage. I do not need to look at emission sites or sites that are not currently in the plan. That would be
5:53:39
as I say a matter were to conclude that additional sites were required that
5:53:45
would fall to the council. But I will and I have looked at the proposed sites that are in the plan including GA2. So I
5:53:51
have been there and I've been to that area. Can I now hear from councelor Taylor please?
5:53:58
Okay. Thank you, sir. Um, first of all, I'd like to thank the council for reducing the amount of green belt to be
5:54:04
used from regulation 18 to 19. So, you know, that that was a positive I'd like to start with. Um and that we can all
5:54:12
hear that lots of effort and reports and and research and work has been um undertaken to choose the green belt
5:54:19
sites in that in direct conflict with the mountain that's been undertaken in
5:54:25
the Roman house site to prove or disprove that it's able or not able to be built on. I thought that would be
5:54:30
really helpful now to have that for you to make a clear determination. So it's
5:54:36
quite stark the contrast there. Um in this inquiry must be evidence-based
5:54:41
after all. I think if we have higher density houses homes rather higher density homes lower housing need in the
5:54:49
brownfield development like the ramen house um would be to take all green belt allocations out of this um this local
5:54:57
plan. Um and regarding um North Farm the the two the two pockets I would like to
5:55:04
see the second pocket G2 removed um because it is a part of the wildlife
5:55:09
corridor and something that I don't know it's been mentioned already or not because I haven't been um I couldn't get on teams like I say yesterday but um the
5:55:18
road over bridge at tile sheds I don't know if people are aware but the um it was it should have been built by now
5:55:25
which it would be going from Bendon Road over to Boga in which is right where the G2 and the site that's no longer on the
5:55:32
local plan sat sat and it was um to help with the the metro and the trains that
5:55:38
are going across the line to get people over quicker now because of campaigns and data wasn't there and everything
5:55:44
that that hasn't happened but if these houses are built on that green belt there will be a higher the data will
5:55:50
then probably be there to show that the this tile shed flyover as campaigners
5:55:56
are calling it will need to be built Now that's going to go straight through a tripi site. All of the great north
5:56:02
forest trees on Benton Road are going to have to be felled for it. And um it's
5:56:07
all like I say it's also a wildlife corridor. So these are the knock-on effects of the green belt. So hopefully
5:56:14
you know all this m I don't know if you do or don't factor this kind of thing in but it all feeds into why we shouldn't
5:56:20
be building on the green belt. Um, in regarding Wellen's Farm, it's just quite
5:56:25
um, you know, sad to see that the the data is there to show why it shouldn't be built on and the views still that it
5:56:33
should be built on. It's it's quite it's quite um quite striking today to hear
5:56:38
that. Thank you. Thank you for that. Obviously, we'll come on to look at the detail of site G2
5:56:46
in Bolton uh Balden, East Balden next week. So, we'll pick up some of those issues. Um then I'm going to move on
5:56:54
from uh general approach to site selection. Um we'll carry on for a little bit longer and then we'll take a
5:57:00
mid a mid-after afternoon um break. Uh item 14 on my agenda for this this
5:57:06
afternoon. Um this is sort of allied to site selection and particularly looking
5:57:12
when we're looking at potential alterations to the green belt. Again, I appreciate we're going to look at this
5:57:18
in more detail for specific sites, but as a sort of a general approach and the MPPF advises again
5:57:25
uh in terms of uh I think it's paragraph uh 142 that first consideration should
5:57:34
be given when looking at um releasing land for green belt to uh land which has
5:57:40
been previously developed and or is well served by public transport. And I'd just like to invite the council, I think it's
5:57:46
in response to my MIQ 411, how you've approached that when you've looked at
5:57:52
potential alterations to the green belt at a at a reasonably high level without getting into sort of too much of the
5:57:58
sight specific detail because we'll we'll come on to that next week. Oh, that's okay. Um so as set out in the
5:58:05
council's response to MIQ 411 um in terms of access to to public transport
5:58:12
um we've set out that the burough is actually quite well served in terms of um accessibility. Um we've referred to
5:58:20
um the carbon audit um document which we mentioned yesterday. Uh in particular
5:58:26
figures um 3.5 and 3.6 that show just a small area to the southwest of the
5:58:32
burough. it's not been um um within at least a kilometer of a bus stop and
5:58:38
identify sort of the central areas um particularly of the green belt um and around the main urban area um to be
5:58:46
accessible to metro systems as well. Um so we considered in terms of the green
5:58:51
belt um that accessibility wasn't particularly a constraint within South Tinside due to those connections al the
5:59:00
the the nature of the burrow being fairly compact um and and in reasonable access to to existing public transport.
5:59:07
Um in terms of um existing brown previously developed land brownfield sites within the green belt um they were
5:59:14
considered through the site selection process um within the response to um 411
5:59:20
I think it's paragraph 457 um we set out a number of sites there
5:59:26
which um were rejected and the reasons for those sites brownfield sites in the
5:59:32
green belt um being rejected that that reason is set out in that response where sites um were brownfields and were
5:59:40
considered to be suitable and available they were allocated. Um so that includes
5:59:46
um land at Whitburn Lodge and Wally Collery in terms of Brownfield Greenb sites.
