Local Development Plan 2030 Updated Response from Statutory Consultees - March 2021 by Mid and East Antrim Borough Council

Local Development Plan 2030

Updated Response from Statutory Consultees March 2021 www.midandeastantrim.gov.uk/planning

DPS-310

Contents 3

1.0 Introduction

Appendix 1 Updated Response from Department for Economy, Minerals and Petroleum Policy Appendix 2 Updated Response from NIHE

1.0

Introduction

1.1

The draft Plan Strategy was published for formal public consultation for a period of eight weeks from 16 October to 11 December 2019. The representations submitted in response to the public consultation on the draft Plan Strategy were considered and Council continued to work with several Statutory Consultees to consider the issues raised.

1.2

This document sets out the updated position of the Department for Economy and Northern Ireland Housing Executive and is in addition to their comments to the Schedule of Proposed Modifications to the Draft Plan Strategy.

Appendix 1

Minerals and Petroleum Branch Room 9, Dundonald House Upper Newtownards Road Belfast, BT4 3SB Tel: 028 9038 8446 (ext: 82646) TextRelay: 18001 028 9038 8446 Web: www.economy-ni.gov.uk 8th January 2021 Briege, COMMENTS ON PROPOSED MODIFICATIONS TO DRAFT PLAN STRATEGY Following our meeting of 10th December in which we discussed the Department’s response to proposed amended wording of the Draft Plan Strategy in relation to mineral development, the Department has considered the three key matters that were addressed and would comment as follows: Special Countryside Areas (SCAs) The Department maintains the position that any proposal to restrict the development of high value minerals which fall under the licensing regime of the Mineral Development Act (Northern Ireland) 1969 is contrary to the wording of the Strategic Planning Policy for Northern Ireland. However, following our meeting I asked the Geological Survey NI to review the proposed location of Special Countryside Areas and how they might affect future high value mineral development. The Department is satisfied that, based on available geological information, the proposed SCA locations are unlikely to have a significant impact. Therefore, having considered the extent of the SCAs and any impact on known prospective areas, the Department can accept the Council approach as reasonable – particularly as the SCA policy does allow for consideration of mineral development where it is of regional or economic significance. Reference to Cautious approach Following your clarification at our meeting on 10 December, the Department understands that the use of the ‘cautious approach’ wording when considering minerals development within areas designated as AONB, will not preclude development but simply reflects the fact that Council will ‘carefully consider’ any applications for development within Council AONBs in line with 6.155 of the SPPS. Definition of Valuable Minerals You are aware of our recommendation that the definition of valuable minerals should be amended to include industrial minerals as well as metalliferous minerals. As they stand your mineral policies do not cover industrial minerals other than salt. I note you are unable to take this amendment forward at this time and have suggested it be addressed through the IE process. I hope these comments are useful and happy to discuss as always. LF

LORRAINE FLEMING Minerals and Petroleum Policy 4

Appendix 2

Policy Area

Social Clauses

Prematurity

Developer Contributions

Detail of Issue Raised

Council's Consideration of Issue

NIHE Consideration

Would like a policy that encourages the use of social clauses, for major development to deliver positive social benefits. These clauses can secure employment opportunities, and training and skills development for local unemployed to underemployed residents. The use of social clauses is often practiced in GB to provide employment or training opportunities for young people or the long-term unemployed. We note that the Department of Finance, in conjunction with the Construction Industry Forum for NI, has drawn up guidance and model contracts on sustainable construction. The aim of which is “to promote social inclusion and equal opportunities, including the progression of people who are long term unemployed and those leaving education and training, as a key way of delivering social elements of sustainable development”. Would like more information on how prematurity will be applied. Believe that Joint Ministerial Statement remains a material consideration in the determination of planning applications.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider any such agreements considered appropriate can be delivered through the existing draft Plan Policies. In addition, a developer’s contribution framework will be considered by Council at some stage in the future.

We accept the Council response and do not believe a change to dPS is required.

Council would refer to paragraph 5.73 of the Strategic Planning Policy Statement (SPPS) which provides a full explanation of the concept of ‘Prematurity’. In addition, Council wold refer to pages 22 and 23 of the draft Plan Strategy which sets out how the Plan Strategy will be used.

We believe the draft PS is an important material consideration, in the determination of decisions, prior to adoption.

Strongly support developer contributions. Would also like to see to help provide affordable housing to aid in matching unmet housing need and achieving balanced communities through mixed tenure housing. Should also help to provide infrastructure allowing release of further land for development.

Where necessary, Council have the mechanism to deliver affordable housing and contribute to infrastructure through the existing draft Plan Strategy policies.

However we do not believe a change to dPS is required. The NIHE has supported the use of a developer contribution, where the developer contributes to the cost of the works. However we accept that a contribution is not required at this stage and would take

additional research etc. We believe that this could be further considered at a later date.

Appendices

Regional Policy Context

Local Policy Context

Vision

Strategic Objective

We do not believe a change to the dPS is required. We accept the Council response and do not believe a change to dPS is required.

Generally supportive of appendices especially Appendix D. Would like to see appendices explicitly set out as supplementary guidance and given weight in determination of planning applications.

Draft Policy HOU 1 explicitly states that Appendix D will be taken into account when assessing proposals for new residential development in settlements.

Support setting the context pages 26-31. Housing policies within the LDP should aim to ensure that new residential developments provide adequate homes for all in Mid and East Antrim area. Support setting the context pages 26-31. Mixed tenure development and adequate supply of affordable/accessible housing will help reach objectives of our Community Plan. Welcome that the LDP vision is primarily based on the vision of Council's community plan as this will encourage synergy between the two plans whilst also support vision has been tailored to include an emphasis on place making. Support strategic objectives. Particular importance to NIHE are economic objective g), social objectives c) and d) and environmental objective i)

Support for this chapter of the draft Plan Strategy is welcomed. The housing polices in the draft Plan Strategy do aim to provide adequate homes for all through a mix of policies set out in Chapter 8.0. Support for this chapter of the draft Plan Strategy is welcomed.

