LDP Report on how POP representations were taken into account - March 2021 by Mid and East Antrim Borough Council

Local Development Plan 2030

Report on how POP representations were taken into account in the preparation of the draft Plan Strategy March 2021 Contents www.midandeastantrim.gov.uk/planning

DPS-507

1.0

Introduction

2.0

Consideration of Preferred Options Paper main issues

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Introduction

1.1

Regulation 20(2)(f) of The Planning (Local Development Plan) Regulations (Northern Ireland) 2015 relating to the ‘Submission of Documents for Independent Examination’, requires Councils to submit a statement setting out: (i) a summary of the main issues raised in representations made in accordance with regulation 11(2), and (ii) how those main issues have been taken into account in the preparation of the development plan document.

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Following public consultation on the Preferred Options Paper (POP) from June to September 2017, the Council published a POP Public Consultation Report in November 2017 summarising the main issues raised in the 132 representations submitted by both consultation bodies and the public. Council considers this Report satisfies Regulation 20(2)(f)(i).

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At that time, the POP Public Consultation Report also highlighted a number of issues for further consideration by Council in preparing the LDP (both draft Plan Strategy and Local Policies Plan). In the intervening period between the POP and the formulation of the draft Plan Strategy, the Council held various meetings with the Project Management Team, Councillors, and numerous other stakeholders on key issues and topics. Each of the Technical Supplements which accompanied the published draft Plan Strategy includes chapters on the POP; Consultee and Councillor Engagement; the draft Plan Strategy Approach; Soundness, as well as a Review of Existing Planning Policies.

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To satisfy the requirements of Regulation 20(2)(f)(i), this additional Report (‘Statement’) supplements information already included within those Technical Supplements with more detailed responses on how the main issues raised in representations to the POP were taken into account in the preparation of the draft Plan Strategy.

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It should however be emphasised, it is the full suite of supporting documents collectively that set out the Council’s full consideration and response to the key issues identified in the POP, the main issues raised in the POP representations, and the full explanation of how the draft Plan Strategy has evolved through the process.

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Consideration of Preferred Options Paper main issues

2.1

The following table outlines the main issues raised in the Preferred Options Paper and how they have been taken into account in preparing the draft Plan Strategy.

Consideration of Preferred Options Paper responses in regard to draft Plan Strategy approach Key Issue/ Section Vision

Strategic Objectives

Issues raised through POP Consultation 1. Concerns were raised over the ability to monitor and measure the LDP Vision statement to ensure that the Vision is being achieved. 2. Vision statement could be shortened to make it clearer and more memorable. 3. Introduction of a mission statement or the inclusion of words such as ‘resilient’ would be beneficial. 4. DfI Planning suggested that the Vision could be further refined to make it more locally distinct through reference to the future vision for key settlements or unique assets within the district. 5. HED highlighted that the vision failed to acknowledge the Historic Environment in the Borough. 1. Respondents welcomed the wide-ranging objectives and noted that the themes were interrelated and in accordance with the principles of Sustainable Development. DfI Planning also considered the objectives demonstrated the link between the Community Plan and the LDP and appreciated the acknowledgement of the RDS and SPPS. 2. The objectives should be more ambitious. 3. The Objectives should quantify the number of jobs and homes which will be created over the Plan Period in order to ensure that suitable and capacity is identified.

Consideration of Issues raised through POP Consultation and draft Plan Strategy approach 1. The LDP strategic objectives are designed to assist in the delivery of the LDP Vision. The Council’s monitoring approach focuses on the LDP objectives, indicators therefore have been set out that will enable us to assess the extent to which they are being achieved through the policies and proposals set out in the LDP – see Technical Supplement 1. 2.-5. It is considered that ‘a vision’ by its nature cannot be too narrowly focused or prescriptive. We believe that the alignment with the Community Plan vision and the slant on creating ‘good places’ is entirely appropriate and fundamental to what the LDP seeks to deliver in broad terms.

1. As the LDP contains a wide range of topics and policies all interrelated, it is therefore considered the Objectives should also be reflective of that to ensure both the delivery of the LDP, and that the full range of other complementary Plans and Strategies are all taken into account. 2. Council consider the objectives are realistic, achievable and measurable, and collectively contribute to the three pillars of sustainable development. 3. The draft Plan Strategy Social Objective c) does include the figure of 7,500 dwellings over the Plan period, whilst the Economic Objectives concentrate more on sustaining the wider economic growth over a number of sectors including business, industry, retail, minerals, tourism etc. and is not just about the number of jobs. 4. Larne Port Gateway is only one opportunity for economic growth within the Borough and can be considered to be covered by these high level Strategic Objectives under Economic Objectives a) and c) in the draft Plan Strategy. Council 4

Overarching Principles

4. A number of respondents highlighted that the objectives were silent in relation to Larne Port Gateway and its future growth potential. 5. A stronger approach towards the protection and enhancement of the built and natural environment needed with a particular emphasis on biodiversity. 6. RSPB expanded on this by suggesting that ecosystem services should be incorporated into the LDP overarching objectives and that the objectives relating to mitigating and adapting to climate change should be strengthened. 7. DfI Planning advised to reduce the number of objectives to be more concise, spatially focused and ensure they can be implemented and monitored. 8. NIHE considered Social Objective d) be amended to refer to mixed tenure and that Social Objective e) should specifically mention affordable housing, wheelchair standard, supported and traveller housing. 9. HED requested that the words ‘protect’ and ‘historic environment’ are included in Environmental Objective d) 10. NIEA desired to see the Water Framework Directive (WFD) water quality objectives explicitly referred to within the objectives. 1. The Overarching Principles overlap with the SPPS and LDP strategic objectives and may, therefore, be superfluous. DfI Planning and ABO NI Ltd stressed that the Strategic Objectives and Overarching Principles should be consistent, with DfI Planning querying how the Overarching Principles complement/add value to the SPPS Core Planning Principles, and indicated it would be useful to clarify the relationship between the Overarching Principles and Strategic Objectives. 2. Some other comments included:

6. 7.

9. 10.

have continued to liaise with Larne Port over their expansion and diversification plans and will continue to support that through the LDP as appropriate at Local Policies Plan stage. Protection of the Built and Natural Environment are considered central to all the Environmental Objectives in the draft Plan Strategy, with particular emphasis on biodiversity in Environmental Objective a) Ecosystem services have now been added to Environmental Objective a) Council have reduced the number of Strategic Objectives by 7 since the POP but consider the objectives retained in the draft Plan Strategy are required to ensure all aspects of the LDP can be fully monitored. Social Objective c) in the draft Plan Strategy now refers to mixed tenure housing and any identified special housing needs (which incorporates affordable housing, wheelchair standard, support and traveller housing). The suggested wording has been added to Environmental Objective e) in the draft Plan Strategy. Whilst it is not considered appropriate to include the Objectives of an individual ‘Directive’ in the draft Plan Strategy without doing so for others, Environmental Objective h) has since been amended to refer to water and drainage.

1. Given the numerous comments in relation to the purpose and added value of the Overarching Principles and the potential repetitiveness, duplication and inconsistencies with Strategic Objectives and the SPPS Core Planning Principles, Council liaised with numerous stakeholders through the Project Management Team before agreeing to remove this element from the draft Plan Strategy. 2. It is considered the other views made by respondents in relation to economic growth; the coast; traffic congestion; design standards; and climate change are already adequately covered by the SPPS Core Planning Principles and the LDP Strategic Objectives.

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Key Issue 1 Developer Contributions

Regard should be had to economic growth particularly as this is a component of sustainable development.  Design standards and the need to accommodate flexible solutions, particularly those which have an emphasis on sustainability.  There should be a reference to the importance of the coast, maritime area and ports/harbours.  In reference to the impacts of traffic congestion, it was suggested that regard should be had to the intention to reduce dependency on, and thereby travel by, the private car.  NIHE expressed support for a high quality design approach which promotes accessibility, energy efficiency, and reduced reliance on the private car, and promotion of shared housing and access to public spaces.  ABO NI Ltd suggested the Overarching Principles should reference “combating climate change” and should give increased weight to the environmental benefits of renewable energy schemes. 1. Comments in relation to this Key Issue were mixed and included the following:  The preferred option provided a long-term stable policy for businesses and economic investment.  Invest NI appreciated developer contributions in respect of private sector developments, but cautioned for public sector developments where wider societal benefits are the driving force rather than profit.  Important that LDP highlights the infrastructure required from developers.  Policy should be based on the infrastructure requirements generated as a result of future development and include costs of delivering

1. Given the significant proportion of unsupportive responses to the preferred option of providing strategic policy on developer contributions, and taking account of some of the concerns raised by the public, statutory consultees and elected members, Council consider this issue needs further investigation with a range of stakeholders. However, there is the mechanism to deliver agreement through the proposed Draft Plan Strategy policies, including affordable housing and infrastructure. Policy TR3 covers ‘New Transport Schemes’ (or connectivity to an existing transportation facility in the locality). The developer contributions framework will be considered at some stage in the future, and will be consulted on.

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infrastructure and the viability of development sites. If developer contribution level unreasonable, then developer will reduce the design style, quality and energy performance to cover any additional costs. Developer investment should not be left to the housing and economic sectors only. Contributions should be considered on a case by case basis and consideration given to the impact on other businesses that might be impacted. Developers must pay for their own infrastructure works and where appropriate, provide public enhancements. Difficulties highlighted in tailoring policy to specific sectors or types of development which have differing commercial basis. A general approach to this can be problematic as site conditions/situations vary. There must always be some form of negotiations with the developer on a site by site basis. Concern over the use of thresholds which could be circumvented by developers. Preferred a hybrid of options 1(a) and 1(c) to address this. Others suggested a combination of options 1(a) and 1(b), where a strategic policy is developed for the entire Borough, augmented with specific developer contributions for zoned sites. Retail NI preferred KSRs which took account of any localised infrastructure inadequacies or specific circumstances. Thought standardised thresholds will result in a potential imbalance of contributions, which will potentially inhibit investment, negatively impact on infrastructure and quality of the environment.