5:59:55
Thank you. And in terms of accessibility to public transport, people have already referred to is it proposed extensions to
6:00:04
the metro network? Um, and the reference to is it
6:00:09
to Washington? Is that something that's committed to or is it still a kind of an
6:00:15
early kind of uh
6:00:20
investigative stage? I think it's just sort of been um announced recently just
6:00:25
before the examination hearings um as sort of that is is is something that would go ahead through the the the new
6:00:33
um me authority
6:00:48
and I'll add as well that we do have um safeguarded and um near the the wardly collery um allocation as well for a
6:00:55
metro station which will be part of that.
6:01:02
Thank you. We will have a a session on general approach to kind of infrastructure as part of stage two. So
6:01:08
if there has been a material change and there is perhaps more positive news or
6:01:13
announcement, we could perhaps feed it into the stage two or understand it as part of the stage two um exam uh stage
6:01:22
two part of this examination. Thank you. In terms of um general
6:01:28
approach to the green belt, I think the the answer I'm getting from the council is that most parts of the green belt are
6:01:35
well related to kind of public transport. Um we'll discuss that in relation to
6:01:46
okay just sorry is it Mrs. Hunter or Mr. Green just to me
6:01:53
in the in the infrastructure plan uh there was talk and aspiration of a uh a
6:02:00
metro station between Felgate and Paw which would have served the housing
6:02:05
felgate housing estate that hasn't got the funding to go ahead. Uh in in
6:02:10
addition uh with Fel Felgate's transport links, although it looks on paper as if
6:02:16
it's fine, you know, you've got a bus service going around the estate, the estate only has two primary exits from
6:02:23
it. One is on the A194, which data statistics, you know, which I'm going to ask you at a later date to request will
6:02:31
show that it is gridlocked every day. The other one is on Felgate Avenue,
6:02:36
Headworth Lane. Now, what happens with that is because it's so close to the uh
6:02:41
to the sorry uh
6:03:06
and head
6:03:12
since January the 6th. Uh it create it creates rat runs through the entire area
6:03:18
as a result of what's happening on Felgate. Now you you've got people on the the cor the next estates down that
6:03:25
complaining because you know there's more and more traffic coming through and our and our argument next week is is is
6:03:31
going to be and we've got all the facts and figures that the the new build on Felgate will will severely make worsen
6:03:40
the situation around the entire area. It's not just it's not just Felgate. It affects the entire entirety of it. So if
6:03:47
you if you're talking about transport links, unless we get hover buses, the buses themselves get stuck in the
6:03:54
traffic what we're getting stuck in. So everything the metro station, you know,
6:03:59
it's small. It's a very small metro station. No, no spaces because all the traffic's gridlock and it's essential
6:04:05
travel because you've got parents taking their children to the gymnastics from work, you know, pick off drop offs. Uh
6:04:12
it's it severely worsens and it's a 20 mph residential road. I know we'll get we'll get into this, but you you cannot
6:04:19
because we're discussing transport links, you cannot get the buses around the estate because on a lot of occasions
6:04:24
it's single lane because you've got residents rightly parking on one side, you've got the buses trying to get in on
6:04:29
the other, but you've got traffic coming coming this way. And I know we'll look into this next week, but in relation to
6:04:35
transport link, Felgate isn't the place to put a development, particularly with an access road onto a 20 m an hour
6:04:42
residential road. You know, it's bonkers. It's It's I could give you a Jordia expression, but I'm not going to
6:04:50
Well, I think that was one. Seriously, if Okay. Thank Thank you, Mrs. Hunter,
6:04:57
please. I think it's just to back up what Mr. Green said there. I've traveled I
6:05:02
traveled on the metro. Thankfully, I don't have to do it now. The metro at
6:05:07
Felgate is absolutely full to capacity from half past 7 7:00 until 9 in the
6:05:16
morning. You've got you can't you couldn't get standing room. You had metros going past and the availability
6:05:23
of putting additional metros on at that station is practically zilch because it
6:05:28
shares it with British Rail. So whilst it has a metro station, does
6:05:35
it have a metro station that could cope with the volume of potential commuters
6:05:40
coming from this build on Felgate? I would say categorically no.
6:05:47
I want to come on to to that's really all I've got next week. But yeah, thank you. Um
6:05:54
councelor Taylor and then Mr. Butler, please. Thank you, sir. Just some uh clarity
6:06:00
about the um you mentioned the Washington Metro line. I know there's
6:06:05
one metro track behind Chaucer Avenue and there's a a one that used to be metro track the mineral line from behind
6:06:12
little running. So which one is it that because it's not easy to tell from the
6:06:17
basic maps available online?
