Submission

Neighbourhood Plan update: pre submission consultation

 

We received over 450 comments during the six week consultation period, which highlights the interest in development in the plan area.

 

A file of the comments, together with our considered responses, can be accessed through the Neighbourhood Plan section of the Seahouses Development Trust website http://www.seahouses.org/neighbourhood-plan/ . This page also links to the revised plan and the supporting and background information. The comments and responses form Appendix C to the Consultation Statement.

 

The revised plan has now been approved by the three parish councils and has been submitted to Northumberland County Council who will manage the next and final stage of the process. They will:

-        Carry out a further consultation process;

-        Appoint, with the parish councils, an independent examiner who will review and report on the plan;

-        Consider this report and discuss whether any changes need to be made;

-        Arrange a referendum to finally approve the plan;

If successful at a referendum the plan will then be adopted.

All these items have statutory time limits. It is likely that the referendum will be next Spring.

 

So there is some way to go but the draft plan will, on submission to NCC, carry significant weight in future planning decisions.

 

The majority of comments on the plan were positive but a number of important issues were raised and we have amended the plan accordingly. Details of the changes are shown in the file above, but in summary:

-        We have corrected some omissions on the policies map;

-        We have adjusted the settlement boundary to reduce the development area in North Sunderland;

-        We have clarified the meanings of major and small scale development;

-        A number of parties, including NCC, noted that our policy on car parking spaces for new developments was in conflict with national planning policy. We have had no choice but to change the policy. This is not as bad as it sounds as new developments should be for permanent housing. We have included a new policy for conversions to holiday homes to ensure the impact on amenity and parking is taken into account. 

 

Thank you for your interest in the development of the plan which now moves out of our hands to the final formal stage. It has taken a long time: we all underestimated the formality of the process. But it should have a long term beneficial impact on our area.

Consultation

The formal consultation period on the neighbourhood plan is now over. We received many comments, the vast majority supportive, particularly from residents in the area.

However, there were a number of comments making recommendation for changes. Most of these related to the settlement boundaries in Seahouses but others raised a number of important issues about plan policies.

We will collate all the responses and publish them here and then consider whether and how the plan should be changed. We will provide a response to each of the comments but this will take some time.

Thank you to everybody who contributed.

Pre submission consultation

We are now ready to start the formal pre-submission consultation on the neighbourhood plan. This is a statutory and formal process. The consultation lasts for six weeks starting with a drop in event at the Hub in Seahouses at 6pm on Tuesday 18^th July.

The formal notice of the consultation has the dates of the other drop in events:

The Parish Councils are required to publicise the Draft Plan and invite comments. Copies of the Plan will be available for public inspection for a period of not less than six weeks commencing at 6pm on 18 July 2017 and ending at 6pm on 29 August 2017.

 

The Plan and supporting documents will be on line at 6pm on 18 July on http://www.seahouses.org/neighbourhood-plan/

 

The Draft Plan will be available for inspection at The Hub, Seahouses Development Trust, Stone Close, Seahouses, Northumberland NE68 7YL on Monday to Thursday between 10.00am to 12.30pm and 1.30pm to 4pm.

 

The Draft Plan will also be available at drop in sessions where there will also be background information about the plan:

The Hub, Tuesday 18 July, 6pm to 8pm; Seahouses Methodist Church, Wednesday 19 July, 10am to 12am; Beadnell WI, Wednesday 19 July, 1pm to 3pm; and Bamburgh Pavilion, Thursday 20 July, 10am to 12 am.

 

Any person, business or organisation may comment on the Plan.

 

Representations may be made by email or by post to the above addresses at the top of this notice.

 

All representations must be received by the Parish Councils no later than 6pm on 29 August 2017. All representations will be publicly available and will be considered by the Parish Councils in producing the final Plan which will then be submitted to Northumberland County Council as local planning authority for Independent Examination.

 

The introduction to the draft plan is as follows:

“This area is special because of the natural beauty and isolation of the landscape combined with our cultural history. But over the last few years it has been damaged by unsuitable development that in many cases has been in conflict with, rather than responding to, these characteristics. It is crucial that further development does not do further damage. These characteristics drive the economy of the area as well as deserving protection in their own right. 