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Key Issue 2 Settlement Hierarchy

Some respondents highlighted the lack of evidential base for needing a strategic policy on developer contributions.  NIHE added that they strongly support the introduction of a policy to provide affordable housing by way of developer contributions.  DfI Planning welcomed a strategic policy on developer contributions. However, they highlighted previous research carried out in 2016 which indicated that most housing markets in NI could not, at that time, sustain a  scheme of developer contributions toward affordable housing.  DfI Roads highlighted difficulties determining size of any developer contribution and ensuring developers do not avoid thresholds.  DfI WDPD welcomed that developer contributions can relate to sewerage connections.  NIEA added it will be important that the policy should include scope for contributions to secure environmental benefits, e.g. management of green infrastructure areas or areas of compensatory habitat creation.  HED highlighted opportunities for the promotion and interpretation of the historic environment, but requested further clarification on archaeological investigation or mitigation costs.  SSE felt more information was needed on a policy for developer contributions and a separate detailed consultation should take place. 1. NISRA settlement bands should be used. 2. Consider a fifth tier for large towns over 5,000. 3. Classification should be based only on population size.

1.-3. The settlement hierarchy for Mid and East Antrim is primarily based on the following evidence:  The RDS Hierarchy of Settlement and Spatial Framework Guidance; 

4. Reclassification should be through community consensus. 8

Detailed settlement evaluation which examined the settlement hierarchy in existing areas plans and assessed each settlement below the top tier of the three main towns, to rank its sustainability; and

5. Kells/Connor (village) should be comparable to Cullybackey (elevated to small town). 6. Carnlough (village) should be elevated to a small town as it has a larger population than Portglenone (elevated to small town). 7. Glenoe (small settlement) should be considered as a village. 8. DfI Planning had concerns regarding the proposed reclassification of the four former villages of Ahoghill, Broughshane, Cullybackey and Portglenone as small towns because their populations fall short of the NISRA definition of a small town (i.e. a population of 5,000 – 10,000). Portglenone was of particular concern. 9. DfI Planning also stated that no sustainability assessment has been carried out for proposed new small settlements. 10. DfI Planning stated that identification of further new small settlements may not support RDS objective to grow hubs and cluster of hubs, advising that the SPPS already allows for rural residential development opportunities. 11. NIHE expressed concern that de-designating some smaller settlements along with the aim to reduce housing in the open countryside (which they do support) may not sustain some existing rural communities.

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4. 5. 6.

Analysis of built up nodes in the countryside to identify any potential new settlements that have a concentration of buildings displaying an obvious sense of cohesion and place offering one or more community facilities. The draft Plan Strategy adopts a new settlement hierarchy for the Borough, which amended the settlement hierarchy within existing area plans through reclassification of existing settlements, addition of new small settlements and dedesignation of selected existing small settlements. A new four-tier settlement hierarchy is proposed (see SGS2 Settlement Hierarchy). This approach was aimed at ensuring a sustainable approach to future growth and development and to remove inconsistencies between the settlement hierarchies of the three legacy councils. The three main towns have been retained at the top tier of the hierarchy as these all have populations well in excess of any of the small towns or villages and are also predominant in regard to their range of services, transport links and strength of their economic base. A detailed settlement evaluation was carried out to determine which settlements should be classified as small towns, villages and small settlements. The addition of a fifth tier was not consideration necessary and only Greenisland would have fallen into this category. The proposed reclassification have been subject to public consultation and 58% of public responses supported the settlement hierarchy. Kells/Connor is not considered to have the population and service provision to justify designation as a small town. It was accepted that Portglenone should be retained as a village on account of its population (1,174) falling well below the 5,000 – 10,000 NISRA definition of a small town. Policy SGS2 Settlement Hierarchy reflects this. Carnlough is not considered to have the population and service provision to justify designation as a small town. The Housing Evaluation Framework from the RDS was taken into account when appraising settlements to determine where they should sit in the hierarchy. Following this detailed settlement appraisal, Glenoe was not considered to have the supporting population and facilities to justify designation as a village. The designation of small towns is based on a Borough wide criteria and no villages in the former Larne Borough were close to meeting this. Furthermore, a disproportionate growth of villages is likely to detract from main towns. It was accepted that Portglenone should be retained as a village on account of its population (1,174) falling well below the 5,000 – 10,000 NISRA definition of a small town. Policy SGS2 Settlement Hierarchy reflects this. However, given the disproportionately high level of service provision, the continued status of 9

Key Issue 3 Spatial Growth Strategy

1. Main roads between Larne to Ballymena and Larne to Carrickfergus should be designated as link corridors. 2. Villages should be more than merely sustained and given appropriate growth, Carnlough singled out. 3. Greater priority should be placed on protecting the environment and rural character than facilitating sustainable development. 4. Major employment locations should be at strategic locations, near transport intersections. 5. Concerns were raised about growth in rural areas, for example: terms such as, "Facilitate appropriate growth in our small towns" and "Facilitate sustainable

Portglenone as a village will need to be considered at Plan Review stage. It was considered that Ahoghill, Broughshane and Cullybackey should be upgraded from the villages tier to small towns tier for two reasons. Firstly, on account of their high sustainability scores which are significantly higher than the scores attributed to the two existing small towns of Whitehead and Greenisland. Secondly, on account of similar population levels as the existing small towns, particularly Whitehead (population 3,786). 9. At the next stage of the LDP, the Local Policies Plan, Council will set development limits for all of the settlements identified within the Settlement Hierarchy. The main objectives of these development limits will be to promote and accommodate new development, and also to contain development within the limits in order to maintain a clear distinction between the built-up area and the surrounding countryside. 10. and 11. It was considered that eight new small settlements should be designated and 12 existing settlements de-designated, as proposed in the POP. In both cases, the draft Plan Strategy approach is based on the level of service provision and the coherence of the built form (the PAC test used at the BMAP Inquiry previously referred to). DfI Planning concerns in regards to the designation of eight new small settlements were centred around the potential impact on the growth of the main hubs. However, Council considers that the following two factors need to be taken into account. Firstly, because only limited opportunities for development will be provided in small settlements (in accordance with the LDP Spatial Growth Strategy), there will be no significant impact on the growth of the main hubs. Secondly, the designation of the eight new small settlements will be offset by the de-designation of the 12 existing small settlements. 1. Transport corridors indicated on our Spatial Strategy map reflect the RDS Spatial Framework and therefore cannot be amended through the LDP. 2. The proposal to sustain growth in villages is in line with the RDS Spatial Framework Guidance 13, which recognises villages as part of the rural area where the objective is to: Sustain rural communities living in smaller settlements and the open countryside. 3. Paragraph 5.1.15 of the draft Plan Strategy highlights that whilst the Spatial Growth Strategy is largely aimed at promoting sustainable housing and economic growth, sustainable development must also pay due regard to environmental considerations. Accordingly, those landscapes and natural/historic heritage assets of strategic significance will be protected through the Strategic Countryside Designations, in the Countryside Strategy in Part 1 of the draft Plan Strategy. 10

10.

11.

development in the open countryside…" will be used as justification to grant approvals beyond what is envisioned in the growth strategy; and it is not sustainable to permit the same level of growth that has occurred since publication of PPS 21. Development in the countryside should be limited to that related to agriculture, food and drink and sustaining rural jobs and services. There should be more opportunities for appropriate small businesses where required in small settlements and the countryside. DfI Planning noted that no alternative growth scenarios were put forward and Council should satisfy itself that all realistic alternatives have been explored. DfI Water and Drainage Policy Division advised that growth should initially be targeted in areas where there are not currently capacity issues with Treatment Works. NIHE seeks to ensure that the countryside continues to be afforded a high level of protection from excessive and inappropriate development. HED highlighted that the growth strategy should demonstrate appropriate protection for the historic environment. RES Ltd and ABO Wind NI Ltd considered that the growth strategy is silent on the correlation between spatial growth and energy demand and provision. Council is encouraged to plan for this growth and in particular to substantially meet new energy demand through renewable energy.

4. The locations of lands zoned for Economic Development is a matter for the Local Policies Plan process. 5. The RDS hierarchy recognises the rural area as including small towns, villages, small settlements and the open countryside. RDS Spatial Framework Guidance 13 states that the objective is to: Sustain rural communities living in smaller settlements and the open countryside. This includes establishing the role of multi-functional town centres as the prime location for business, housing, administration, leisure and cultural facilities for both urban and rural communities, revitalising small towns and villages, facilitating the development of rural industries, businesses and enterprises in appropriate location and encouraging sustainable and sensitive development. (See Table 5.1 Page 51 of draft Plan Strategy). It is considered that the Spatial Growth Strategy achieves a balance between facilitating appropriate and sustainable growth whilst balancing the need to protect the environment and rural character. This is supported by CS1 Sustainable Development in the Countryside and the relevant subject policies in Part 2 of the draft Plan Strategy. 6. Policies ECD1 Economic Development in Settlements and ECD4 Economic Development in the Countryside in the draft Plan Strategy provide adequate opportunities for small businesses in smaller settlements and the countryside. 7. Council consider that the proposed Spatial Growth Strategy aligns closely with the RDS/SPPS direction, with the draft Plan Strategy objectives and with the thrust of the Community Plan. 8. Council continue to work closely with DfI WDPD and NI Water in relation to wastewater capacity issues. 9 and 10. Paragraph 5.1.15 of the draft Plan Strategy highlights that whilst the Spatial Growth Strategy is largely aimed at promoting sustainable housing and economic growth, sustainable development must also pay due regard to environmental considerations. Accordingly, those landscapes and natural/historic heritage assets of strategic significance will be protected through the Strategic Countryside Designations, in the Countryside Strategy in Part 1 of the draft Plan Strategy. In addition, Paragraph 5.1.7 of the draft Plan Strategy highlights that the Spatial Growth Strategy has informed the operational strategic subject policies in Part 2 of the draft Plan Strategy, which includes specific policies to protect the historic environment. 11. We consider that the strategy facilitates sustainable development in the round, and thereby includes renewable energy development in appropriate locations.