6:06:24
It's it's just loop. I don't think it's shown on our policies map what
6:06:31
so it's not the mineral line that runs right. Thank you. Thanks for clarifying that
6:06:37
Mr. Butler please. Thank you sir. Um yes in terms of uh
6:06:42
whether sites will be well served by public transport. Um we had the exchange yesterday over the situation at East
6:06:49
Balden Metro Station. Um we have a a metro station there. it's at capacity in
6:06:55
terms of ability for commuters to park their cars and has been a continuing and
6:07:00
long-standing issue of overspill into the surrounding residential streets. So,
6:07:06
locationally uh you may think that the the metro uh would be uh uh enable those
6:07:13
sites to be well served, but in practice it's a real problem.
6:07:20
Thank you, Mr. Thompson. Yeah. Um I would just like to add that
6:07:27
um I don't think the approach has considered um areas well served by public transport. We've obviously heard
6:07:33
about Felgate, but um obviously I'm going to talk about Witburn. Um Witburn is well served by public transport and
6:07:40
only has two small allocations there on the north side. So um yeah.
6:08:03
Thank you. Just looking at my agenda uh item 15. We've covered some of this I
6:08:09
think already and I'd asked Mr. Allen about the approach to kind of compensatory uh improvements. This is also a part of
6:08:16
paragraph 142 of the MPPPF and just the general principle of looking at um green
6:08:21
belt um alterations. Can I just ask from the council in followup to my MIQ412?
6:08:28
Has it been the council's approach to adopt what was put forward in the um the LU
6:08:35
report or have you revisited that, amended it? uh looked at kind of
6:08:43
additional or alternative approaches to compensatory improvements. No, the um the LU report has informed
6:08:51
the um the key considerations that are included in policy SP4 for the site
6:08:56
allocations. And I have got questions for those who
6:09:01
come to all of the respective sessions when we look at
6:09:06
uh Balden the Fel Felgate uh Whitburn site, Cleon site. I've got a
6:09:13
specific question around compensatory improvements and how that will be secured through those um uh proposed
6:09:19
allocations. I'm going to suggest a short midafter
6:09:25
afternoon break before we return for the issue of safeguarded land. Um Mr.
6:09:30
Hutchson, is this is that name plate up from earlier?
6:09:37
Thank you, sir. It's with regard to um question 15. if I'm able to respond to
6:09:42
that. Um I know you're going to talk about specific sites uh next week, but
6:09:49
in in relation to compensatory improvements to the the green belt area,
6:09:57
um we go into more detail about that next week when we're talking about site GA2.
6:10:03
The proposals for potential mitigation and enhancement measures are outlined in
6:10:09
the green belt study um 2023 GRB1 and the South Tinside green and blue
6:10:16
infrastructure GBI strategy 2023 NAT1. However, they haven't been con
6:10:24
carried through as considerations um for the developments of the sites in question.
6:10:31
Thank you. I do want to follow that up as a specific question when we come on to um the individual sites. So I'm I
6:10:39
note um east east B uh East Ben Neighborhood Forum's position on that.
6:10:45
Okay, I'm going to take a brief midafter afternoon German. We're not quite at half past 3. Um can we be back in this
6:10:53
room please at 20 to 4 and when we return it will be item 16 and 17 on my
6:10:59
agenda around safeguarded land. Thank you.
6:23:06
Okay, it's coming up to 20 to 4, so we'll uh press on. This will be the final session you'll be pleased to hear
6:23:12
for this matter for discussion. Um, today uh I'd like to pick up my agenda.
6:23:18
It's item 16. uh and we'll probably wrap that into item 17 as well.
6:23:25
uh the MPPPF at paragraph 143 of the September 2023 um version of that
6:23:33
document. Uh obviously also sorry also sets out other matters to kind of
6:23:40
consider when defining green belt boundaries. um primarily as part of the um local plan process. Um and the things
6:23:49
that uh should be taken into consideration and one of those factors is criterion C which says where
6:23:57
necessary identify areas of safeguarded land between the urban area and the green belt in order to meet longerterm
6:24:03
development needs stretching well beyond the plan period. Uh I think I've tried to sort of stress for the benefit of
6:24:09
those who don't deal in planning or policy on a day-to-day basis, safeguarded land has a particular
6:24:16
meaning. It's land that is taken out of the green belts or uh
6:24:21
require alteration and therefore the exceptional circumstances um to do that. But in in essence it's
6:24:28
safeguarded or put to one side for future uh development requirements
6:24:34
principally as part of the next local plan uh process. So my general questions at MIQ's 413 and
6:24:44
414 whether it was necessary for soundness to further alter um the green
6:24:50
belt boundaries uh in terms of their longer term uh endurance. Uh, and I
6:24:56
think I
6:25:31
need
6:25:37
and candid in that it is meeting its need according to the standard method
6:25:42
and no more and that is the purpose of this particular
6:26:06
in my submission for this authority to propose any further green belt ban for development on a safeguarded basis.
6:26:15
I That sums up our position.