 

 

The area also faces the problems resulting from the success of the visitor economy: house prices are high and many jobs are seasonal.

 

 

These factors are why the three parish councils of North Sunderland, Bamburgh and Beadnell have come together to develop this draft neighbourhood plan. Although Northumberland County Council’s emerging local plan does provide some guidance for this area, we believe that we should set out specific planning policies and aspirations. Things don’t stand still: further development will come to the area, and it is important for the economy and the residents that it does so. But it is also important that development matches the aspirations of those of us who live here.

 

 

The area faces some contentious current and potential planning applications. This plan is of necessity neutral on individual applications but sets out principles of good design which respect the neighbourhood. They will not have planning weight unless the plan is adopted but we hope future applications take the principles into account.

 

 

This draft plan has been based on consultation with residents, businesses and other stakeholders. This is your chance to contribute to and comment on a complete draft. I hope you take advantage of this opportunity – and note that comments in support of any aspects are just as important as suggested changes.”

Draft plan consultation

We have now received the environmental assessments that had to be carried out on the draft plan. They were positive and recommended no material changes to the plan or the draft policies.

This means we can now move to the formal consultation on the draft plan. This is as originally planned (see post below) and will be a six week consultation starting in mid July with drop in events in each of the three villages. We will also be writing to formal consultees and to the local organisations we previously contacted.

We are currently finalising dates and locations for the drop in sessions which will be publicised here, in local papers and by leaflet.

Draft plan launch

We have had to cancel the meeting referred to below.

The Council have advised that because of our adjacency to various protected habitats the plan will have to have a Habitat Regulations Assessment and a Strategic Environmental Assessment before the formal public consultation. Had the Council's Core Strategy been implemented according to the original timetable, this would not have been necessary as the assessments would have been done as part of that plan. Unfortunately this will delay the consultation by a couple of months.

The assessments are unlikely to raise major issues but they still have to be done. We are getting technical support from a Government programme to do them.

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There will be a public meeting on Monday 28 November at 7pm at Seahouses Social Club to launch a six week consultation on the draft neighbourhood plan. There will be drop in sessions in Bamburgh (Tuesday morning at the Castle Hotel), Beadnell (Tuesday afternoon in the WI Hall) and Seahouses (Wednesday morning, location to be advised).

The introduction sets the context of the plan and the consultation; the draft plan is being finalised for presentation on the 28th:

This area is special because of the natural beauty and isolation of the landscape combined with our cultural history. But over the last few years it has been damaged by unsuitable development that in many cases has been in conflict with, rather than responding to, these characteristics. It is crucial that further development does not do further damage. These characteristics drive the economy of the area as well as deserving protection in their own right. 

The area also faces the problems resulting from the success of the visitor economy: house prices are high and many jobs are seasonal.

These factors are why the three parish councils of North Sunderland, Bamburgh and Beadnell have come together to develop this draft neighbourhood plan. Although Northumberland County Council’s emerging local plan does provide some guidance for this area, we believe that we should set out specific planning policies and aspirations. Things don’t stand still: further development will come to the area, and it is important for the economy and the residents that it does so. But it is also important that development matches the aspirations of those of us who live here.

The area faces some contentious current and potential planning applications. This plan is of necessity neutral on individual applications but sets out principles of good design which respect the neighbourhood. They will not have planning weight unless the plan is adopted but we hope future applications take the principles into account.

This draft plan has been based on consultation with residents, businesses and other stakeholders. This is your chance to contribute to and comment on a complete draft. I hope you take advantage of this opportunity – and note that comments in support of any aspects are just as important as suggested changes.

Once this stage is complete, in mid January, we will deal with the comments and will start the formal consultation process with the County Council.

Settlement boundary methodology

An important part of the plan will be the creation of settlement boundaries around the three villages. This is to ensure that the setting of the villages is not harmed by unsuitable development and that new development does not cause unsuitable sprawl.

We are using a neutral methodology to define the boundaries and are confident that there is space within the resulting boundaries for sustainable development consistent with the Council's emerging core strategy.

