Finally, after six years in preparation, Formby and Little Altcar Parish Councils have submitted the Formby Neighbourhood Plan to Sefton Council.
Six years is a very long time but presumably, the plan is the very best the two Parish Councils can produce?
So it's disappointing to note that the Sefton Council reception seems to raise some doubts. I've highlighted them in bold.
The Sefton document starts by setting out the Parish Councils' purposes. Almost immediately they add some notes of concern. You can read them in the following extract.
3.1 The Formby Neighbourhood Plan sets out a shared vision for Formby and Little Altcar Parishes. The whole of both Parishes were designated as a neighbourhood area’ for the purposes of preparing a neighbourhood plan and approved by Cabinet Member on 12th September 2013. The plan contains policies on the following areas
Working and shopping
Community, leisure and wellbeing
Environment, sustainability and design
3.2 Consultation on the draft plan (known as Regulation 14 Consultation) was undertaken by the Parish Council between 31st October 2016 and 12th December 2016. The Parish Council took account of comments received during this period in the submitted plan.
3.3 There are some concerns about some of the submitted documents and whether they fulfil some of the basic conditions.
The Neighbourhood Plan needs have regard to the National Planning Policy Framework and the Local Plan. The Neighbourhood Plan and the Basic Conditions Statement repeatedly refer to the 2012 NPPF that has since been superseded.
The Neighbourhood Plan includes some policies that are contrary to strategic policies in the Local Plan, this includes a radical change to the affordable housing policy.
The consultation framework is required to show people’s comments from the reg.14 consultation, what they said and how they have been considered. Whilst all comments are either summarised or included verbatim, it has not been shown how resident’s comments or the comments of other bodies have been considered, the statement simply says what they said.
3.4 The Neighbourhood Plan steering group did not accept the offer of advice from Sefton Council before submitting the plan.
3.5 It is up to the Examiner to decide whether the policies and content of the plan meet the basic conditions. The Council will make comments at the reg.16 stage.
(Source: Sefton Council: Report from Chief Officer Planning to Cabinet Officer Building and Planning Control for decision)
In my view, the most significant comment is item 3.4. It raises a number of questions.
- Did both Parish Councils agree to 'disagree' with the Sefton Council advice?
- Why did the Parish Councils reject the advice from the highly experienced Council officers?
- Is there a conflict of views on some or all of the issues involved between Sefton Council and the two Parishes?
- What are those?
- Is this difference of views related to legal interpretations over the relative powers of Parish Councils and District Councils?
- Has it to do with the Green Belt redesignation and the new housing developments, which have received official inspectors approval, thus confirming the status of the Local Plan?
Then there's the matter of the 2012 NPPF policy (National Planning Policy Framework)? Why have the Parish Councils not acted, after all, there's a seven-year gap between that change and now?
It is a remarkable passage of time, why have the Parish Councils not make the necessary adaptations?
Finally, on the question of the representation and response to the public views generated during the consultations is likely to compromise the whole plan. It is supposed to be a shared, collective and agreed public policy - not simply the Parish Councils policy.
Sefton Council closes in 3.5, with two observations:
- A comment about the function of the Official Inspector, It's difficult not to draw the conclusion that the plan could be failed at this stage.
- Sefton Council has also highlighted they will make comments at the 'Reg 16' stage of the process, could there more potential issues for the viability of the Plan?
If you want to read more about the Neighbourhood Plan process I advise you to visit the Formby Parish Council website. There's a dedicated section with access to the various reports but following the plan through the Formby Parish Council minutes of meetings is more difficult. At one stage I noticed a reference to the near completion of the plan sometime in 2017, apparently, it just required some relatively small updates.
It seems to have taken over two years to make those additions and of course, the late submission date means that the current membership of both Councils is due for re-election, retirement or replacement, in the May elections.
It begs the questions, why so long, what of the notion of electoral accountability, what has it all cost, what happens it the whole plan fails, who will be to blame?
To read the full report on the Sefton Council website follow the link: http://modgov.sefton.gov.uk/moderngov/mgIssueHistoryHome.aspx?IId=56436&Opt=0