6:26:21
Can I Well, I'm I say can I I'm going to uh seek clarification on um some parts
6:26:28
of the council's statement uh just so that I'm I'm clear.
6:26:33
Okay. Thank you. It was just um I just wanted to explore a little bit more with
6:26:38
the council. But paragraph 469 of your statement and response to my um matter
6:26:45
is question 413, the council describes in inherent
6:26:50
inherent uncertainty in determining housing needs um in the
6:26:56
future. Uh it would be difficult to demonstrate exceptional circumstances.
6:27:02
Um and then at paragraph 472 and as we've discussed at um
6:27:09
previous sessions. It's obviously a transitional plan. Um
6:27:15
anticipation will be a a local plan, a new local plan will follow shortly thereafter. Uh and it's the council says
6:27:23
as it's accepted that in all likelihood it will be necessary to allocate additional uh green belt um land. And as
6:27:31
we sit here now, is there that inherent uncertainty around uh determining housing needs and
6:27:39
numbers in the future? I think what uh the first paragraph that
6:27:44
you're referring to um that is basically um refers to our position at the
6:27:52
preparation the regulation 19 version of the local plan obviously where the safeguarded land at the south of Felgate
6:27:58
was removed. Um I think if refer to um the council's response um to question
6:28:05
415 particularly paragraph um 4.82 and it sets out um some of the
6:28:11
considerations in terms of housing numbers um that were at play at that
6:28:16
point in time when we were considering um whether or not to retain the safeguarded land in the regulation 19
6:28:23
document. I think that's the the uncertainty that um that paragraph is is
6:28:29
relating to in terms of the decision making um in in preparation of the the
6:28:34
publication draft local plan.
6:29:00
Thank you for that. Must admit I must have read the uh paragraph 469 is about
6:29:06
an inherent uncertainty in terms of determining housing numbers beyond this plan um period. Um but I've made a note
6:29:16
of the um the council's um response to that that particular uh point.
6:29:24
If I can turn to those who uh are advocating or suggesting it would be necessary for soundness um to uh include
6:29:32
safeguarded land as part of this uh plan. I'm going to invite Mr. Morton
6:29:38
first as I think that has direct bearing um to the example uh referred to by Mr. Shadaravian
6:29:46
and I've obviously read your representations and I understand others are all similly advocating for this plan
6:29:52
to have safeguarded land and that be a modification necessary for soundness. So
6:29:57
Mr. Morton first please. Thank you sir. Um just starting with with policy
6:30:04
um and 143 C of the MPPF I think the uh the key word there is
6:30:11
well beyond. So there needs to be um enough green belt release to ensure
6:30:17
housing needs are met well beyond the plan period. Um as we discussed um
6:30:24
yesterday this plan sets a bare minimum housing need um and against that um it
6:30:32
removed the 15% buffer and it removed safeguarded land. So um those two
6:30:38
contingencies and flexibilities on the on the plan have both been removed. So
6:30:45
um what this end of the table said yesterday is this is a plan that that does the bare minimum. um in terms of
6:30:52
green belt release and then that's got to sit beside that well beyond um part
6:30:57
of the MPPF. So I'm struggling a little bit with that. Um just in terms of that
6:31:03
inherent um difficulty point um here what Miss M Miss Lamb says um but what
6:31:11
we do know is that prior to submission um the government produced a new standard method figure um which means
6:31:19
the council will need to prepare a new local plan um and we we heard yesterday that the intention is to do that
6:31:25
quickly. I have some doubts about that. Um but what we do know is that that new
6:31:31
standard method figure um means there'll be a need for an extra 5,000 houses on
6:31:38
top of what's in this local plan. And given the council's position that exceptional circumstances apply in this
6:31:46
plan, plan number one, um it's inherent that those extra 5,000 houses are going
6:31:52
to have to come from the green belt. And um I included in an appendix to uh to my
6:31:58
statement where the council estimated that would be an extra 200 hectares of of green belt land. So it's academic
6:32:06
that more green belt land's going to be needed through a plan. So my suggestion is that safeguarded land is the
6:32:14
appropriate policy bridge between plan number one and plan number two. Doesn't
6:32:19
allocate the land for development in plan number one. um it's simply signposts that that's land for extra
6:32:26
development. Um and it's a decision for plan number two as to as to whether that
6:32:32
that should be allocated. But coming back to the fundamental point um I fail
6:32:38
to see how this plan can demonstrate consistency that green belt boundaries
6:32:43
won't need to be amended well beyond the plan period.