The draft methodology is set out below:

Introduction

This background paper sets out a proposed methodology for the definition of settlement boundaries in the emerging North Northumberland Coast Neighbourhood Plan.

The delineation of settlement boundaries was considered to be the best mechanism to achieve some of the main elements of the vision and objectives of the neighbourhood plan, particularly those related to landscape protection in the Northumberland Coast Area of Outstanding Natural Beauty (AONB).

The neighbourhood plan is planning positively for housing in the plan area.  The objectively assessed need for housing for the plan area over the plan period stands at 110 dwellings.  Although housing sites have not been allocated, the settlement boundaries have, collectively, allowed for more than enough land within them to more than adequately fulfil this housing requirement. 

What is a settlement boundary?

In simple terms, a 'settlement boundary' is a dividing line, or boundary between areas of built/urban development (the settlement) and non-urban or rural development (the open countryside).  Although a settlement boundary does not preclude all development beyond the boundary[1], it does give clarity as to where new development (particularly housing) is likely to be acceptable in planning terms.

Inclusion of land within a settlement boundary does not mean that all land within the boundary is automatically suitable for new development.  There may be areas of land within the settlement boundaries that are not suitable for development due to other constraints, for example, tree preservation orders, land protected as Local Green Space (to be allocated through the neighbourhood planning process) or areas of special townscape character, Conservation Areas, Scheduled Monuments, listed buildings, etc.  Policies in the neighbourhood plan will clearly define what proposals are likely to be acceptable, and where.

The benefits of establishing settlement boundaries are as follows:

·       Ensure development is directed to more sustainable locations, both in terms of accessibility to and support of existing services and transport, and in terms of landscape.

·       Protect the special character of the AONB from encroachment of land uses more characteristic of built up areas.

·       In conjunction with other policies in the neighbourhood plan, to sustain the individual identity of each of the communities and maintain the distinctiveness of each settlement.

·       Provide greater certainty to communities, landowners and developers over where certain types of development could be acceptable in principle.

·       Support the plan led approach to development, giving a local context to the strategic intention of the emerging Northumberland Core Strategy.

Current Planning Context

The North Northumberland Coast Neighbourhood Plan proposes a general presumption in favour of sustainable development within the settlement boundaries of the three settlements in the plan area:  Seahouses and North Sunderland, Beadnell and Bamburgh.

The current strategic plan for the neighbourhood plan area is the Berwick-upon-Tweed Local Plan (April 1999).  Northumberland County Council is in the process of preparing a Core Strategy (currently consulting on major modifications until 27th July 2016).  Emerging policies from the Core Strategy as well as the current Berwick-upon-Tweed Local Plan are being considered in the formulation of policy in the neighbourhood plan.

In line with national planning policy, the current strategic policy for Northumberland is to direct development to the most sustainable locations in the county.  The emerging Core Strategy identifies main towns and service centres across Northumberland that are able to accommodate some growth[2]. 

There are no 'main towns' in the neighbourhood area, but it is important to distinguish between Seahouses and Beadnell and Bamburgh in terms of the strategic aims of the Core Strategy: 

Seahouses is defined as a service centre, whereas Beadnell and Bamburgh are smaller settlements which are not expected to contribute significantly to housing delivery in the area.  It is therefore reasonable to expect that Seahouses will accommodate the largest amount of new development, and that new development in Bamburgh and Beadnell will be at a smaller scale, commensurate with the nature of those settlements. 

It is considered that the definition of settlement boundaries for the main settlements in the neighbourhood area is a spatial planning tool that can be used to direct development to the most sustainable locations in the area, whilst protecting the very special character of the countryside, the coastal environment and the setting of these settlements.  

Seahouses and North Sunderland and Beadnell do not currently have settlement boundaries delineated in the Local Plan.  However, Bamburgh does (Policy S9 (saved)).  Therefore, the process of delineating settlement boundaries will involve a review of the current boundary, in Bamburgh, and the creation of new settlement boundaries for Seahouses and North Sunderland, and Beadnell.

The principle of development within the settlement boundaries will be supported provided that it complies with other relevant policies, is of a scale and nature appropriate to the character and function of the settlement and is in accordance with the spatial strategy for the neighbourhood area.  Development will not be permitted outside of settlement boundaries, subject to a number of exceptions which will be set out in neighbourhood plan policy, within the context of the NPPF.