N/A

Support for our Vision is welcomed.

N/A

Support for these strategic objectives is welcomed.

N/A

Support Support the Growth Strategy as it is closely linked to the RDS SFG and believe it will help promote sustainable development.

Support for the proposed policy approach is welcomed.

N/A

Support for the proposed policy approach is welcomed.

N/A

The merits of a greater housing allocation to Portglenone is considered under the rebuttals to SGS3.

We accept the approach in the rebuttals.

Support for the proposed policy approach is welcomed.

N/A

Spatial Growth Support the statement that housing zonings will ensure Strategy land availability over the plan period.

Settlement Hierarchy

Strategic Allocation of Housing to Settlements

Welcome directing growth to urban fabric and brownfield land within the main towns and appropriately scaled residential development within villages and small settlements. Support Support the settlement hierarchy. Miscellaneous - Portglenone should be treated as an exceptional case as village that could support growth beyond other villages Argue that Portglenone, given its level of services and facilities, could be treated as an exceptional case as a village which could support further growth beyond other villages. Allocation of housing to settlements is logical and takes account of the RDS Housing Evaluation Framework and the plan, monitor and manage approach can help ensure there is sufficient housing land, including for affordable housing over the plan period.

Would like flexibility in allocation figures over the plan period especially in settlements where there is an existing or arising affordable housing need.

Strategic Allocation of Housing to Settlements

In relation to comments on SGS2 Settlement Hierarchy, regarding Portglenone it is considered this settlement should be treated as an exceptional case with further growth than other villages.

Support Protection of Support the policy, which will protect housing land, in Zoned Housing order to meet housing need over the Plan period and to Land ensure there is adequate housing land to meet need.

Currently there would appear to be ample potential from whiteland within settlement limits in the villages. For example, the potential in Carnlough is 328 and social rented need is 34, Portglenone has potential of 235 and social rented need of 20 and Glynn has a potential of 154 and social rented need of 8. Many of the other villages do not have a social rented need at present but all save from Ballygalley and Martinstown have quite a lot of potential still within the limits. SGS5 allows for flexibility in the small towns in relation to affordable housing as it states that 'where urban capacity sites or windfall potential would not meet the affordable housing need identified by NIHE, additional land may be zoned where it is sustainable to do so and it is not reasonable for the need to be met in a nearby settlement'. Council is content that there is flexibility built into the dPS through the identification of a land supply that exceeds the notional housing allocation and through the required review process to ensure it is fit for purpose. The status of Portglenone has previously been discussed and on the advice of DfI the decision was taken to retain it as a village. It is recognised that Portglenone has facilities over and above that of other villages however, it does not have the population to justify changing the methodology in order to award it a higher allocation. It should be noted however that there is capacity within the settlement limits for further housing development. Support for the proposed policy approach is welcomed.

We accept the Council response and the flexibility the dPS permits and do not believe a change to dPS is required.

We accept the Council response and do not believe a change to dPS is required.

N/A

Protection of current housing sites, prior to LPP adoption, that do not meet the sequential test undesirable -sustainable development should be a material consideration in their assessment It is understood that this policy will be enacted once the Plan Strategy is adopted and that extant housing Protection of zonings will be protected. However, it is considered Zoned Housing that the protection of any current housing sites, prior to Land LPP adoption, which do not meet the sequential test or undermine the achievement of sustainable development, may be undesirable. In these instances, we would like to see sustainable development included as a material consideration in the assessment of planning applications. The Housing Executive supports the Strategic Allocation of Land for Economic Development, which focuses economic zonings in the three main hubs. We believe that these towns will be accessible to the majority of Strategic residents in Mid and East Antrim, and are well served Allocation of by public transport. We welcome opportunities for Land for business growth within the settlement limits and would Economic like to see a sequential approach to the allocation of Development employment land where land outside development limits is only considered where there are no suitable sites available in towns and villages, and is of an appropriate scale. NIHE strongly supports the Transport Objectives. We believe these will promote the integration of transport and patterns of development, which reduce the need to travel, promote connectivity and modes of active travel, Transport as well as being more sustainable through a reduction Strategy in the use of private cars and travel times. We note that the plan objective to reduce travel demand through integration of land-use planning and transport aligns with a key objective of the draft PfG delivery plans.

The intent of the policy is not to protect existing zonings. We accept the Council response The Justification and Amplification states that sites will be and do not believe a change to selected for zoning, and where applicable phasing in the dPS is required. Local Policies Plan and it is these sites that will be protected.

Support for the proposed approach is welcomed.

N/A

Support for the proposed transport objectives is welcomed

N/A

Due to different car ownership levels for social housing, than other tenures of development (55% of social housing tenants do not have access to a car, NIHE 2018) we strongly support the promotion of public transport and active travel networks to provide accessibility and connectivity for all. Open Space Strategy

Open Space Strategy

Special Countryside Areas

Support Support the intention to provide a strategic policy framework for the provision of green and blue infrastructure. Miscellaneous - Promote Strategies and Masterplans Highlight the opportunity for Mid and East Antrim to develop further comprehensive open space strategies as Belfast have proposed. Believe that master planning would provide a strategic approach to the creation of new open space that forms part of a network. Believe that strategic development sites and in areas which are in 'an accessibility hotspot', potential open space areas could be allocated and protected in the LPP to ensure a cohesive approach in the delivery of new spaces, which are not subject to a reactive and possible piecemeal approach. Page 40 of Rep - Special Countryside Area (CS2) NIHE supports this policy to protect sensitive landscapes from excessive and inappropriate development. NIHE would like to see affordable housing need met within settlement limits in these locations, as a rural exceptions policy may not be suitable within Special Countryside Areas. Currently, there is a social housing need in Carnlough, so NIHE would like to see if there is an opportunity to uplift the proportion for affordable housing in this location, due to local circumstances, at Local Policies Plan stage.

Support for the proposed policy approaches is welcomed.

N/A

The open space network will be examined further through the Local Policies Plan process. This will include identifying Community greenways which will link existing and proposed open spaces and connect into the wider regional greenway network. In assessing this account will be taken of other Council Strategies such as the Cycling Routes Masterplan.