6:33:04
Thank you mi thank you Mr. Morton, in terms of sort of just draw you on my my
6:33:09
sort of second point at item 17 of asking the question whether the
6:33:15
evidence exists to identify areas for safeguarded land or whether further work would be necessary and I've heard from
6:33:20
the council. I think they say there's been no sort of exercise of kind of looking at alternatives
6:33:26
uh to date. So um again thinking about uh the practicalities of
6:33:33
addressing if there is a potential soundness issue
6:33:40
um potentially um I think what I would go back to there is you wouldn't be
6:33:46
starting from from scratch on this and um just picking up the case point
6:33:52
yesterday this isn't a a modification that changes a plan period or anything like that um so slightly easier to deal
6:33:59
with. Um there has been work done by the council
6:34:04
at the at the regulation 18 stage where the felgate land was identified as as
6:34:10
safeguarded land and um that green belt assessment I know it's moved on with the
6:34:15
with the LUC work but that green belt assessment did assess um the Felgate
6:34:21
site as a whole and scored it relatively strongly. um there was a category above
6:34:27
that which was strongly and it didn't fall into into that camp. um
6:34:34
I think just perhaps thinking about a point which may come up that um the
6:34:39
safeguarded land would go into land which LU um have identified as high and
6:34:45
and very high harm. Again, thinking about local plan number two, local plan
6:34:51
number one, this plan already allocates um or proposes to select sites that are
6:34:57
moderate in in green belt terms. So to identify land for a further 5,000
6:35:04
houses, again, to me, it's academic that um we're going to have to go into land
6:35:10
that's high and very high harm.
6:35:30
Okay, thank you. If I can bring in anybody else who was uh coming in on
6:35:36
this point of safeguarded land. I think others. Yes. Slitchfields for uh Avent
6:35:41
Homes. Mr. Westwick. Uh yes sir. Um fully support uh Mr. Morton. Uh probably
6:35:47
the question is uh where that safeguard land is and I think it just goes back to your point about how quickly that could
6:35:52
be done if there was a issue. I think yesterday we had the we did have the conversation about adding additional
6:35:58
within the within the evidence base you've got can be done within the with within the six month period. I think the
6:36:04
council acknowledged that and I think um we heard today they've got a very thorough green belt review. Um, I don't
6:36:09
think it'll be too challenging for the council to essentially look at those sites and do that within the time time
6:36:15
scales prescribed.
6:36:32
Thank you, Mr. Thompson. For banks, please. Uh, I was just going to say what Mr. Westwick's just said there. basically
6:36:38
that that the green belt study's been done. It's identified land that's of moderate harm. We've seen that sites of
6:36:44
moderate harm being allocated. Um so as a starting point, that would be a an
6:36:50
easy area to go to to to safeguard land there.
6:37:06
Thank you. Just pick up. I'll just be clear on um
6:37:13
I think reasons why people are are putting forward safeguarded land uh or
6:37:19
the the option or potential modification of safeguarded land, not just in ter in
6:37:26
relation to what the uh MPPF says in terms of meeting longer term
6:37:32
needs um stretching well beyond the plan period. So I've heard from Mr. Morton in terms of direction of travel uh in terms
6:37:39
of uh housing need uh figures um I don't know if it was can't recall
6:37:46
if it was banks property or somebody else also saying around safeguarded land being having a benefit in terms of
6:37:51
d-risk if there are risks around delivery with felgate it would provide alternatives. Yeah.
6:37:58
Well, on obviously Felgate's a big site. Heard about issues that could arise um
6:38:04
of infrastructure delivery and the impact that'll have on on housing delivery. Um our opinion is that the the
6:38:13
schlar delivery on Felgate is quite optimistic to deliver all them units in the plan period and quite high yields as
6:38:21
well in some of the years. Um, so by safeguarding additional land that allows
6:38:27
a bit of a buffer there if Felgate was to underdel in this planned period that
6:38:32
other land would be available there to to make up that shortfall.
6:38:51
Okay, thank you. Uh, if I come to Mr. Green and then councelor Taylor, please.
6:39:03
Sorry. Uh, yeah, the the Felgate Green Bill. Yeah, I mean, we'll go on about I
6:39:09
mean, I'm just reading the exceptional circumstances here. Uh, point two 2.21
6:39:15
assuming I'm on the right report. Uh the health of residents in South Tes is generally worse than the regional
6:39:20
natural averages with many residents facing health inequalities across the burough. Uh one of the council's key
6:39:27
ambitions is for residents to be healthy and well. Residents will enjoy good mental well-being and physical health
6:39:32
throughout their lives. They'll have the best start in life and to be able to live and age well. Now the Felgate
6:39:39
community is a community. They're on about putting another community in, but
6:39:44
the Felgate Green Belt consists it's it's got a working form which is a a
6:39:49
community within a community. So, it helps us, but they've got their own community within it as well. We we've
6:39:55
already we've talked for the past three days about the problems it has with traffic, flooding. There's been
6:40:03
who's responsible for the flooding, who's going to pay for the traffic in infrastructure.
6:40:08
Uh, one one of the costings.
6:40:37
undermining urban regeneration goals conflict with South Tinside local plan
6:40:43
policies as well. South Tinside adopted core strategy includes policy AA1 which
6:40:48
seeks to maintain the openness of the green belt. Any allocation of green belt for development must demonstrate that
6:40:55
alternatives have been considered and the plan approach is being followed. Peace meal release undermines local plan
6:41:01
consistency and public confidence. environmental and landscape harm as
6:41:06
well. Green belt and south tinside includes areas of high landscape value, farmland and coastal green wedges.