Key Issue 4 Housing Allocation Strategy

1. Preferred option could perpetuate unsustainable patterns of growth that are counter to RDS focus to grow hubs. 2. Increase sustainable patterns of growth and bolster town centre living by increasing main towns’ allocation to 65% and aim to meet the RDS 60% brownfield target in settlements over 5,000. Open countryside allocation should be reduced to 5%. 3. Increase small towns’ allocation to 20%. 4. Villages should be increased at a rate similar to small towns versus an alternative view to decrease their allocation to 8%. 5. Mixed response for small settlements with some suggesting a larger allocation should be given to proposed small settlements to offset the loss of others. Alternatively, others considered small settlements should not be overdeveloped as this would threaten their sense of place. 6. DfI Planning highlighted that our evidence showed a fall between 2001-2011 in the proportion of population in Ballymena and Larne relative to their Districts, coupled with slight percentage increase of households in villages. They are concerned the preferred option reinforces this trend of disproportionate growth in lower tier settlements and will fail to strengthen the population in hubs. In turn, this may not present opportunities to change travel patterns and may create pressure on existing infrastructure in villages. 7. The main issue should be the housing growth figure, not its spatial allocation. Many considered the DfI revised HGI as being too pessimistic as it is allegedly based on housing completions during the recession, which was not a normal period of growth. Council is urged to increase the housing growth figure and a variety of methodologies and proposed figures were suggested. These range from a modest uplift and oversupply of

1-6. Taking account of the comments to Key Issue 4 of the POP and in line with our proposed Spatial Growth Strategy, the strategic housing allocation in the draft Plan Strategy sets out to significantly increase the 2011 Census status quo in terms of the proportion of households in main towns (62%), and to marginally increase the percentage in small towns (15%), villages (8.5%) and small settlements 2.5%). This is in line with the RDS in that most housing growth is directed to the main towns of Ballymena, Larne and Carrickfergus whilst ensuring that the needs of the rural community are met in a sustainable manner (See Technical Supplement 3 Housing – Table 7.1). 7. The draft Plan Strategy takes account of the HGIs as required by both the RDS and SPPS. HGIs are based on the best available evidence, largely related to anticipated household formation and SGS3 uses them as the broad parameter for the housing allocation process to produce ‘notional’ housing allocation figures. Council accepts that the HGIs only provide an estimate of future housing need throughout NI and that they should be used as a guide to where development should happen to meet DRD (now DfI) objectives. SGS3 does not treat the HGI as a target, cap or rigid figure and this is demonstrated by the following:  Potential housing land supply significantly exceeds housing allocation to settlements based on HGI, as illustrated on pages 323 -325 of the draft Plan Strategy;  The draft Plan Strategy will be zoning suitable uncommitted urban capacity sites in urban footprint of main towns as phase 1 housing land irrespective of allocation;  Existing commitments can be developed and for many settlements this largely meets or exceeds the notional allocation;  The draft Plan Strategy allows for phase 2 land to be brought forward in main towns. In addition, in the remaining small towns where urban capacity sites or windfall potential would not meet affordable housing need, additional land may be zoned for housing if it is sustainable to do so; and  HGIs will continue to be reviewed by DfI and taken into account in review of the LDP. Whilst it is accepted that not all sites may be suitable there is still a significant ‘cushion’ over and above the notional allocation in existing settlements. Accordingly, there is sufficient flexibility for the LDP to react to variants such as housing need, population and economic factors. In addition to the HGI, the housing allocation process also takes account of other relevant factors such as the 12

15%, to figures of 8,060, around 12,000 and 16,209 if the original RDS HGI is used and a five-year supply added. Some respondents also argued for an increased figure to ensure a five-year supply at the end of the plan period. One respondent supported an increased HGI to offset market housing restrictions due to the social housing need being predicted to absorb 38% of the HGI over the Plan period.

Existing Housing 1. The majority believed insufficient land is currently zoned Commitments for housing. 2. A detailed review of all zoned and unzoned sites within settlement limits should take place to analyse their deliverability. Some provided counter arguments to potential yields stated in the 2016 Housing Monitor and a number of respondents believed that additional land for housing would be required in various settlements including Ballymena, Greenisland Cullybackey, Broughshane, Portglenone and Ballygalley. 3. RSPB stated that the Housing Land Evaluation Framework should be applied to all zonings, including existing zonings. 4. DfI Planning raised the following:  it is not apparent from the POP how the figure of 8,390 dwelling commitments has been established, and they are somewhat concerned that it is 35% above the HGI;  as housing markets cross council boundaries the housing requirements should be considered in light of the potential implications on neighbouring Councils;

RDS direction in favour of main towns, demographics and those factors considered through the Housing Evaluation Framework. Following a public consultation, an agreed HGI methodology was established in 2005 by DfI (then DRD) and that has been replicated as closely as possible for all HGI updates since then. The HGI’s are published by DfI and it is their responsibility to decide if and when to carry out public consultation in regard to the figures and/or methodology. The purpose of the LDP is to ensure that the housing need for the remainder of the plan period can be met. Council is content that housing land supply exceeds housing allocation and that many settlements have more than sufficient land to allow them to exceed their notional allocation based on the HGI by the end of the plan period. As part of the Local Policies Plan process the status of sites will be re-examined to consider their potential for housing and housing land supply will also be considered at Plan Review stage, prior to 2030. 1. At the time of the draft Plan Strategy, it was estimated that undeveloped and uncommitted housing zonings extended to approximately 132 hectares in main towns (See Appendix A of draft Plan Strategy). Policy SGS5 Management of Housing Supply sets out the circumstances where land will be zoned for housing at Local Policies Plan stage. 2. As part of the Local Policies Plan process, the status of sites will be re-examined to consider their potential for housing. 3. Existing uncommitted zoned housing land outside the urban footprint will be assessed along with other potential phase 2 land. The LDP has to deal with the legacy of existing extant plans. It aims to actively manage the release of this legacy of housing zonings and whiteland outside the urban footprint of main towns and Greenisland by holding it in reserve as phase 2 housing land through the Local Policies Plan process. The extent of urban fringe sites in the remaining small towns is significantly lower. In the case of Ahoghill and Broughshane, such sites in the urban fringe may be required to meet the social rented need. Council is not in a position to revoke planning permissions for sites within settlement development limits. 4.  The figure of 8,390 dwelling units quoted in the POP, represented those sites in the 2016 Housing Monitor that had a live permission or were zoned for housing/within Housing Land Use Policy Areas but did not have a live permission. This was to provide an approximate estimate of committed housing land within the Borough.

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SPPS provision relating to the maintenance of a 5 year supply of deliverable housing land during the lifetime of the Plan should be addressed; and  clarification requested on how the excessive housing land supply from extant provisions will be addressed. 5. NIHE considered there is sufficient land zoned for housing in terms of the HGI. They also made the following comments:  advised that housing land allocation should take account of NIHE Housing Need Assessment and committed housing sites as there needs to be sufficient uncommitted housing sites to help address affordable housing need, on mixed tenure sites, in order to create balanced and inclusive communities;  stress that housing zonings in the new LDP should be developable and have a reasonable expectation of coming forward for residential development during the plan period;  would like the existing uncommitted housing zonings to be subject to a feasibility assessment. Also, if the prospect of development on currently zoned land is unlikely, the zoning should be removed and alternative housing land identified. This assessment should test whether the owners are willing to provide their land for future housing development.

Further work on the current status of commitments and potential housing land is set out in Further Evidence Report – Housing.  The draft Plan Strategy has used DfI’s HGI as a baseline for its Housing Allocation and Pages 10 and 11 of Technical Supplement 3 Housing set out the cross boundary policy context in regard to housing.  Further Evidence Report – Housing sets out the considerable level of potential sources of housing land within the settlement limits of existing settlements in excess of the notional housing allocation until the end of the plan period in 2030.  The LDP policy approach will be to phase housing land in our three main towns and Greenisland at Local Policies Plan stage in accordance with draft Plan Strategy SGS5 Management of Housing Supply. To actively manage the release of the legacy of housing zonings outside the urban footprint, such land will be held in reserve as phase 2 housing land at Local Policies Plan stage in settlements with a population over 5,000. 5.  Potential housing land supply significantly exceeds housing allocation to main towns based on HGI, as illustrated on page 323 of the draft Plan Strategy; therefore, it should have the capacity to meet affordable housing needs. Where necessary, in small towns (save for Greenisland) SGS5 Management of Housing Supply allows for additional land to be zoned for housing where urban capacity sites or windfall potential would not meet the affordable housing need identified by NIHE, if it is not reasonable for the need to be met in a nearby settlement.  The level of existing commitments in settlements, which largely meets the notional housing allocation for settlements, indicates provision of an ongoing supply. In the main towns initial assessments, see Figure A4 page 323 of the draft Plan Strategy illustrates a potential land supply in excess of the notional allocation from various sources. As part of the Local Policies Plan process, the status of existing approvals and the capacity of settlements will be examined further. It is accepted that not all sites may be suitable. However, given the extent of the oversupply the Council is content at this stage that land supply should not be an issue in the main towns. Council is aware that there is limited capacity within some of the small towns, particularly in relation to affordable housing need. SGS5 however, makes provision for any deficit in small towns to be addressed through the zoning of additional land if it is sustainable to do so as part of the Local Policies Plan process. In the villages as illustrated on Figure A6, page 325 of the draft Plan Strategy there is a potential land supply in excess of the proposed allocation in the majority of 14

Economic Development Strategy (EDS)

1. Retail NI had reservations in respect of the release of any economic land for other uses and specifically for retailing or mixed-use development outside of designated centres. 2. There is a need to ensure that an ample supply of economic land is in the right strategic locations, for example near transport intersections or to take advantage of road upgrade schemes. 3. Respondents highlighted the issue of land banking. LDP should ensure there is adequate competition on availability of economic development land in the main towns. 4. RSPB was not supportive of the EDS, and expressed disappointment that there was no reference to the environment within this section or the ecosystems services which flow from it. They felt it failed to place emphasis on sustainability, or commitment to explore brownfield sites in identifying future economic sites. 5. NIHE was content with the suggested approach of the EDS and emphasised the importance of a feasibility assessment of existing economic zonings. 6. DfI Planning stated it was unclear how the preferred approach which included facilitating for economic development needs in villages, small settlements and the countryside in line with the policy direction of the SPPS aligns with regional policy direction and the need for a robust evidential context to any departure from regional policy. 7. DfI Rivers and DfI WDPD highlighted the importance of flood risk and adequate water, sewerage and drainage infrastructure respectively

2. 3.