We welcome this clarification and do not believe a change to dPS is required.

Council welcomes the comment.

N/A

Rural Landscape Wedges

Antrim Coast and Glens AONB

Developed Coast

Local Landscape Policy Areas

Protection of Main River Corridors

Page 40 of Rep - Rural Landscape Wedges (CS4) NIHE support the designation of Rural Landscape Wedges, which they state can help promote compact urban forms where amenities and services are closer to the communities they serve. Page 40 of Rep - Antrim Coast and Glens AONB (CS5) NIHE support this policy, which seeks to protect, conserve, and where possible enhance the scenic quality and distinctive character of the Antrim Coast and Glens AONB from inappropriate development. They state that this will help conserve the natural beauty and landscape of the area, thereby contributing to the wellbeing of local people and visitors. Page 40-41 of Rep - Developed Coast (CS6) NIHE welcomes this policy which they state will help protect the coast from unacceptable development but would allow flood defences and development to provide public access and environmental benefit. They state that this will assist the regeneration of coastal areas and will encourage recreation leading to active lifestyles, promoting health and well-being of communities. Page 41 of Rep - Local Landscape Policy Areas (CS7) NIHE support the designation of LLPAs which protect environmental assets. They state that this helps enhance a sense of place and promotes quality development. Page 41 of Rep - Protection of Main River Corridors (CS8) NIHE supports the protection of river corridors to maintain or enhance biodiversity, water quality and to restrict development that could result in increased flooding.

Council welcomes the comment.

N/A

Council welcomes the comment.

N/A

Council welcomes the comment.

N/A

Council welcomes the comment.

N/A

Council welcomes the comment.

N/A

Development at Risk from Land Instability or Coastal Erosion

General

General Policy for all Development

Page 41 of Rep - Land Instability and Coastal Erosion (CS9) NIHE welcomes this policy to ensure safe development that minimises the risk to health and safety.

Council welcomes the comment.

N/A

Page 9 of Rep (page 7 of Housing Executive Response to MEA LDP Strategy) - Countryside Strategy NIHE support the policy aims of the Countryside Strategy. However, NIHE would like to see the policy aims expanded to allow development that also contributes to a sustainable rural community, not solely the rural economy. This would better promote sustainable development, where equal weight should be given to social, economic and environmental factors.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, Council suggest amending the wording of the first aim in paragraph 5.9.6 of the Countryside Strategy to read: To facilitate development which contributes to a sustainable rural economy and community in Mid and East Antrim.

We welcome the suggested amendment.

N/A Welcomes the policy.

Support for the policy is welcomed.

Would like to see proposals assessed with reference to the positive and negative effects they will have on economic, environmental and social factors.

Economic, environmental and social factors are the 3 pillars of sustainable development. The opening paragraph within the policy box of Policy GP1 states that, 'Planning permission will be granted for sustainable development where the proposal accords with the LDP and there is no demonstrable harm to interests of acknowledged importance.' Therefore, Council consider the draft Plan Strategy to be sound and does not need changed as this issue is addressed by Policy GP1. Council considers criteria e) point v and paragraph 6.1.15 adequately address climate change and resilience of development through the LDP.

General Policy for all Development

Welcome criteria e) v. to take account of the efficient use of energy, water and other resources but would like more detail added to this policy or a new policy dedicated to climate change and resilience developed.

We accept the Council response and do not believe a change to dPS is required.

We believe Planning does have a key role in the reducing greenhouse gas emissions and in the mitigation and adaption to climate change as set out in the SPPS. However we acknowledge criteria e) point v and the statements in paragraph 6.1.15 and we do not

believe a change to dPS is required. Would like to see developers expected to demonstrate that measures to reduce energy consumption and sustainable design solutions have been considered and incorporated in their proposals.

The points raised go beyond the remit of the LDP and are more appropriately controlled by building regulations.

General Policy for all Development

N/A

Would like to see restriction for development that may present a potential risk to health, protecting public from exposures to harm, and that any adverse effects are mitigated. Would like to see inclusion of Health Impact Assessments for major development - NIHE recognise importance of considering health as part of the planning process and HIAs are often required for applications in GB and can help meet SPPS and Community Planning objective to improve health and wellbeing. The Housing Executive is supportive of the dPS’s economic policies. However, would like to see a policy that encourages the use of social clauses, for major development to deliver positive social benefits. These clauses can secure employment opportunities, and training and skills development for local unemployed to underemployed residents. The use of social clauses is often practiced in GB to provide employment or training opportunities for young people or the longterm unemployed. We note that the DoF, in conjunction with the Construction Industry Forum for

To address these potential risks, Council consider that policies already exist in the draft Plan Strategy to address these potential risks, for example Policies GP1 d)i, TOC1, RE1, WMT1, WMT4 etc. Council consider that the point raised does not affect the soundness of the plan and is not required by legislation or the SPPS.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider any such agreements considered appropriate can be delivered through the existing draft Plan Policies. In addition, a developers contribution framework will be considered by Council at some stage in the future.

We believe that a statement from applicants would assist case officers (and stakeholders/the public) to assess whether criteria e) point v has been met. We do not believe the policy is unsound but believe the suggested change could add further clarity. We accept the Council response and do not believe a change to dPS is required. We accept the Council response and do not believe a change to dPS is required.

We accept the Council response and do not believe a change to dPS is required. We welcome the statement that developers’ contribution framework will be considered by the council in the future, and we would value an opportunity to assist the Council in developing this work.

NI, has drawn up guidance and model contracts on sustainable construction. The aim of which is “to promote social inclusion and equal opportunities, including the progression of people who are long term unemployed and those leaving education and training, as a key way of delivering social elements of sustainable development”.