Hamlets and small settlements located outside settlement boundaries are considered to be part of the 'open countryside' in planning terms.  These hamlets are therefore treated as part of the countryside and do not have settlement boundaries.

Methodology for defining settlement boundaries

Background

There is no single established methodology for defining settlement boundaries, and different local planning authorities across the country have taken different approaches to drawing settlement boundaries.  However, where a methodology has been used the criteria are generally similar from one local authority to another. These include questions such as whether to draw a boundary around clusters of buildings close to but separate from the main settlement; and whether particular uses should be included or excluded from the boundary, where they occur at the edge of a settlement.   This report has drawn on existing methodologies, and sought to pull together a methodology considered to be most appropriate within the context of the sensitive AONB landscape around the settlements in the neighbourhood plan area.

The methodology does not determine whether a settlement will have a boundary or not.  The decision to define settlement boundaries has been taken by each of the parish councils in the neighbourhood area, to give clarity and context to policies proposed in the neighbourhood plan.   The neighbourhood plan will not allocate sites for development. 

Any methodology must be clear, easy to understand, and replicable.  The same methodology will be used for all three settlements in the neighbourhood area.  

Existing evidence

There is a significant amount of evidence available to the neighbourhood plan Steering Group, and the desk-top element of defining settlement boundaries has drawn on a range of published studies and evidence base relating to landscape, townscape, land ownership and the historic and natural environments.

The following evidence has been used as background information to inform settlement boundaries, as well as the criteria put forward later in this paper.

Strategic Land Review for the Northern Delivery Area (NCC) June 2016

It is important to ensure that the settlement boundaries leave sufficient land to meet the housing requirement for the delivery area over the plan period. This document details the housing delivery requirement for the Seahouses sub-area, and is used to ensure that settlement boundaries incorporate enough land to reflect the unmet housing requirement for the sub-area.

 

Consultation with parish councils and local landowners (ongoing)

Consultation has taken place with parish councils defining initial settlement boundaries, and local landowners also defining where they consider settlement boundaries should be to reflect their longer term interests.

Northumberland Landscape Character Assessment (August 2010)

This document was produced as part of the evidence base for the Northumberland Core Strategy (emerging). It was envisaged that the study would inform decision-making and policy development at a strategic level.  It contains detail on the landscape character areas within which each settlement is situated.

Northumberland Coast AONB Landscape Sensitivity and Capacity Study (August 2013)

This document was commissioned by the Northumberland Coast AONB Partnership to identify the sensitivity and capacity by rating from high to low each landscape character area within the AONB to accommodate housing (and other types of development).  It specifically identifies settlement edges that are particularly sensitive to new development (in landscape terms).  

Northumberland Coast AONB Management Plan (2014 - 2019)

The Management Plan, although not a statutory plan, has policies that are used to influence decision-making in the AONB area.  It sets principles for development within the AONB area.

 

Conservation Area boundaries and Character Appraisals

Seahouses has a Conservation Area, and supporting Conservation Appraisal document.  Bamburgh has a Conservation Area defined (but no appraisal), and Beadnell has no Conservation Area, although the neighbourhood plan is seeking to define a Historic Core Character Area, and it is proposed, at a future date, to define a Conservation Area for Beadnell.  The Seahouses Conservation area appraisal makes recommendations for the area which will be taken into account in the review of the settlement boundary where the conservation area lies on or close to the proposed settlement boundary.

The Northumberland Coast AONB Design Guide for Built Development

The Design Guide makes recommendations for design, but has information on the character of each settlement in the AONB. 

The Northumberland and North Tyneside Shoreline Management Plan 2 (SMP2) (May 2009)

This document provides an assessment of the risks associated with coastal evolution and presents a policy framework to address these risks to people and the developed, historic and natural environment.  It contains key recommendations along the coast that could have implications for settlement boundaries, particularly in Beadnell and Seahouses.