5. 6.

cases. As part of the Local Policies Plan process, the status of existing approvals and the capacity of settlements will be examined further. In relation to villages with limited capacity, Council will consider how to sustainably achieve their notional allocation. The Economic Development policies in the draft Plan Strategy make it clear that retailing will not be permitted, either on land zoned for economic development uses (with the exception of a sui generis employment use) or within the countryside (with the exception of those permitted under Policy RET4). The locations of lands zoned for Economic Development is a matter for the Local Policies Plan process. The LDP process has no control over the ownership of sites or land banking. Council have however allocated a gross amount of land in each of the three main towns which will offer the required generous supply of land and range and choice of sites for economic development uses. Council noted RSPB’s concern and would add that Council’s commitment to the safeguarding and enhancement of the environment is assessed in other sections of the draft Plan Strategy. In addition, the Economic Policies also protect and encourage the re-use of land currently or last used for economic development with only limited circumstances for economic development on greenfield locations such as the countryside. Council have undertaken the relevant parts of Stage 1 and 2 of the RDS ELEF, with Stage 3 to be completed as part of the Local Policies Plan process. Council consider the EDS approach and Economic Development policies in relation to villages, small settlements and the open countryside aligns with both the SPPS and RDS policy approach. Policies in the draft Plan Strategy, including a new policy on Sustainable Drainage, demonstrate the Council’s commitment to preventing flood risk and improving drainage. Council also continue to work closely with DfI WDPD and NI Water in relation to wastewater capacity issues. At draft Plan Strategy stage, EDS only determines in broad terms the amount of gross land needed for economic development in each of the 3 main towns. The location of those zonings and accessibility to such is considered a matter for the Local Policies Plan process.

Retail Strategy

Key Issue 5 Hierarchy of Centres

8. DfI TPMU was concerned that there is no reference to accessibility or location in the EDS. 1. Some respondents who did not support our proposed classification suggested alternative tier structures in the Hierarchy of Centres or alternative uses within our definitions of the proposed tiers. For example, a 3 tier system of Town centre/Small town as tier 1, District centre as tier 2 and Local centre as tier 3, with additional village and neighbourhood centres to be considered based on need. 2. Careful identification of town centres and small towns was cautioned to ensure they do not prejudice investment and development. 3. Flexibility was suggested for local shopping facilities and petrol forecourts beyond designated centres. 4. Wide variety of views were received regarding the proposed inclusion of District and Local centres in the Hierarchy of Settlements. These ranged from welcoming their inclusion, to seeking clarification of the selection process and appropriate uses within these tiers, to suggestion that the Borough was not large enough to justify these additional tiers. 5. Translink suggested District centres should be centred on the local Ulsterbus network and Local centres should be within 800m. 6. HED advised that retail classifications and planned growth should consider any impact development might have on historic buildings and settings of heritage assets. 1. Concern was expressed that planned growth of small towns may dilute the main town centre offering in terms of retailing and associated uses. 2. Several respondents endorsed the suggested district and local centres and some additional district and local centres were proposed while two of the suggested centres were opposed.

1-2. The appointed Retail Consultants reviewed the POP comments and proposed Retail Hierarchy and assessed each centre within the Borough in terms of population, number of units, market share, convenience offer and community services provision. Based on these findings, a slightly amended Retail Hierarchy is proposed in the Draft Plan Strategy. 3. A new policy RET4 – ‘Rural Shops and Roadside Service Facilities’ - was developed to outline what types of retail floorspace are permitted in the countryside and in what circumstances roadside Service Facilities are permitted. 4-5. Greenisland was changed from its status as a ’local town’ to a ‘local centre’, given its lack of retail offer and recognisable centre. Aside from Galgorm, other local centres proposed were discounted for reasons explained in the Retail Study. As none of the centres met the definition of a ‘District Centre’ this tier was also dropped from the retail hierarchy. 6. Built Heritage Policies HE3 to HE8 promote the conservation, preservation and where possible the enhancement of heritage assets that are found within, town centres.

1. Policy RET2 –Retail Impact Assessment – addresses proposals for retail development in small towns and requires an assessment of retail impact to be submitted to consider the impact on any other town within its catchment. Policy wording changes are proposed in the Schedule of Modifications to add ‘regardless of its position in the Retail Hierarchy’ to make it clear that consideration of impact on towns in a higher tier has to be done.

Key Issue 6 Location of Class B1 Business Uses

3. It was recommended that some of the suggested 2-3. All suggested local or district centres were considered however none of the centres district centres should remain within the town centre were found to fall within the definition of a district centre so this tier was omitted boundaries. It was felt that reducing town centre from the LDP Retail Hierarchy. Greenisland was changed from its status as a ’local boundaries to exclude these areas could jeopardise town’ to a ‘local centre’, given its lack of retail offer and recognisable centre. Aside their ability to offer a large enough range of good sized from Galgorm, other local centres proposed were discounted for reasons explained sites and could deter investment due to the ‘town in Technical Supplement 6 - Appendix C - Retail Hierarchy. The Tesco Superstore / centre first’ approach. Dunelm Complex was assessed by the Retail Consultants and was considered to be 4. DfI Planning were concerned that proposed designation an out-of-centre location and the town centre first policy should direct new of district or local centres that are separated from the development to within the town centre boundary as a priority, rather than to this town centre by main roads could be seen to be diluting location. They did not recommend that an additional category for out-of-centre the ethos and the spirit of the SPPS in regard to its retail locations was included in the retail hierarchy. ‘town centre first’ approach. Such centres should be a 4. The POP suggested several locations as potential District or Local Centres, not focus for everyday shopping and complementary to the specifically separating them into one or other category. This included areas that role and function of the town centre in line with were adjacent to or partly within existing town centre boundaries, which may have paragraph 6.277 of SPPS. given rise to the concerns raised here. However following analysis of all suggestions 5. DfI Planning advised that the LDP should use the RDS both in the POP and by respondents, the retail consultants outline in the Retail Study Hierarchy of Settlements and related infrastructure what they consider to be local centres and confirm that none of the suggestions diagram to help identify the appropriate level of meet the definition of a district centre so this tier was dropped from the revised services and facilities for each tier in the settlement retail hierarchy. hierarchy. 5. The RDS Hierarchy of Settlements and related infrastructure diagram was taken into consideration when describing the types of uses and functions acceptable in each tier of the Retail Hierarchy. 1. The preferred option promotes town centre vitality and 1. Policy ECD1 primarily promotes the town centre first, along with other locations viability, and also provides the necessary flexibility for specified in the LDP, with exceptions having to meet all the criteria outlined. Class B1 uses. 2. The Policy approach of town centres and other locations specified in the LDP (such 2. All economic zonings should adopt a flexible approach as potentially economic zonings) permits the flexibility required in relation to the to land uses and include Class B1 uses. These areas various types of Class B1 business uses. should be given preference in front of district and local 3. Policy ECD1 primarily promotes the town centre first, along with other locations centres in order to encourage land uptake. specified in the LDP of which Council will have considered and assessed for 3. NIEA stated as it does not restrict Class B1 uses to the sustainability as part of the Local Policies Plan process. town centre only, there was potential to encourage car 4. Policy ECD1 includes the flexibility needed to attract various types of Class B1 use unless linked to sustainable transport policies. Business uses, some of which may be unsuitable or unable to be accommodated 4. DfI stated it was broadly in line with the SPPS which within the town centres. Policy ECD1 of the draft Plan Strategy – Economic provides some flexibility for councils to specify Development in Settlements is worded that Class B1 Business Use will be permitted “other locations” for such development. They within a town centre and in ‘other locations specified for such in the LDP’. Those requested clarification on rationale for including locations will be considered as part of the Local Policies Plan process. Accessibility 17

5. Key Issue 7 Availability of start-up and grow-on business space across the Borough

Key Issue 8 Alternative Uses on land zoned for

1. 2.

economic development zonings in a sequential approach. Translink also raised concerns regarding including economic zonings in the sequential approach due to accessibility. HED highlighted potential for sympathetic re-use of vacant historic properties for business uses. Invest NI welcomed proposals to utilise unoccupied buildings to assist economic growth whilst other respondents stated the re-use of existing sites and buildings should be actively encouraged by the LDP. Some respondents stressed however, that a flexible approach is needed with caution expressed against prescriptive zoning specifically for business start-ups which could prove counter-productive as it may limit choice, drive down land values, and restrict equally suitable alternative economic uses. More flexibility needed in relation to start up and growon developments associated with agri-food production in the countryside. Some respondents also suggested there should be a relaxation of planning policy in the countryside for small businesses. DfI TPMU had concerns that the preferred option would allow for ‘edge of settlement’ development whilst NIHE added that consideration should be given to locations in areas of deprivation and locations well served by public transport in order to remove barriers to employment and support the development of sustainable communities. DfI WDPD requested provision for green space for sustainable drainage, where appropriate, when assessing quantity of land needed for business accommodation. Marginal support for this Key Issue but numerous comments and differing views. Given wide variety of compatible uses which may be appropriate, policy should allow sufficient flexibility and

will be one consideration when assessing the suitability of those sites for B1 Business Uses. 5. The Historic Environment chapter of the draft Plan Strategy includes Policy HE8 on Locally Important Buildings, including an element specifically on conversion or reuse. 1. Elements of Polices ECD1, ECD2 and ECD4 in the draft Plan Strategy all seek to either protect or utilise buildings for economic development purposes and economic growth. 2. The wording of the draft Plan Strategy Economic Development policies offers a required balance of prescriptiveness and flexibility. The locations of zoned land and associated key site requirements are matters for the Local Policies Plan process. 3. Council consider the wording of Policy ECD4 offers a required balance of prescriptiveness and flexibility for economic development opportunities in the countryside. 4. The locations of lands zoned for Economic Development is a matter for the Local Policies Plan process. Sustainability and Accessibility will be considerations of that process. 5. Council have included a new policy, Policy FRD4 on Sustainable Drainage which promotes a SuDS first approach.