6:41:13
Development risks permanent harm to visual immunity, landscape character and
6:41:18
sense of openness. This conflicts with local and national objectives for landscape protection and green
6:41:24
infrastructure.
6:41:29
There's been several well about I don't four or five councils where the local plan was
6:41:36
dismissed and that was primarily due to weak justification for green belt release which I hope that is evident at
6:41:45
the end of this um process as well. You've got um South Oxford District Council, Castle Point Ba Council in
6:41:52
Essex and Alburn's City and District Council um
6:41:57
and I know one one of um was it um South Oxford District Council that um the
6:42:03
examiner forced the green forced changes to that and it did actually go through but that was that was all because of the
6:42:09
green belt as well. Exceptional circumstances weren't met. Um, so I
6:42:14
submit that releasing green belt land in South Tesight is contrary to national planner policy in the NPPF which
6:42:21
requires exceptional circumstances and prioritizes brownfield redevelopment. The allocation fails to meet the tests
6:42:28
of green belt release risks undermining urban regeneration and would harm landscape biodiversity and climate
6:42:35
commitments. I urge you, the inspector, to conclude that this allocation is unsounds of inconsistency with national
6:42:42
plan and policy, lack of justified evidence in conflict with the planled approach.
6:42:51
Thank you. Uh I think it was Mrs. Hunter next and then Mr. Green and then I'll
6:42:57
come back to the council. If you build in a safe guard,
6:43:04
it will building apathy the council it will restrict the council from looking
6:43:11
at for more brownfield sites the reaction of Mr. Morton, I think he
6:43:17
already knows that he's going to immediately go for the safeguard of another 1,800 houses. This isn't, you
6:43:24
know, I would like to know how we can see in the future because I don't think any of us can. We've got massive massive
6:43:32
movement in AI. We've got massive movement in automation. We've got massive movement with world trade. There
6:43:38
is nothing there that would infer that there is going to be a need for an
6:43:44
increase in the sort of houses that would be built on that green belt. So I
6:43:49
go back to the initial why the government have set these targets and one of the main reasons they've set this
6:43:56
target is because of homelessness or inability to afford a home. These homes
6:44:02
on that green belt are not going to be affordable. So whilst the government are saying they're setting a figure of say
6:44:09
for example 3,000, they're not setting a figure of 3,000 prestigious homes that
6:44:15
are out of the range of the residents in the burough. If we build this safeguard
6:44:21
in there, you you're doing a disservice again because you're not you're actually hitting a figure but not getting at the
6:44:27
root of the problem. So I think we need to to revisit just exactly what the government is trying to
6:44:34
achieve when setting these housing figures. It isn't a a a pass to the
6:44:39
developers to make millions on a green belt land. It's to actually solve
6:44:44
problems at the lower level. And I think when you look at the way forward, if you
6:44:51
like, if you can see the way forward, the way forward is not going to be for prestigious homes. There's going to be I
6:44:58
know I sound like a harbinger of doom but you know we are sleepwalking into what AI is going to actually achieve and
6:45:05
the first thing it's going to do is get rid of jobs. If we tie people into
6:45:11
massive mortgages that they can't afford, they will leave that house and what will they be looking for? We won't
6:45:18
have it. So whilst it's it's not a charter for developers to build
6:45:24
prestigious homes on the back of something that the government implemented to solve an issue that
6:45:30
they're not going to solve. That's all I'm saying. I think it's just
6:45:35
dangerous to build in a sea of God. Thank you, Mr. Green, please.
6:45:42
Yeah. Uh this this area, you know, it's got, you know, it had a massive ship building industry. has been renowned for
6:45:49
heavy industry throughout the years. Now that's gone. And what what what they've
6:45:54
done in this area is without releasing any green belt, they built on those heavy industry sites. You know, you've
6:46:00
got the Hawthorne shipyards, you've got railroads, you got the old Heaven College, the Maples, Old Hullborn, Py,
6:46:06
and there was no Green Belt land used up for that was it was brownfield sites, you know. Uh now what's to say that over
6:46:14
the next 15 to 20 years again going on what Karen's just said about AI that a lot of where industry settled at the
6:46:21
moment uh so you know you've got a lot of industrial complexes around the area you've got uh pollen speed there's a lot
6:46:28
what's to say that the land there won't become available to build the houses for
6:46:33
the future generations instead of safeguarding the safeguarding the green belt and I I mean we're not I mean I'm
6:46:41
just reading something here you uh yeah there's been you know the Saviles have
6:46:46
put 11 years work during which time significant investment resources have been put putting into the plan by many
6:46:51
stakeholders in what I'm saying is the investment we have to put in is not for for monetary purposes it's for our
6:46:58
children and our grandchildren and that the take it away you know we're not
6:47:04
doing it for profit monetary we're doing it to safeguard it for the children so instead of safeguarding the land you
6:47:10
know for their purpose safeguarded so that they've still got some green space left.