Existing statutory designations

There are international, national and local nature conservation designations along the Northumberland Coast which will be important in relation to settlement boundaries.  International statutory designations comprise: Ramsar sites, SPAs, SACs and the Berwickshire and North Northumberland Coast European Marine Site. 

National statutory designations include: SSSIs, Northumberland Coast AONB, Scheduled Monuments and Listed Buildings.  Local statutory designations include: Local Wildlife sites, Local Nature reserve and Conservation Areas.  Non-statutory designations which are also important are the Heritage Coast designation, non-designated archaeology and locally listed heritage assets (the neighbourhood plan is defining a list of these)

Settlement boundaries will need to ensure that these designations are also considered.

Local Features

Barring the exceptions below, settlement boundaries will be drawn along defined features such as walls, hedgerows, waterways and roads where possible.

Site visits, aerial photographs and use of evidence base documents referred to above as well as criteria listed below will be essential to ensure a consistent approach.

Where no specific recommendations arise from the above evidence base studies, the following principles have been applied to the inclusion or exclusion of specific uses from within the settlement boundary where they occur adjacent to an existing or proposed new settlement boundary. The reasoning for these principles is provided in the paragraphs that follow.

The table below describes what types of development will be included or excluded from settlement boundaries.  It is important that a consistent and clearly replicable approach is used for all three settlements in the plan area.  Inevitably, some types of land/development may need to be decided on a site by site basis.

Site by site basis	Include	Exclude
Agricultural fields or paddocks that are surrounded by development on all sides	Built development forming the main settlement	Allotments (unless within the built up area)
Former farm buildings, converted to other uses adjacent to the settlement (account will be taken of defensible boundaries and the age of building - i.e. how established it is within the settlement)	Hard surfaced school playgrounds and playing fields where within, or on the edge of a settlement	Isolated housing not well related visually to the settlement.  Housing in large plots on the edge of settlements, but not well related to the built form, will be excluded.
Caravan sites, except where clearly within a settlement	Community facilities e.g. schools, public houses where they are within the existing  built environment	Designated wildlife sites (unless within the built up area)
Edge of settlement sites included in the SHLAA or put forward by local landowners	Local Green Spaces (designated through the neighbourhood plan) within settlements	Woodlands, orchards and other community green spaces, including cemeteries and churchyards (unless within the built up area)
	Land with planning permission for new development within or well-related to the settlement	Agricultural units (farmyards and farm buildings) including agricultural workers' dwellings, horticultural nurseries, equestrian facilities where not well related to the settlement
		Car parks on the edge of settlements
		Community facilities clearly outside the settlement (i.e. pubs/hotels)
		Roads, tracks and public rights of way running along the boundary
		Designated coastal habitats and areas identified in the SMP as being sensitive to erosion and unsuitable for development

Explanation of exclusion/inclusion criteria:

Nature Conservation Designations

The Coastal habitat designations in the area are highly sensitive, and will also be excluded from settlement boundaries.  The Shoreline Management Plan (2) identifies coastal areas which should remain undeveloped.  These will be excluded from settlement boundaries.

Agricultural fields and paddocks

Where agricultural fields and paddocks, including those no longer in agricultural use, are entirely surrounded by a built up area, they will be assessed on a case by case basis. If they contribute positively to the landscape and/or have biodiversity, historic and recreational value then it is likely that they will be designated as Local Green Space through the neighbourhood plan where they can be demonstrated as having particular importance to the local community they serve.

 

Agricultural buildings

Agricultural farmsteads are characteristically part of the countryside and provide the historical connection between settlements and their agricultural origins. These buildings can provide visual links to the rural context beyond. Therefore, where farmsteads are situated on the edge of the built form of settlements, they will be excluded if they are not well related to the settlement.  Where farmsteads are clearly integral to the built up part of the settlement, they will be included within the settlement boundary. 

Other countryside development

Other developments that would be allowed in the countryside or have been allowed under countryside policies in the past are considered to relate more to the countryside than to the settlement and will therefore be excluded where they lie adjacent to the boundary. This category includes equestrian developments; housing for agricultural or forestry workers and garden centres and nurseries and other 'paragraph 55' development.