1. The preferred option has been amended to the extent that the Economic Development Policies addressing this issue within the draft Plan Strategy are now somewhat less prescriptive.

Economic Development

uses assessed on merit on a case-by-case basis given the impact on/conflict with neighbouring businesses. NIEA also highlighted importance of ensuring these uses are also compatible with the surrounding environment. Policy should not be prescriptive and should not identify uses including those seen as retailing which could be manipulated. Others said provision should be made for some level of retail, commercial leisure and cafe/restaurant uses to allow for complementary services to industrial businesses on site. NIHE also welcomed that policy will clearly state retailing will not be acceptable within land zoned for economic development. They did however suggest that under any revised policy consideration should be given to the provision of social housing and the substantial community benefit that outweighs the loss of economic land. Invest NI was strongly supportive of the LDP seeking to address this issue and outline the difficulties associated with it. Invest NI is generally opposed to the loss of land either currently or last used for industrial development. They cite concerns that in removing the existing criteria and including it as guidance this would lead to a weakening in policy protection. DfI Planning outlined its concerns with compatibility of the proposed uses such as ‘sale and display for sale of motor vehicles’ and ‘a scrap yard, or a yard for the storage or distribution of minerals or the breaking of motor vehicles’ and advised that the Council ensure that all the factors set out in the SPPS have been taken into account. DfI Planning also stated policy for alternative uses should not be applied on a blanket basis on all economic land – instead need to specify appropriate individual zonings.

2. Policies ECD2 on Retention of Economic Development Land and ECD3 on Development Incompatible with Economic Development Uses are intended to protect economic land from both inappropriate and incompatible development. 3. Policy ECD2 explicitly states that Retailing or Commercial Leisure will not be permitted except where justified as acceptable ancillary development. This is to protect our town centres, as well also ensuring the supply of land zoned for economic development is safeguarded for Class B Uses. 4. Policy ECD2 in the draft Plan Strategy outlines the criteria to be met for a development proposal, which would result in the loss of land zoned for economic development. 5. Council have worked closely with numerous stakeholders including Invest NI in formulating the draft Plan Strategy policies and consider the Policy wording in Policies ECD2 and ECD3 strike the required balance of prescriptiveness and flexibility for protecting economic development land for appropriate uses. 6. Policy ECD2 was drafted taking into consideration the POP comments received. Council have since worked closely with DfI and other stakeholders on the Policy Wording. The specifying of appropriate uses for individual zonings will be further considered as part of the Local Policies Plan process.

Key Issue 9 Range of town centre uses

Key Issue 10 Protecting and promoting other town centre uses

1. There were mixed views as to which town centres should be designated with Primary Retail Cores (PRC’s). Opinion ranged from designating only Ballymena town centre with a PRC to designating all three main towns. 2. It was cautioned that overly prescriptive criteria in PRCs can lead to high vacancy rates at ground floor level, and it was suggested that other town centre uses can strengthen the retailing role and improve evening economy. 3. HED say care must be taken not to promote a retail core on economic grounds at the expense of other policies e.g. SPPS strategic objectives aimed at the protection, conservation and enhancement of our archaeology and built heritage 4. It was emphasised that it may not be possible within PRCs to develop large scale proposals such as supermarkets given the need for convenient car parking and was therefore contended that town centres need to provide a variety of suitable opportunity sites (including re-generation and re- use) to meet the scale and form required by investors. 5. DfI Planning welcomed Council striving to ensure appropriate sites are designated to provide a diverse offer and mix of uses and advised that a ‘call for sites’ should be undertaken. 6. HED highlighted the importance of using historic properties in town centres for retail and other mixed uses to promote these centres as attractive and distinct places to live and invest. 1. It was not considered necessary to protect existing housing stock, citing that town centre development and regeneration was likely to promote a residential element to new schemes to compensate for the loss of older housing stock. 2. There was a consensus that policies should be sufficiently flexible to allow for appropriate mixed uses

1-3. Following Council members’ views and advice from the Retail Consultants, PRC’s were not proposed as part of the sequential approach to site selection for retail development in policy RET1. 4-5. A ‘Call for Sites’ consultation exercise will be undertaken at Local Policies Plan stage to identify suitable mixed use development opportunity sites to meet the additional floorspace needs for Convenience and to a lesser extent Comparison Shopping identified in the Retail Study. 6. Policies HE3 to HE8 promote the conservation, preservation and where possible the enhancement of heritage assets that are found within town centres.

1. Council consider the protection of existing town centre housing stock essential as such areas provide valuable housing stock and homes for established communities, which helps retain the town centres’ vitality, reduce vandalism and generally make it a more attractive place to live. Protected town centre housing areas in the extant plans will be assessed and amended as necessary at Local Policies Plan stage. 2. Policy RET1 and justification and amplification paragraph 7.2.14 refer to retail and other town centre uses and footnote 27 explains that other town centre uses 20

within town centres to encourage a wide variety of uses. This in turn would help create a multi-functional centre, encourage investment, reduce vacancy and help tourism. 3. HED considered the promotion of the concept of LOTS would help to create diverse town centres. Further they promoted the re-use of vacant or underused historic assets generally, including within town centres. Key Issue 11 1. Accommodating Future Tourism Demand 2.

3. 4. 5.

include cultural and community facilities, retail, leisure, entertainment and businesses. Policy HOU2- The Conversion or Change of Use from existing Buildings to Flats or Apartments – encourages town centre living. Policy HOU4 – Protecting Town Centre Housing Areas – protects established town centre housing stock and Policy ECD1- Economic Development in Settlements – facilitates Class B1 Business Uses in town centres. 3. Built Heritage Policies HE3 to HE8 promote the conservation, preservation and where possible the enhancement of heritage assets that are found within town centres. A number of those who expressed support for the POP 1. and 2. Instead of bringing forward bespoke policy tailored to the tourism potential of also expressed that the LDP should not be too vulnerable, sensitive and opportunity areas within the Borough, this approach will be prescriptive as there may be a need to facilitate a range delivered in a more strategic way through the Tourism Strategy set out in the draft of accommodation types including hotels at strategic Plan Strategy (refer to SGS8). This will serve to provide broad direction on the locations. potential opportunities and constraints for tourism development within these three Those unsupportive stated that tourism development categories. The policy approach proposed within these categories is then given should be assessed on its own merits. The restriction of greater definition through the strategic subject policies TOU2 and TOU3. Policy development in certain areas and the subsequent TOU3 All Tourism Development in the Countryside highlights that tourism proposals economic impact was also a key issue for those who did in Special Countryside Areas and other vulnerable areas (those listed in the not support the option. Justification and Amplification of SGS8) will only be permitted where they meet the Protection of a number of areas was suggested exceptions specified in the LDP policy for the specific designation. Separate strategic alongside additional opportunity sites. proposals and strategic subject policies (such as those in Chapter 5 Countryside Knockdhu ASAI should be listed in the vulnerable Strategy, Chapter 10 Historic Environment and Chapter 11 Natural Heritage) will also category. HED recognised its tourism potential. help protect locations within the vulnerable and sensitive categories. Policy TOU2 It was also suggested that greater consideration should Tourism Development in Settlements and Tourism Opportunity Zones sets out be given to promoting tourism through alternative uses bespoke policy for those locations within the opportunity category. and diversification in the countryside. 3. and 4. The locational types included under each of the vulnerable, sensitive and DfI highlighted that consideration needs to be given to opportunity categories have been slightly amended as follows: flooding as well as infrastructure implications in relation  To take account of our new designations (e.g. Areas of High Scenic Value changes to developments particularly in the rural area. to Areas of Constraint on High Structures). Caution in relation to the identification of  Moving Gracehill Conservation Area from the vulnerable category to the sensitive Magheramorne quarry as an opportunity zone, stressing category as Conservation Area policy does not differentiate between areas. the need to ensure it is considered in the HRA due to its  Clarifying Sites of Archaeological Interest following discussion with Historic proximity to Larne Lough. Environment Division. Some concern was raised about the identification of  Moving Historic Parks, Gardens and Demesnes from the vulnerable category to Carnfunnock as an opportunity zone due to its the sensitive category in recognition that sensitive tourism development may be one method to help maintain these assets. 21

sensitivity and importance from a historic environment perspective

Key Issue 12 Balancing the need for Minerals Development with safeguarding of Landscape and Environmental Assets

1. Keep Area of Salt Reserve and expand existing quarries with applications on a case-by-case basis against policy criteria. DfE suggested that it is important to retain Areas of Salt Reserve from BMAP 2015 due to the importance of salt extraction to NI economy. 2. POP is too simplistic and not derived from robust evidence base. MPANI said we should do an economic assessment of current resources and demand over plan period – adding borough needs to safeguard 50m tonnes up to 2032