Economic Development in Settlements

Retention of Economic Development Land

NIHE welcomes the policy focus on enterprise and employment growth within the main towns across the Borough. Welcome the sequential approach used to identify employment land, which directs employment to the Hubs and local towns first. Support barrier-free employment locations within the urban footprint, near to residential areas or close to centres, which are accessible by means other than the private car. Would like to see a statement which explicitly states that economic development sites that are accessible by public transport will be included in a sequential test. We note that reducing travel demand through integration of land-use planning and transport is a key objective of the draft PfG delivery plans. We believe that the designation of a plentiful supply of employment land can support business development and job growth, leading to sustainable communities. The Housing Executive supports the presumption against the alternative use of land zoned for economic development, which aligns with the RDS principle to maintain an adequate supply of employment land throughout the Plan period. We would also like to see the Policy state that if employment land is to be released for alternative uses; it would need to be ensured that an adequate supply of employment land is retained to meet the needs of the Borough.

Support for the proposed policy approach is welcomed. Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council considers that the wording of the policy (i.e. Town centre, edge of centre or locations specific in the LDP) addresses NIHE's point in relation to employment locations being accessible by public transport as these locations in policy will largely be the most accessible.

We accept the Council response and do not believe a change to dPS is required.

Support for the proposed policy approach is welcomed. Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council considers policy criterion c) adequately addresses this concern.

We accept the Council response and do not believe a change to dPS is required.

Development incompatible with Economic Development Uses Economic Development in the Countryside New & Extended Holiday Parks in the Countryside Quality in New Residential Development in Settlements

Quality in New Residential Development in Settlements

We welcome this policy which by not permitting adjacent incompatible uses to economic development can protect residential amenity. This will ensure that local residents are not adversely affected by any industrial emissions, noise or heavy traffic.

Support for the proposed policy approach is welcomed.

N/A

In respect of economic development in the countryside, we support the sequential approach for the location of economic development sites with land within settlements being considered first before open countryside sites are investigated. This will help protect rural character. Amend J&A - Model Licence Conditions Suggest that Policy TOU7 should direct applicants to the new 'Model Licence Conditions 2019' for caravan sites, published by DfI.

Support for the proposed policy approach is welcomed.

N/A

It is considered that Appendix C adequately covers the broader planning considerations in terms of holiday parks and as the Model Licence Conditions are out with planning regulations it is not necessary to include reference to them under this policy. Support for the proposed policy approach is welcomed.

We accept the Council response and do not believe a change to dPS is required.

Amend policy- Size standards in Appendix F should apply to all new housing Welcome the proposal that all new dwellings in established residential areas should be built to a size standard, set out in Appendix F, but believe these standards should be adopted for all new housing. These standards accord to social housing space standards, which ensure that homes are large enough to meet the needs of occupiers.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as the size or the reduced size of dwellings has only been identified as an issue, largely, in established residential areas, it has not presented as an issue elsewhere in the Borough. Applying the standards in established residential area will help to ensure the character of such areas are safeguarded.

We accept the Council response and do not believe a change to dPS is required.

Support the proposal that all residential units should be accompanied by a concept statement Support the proposal that all residential units should be accompanied by a concept statement.

Support for the proposed policy approach is welcomed.

N/A

Support this policy, which will aid good design and place making Support this policy, which will aid good design and place making.

N/A

Quality in New Residential Development in Settlements

Residential Extensions and Alterations

Amend policy/J&A- Support open space in new developments, prefer variety of formats and native species planting Support the requirement for adequate open space provision in new residential developments, which is particularly important for new family dwellings. Would welcome a statement stating that open space should be in a variety of formats dependent on the type of residential units proposed. NIHE would like to see planting of native species in housing developments encouraged, including the promotion of tree-lined streets.

Council note the issues and consider the draft Plan Strategy to be sound and does not need changed. Policy OSL4 elaborates on open space requirements and indicates that it can be in a variety of different forms. The use of native species in landscaping schemes is referred to in 'Creating Places' and Policy HOU1 signposts to 'Creating Places' in the policy box.

We accept the Council response and do not believe a change to dPS is required.

Amend policy- Opportunity for the policy to promote energy efficient homes Believe there is an opportunity for the policy to promote and encourage energy efficient homes and buildings that can easily incorporate renewable energy technology e.g. renewable heating sources.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Policy GP1 (e)(v) already states that the development should take account of efficient use of energy, water and other resources where feasible and practicable, integrating micro-generation and passive solar design and it is considered that extending this further would diverge into Building Control Regulations, beyond the remit of the LDP. Appendix D is referred to in the policy box and includes guidance on Sustainable Design (page 330).

We accept the Council response and do not believe a change to dPS is required.

Support for the proposed policy is welcomed.

N/A

It is considered that a future proofed home looking holistically to meet the changed climate, and demographic and social needs, will improve health and wellbeing ,address housing inequality and fuel poverty, as well as helping to mitigate the environmental impacts of housing. Support this policy which can enhance the flexibility, resilience and endurance of a dwelling Support this policy which can enhance the flexibility, resilience and endurance of a dwelling, allowing it to adapt to different users and their needs.

Protected Town Centre Housing Area

Support strongly the policy The policy is supported. Strong support for increasing the supply of affordable homes through protecting town centre living areas, by including Key Site Requirements (KSRs) for affordable housing within development opportunity sites and vacant sites, and by promoting “Living Over the Shops” (LOTS). Town centre living and LOTS can stimulate additional activity and footfall, thereby assisting regeneration. This will help promote accessible retail and services, an important element of sustainable communities.

Support for the proposed policy is welcomed.

N/A

Council note the issues and consider the draft Plan Strategy to be sound and does not need changed. 1. Residential development schemes for town centre living will be assessed under policies such as GP1, HOU1 and HOU2 which require criterion to be met to ensure adequate access and provision of amenity space for refuse and fuel storage.

We accept the Council response and do not believe a change to dPS is required.

In particular, the reference to housing as an acceptable use in town centres as this can help promote the vitality and viability of centres is welcomed.

Protected Town Centre Housing Area

Miscellaneous- Support accessible town centre living, with space for refuse and fuel and flexible parking standards Would like to see: 1. Planning permission granted for town centre living accommodation where there is adequate access, and facilities for essential services such as refuse and fuel storage. 2. Flexibility in car parking standards for town centre housing schemes.