6:47:19
Thank you. I'd like to come back to the council. I think the points that been made by Mr. Morton and similarly by Mr.
6:47:27
Thompson uh and particularly this issue I think sort of pushing back on the council's uh
6:47:34
position that it would be premature that there is grounds now here
6:47:39
for safeguarding to be part of an appropriate strategy for this plan.
6:47:45
Okay. Um in order to um answer that question my
6:47:51
first proposition is that the issue of safeguarding has to be looked at strategically.
6:48:00
That in itself has implications in terms of looking at what alternatives exist
6:48:06
and what information is needed in order to support any such assessment. I'll
6:48:11
come back to that. Let's remind ourselves then what the
6:48:17
strategic responsibility of local planning authorities is.
6:48:22
It is to establish a housing requirement figure for the whole area which shows
6:48:27
the extent to which the the identified housing need and any needs that can't be
6:48:33
met from neighboring areas if relevant can be met over the plan period
6:48:40
and the MPPF makes it clear that the requirement may doesn't have to be may
6:48:46
be higher than the identified housing need if for example it includes
6:48:51
provision for neighboring areas or reflects growth ambitions linked to economic development or infrastructure
6:48:58
investment.
6:49:04
So that then is carried forward into the requirement for local authorities to
6:49:10
identify land for homes. You set the requirement
6:49:16
having regard to the need and then you need to identify the land for the homes.
6:49:22
And the requirement is that specific deliverable sites for five years
6:49:28
following the intended date of adoption sites should be identified. Specific
6:49:33
deliverable sites should be identified
6:49:38
for years 6 to 10 and where possible I emphasize that where possible for years
6:49:45
11 to 15 or the remaining plan period specific deliverable sites or broad
6:49:51
locations for growth need to be identified.
6:49:58
That is the requirement. We fulfill both of those. Albeit that
6:50:04
there is an issue over the final year of the plan
6:50:14
when we go on to consider um this in the in the context of paragraph C. Just let
6:50:20
me go back to it. I'm actually working from the wrong MPPF mistakenly, but I'm that's why I'm not referring to
6:50:25
paragraph numbers at the moment, but the content is the same. Just forgive me. Bear with me for a second.
6:50:35
The requirement is hang
6:50:45
where necessary to safeguard land. And that necessity is expressed as being
6:50:54
for development well beyond the plan period. I've given one example where that might
6:51:01
apply. So for example, uh we may be fulfilling the requirements
6:51:08
of the MPPF in identifying land for housing to meet the identified need and
6:51:14
the requirement for the plan period by identifying a site which is going to
6:51:21
actually fulfill ambitions for growth well beyond the plan period because it's It's the most
6:51:28
viable and effective way of delivering growth through the plan period and beyond by way of a new settlement.
6:51:38
You can't plan for a new settlement just within the plan period. You've got to know what's going to happen well beyond
6:51:44
it. And I'm giving this as an example only. There might be other examples
6:51:49
that requires infrastructure investment long-term um uh internalization objectives which
6:51:58
require um the sequential development of land.
6:52:05
So that development comes in an orderly fashion and a sustainable fashion. You
6:52:11
can say with a reasonable degree of certainty at this stage that that other
6:52:17
that safeguarded land will be needed beyond the plan period
6:52:25
and can be accommodated as part of a review earlier on if it needs to be
6:52:30
brought forward at any particular stage. So that's a prime example of where it
6:52:36
becomes necessary to safeguard land because it's almost inevitable that that
6:52:41
land will be included in later phases of development. We can't say that here.
6:52:47
There is no comparable situation here. And moreover, for as long as we are
6:52:53
meeting the requirements of the MPPF in identifying sites for the plan
6:52:59
period, there is no necessity to safeguard land
6:53:06
beyond the plan period.
6:53:11
So it just doesn't arise. If there is a need to identify further
6:53:18
sites to provide flexibility in terms of meeting that need within the plan
6:53:24
period, then you will come to the decision that there is a need to go back and look
6:53:30
at other sites in order to supplement provision through a modifications
6:53:36
process. And that would allow you then to make assessment of um sites, alternative
6:53:45
sites in a green belt context as well.
6:53:51
It would need to consider all aspects. Much of the work would have been done, of course. It would need to be refreshed
6:53:57
and made sure it's still up to date. Um but the raw material is there upon which to make those further judgments should
6:54:03
it be deemed necessary to do so.
6:54:18
Okay. Are there any further submissions on safeguarded land?