 Removing the Gobbins visitor centre/path from the opportunity category as the visitor centre is already with the settlement of Ballystrudder and therefore does not need to be specifically identified as having opportunities for tourism development. Removing the Gobbins path as an identified opportunity zone will avoid targeting specifically tourism development on this vulnerable coastal asset and therefore safeguard its value as a tourist attraction. 5. Policy TOU5 Hotels, Guest Houses and Tourist Hostels in the Countryside encourages conversion/re-use of existing rural buildings. Policy ECD4 Economic Development in the Countryside also allows for Farm/Forestry Diversification where particular criteria are met including for tourism schemes. 6. Policy TOU3 All Tourism Development in the Countryside requires proposals to meet the General Policy and accord with other provisions of the LDP, this would include Policy GP1 c) Criteria relating to Access/Movement/Car parking, d) Criteria relating to Safety and the Safeguarding of Human Health/Wellbeing and e) Criteria relating to Sustainable Development. In addition, the policies in 9.2 Flood Risk and Drainage would also apply. 7. and 8. In regard to the comments raised at POP stage about the former Magheramorne Quarry and Carnfunnock Country Park being included as Tourism Opportunity Zones, this has been carefully considered in light of the existing planning approval at Magheramorne Quarry and the Council masterplan for Carnfunnock. The policy wording of Policy TOU2 Tourism Development in Settlements and Tourism Opportunity Zones, ensures that the General Policy and other provisions of the LDP (such as Historic Environment and Natural Heritage policies) must also be met. In addition, the policy allows for key site requirements to be introduced where necessary at Local Policies Plan stage. 1. Council extended the BMAP Salt Reserve Area to include existing ISME Mineral Petroleum Licencing Areas and carried across the Salt Reserve Policy from BMAP. Minerals Policies have been amended and updated, in line with SPPS, regarding the importance of a sustainable approach, through balancing the need for minerals development against safeguarding the environment. 2. It is not possible for Council to quantify precise amount of aggregates required up to 2030. Ultimately, and in line with POP, LDP will adopt a Plan led approach identifying MRAs and ACMDs in keeping with the SPPS. However, this approach needs to be informed by a robust evidence base which is currently lacking and which will not be substantially addressed by the DfE Annual Minerals Statements. A cross-council Minerals Working Group was set up June 2018 with representatives from DfE, DfI, 22

3. MPANI say there is no clear evidence for existing ACMD and had concerns that ACMD in the AONB could sterilise a large proportion of significant mineral resources. Removal of the ACMD would provide mineral operators confidence to sustainably expand, boosting economic growth. 4. POP doesn’t define Mineral development, mention exploration of minerals or other specific issues. 5. Policy should seek to restrict minerals development in certain areas due to environmental and social obligations. 6. Consideration should be given to those species and habitats most at risk in terms of environmental impact. 7. Woodburn forest, Larne Lough, Kilwaughter castle and demesne and River Bann corridor should be considered as ACMD 8. Peat extraction should be curtailed 9. The protection of “at risk” species and habitats should be considered when designating ACMD. NIEA say it is important to assess whether habitats/species are likely to be impacted upon when identifying MRA 10. DFE say MRAs should be reviewed over plan period. 11. MUDC say adjoining Council’s should work together and that Lough Beg should be protected due to its environmental value. 12. DfE say there should not be a presumption against the exploration for valuable minerals in ‘any area’, in accordance with the SPPS.

7. 8. 9. 10.

11.

Councils, and industry to gather an evidence base to assess supply and demand and to ultimately inform LDPs. Existing ACMDs were designated under Larne Area Plan 2010 by another planning authority, and went through a public inquiry process. Council have taken a precautionary approach to maintain the existing ACMDs and not seek to identify new ACMDs or MRAs until a sufficient evidence base is in place. Council have removed from the ACMD designation, the one quarry that lies within the existing ACMD. DFE advised there was no immediate demand for new quarries in the borough. Mineral Development is clearly defined in Technical Supplement 10, the Introduction to the Minerals Policies and the Justification & Amplification of each Policy. Some forms of Mineral exploration are permitted without planning permission. For proposals that require permission, Policy MIN1 directs extraction and processing of Hard Rock and Aggregates, Policy MIN2 directs Valuable Mineral exploitation, Policy MIN3 directs Hydrocarbon exploitation and Policy MIN7 directs commercial peat extraction. and 6. Policies NAT1-NAT5 protect international, national and local environmental designations, species protected by law and habitats, species or features of natural heritage importance. In regard to protecting social obligations, Policy GP1 addresses safeguarding residential amenity, human health and well-being. These areas will be examined at Plan Review stage when all existing ACMDs are being reviewed and potential new MRAs and ACMDs are being considered. New Policy MIN7 directs commercial peat extraction. Noted. This will be taken into consideration at Plan Review Stage. DfE had indicated that there needs to be a more comprehensive and clearer understanding of both the supply and the demand for mineral products across Northern Ireland and beyond to properly inform LDP minerals policies and proposals. Particularly in relation to the designation of areas seeking to safeguard mineral reserves and the defining of areas of constraint. Therefore, Council regarded it as premature to designated MRAs at draft Plan Strategy stage but have committed to review such designations at Plan Review stage when hopefully robust evidence will be in place. Council are represented on the cross-council Lough Neagh and Lough Beg Forum. Lough Beg is protected as a Special Countryside Area under policy CS2 and as an Area of Constraint on High Structures under policy CS3.

Key Issue 13 Safeguarding against potential subsidence and the effects of land instability

1. There should not be a presumption against all development in Areas of Subsidence if sufficiently robust information can be provided to demonstrate land stability. DfE outlined that any increased protection should be carefully balanced against the level of mineral development proposed and not result in a blanket ban on low impact exploration activity. 2. It is important that there is a plan for the restoration of quarry areas after the completion of operations. 3. A review of all existing designated Areas of Subsidence should be carried out. Some additional areas for investigation were also suggested. 4. HED suggested that the iron ore mine workings around Cargan and Glenravel are identified as additional areas that may be prone to subsidence

Key Issue 14 Facilitating Social and Affordable Housing

1. A key theme from the responses was that any social housing policy should only be applicable where a need is identified. 2. NIHE supported the policy approach to move away from large mono-tenure estates to mixed tenure developments which should help create more balanced communities. They consider the only exception for sites zoned solely for affordable housing should be in areas

12. SPPS paragraph 6.75 also allows areas of countryside that exhibit exceptional landscapes to be protected from unnecessary and inappropriate development with development only being permitted in exceptional circumstances. Following Geological Survey NI’s review of the proposed locations identified in Policy CS2 Special Countryside Areas- and how they might affect future high value mineral development, DfE have advised Council they are satisfied that, based on available geological information, the proposed SCA locations are unlikely to have a significant impact on known prospective areas. DfE 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. 1. Council reflected the information provided by DfE GSNI in Policy MIN6Development at Risk of Subsidence due to past or present underground mineral extraction. This policy permits a Mine Risk Assessment to be submitted along with any proposals for new built development in proximity to known abandoned mines, shafts and adits. If the Mine Risk Assessment confirms the suitability of the site for development and addresses any health and safety issues, to the satisfaction of the council, permission will be granted. 2. Policy MIN8-Restoration and Management of Minerals Sites directs applications for mineral development to be accompanied by restoration proposals and a management plan to ensure the appropriate and sustainable ongoing use of the site subsequent to the cessation of minerals extraction and/or processing operations. 3. Council defer to experts in DfE Geological Survey NI for guidance on areas of subsidence and are advised that appraisal of risk associated with the areas shown on Map 7.1 in the draft Plan Strategy is ongoing and no changes to the extent of these areas are suggested, whilst underlying voids exist. Policy MIN6 also provides a website link to the GSNI GeoIndex map viewer which details other known abandoned mines shafts and adits. 4. These known areas are identified on the GSNI GeoIndex map viewer. 1. Policy HOU5 Affordable Housing in Settlements in the draft Plan Strategy sets out that the policy will apply where a need for affordable housing is established by NIHE or other relevant housing authority through a Housing Needs Assessment. 2. The SPPS states that the LDP process is the primary vehicle to facilitate any identified affordable housing need by zoning land or by indicating through key site requirements, where a proportion of the site may be required for social/affordable housing. It is also noted that this will not preclude other sites coming forward through the development management process. Whilst our preferred option at POP 24

with acute social housing need and little land availability. However, NIHE preferred the following option - Strategic policy requiring all housing sites, over certain thresholds, to provide a proportion of social/affordable housing. In addition, set out a strategic policy to enable the Local Policies Plan to include in certain areas zoned housing sites with KSRs for specific requirements for social housing, up to 100% when appropriate (i.e. social zoning). 3. NIHE also strongly supported the introduction of a developer contributions policy to provide affordable housing but DfI Planning advised caution regarding developer contributions toward affordable housing due to the potential impact on development viability and deliverability. 4. Developers stressed the importance of having a robust evidence base for the preferred option to ensure it is viable and deliverable. 5. HED highlighted that there is potential for the re-use of vacant or under used historic assets to provide social housing provided policy is in place to ensure their appropriate redevelopment.