2. Policy TR6 allows for flexibility in car parking requirements i.e. in highly accessible locations such as town centres.

Support policy, thresholds and paragraph 8.1.39 Strongly support this policy which meets the aims of the RDS, SPPS and the LDP and will help meet affordable housing need throughout the Borough, and it will help to provide a mix of tenures, to meet need and create cohesive, balanced and sustainable communities.

Support for the proposed policy approach is welcomed.

Support the thresholds which is believed will address affordable housing need, and that the 10 unit threshold is appropriate to maximise the number of sites to which the policy can be applied.

Affordable Housing in Settlements

State that the Justification and Amplification has a role in the identification of need and that the applicant should liaise closely with a Housing Association to discuss the affordable housing requirement. Support paragraph 8.1.39 which states in some instances there may be a potential for a higher proportion of affordable housing and that the proportion can be adjusted in the LPP. Support the delivery of affordable housing being secured by a Section 76 planning agreement.

N/A

Affordable Housing in Settlements

Amend J&A- Expand definition of affordable housing Request the definition of affordable housing should include the following criteria: 1. the affordable housing is delivered by a registered housing association: 2. the affordable housing is allocated by a housing association to eligible households who cannot access market housing; and 3. the affordable housing units remain at an affordable price for future eligible households or if these restrictions are lifted, the subsidy shall be recycled for alternative affordable housing provision. Amend J&A- Development to be tenure blind and social housing delivered to DfC's Housing Association Guide Standards Would welcome the inclusion of the following statement: The development should be tenure blind and integrated with market housing. This will ensure that there is a genuine housing mix, promoting more cohesive communities.

Council do not consider it necessary to include the three criteria suggested by NIHE as the definition of 'social rented housing' within the glossary of the draft Plan Strategy addresses the first two proposed criteria. In terms of the third proposed criteria, the LDP has no control over the price of affordable housing.

DFC are due to publish a new definition of affordable housing. Once published, the PS could refer to the updated definition.

It is acknowledged that there are advantages and disadvantages to including the reference to pepperpotting but by not specifically referring to it allows flexibility.

We believe that pepper potting or clusters of development can be considered on a case by case basis. However, it may be difficult to achieve pepper potting if there is not a strong statement of intent within the policy. It may be difficult to achieve a mix of tenures, if the social housing is developed at one location. We do not believe the policy is unsound but believe the suggested change could add further clarity.

Affordable Housing in Settlements

Amend J&A- Development to be tenure blind and social housing delivered to DfC's Housing Association Guide Standards Would welcome the inclusion of the following statement: The social housing is delivered to DfC's Housing Association Guide Standards.

Council note the issue and consider the draft Plan Strategy to be sound. In light of the comment made, for clarity, Council suggest the following minor change to the wording in the second sentence of paragraph 8.1.38 to read: 'Prior to submitting a planning application, an applicant/developer is therefore advised to liaise closely with a registered Housing Association and the NIHE to 20

NIHE can only provide grant for social housing, where it meet DFC HAG standards. So while we/HA can advise the applicant, we would support a sentence within policy / J&A and any additional guidance to ensure the housing can be delivered as

discuss the exact mix and standard of affordable housing required in each case'.

Housing Mix (Unit Types and Sizes)

Adaptable and Accessible Homes

social housing, and to notify developers who do not seek additional advice. We believe this would add clarity and aid implementation.

Support strongly the policy Strongly supports this policy, which will meet housing needs in the Borough and will promote mixed tenure development to help ensure balanced communities. Well-designed neighbourhoods provide variety and choice of homes to suit all needs and ages, this includes people who require affordable housing, families, older people, students and people with physical difficulties or mental health needs. Support Strongly support the policy criteria to help ensure new homes are adaptable.

Support for this proposed policy is welcomed.

We do not believe the policy is unsound but believe the suggested change could add further clarity. N/A

Support for the policy criteria is welcomed.

N/A

Require proportion of wheelchair standard dwellings Would like to see a requirement for a proportion of wheelchair standard dwellings to be delivered as these units can better meet the needs of wheelchair users. Currently, demand from people with a disability who wish to own their own homes cannot readily be met, as there is no requirement for market housing to provide wheelchair accessible homes. A proportion of social housing schemes are now required to provide wheelchair standard units, with a target of 10% to be developed by 2020/2021, therefore, we believe it is reasonable that a similar proportion is required of the private sector to help meet the needs of wheelchair users who wish to own their own homes.

Council has taken into account the specific needs of disadvantaged and marginalised groups and as such has included Policy HOU7 as the best and most practical way to meet these needs as is possible through its remit. The issue in relation to the LDP requiring wheelchair standard houses as part of residential developments has already been explored. A policy for wheelchair accessible homes was put forward at POP stage and ultimately discounted following discussion with Building Control as given the technical nature it was not practicable to bring such a policy forward (see Housing Technical Supplement).

We strongly support the need for adaptable and wheelchair housing policy, as building standards remain unchanged. We welcomed Belfast City Councils approach where criteria were established as according to what planners could easily assess.

The draft PfG’s Delivery Plan (October 2016) states that there is an under-supply of appropriate housing for particular groups, including housing for older people. It also states that there should be more accessible homes for wheelchair users within the private rented and owner occupied sectors. We note there is a statutory link between LDPs and Community Plans, therefore, we would like to see the LDP help achieve Mid and East Antrim Community Plan’s “Putting People First” priorities. Housing is considered inadequate if the specific needs of disadvantaged and marginalized groups are not taken into account. Section 75 of the Northern Ireland Act 1998 requires public authorities, in carrying out their functions, to have due regard to the need to promote equality of opportunity between nine equality categories, including persons with a disability. Soundness Tests C1: The RDS under RG8 states that the varied housing needs of the whole community need to be met. It also states development plans should ensure an adequate and available supply of quality housing to meet the needs of everyone. C2: The Community Plan states that, infrastructure projects being considered include housing developments and supported living to support the needs of older people and those with disabilities, to support independent living for vulnerable people, and for an aging society. We believe the Plan Strategy can have an important role to help deliver this Community Plan action. C3: The SPPS states that sites should be zoned in larger settlements for housing and Housing Policy Areas in 22