6:54:25
Oh, councelor Kilgore. Thank you, sir. Um ju just kind of to
6:54:31
summarize and I absolutely do agree with council on this um that we've already
6:54:38
discussed today the the inconsistencies the uncertainty
6:54:44
traffic flooding bridal path we need to consult on the likes of grey belt there
6:54:50
isn't the metro that was intended to be planned for the lem sideline um we
6:54:56
simply don't have the detail and and It's not an exceptional circumstance
6:55:01
that's been able to be demonstrated to remove um from the green belt for,200 houses, let alone 3,000. So I would
6:55:09
absolutely um agree with Mr. Allen on that as well when he looked at the openness, the impact that um 1,200 alone
6:55:18
would have would be unacceptable, let alone 3,000. And I totally concur with the council and my my colleagues along
6:55:25
this side with regards to the refusal of any uh provision for safeguarded land. Thank you.
6:55:35
Thank you uh Mr. Butler. Thank you sir. I would also concur with the council. There's not a need for
6:55:41
safeguarded land. Um you pointed out uh the paragraph in the in the MPPF says
6:55:48
where necessary. Uh I think Um you've also uh indicated uh that the council at
6:55:57
the moment uh has prepared proposals that would meet the standard method
6:56:02
although of course I've made a submission that that should be lower uh than the figure that's been given. Uh we
6:56:09
also have a significant nationally important employment site underway.
6:56:15
We're not just talking about potential safeguarding for housing here. We're talking about safeguarding for all types
6:56:21
of uses and uh therefore there is at the moment uh the long-term planning both uh
6:56:29
from the IMP position in terms of employment and for uh housing uh that
6:56:35
can be accommodated in this plan and therefore safeguarding is not necessary at this time.
6:56:53
Thank you. Okay. I think the matter of safeguarding is firmly left with me as
6:56:58
part of my deliberations. Heard the respective submissions and I've got the um uh various statements um that I'll be
6:57:06
looking at. I wonder if I can just bring this afternoon session to its close. We've kind of touched upon this um and
6:57:12
there may not be too much need to kind of go over this uh too
6:57:18
uh go over this further in sort of too much um depth or detail. uh but my
6:57:24
MIQ415 and it's my final sort of question uh or agenda item 18 was around obviously uh
6:57:34
I'm looking at the soundness of the plan that is uh put before me that was the regulation 19 plan in 2024
6:57:41
obviously during the course of the plan preparation uh various other proposals including safeguarded land that we've
6:57:48
just been considering were uh consulted on but subsequently revised and not presented Ed and whether that remains uh
6:57:56
a justified uh approach supported by the available evidence including the green belt review and the submitted uh and the
6:58:03
so the sustainability uh appraisal. Appreciate the council's given its answer to my MIQ uh for 15. I don't
6:58:12
there's anything further the council wishes to add or expand upon that point? No. Are there any sort of final further
6:58:20
submissions on that? I'm probably looking principally at the bottom end of the table that you haven't already made
6:58:26
today and various um item items on the agenda.
6:58:32
Mr. So sorry just in relation to the buffer
6:58:37
in terms of land supply um
6:58:43
understand there's no buffer being applied so not 15% um in our submissions I think there's a
6:58:49
clear place for a 20% buffer to be applied to the first five years um in accordance with paragraph 68A of the
6:58:55
MPPPF um the regulation 18 version had a 15% buffer I think um and the Reason the
6:59:03
council provided for having that was to give the plan the flexibility and ensure
6:59:09
that if there is a degree of slippage over the plan period that it does not ultimately leave the plan vulnerable against delivering upon its need. This
6:59:17
ensures the plan is all positively prepared and effective. I still see those reasons being applicable. Um, so I
6:59:24
guess when I see the requirement in the MPF for a 20% buffer to be applied, I don't see any justification not to apply
6:59:30
that. Thank you. I think the council confirmed yesterday, correct me if I'm wrong, that
6:59:36
that 15% was kind of a buffer on the land supply situation, not the the housing
6:59:43
requirement. So I think I will want to kind of come back and look at this, Mr. When we look at overall housing land
6:59:48
supply very much picking up the point from Mr. Chadavian about a deliverable supply in years one to five and really
6:59:56
ensuring that that's in place to give planled
7:00:01
uh certainty. Um to make it absolutely clear my response on the issue of
7:00:09
safeguarding land um wasn't intended to mislead you on on what the MPPF requires
7:00:16
in terms of housing supply. I was really setting out um um what it
7:00:22
requires in the context of um uh meeting need over a period of time um and how um
7:00:32
the safeguarding um elements of the MPPF related to that.
7:00:40
Thank you. I'm going to draw this afternoon session to a close. Can I thank everybody for their contributions
7:00:46
uh today? Um we are sitting again tomorrow. Uh people
7:00:52
might be pleased to hear it'll be for tomorrow morning only but we are starting the first of various discussions on sites and we're going to
7:00:59
be looking at uh the first site in Heburn and then uh the wardly collery
7:01:04
site. Um again it's another 9:30 start. I might see some of you there. Alternatively, I might see some of you
7:01:11
at subsequent sessions next week when we return for Felgate, the Baldens, Cleonen, Whitburn, and all points in
7:01:18
between. So, thank you everybody. people are German.