Key Issue 15 Delivery of Housing to meet the needs

1. Preferred option should be extended to other dwelling types to deliver more in terms of maximising the number of accessible units and taking account of those with other mobility and mental health issues; and as

stage was for ‘every tenth unit within housing developments to be a social housing unit’ in settlements where a need had been identified, this approach evolved as the draft Plan Strategy was progressed through further analysis and discussion with NIHE. It is recognised that the quotas in Policy HOU5 Affordable Housing in Settlements will not meet 100% of the social rented housing need. However, the justification and amplification of the policy also allows, where necessary, for a higher proportion of affordable housing to be sought at Local Policies Plan stage through key site requirements attached to specific housing zonings. NIHE acknowledged that planning policy and the private sector will not necessarily meet all social rented housing need and a proportion will continue to be delivered directly through housing associations. 3 and 4. Further to their POP comments, NIHE have advised that social rented housing is typically funded through a combination of DfC grant funding, which is administered by NIHE, and a registered housing association’s own funding. Social rented housing development is controlled within financial parameters, set out by the DfC under Total Cost Indicators (TCI), an ‘all-in’ forecast on unit costs based on land and property costs from Land and Property Services. Policy HOU5 Affordable Housing in Settlements allows for housing that will be used for social renting to be purchased from the developer by a registered housing association at TCI. This typically provides a 15% profit to developers. As grant will only be payable to registered housing associations, who acquire properties from the developer; therefore, the developer should discuss proposals, TCI levels and financing with a registered housing association at an early stage in the process. Intermediate housing will also be fully funded and will provide a profit for developers. As the affordable housing units will be financed by registered housing associations, it is understood that schemes should be financially viable. In addition, the provision of affordable housing will guarantee the developer certain sales, delivering a cash flow to provide finance for the market housing. 5. Policy HE3 in the draft Plan Strategy allows change of use of a listed building subject to criteria and Policy HE8 allows the conversion/reuse of unlisted locally important or vernacular buildings to other appropriate uses and this could include social/affordable housing. 1-4. Our population is ageing, and as previously stated it is projected that 24% of the population in the Borough will be 65 and over. To address meeting the housing needs of the general population who require a wheelchair standard dwelling and also the needs of an ageing population, the POP included a preferred option which 25

of people with mobility difficulties

apartments (ground floor or otherwise) may not be suitable for other family members. 2. Provision of such units should be developer led with the Council only seeking to influence their delivery where there is an identified need. 3. Whilst supportive NIHE would like the proposed policy to go further and include a broader range of dwelling type. 4. DfI Planning welcomed the focus on supporting housing for people with specific needs. However, they stress the need to ensure evidence justifies the approach and that the implications of such a policy, in terms of development viability, should be considered.

proposed that all ground floor apartments in blocks of two storey and above should be to wheelchair standards. The preferred option received support from the public and consultees. During preparation of the draft Plan Strategy, discussions took place with Council’s Building Control section to consider in detail the implications of bringing forward a policy for wheelchair standard units in terms of the assessment and enforcement of these standards. The outcome of these discussions was that due to the technical nature of these standards, it would not be practical to bring forward such a policy at this time. In light of the above discussions, the approach of the draft Plan Strategy is to require all new residential properties to conform to a number of Lifetime Homes Standards through Policy HOU7 Adaptable and Accessible Homes. Lifetime Homes Standards are a nationally recognised set of 16 design criteria to ensure new dwellings are adaptable enough to accommodate a household’s changing lifetime needs and enable them to be lived in and visited by people with varying degrees of mobility. It has already been a requirement for housing associations in Northern Ireland to build to full Lifetime Homes standards since 1998. In 2015, Lifetime Homes Standards in England and Wales were superseded by a national standard for accessible and adaptable dwellings incorporated within the Building Regulations. Existing Building Regulations (Northern Ireland) 2012 focus on ensuring dwellings are accessible for visitors and only some of the Lifetime Homes Standards are included within them, therefore at present there is not the same onus on private developers to provide homes that would meet a broader range of needs within our society. Lifetime Homes Standards also present practical difficulties in terms of their assessment and enforcement through the planning system given their technical nature. Each Lifetime Home Standard was therefore discussed in detail with Council’s Building Control section in terms of cross over with existing Building Control regulations and guidance, and practical application and enforcement. It was considered that there were elements of five of the 16 Lifetime Homes Standards that could be assessed and enforced (by planning staff) and these have therefore been incorporated into Policy HOU7. It is acknowledged that Policy HOU7 does not include all 16 of the Lifetime Homes Standards. To introduce all of these would lead to competing standards with Building Control Regulations and guidance and could cause confusion. Mainland UK experience would show it is more appropriate to secure Lifetime Homes Standards via Building Regulations rather than through planning policy. Essentially, this is because the planning application stage is considered too early in the development process to consider all the necessary detail. It is the intention of Policy HOU7 that 26

Outdoor Sport provision – Playing pitches

Improving Health and Wellbeing

homes are accessible for those who live in them and will apply to all proposals for new dwellings, flats and apartments including single dwellings in the countryside. Through this policy the draft Plan Strategy seeks to increase the amount of housing stock which is adaptable and accessible, that will meet the needs of all and which will allow people to remain in their homes for as long as possible. 1. and 2. SGS9 Open Space Strategy in the draft Plan Strategy supports the retention and enhancement of existing open space (which includes outdoor sports facillties such as pitches, tennis courts and bowling greens) as required by the SPPS and will support opportunities to create new open spaces including playing pitches. 3. Open space policies in the draft Plan Strategy, including policies OSL3, OSL4 and OSL5 require the specific criteria of that policy and other provisions of the LDP to be met, this includes meeting Historic Environment policies (Section 10.1) and Flooding policies (Section 9.2).

1. Those unsupportive of protecting pitches felt that it does not guarantee delivery and may hinder development of other amenities and services that could also be of benefit. Instead, it is suggested that policy wording should encourage provision of new sports facilities as well as pitches to allow for a more flexible approach to their delivery. 2. Others suggested that the approach should be widened to identify and protect other existing sport and recreational facilities. 3. It was stated that the provision of pitches either through zoning or through individual applications needs to take account of the historic and natural environment and flooding. 1. Ensure accessibility to green space in order to promote 1. Draft Plan Strategy Social Objectives d), f) and g) aim to deliver quality residential green exercise and active exposure to nature. environments including public open space and linkages to green infrastructure 2. Promote existing sports and recreational facilities, networks, safeguard access to the coast and promote opportunities for walking and especially water sports and provide urban sports cycling. This is followed through in SGS9 Open Space Strategy, Policy HOU1 Quality facilities. in New Residential Development in Settlements and the policies in section 8.2 Open 3. Create safe environs and mixed housing areas. Space, Sport and Leisure. 4. Require health assessments to accompany residential 2. Policy OSL5 Sport and Outdoor Recreation Facilities supports appropriate facilities in applications. the Borough. 5. Increase opportunities for economic and tourism 3. Policy HOU1 Quality in New Residential Development in Settlements and Appendix D development. in the draft Plan Strategy aims to encourage residential layouts that enhance security 6. HED suggested under-utilised open spaces associated from crime and discourage anti-social behaviour. Policy HOU5 Affordable Housing in with heritage assets such as historic graveyards as Settlements requires a mix of tenure where there is an affordable housing need and distinct and peaceful places which could be of benefit. Policy HOU6 Housing Mix requires a mix of house types and sizes in developments 7. NIEA Natural Environment Division highlighted the over 25 units. In addition, Policy GP1 The General Policy for all Development also importance of meeting Water and Air Quality Standards. requires proposal to comply with d) Criteria relating to Safety and the Safeguarding 8. DfI Planning highlighted the role of blue infrastructure in of Human Health/Wellbeing which has specific points about development being improving health and wellbeing. designed to deter crime and promote personal safety. 27

Key Issue 16 1. It was stressed that care should be taken to ensure that Community any proposed sites are suitable with regard to Growing Spaces contamination from previous land uses. and Allotments 2. RSPB suggested that: environmental considerations should form part of policy wording to ensure no detrimental impact on biodiversity or sensitive environmental areas; proposals should be required to submit a detailed landscape strategy to show open space is adequate, well designed and integrated; and a requirement to support wildlife should also be included. Key Issue 17 1. Routes should be multifunctional and not solely for Community recreational use. Also, this preferred option should be Greenways/ used to create a wider integrated blue and green Pathways infrastructure network with access to other amenities and transport nodes. 2. Account should be taken of residential amenity. 3. Environmental issues should be considered to protect against any detrimental impact on biodiversity or sensitive areas.

4. This is not currently a requirement set out in the SPPS. 5. Chapter 7 of the draft Plan Strategy sets out policies to support sustainable economic growth, including providing sufficient supply and choice of sites for business, supporting tourism as a key growth sector and facilitating sustainable economic development in the countryside where it is in an appropriate location and it is appropriate in terms of scale and nature. 6. Section 5.8 Open Space Strategy recognise cemeteries and churchyards as open space of public value. 7. Policy GP1 The General Policy for all Development in the draft Plan Strategy includes criteria relating to Safety and the Safeguarding of Human Health/Wellbeing. Criteria d) iv. requires any emission or discharge of effluent arising from the development is in accordance with legislative requirements pertaining to air and water quality. 8. The role of important blue infrastructure is recognised through SGS 9 Open Space Strategy and through the open space operational polices as well as through the Countryside Strategy and those polices which seek to safeguard or natural environment. 1. Policy OSL6 Community Growing Spaces and Allotments in the draft Plan Strategy highlights at point a) that it should be demonstrated that the site is suitable for growing food and where applicable any risks from contaminated land are appropriately managed. 2. Policy OSL6 Community Growing Spaces and Allotments in the draft Plan Strategy highlights at point b) requires satisfactory arrangements for an appropriate landscape scheme and to demonstrate that the proposal will support wildlife. In addition proposals are required to meet the General Policy which includes criteria relating to Sustainable Development (part e) iv). 1. SGS9 Open Space Strategy and Policy OSL2 Greenways in the draft Plan Strategy support delivery and protection of regional and local community greenways that will provide multiple benefits for active travel, recreation and tourism alongside environmental and ecological benefits. 2. Policy OSL2 Greenways in the draft Plan Strategy requires greenway proposals to meet the General Policy, which includes criteria relating to Safeguarding Residential Amenity (part b). 3. Policy OSL2 Greenways in the draft Plan Strategy requires greenway proposals to meet the General Policy, which includes criteria relating to Sustainable Development (part e) iv). 28

4. A number of routes were suggested to form part of the green network. 5. Important to provide new routes but also ensuring the protection of existing linear open spaces, greenways and railway lines. 6. HED stated that it is important that heritage assets are protected and that any future guidance should take account of the historic environment.