Travellers Accommodati on

Affordable Housing in the Countryside

smaller settlements should meet the full range of identified need. C4:The draft PfG’s Delivery Plan, indicators state that there is an under-supply of appropriate housing for older people. To address this, it states actions should be established, to improve independent living and the provision of suitable homes, including more accessible homes for wheelchair users within the private rented and owner occupied sectors. Support This policy to ensure that travellers' needs are adequately catered for within the LDP is welcomed. Notes the HNA carried out by NIHE only considers the housing needs of Irish Travellers. Amend J&A It is suggested that the policy could refer to: The new Model Licence Conditions 2019 for Caravan Sites (DfI) and draft Design Guide for Travellers' Sites 2019 (DfC). Adherence to relevant guidance will assist in the delivery of high quality designed sites, improving living standards for travellers, thereby improving health and wellbeing. Support The policy is welcomed and it is considered that it will provide flexibility should the need arise during the plan period.

Support for the proposed policy approach is welcomed and comments noted

N/A

As the guidance documents suggested are outwith the remit of planning it is not considered necessary to refer to them in this policy.

We accept the Council response and do not believe a change to dPS is required.

Support for the policy is welcomed.

N/A

Amend Policy and J&A 1. Support that proposals submitted under this policy should be submitted by a Housing Association, but request that the policy and J&A are amended to also include NIHE. 2. Request that the wording of the policy/Justification and Amplification are amended to state that the onus is on the developer to demonstrate that there are no alternative available sites within settlement limits.

Affordable Housing in the Countryside

Miscellaneous- Joint protocol Request the retention of the joint protocol with DoE in regards to the approach to be taken when applying for planning permission for affordable housing in the countryside.

The wording in the second sentence in the policy box could be construed as ambiguous as it puts the onus on NIHE to confirm the provider cannot meet the need in an existing settlement. As NIHE have now confirmed they may submit an application for affordable housing in the countryside it is considered reasonable to amend the text in this regard as they are the strategic Housing Authority for NI. To ensure clarity for the reader it is suggested that the policy text (second sentence paragraph one) should be amended to read: Planning permission may be granted for a group of no more than 14 dwellings adjacent to a village or no more than 8 dwellings adjacent to a small settlement to meet an identified affordable housing need of a rural community. Planning permission will only be granted where the application is made by a registered housing association or the Northern Ireland Housing Executive (NIHE) and where a demonstrable need has been identified by NIHE which cannot readily the Northern Ireland Housing Executive (NIHE) confirm that the need cannot be met within an existing settlement in the locality. For consistency it is also suggested that paragraph 8.1.76 should be amended to read: Applications for affordable housing groups will be restricted to registered housing associations and NIHE. Such proposals will need to be accompanied by information demonstrating that the potential to locate the necessary housing within settlement limits has been explored, and that no suitable sites are available. Discussion on any protocol between Council and NIHE, for the operation of Policy HOU16, will take place outside the LDP process.

We welcome the suggested amendments.

We accept the Council response and do not believe a change to dPS is required.

As supported housing need is not projected on a longterm basis, it is recommend that a development management policy in respect of supported housing is included within the LDP. The policy should acknowledge that supported housing schemes should be prioritised and flexibility should be applied in the application of residential design standards due to the specific nature of supported accommodation. Accommodation can take the form of self-contained or shared accommodation. Supported housing need is identified, for a three-year programme, through a commissioning process with partners including the Housing Executive, the Health and Social Care Board, Health Trusts and the Probation Board.

Supported Housing

A Supported Housing Policy would help promote sustainable development. Increased provision of Supported housing can contribute to achieving outcomes of the draft Programme for Government’s Delivery Plan, (October 2016). The Delivery Plan states that there is an under-supply of appropriate housing for particular groups, including housing for older people. In addition, it is noted that there is a statutory link between Draft Plan Strategy and Community Plans, therefore, it would be good to see the LDP help achieve Mid and East Antrim Community Plan’s “Putting People First “priorities. Housing is considered inadequate if the specific needs of disadvantaged and marginalized groups are not taken into account. Section 75 of the Northern Ireland Act 1998 requires public authorities, in carrying out their functions, to have due regard to the need to promote equality of opportunity between nine equality categories, including persons with a disability.

Whilst the draft Plan Strategy does not include a specific policy for the assessment of supported housing applications, Council is of the opinion that there is nothing within the draft Plan Strategy that would prejudice or prevent their development. When this was highlighted to NIHE, they considered that a separate policy may not be necessary to ensure the LDP was sound but suggested the Justification and Amplification of Policy HOU 1 should state that supported housing, as identified by NIHE and other specialist accommodation will be assessed under Policies HOU1 and GP1. This additional directional text is not considered necessary as already paragraph 1.7.8 of the draft Plan Strategy states that all policies considered relevant to the proposed development will be taken into account when determining an application for example this may include relevant policies such as GP1, HOU1 and TR6. Policy TR6 Parking and Servicing allows for the precise amount of car parking to be determined according to the specific characteristics of the proposal.

Soundness Tests C1: RDS under RG8 states that the varied housing needs 25

We accept the Council response and do not believe a change to dPS is required.

Protection of Open Space

of the whole community need to be met. It also states development plans should ensure an adequate and available supply of quality housing to meet the needs of everyone. C2: The Community Plan states that infrastructure projects being considered include housing developments and supported living to support the needs of older people and those with disabilities, to support independent living for vulnerable people, and for an aging society”. Believe the Plan Strategy can have an important role to help deliver this Community Plan action. C3: SPPS states that sites should be zoned in larger settlements for housing and Housing Policy Areas in smaller settlements should meet the full range of identified need. C4: The draft Programme for Government’s Delivery Plan, indicators state that there is an under-supply of appropriate housing for older people. To address this, it states actions should be established, to improve independent living and the provision of suitable homes, including more accessible homes for wheelchair users within the private rented and owner occupied sectors. Support Support the policy but make comments on the exceptions within the policy. Amend J&A - Include affordable housing as a substantial community benefit The following comment is made about the exceptions within the policy: For exception a) would like to see the provision of affordable housing included as an example of a substantial community benefit.