Community facilities

Extensive community facilities such as hard surfaced sports grounds (including pavilions) and car parks, where they have been built outside existing settlement boundaries will be excluded.  More intensively built up community uses such as schools (and their playing fields) or public houses have been included in the boundary if they are already within the built up area or if they have been built adjacent to the built up area, and relate well to the settlement.

Caravan Sites

Caravan sites occurring at the edge of settlements have been assessed on a site by site basis.   Caravan sites not within a settlement are excluded.  Caravan sites within settlements are included. There are a significant number of caravan sites in the neighbourhood area.

Employment sites or other designated sites

Existing employment sites are included within the settlement boundary.  Sites designated for housing or other development are included in the settlement boundary.

Tracks and roads

Where settlement boundaries run along roads, tracks or public rights of way, they have been drawn along the edge closest to the settlement.

Detached parts of settlements

Detached parts of settlements of over 20 dwellings of a density in the region of 30 dwellings or per hectare, may have boundaries drawn around them. 

Clusters of low density villa style housing or of detached houses with sizeable side or front gardens will not be given settlement boundaries and will be considered to be in the open countryside for planning purposes.

Where boundaries are drawn around detached parts of settlements, this will not have any implications for land lying outside the boundary between the main part of the settlement and the detached part.  This land will be treated as open countryside for planning purposes.

Conclusion

This methodology is sought for approval by all three parish councils in the neighbourhood area, prior to the settlement boundaries being drawn and consulted on in the pre-submission draft version of the neighbourhood plan.

Next steps:

·       Methodology is approved/amended by Steering Group/parish councils and NCC

·       Meeting with Steering Group and with NCC planning officers - Methodology amended and approved.

·       Desk-top study and site visits (with members of Steering Group where necessary) are undertaken by planning consultant

·       Site visits and meetings took place with all Parish Councils in August 2016 to further define boundaries.

·       Proposed settlement boundaries are drawn, based on methodology contained in this paper and a written record produced

·       Proposed settlement boundaries are agreed by parish councils prior to formal consultation on neighbourhood plan

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[1] A number of exceptions exist, including 'exceptions' housing proposals, some business and employment related activities and development in the countryside in accordance with paragraphs 55 and 28 of the NPPF.

[2] Policy 3: Spatial distribution - NCC emerging Core Strategy  

Spring 2016 Update

The draft plan is almost here; it has taken some time particularly dealing with the evidence for housing need to support requirements for more permanent housing. It is clear that the villages continue to lose permanent housing to second and holiday homes and although these form an important part of the local economy we need to retain some balance.

The plan will contain policies on:

Landscape and Environment

-        Promoting small scale development but not major developments;

-        Protection of landscapes and designations

-        Protection of seascapes and the coastal strip

-        Dark Sky protection

Sense of Place

-        Design

-        Particular policies for village locations

-        Shop fronts and advertisements

Historic Environment

-        Promotion of conservation areas and protection of heritage assets and landscapes

Housing

-        Development

-        Local needs housing

-        Mix and Type

-        Change of Use

-        Standards

-        Extensions and annexes

Local economy

-        Promotion of start up business development

-        Change of Use

-        Broadband and mobile infrastructure

Facilities

-        CIS levy spending

-        Assets of community value

-        Visitor facilities

-        Footpaths

-        Caravan sites

-        Small scale tourism accommodation

Local Green Spaces

-        Protection for identified local green spaces

 

We are currently working on identifying local green spaces for designation. There are national guidelines for what is suitable; they have to be within the village boundary, of special significance and local in scale. Current first ideas are below; we’d be happy to hear any views.

Bamburgh:

The Grove; The Triangle; Castle Green; Pepper Close fields; Glebe field; Duckett field; Pinfold.

Beadnell:

Bull Ring; Benthall; Land at the Haven/Church Cottages; Old School playground; Open Space at boarting area; Spaces between Longstone Park, Longstone Close, and St Ebba’s Way and Longbeach Drive and Beadnell Point; White Rock and the Haven coastal strip; Dell Point.

Seahouses and North Sunderland:

Playing fields at Broad Rd and the Fire Station; Cliff top promenade; Stone Close open spaces; Open space at St Aidan’s; Quarry Fields corridor.