Support for the proposed policy approach is welcomed.

N/A

It is not considered appropriate to single out affordable housing as an exception within the policy as there could be many other examples of proposals that could provide community benefits. Council are of the opinion that the proposed policy as presented is flexible as it does cater for such an exception. Listing some exceptions and not others potentially limits the flexibility of the policy.

We accept the Council response and do not believe a change to dPS is required.

Protection of Open Space

Greenways

Amend J&A - Community should support the development and applications should demonstrate community has been consulted The following comment is made about the exceptions within the policy: Justification and Amplification should state that generally the community should be in support of the development and that applications should demonstrate they have consulted the community, even if the development is not classified as ‘major’ and how community views have been taken into account.

The proposed Justification and Amplification states that proposals have to be supported by the community and this should be demonstrated. As it stands this applies to all applications for loss of open space which fall under exception a) not just applications classified as 'major'.

We accept the Council response and do not believe a change to dPS is required.

Miscellaneous- Retain the Joint Protocol between NIHE and DOE, produced for the operation of the open space exception policy in PPS 8 Retain the joint protocol between NIHE and DOE, produced for the operation of the open space exception policy in PPS 8. Retaining would provide guidance for all stakeholders on the approach to be taken when implementing an exception to this policy.

Discussion on a similar protocol between Council and NIHE, for the operation of Policy OSL1, will take place outside the LDP process.

We accept the Council response and do not believe a change to dPS is required.

Support Support and agree with the policy approach to protect and enhance greenways which will form part of a multifunctional green and blue network. Miscellaneous - Council should work with adjacent councils to facilitate greenways across boundaries Would like to see Mid and East Antrim work with adjacent Councils to ensure that, where opportunities exist, greenway linkages across council boundaries are facilitated to create a network of traffic free routes.

Support for the proposed policy approach is welcomed.

N/A

As the LDP progresses Council will continue to engage and work with our neighbouring council's on the cross boundary issue of greenways.

We accept the Council response and do not believe a change to dPS is required.

Miscellaneous- Would like bike hire stations along greenways. Would like to see bike hire stations along greenways.

Comment noted.

We accept the Council response and do not believe a change to dPS is required.

New Open Space Provision New Open Space Provision, Public Open Space in New Residential Dev New Open Space Provision, Public Open Space in New Residential Dev New Open Space Provision, Public Open Space in New Residential Dev New Open Space Provision, Public Open Space in New Residential Dev

Support Support this policy.

Support for the proposed policy approach is welcomed.

N/A

Support Support the requirement of adequate open space provision, which is particularly important for new family dwellings. Believe the provision of open space and its long terms maintenance and management is important for the creation of sustainable communities.

Support for the proposed policy approach is welcomed.

N/A

Amend J&A - State open space should be in a variety of forms and encourage use of native species Would welcome a statement that open space should be in variety of forms dependent of the type of units proposed. In addition, would like to see the planting of native species in housing developments encouraged, including the promotion of tree lined streets.

The text in the policy already states the amount, location, type and design of open space provision will be negotiated taking account of the specific characteristics of the development, site and context. The Justification and Amplification also states that open space can be provided in variety of different forms. Council are also content that the requirements and guidance within Policy HOU1 and Creating Places are sufficient in this regard. The policy text addresses the point raised as it states that public open space required by this policy should provide safe and easy access for the residents and in addition proposals must meet the General Policy which includes criteria (c) ii - a movement pattern supports active travel and meets the needs of those with disabilities.

We accept the Council response and do not believe a change to dPS is required.

Support for the proposed policy approach is welcomed.

N/A

Amend policy - Include requirement that children's play areas should be easily accessible Would like to see a requirement that children's play areas and facilities are easily accessible to meet the needs of disabled people and that children can access them safely - using pedestrian crossings. These spaces and safe routes to them should be explicitly planned into residential areas and town centres. Support Welcome the potential for developer contributions for new or upgraded play facilities and the production of a guidance note on this matter.

We accept the Council response and do not believe a change to dPS is required.

New Open Space Provision, Public Open Space in New Residential Dev Sport and Outdoor Recreation Facilities Sport and Outdoor Recreation Facilities Community Growing Spaces & Allotments Education Health Community and Cultural Facilities

Education Health Community and Cultural Facilities

New development should conserve wildlife and vegetation and promote further diversity Advise that new development should conserve wildlife and vegetation and promote further diversity.

The Justification and Amplification of this policy along with Policy GP1 a (iv) and e (iv) provide sufficient safeguarding to ensure that development should conserve wildlife and vegetation and promote further diversity.

We accept the Council response and do not believe a change to dPS is required.

Support Support the policy and the submission includes reference to the critical role that play has in the lives of children and young people .

Support for the proposed policy approach is welcomed.

N/A

New development should conserve wildlife and vegetation and promote further diversity Advise that new development should conserve wildlife and vegetation and promote further diversity.

It is considered that the Justification and Amplification of this policy (para 8.2.27) along with Policy GP1 a (iv) and e (iv) provide sufficient safeguarding to ensure that development should conserve wildlife and vegetation and promote further diversity. Support for the proposed policy approach is welcomed.

We accept the Council response and do not believe a change to dPS is required.

Support for the proposed policy approach is welcomed.

N?A

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. If appropriate, Council have the mechanism to contribute to infrastructure through the existing draft Plan Strategy policies.

We accept the Council response and do not believe a change to dPS is required.

Support Strongly support the development of community growing spaces and allotments which can encourage healthy lifestyle and promote community cohesion. Support Support the allocation of land for education, health, community and cultural facilities within COM1 and to protect land for community and cultural facilities and public services. These services and facilities are necessary components of sustainable communities. Miscellaneous - Developer Contributions Would like to see a developer contribution policy, where the uplift in land values generated by the granting of planning permission should help fund additional community infrastructure that is needed to contribute to the development of sustainable communities and their well-being.

N/A

Disused Transport Routes

Active Travel

NIHE agrees with the policy aim to protect disused Support for the proposed policy approach welcomed. transport routes identified in the Plan for re-use for transport purposes, or for alternative appropriate recreational, nature conservation or tourism related uses which will deliver environmental, social or economic benefits. Policies which support active travel can improve health and wellbeing and help mitigate the effects of climate change by promoting a modal shift away from the car. NIHE welcomes the promotion of accessibility and the Support for the proposed policy approach welcomed. encouragement of a modal shift away from car use towards more sustainable and active transport choices, particularly as 76% of the Borough’s residents travel to work by car (2011 Census figures). We note that reducing travel demand through the integration of landuse planning and transport is a key objective of the draft Programme for Government delivery plans and we support the measures outlined in the Transport Strategy (5.7, pages 82 and 83) and policy TR5 to help achieve this. We believe that new developments should be concentrated in locations with good access to public transport, walking and cycling facilities. As well as contributing to the reduction of greenhouse gases and promoting active lifestyles which are key aims in the SPPS, a reduction in car use can lead to communities that are more cohesive. Research shows that as people travel without cars, they interact with neighbours and use local shops and facilities. Developments should be promoted which reduce car dominance in local streets, encourage pedestrian and cycle journeys, and make it safer for children to walk to school and play outside. Designing developments where pedestrians and cyclists are given priority will help support better health outcomes.

N/A

Parking and Servicing

Development within Floodplains

Sustainable Drainage (SuDS)

Renewable Energy Development

In relation to policy TR6, NIHE would like some flexibility in the application of parking standards in affordable housing schemes, due to lower car ownership levels for social housing, than other tenures of development, (55% of social housing tenants do not have access to a car, compared to the Northern Ireland average of 20%). Also mention under HOU 2 they would like to see flexibility on car parking standards in town centre housing schemes. NIHE welcome policies that provide criteria for development on flood plains, flood risk management and flood prevention so that new development does not increase the risk of flooding. We support actions which can increase resilience to climate change and which are important ways to assist flood prevention. NIHE support that the precautionary approach taken in PPS 15 is included within the draft Plan Strategy

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider that flexibility is afforded in the policy wording and in para 9.1.34 stating it may not always be required. Will be determined by specific characteristics of the development and location, as well as one of the 5 criteria for reduced parking standards.

We accept the Council response and do not believe a change to dPS is required.

Support for the proposed policy approach is welcomed.

N/A

Support for the proposed policy approach is welcomed.

N/A

NIHE welcome the need for drainage assessments to be provided for all new residential developments in areas where there is evidence of/potential for surface water flooding and in other circumstances as specified in policy FRD3. NIHE support the promotion of the use of Sustainable Urban Drainage Systems, which can be used effectively to manage surface water run-off by, for example, the use of green roofs/walls, tree pits and swales, which help integrate green and blue infrastructure into the public realm/buildings and enhance nature conservation and biodiversity. NIHE, as the Home Energy Conservation Authority for Northern Ireland, supports maximising the opportunities to develop renewable energy generation facilities in appropriate locations, as these can bring many social, economic and environmental benefits. Renewable energy schemes can reduce fuel poverty for

Support for the proposed policy approach is welcomed.

N/A

Support for the proposed policy approach is welcomed.

N/A

Comments welcomed and noted.

N/A

local people and help improve air quality, thereby increasing and protecting health and wellbeing.

Telecommunic ations Development and Overhead Cables

Development Relying on Non-Mains Wastewater Infrastructure European & Ramsar Sites – International; Species Protected by Law; SNCI – National; SNCI – Local; Habitats, Species or Features of Natural Heritage Importance

NIHE recognise that access to high-speed broadband is essential for sustainable economic development and can help reduce social isolation and provide access to services. NIHE therefore support this policy, which aims to facilitate the development of telecommunications and utilities infrastructure in appropriate locations while minimising the environmental impact of such infrastructure. The Housing Executive supports this policy, which seeks to ensure that proposals for new development relying on non-mains wastewater infrastructure, either individually or cumulatively do not increase the risk of pollution, which is in the interests of sustainable development. NIHE support the requirement for developer contributions towards infrastructure upgrade costs to facilitate development. HE supports policies that protect natural heritage assets and welcomes the commitment to the conservation, protection and where possible the enhancement of biodiversity in NAT5 including the use of the NI Biodiversity checklists.

Support for the proposed policy approach is welcomed.

N/A

Support for the proposed policy approach is welcomed.

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Support for the proposed policy approach is welcomed.

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HE would however like to see the inclusion of a specific policy relating to trees and development.

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Consider that there is an opportunity within the dPS to proactively promote biodiversity through the development management process.

N/A

Strategic Focus Areas

The Housing Executive supports the place-making approach set out within this policy as this Focus Areas can lead to successful places. Place making links with urban design, as this approach advocates that buildings should not be looked at in isolation, but should be considered with regard to how they contribute to the overall function and appearance of an area. We support the policy approach of designating distinctive urban areas as Strategic Focus Areas, in order to promote good place-making in such areas and support their successful and sustainable development. However, we would like to see a place making approach being delivered in all areas.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Whilst there is no specific policy relating to trees and development, it should be noted that the draft Plan Strategy is intended to be read in the round, the importance of retaining existing and planting new trees is directly referred to throughout the document. Council may consider producing SPG relating to Trees and Development as part of the ongoing LDP process. Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change. The dPS is intended to be read in the round, high quality design that takes account of its surrounding context including biodiversity which is promoted through Policy GP1 (e) Criteria relating to Sustainable Development point (iv) and is supported by additional policies and guidance within the draft Plan Strategy and as such will provide sufficient safeguarding to ensure that development will conserve wildlife and vegetation and promote further diversity. Council welcomes the support for this policy approach.

We would welcome an SPG relating to Trees and Development.

N/A

Local Development Plan Team Silverwood Business Park 190 Raceview Road Ballymena BT42 4HZ Tel: 028 2563 3500 planning@midandeastantrim.gov.uk