Key Issue 18 Play Park Provision

1. A number of respondents thought that consideration should be given to the provision of more imaginative play equipment. 2. Suggested that play parks should also be provided within smaller residential sites, some suggestions included:  Lowering the threshold to sites of 20 units or more; or  On smaller sites, developers could be provided with an incentive to include such facilities perhaps through any developer contribution policy. 3. DfI suggested that play parks should not be limited to within residential developments and that the need for such facilities should be included in the overall Open Space Strategy for the Borough. Key Issue 19 1. Unsupportive views varied from lowering the threshold Open Space for providing open space to there being no necessity for Provision in open space. New Residential 2. The delivery of open space under PPS 8 was criticised Developments and it was highlighted that the 10% target is rarely reached and that any policy change to reduce this amount should be avoided.

4. Where specific routes have been suggested to form part of this network, we will take account of these in preparing the Local Policies Plan alongside greenways designated in existing area plans and within DfI’s proposed regional network. 5. SGS9 Open Space Strategy and Policy OSL2 Greenways in the draft Plan Strategy aim to protect the regional and community greenway network. Policy TR4 Disused Transport Routes in the draft Plan Strategy aims to protect those disused transport routes identified in the plan where there is a reasonable prospect of re-use for future transport purposes or where this is not the case for alternative appropriate recreational/nature conservation or tourism uses. 6. It is considered that the importance of the historic environment in relation to such proposals has been adequately addressed in Policy OSL2 Greenways in the draft Plan Strategy which states that proposals will have to meet the General Policy and accord with other provisions of the LDP. This includes policies protecting the historic environment. 1. Local needs for the level and type of equipped children’s play spaces will be assessed taking into account the Council’s Play Strategy. 2. Policy OSL4 Public Open Space in New Residential Development in the draft Plan Strategy sets out that residential developments of 100 units or more/five hectares or more should provide an equipped children’s play area unless otherwise specified through key site requirements on sites zoned in the Local Policies Plan. The threshold of 100 units has been used in PPS 8 for a number of years and lowering this to 20 units or more would not be viable or in line with Council’s Play Strategy which is for more informal local play areas and better equipped centralised play areas. 3. When preparing the Local Policies Plan, key site requirements will be applied to zonings to assist delivery where necessary. This approach will not preclude play park proposals outside residential developments and is not intended to be the sole method of delivery. 1. The SPPS requires new residential development of an appropriate scale to provide adequate open space. Such a policy approach has multiple benefits including improving health, visual amenity, conserving and enhancing biodiversity and protecting the setting of historic and archaeological assets. 2. Policy OSL4 Public Open Space in New Residential Development in the draft Plan Strategy states that a normal expectation will be at least 10% of the total site area or 29

3. RSPB advocated the provision of green spaces that are ecologically functioning. They suggested that biodiversity features should be incorporated into schemes such as SuDS, green roofs, living walls, wildlife friendly vegetation and lighting, wildlife corridors and wildlife homes. 4. NIHE suggested in considering policy for open space in new developments, existing habitats and vegetation should be conserved, as well as providing an opportunity to further promote biodiversity through uncultivated areas and green corridors. 5. DAERA: Natural Environment Division also stressed the importance of ensuring open space is linked through developments in order to provide a green network. 6. HED suggested that the presence of historic environment assets or archaeological remains within a residential site may warrant the provision of greater amounts of open space than those stipulated. Health, 1. Plan should be flexible if and zoned for ‘firm’ health/ Education, education/community proposals later become surplus Community and to requirements during the plan period, it should be Cultural released for alternative uses. Facilities 2. Proposed approach lacked ambition as it simply states what a plan led system will do when presented with such an application. The LDP needs to fully integrate the three pillars of sustainable development in order to be more proactive in delivering for the health and wellbeing of our population. 3. DfI Planning highlighted the need to remain flexible in our approach as more concrete proposals may come forward as the plan progresses. It was also raised that the delivery of such facilities should be linked into any policy approach taken on developer contributions. 4. HED felt that more consideration should have been given to the role of the historic environment and

15% where the site is 10 hectares or more. The later requirement was in response to the limited number of large developments in the Borough. It is the intention that where possible open space in new residential developments should form part of an integrated green and blue infrastructure network across the Borough and we will take account of this when preparing the Local Policies Plan. Council are content that the requirements and guidance within Policy HOU1 Quality in New Residential Development in Settlements and Appendix D (pages 330 and 331) and Creating Places are sufficient in this regard. Council are content that the requirements and guidance within Policy HOU1 Quality in New Residential Development in Settlements and Appendix D (page 331) and Policy OSL2 Greenways in the draft Plan Strategy are sufficient in this regard. Policy OSL4 Public Open Space in New Residential Development in the draft Plan Strategy states that the precise amount, location, type and design of public open space provision will be negotiated with applicants taking account of the specific characteristics of the development, the site and its context and this may include the presence of historic environment assets or remains.

1. As the LDP will be reviewed regularly there will be opportunities to reconsider zonings for health/education/ community proposals should they become surplus to requirements 2. Our LDP will aim to proactively deliver for the health and wellbeing of our population (see draft Plan Strategy Social Objectives and Section 8.2 Open Space, Sport and Leisure). Whilst also aware of how our rich historic environment can contribute to health and wellbeing. However, this particular issue dealt solely with proposals for health/education/community and cultural facilities. 3. Policy COM1 Education, Health, Community and Cultural Facilities in the draft Plan Strategy highlights that where a firm proposal for education, health, community and cultural facilities is in place on the part of a service provided land will be identified for such purposes in the Local Policies Plan. 4. This was not considered necessary as the draft Plan Strategy at paragraph 1.7.8 sets out that all policies considered relevant to the proposed development will be taken into account when determining applications. Therefore, where applicable the Historic Environment policies would be applied alongside Policy COM1 Education, Health, Community and Cultural Facilities

Key Issue 20 Reliance on the private car/ Promote sustainable transport and active travel

4. 5.

Key Issue 21 Areas of Car Parking Restraint (AoPR)

heritage assets and how they contribute to health, education, community and cultural needs. Some respondents stated a policy based on the preferred option could potentially make the single greatest contribution to securing sustainable transport and active travel, whilst others thought the approach needed to be even more ambitious. DfI would welcome widening the focus of this preferred option to ensure all aspects of sustainable transport promoted. Other comments included that all new development should be located/integrated so as to enable/support public transport provision and reduce dependence on private vehicles NIHE also supported the preferred option highlighting importance of ensuring new development includes sustainable travel patterns at the earliest stages of design and planning. HED welcomed the approach for sustainable travel and requested Council consider the historic environment and heritage assets in key site requirements and in locating any potential facilities. NIEA supported this policy which could be linked with green infrastructure. Invest NI and others commented that good transportation systems & connectivity is crucial to fostering economic prosperity and social integration. Facilitate more car sharing facilities / park and ride schemes at key locations around public transport nodes in the Borough, and also improvements to walk and cycle access routes to rail and bus stations is needed. Response rate on this issue was low with relatively evenly split support/unsupport. Comments included that AoPRS will assist in promoting more sustainable transport options within main towns, however, complementary transport measures are required to make them work. At present, the public transport network is simply not strong enough to justify a

1. The preferred option has evolved into various transportation policies in the draft Plan Strategy. These include a new element within Policy TR3 on the delivery of Transport Schemes by developers; a new bespoke policy on Active Travel (Policy TR5); and new criteria in Policy T6 on Parking and Servicing in relation to the level of parking provision in highly accessible locations or as part of a package of measures to promote alternative transport modes. In addition, Policy TR7 also promotes Park and Ride/Share proposals along with provision for security, safe access and movement of cyclists and pedestrians. 2. In addition to Policy TR5 on Active Travel, Policy TR3 now includes an element on the delivery of Transport Schemes (which include road, public transport provision, park and ride proposed and cycle/pedestrian networks). Policy TR6 also has criteria on an acceptable level of reduced parking in highly accessible locations. 3. The Transportation and Historic Environment policies in the draft Plan Strategy will be supplemented at Local Policies Plan stage with further detail including potential key site requirements. 4. Policies TR3 on New Transport Schemes and TR5 on Active Travel are also supplemented by Policy TR4 on Protecting Disused Transport Routes and Policy OSL2 on Greenways. 5. It is considered the full suite of Transportation policies (Policies TR1 – TR7) will collectively contribute to good transportation connectivity within our Borough. 6. Policy TR3 and TR7 both include detail on the provision of park and ride schemes. Council will continue to work with DfI and Translink in relation to future schemes as part of the Local Transport Plan and Local Policies Plan processes.

1. Given the low response rate on this issue and the relatively even split of comments in support of designating AoPRs, this issue was discussed further with Councillors in developing the draft Plan Strategy Parking Policies. There are currently no AoPRs in any of the adopted Area Plans for the Borough, with only draft BMAP proposing to designate an AoPR in Carrickfergus using the town centre boundary line. Whilst it is recognised that AoPRs may have a part to play in influencing the amount of parking and the overall modal choice of transport, it was considered this in itself was of 31

Key Issue 22 Protection of proposed road schemes

reduction in parking provisions. Others thought town little benefit to Ballymena, Larne or Carrickfergus without a much wider series of centres were already suffering from parking restrictions complimentary transport measures to support the designation of an AoPR. Without and this was not a matter for Planning. Retail NI stated such measures, it was considered it may even lead to having a detrimental impact that the introduction of AoPRs, whilst very unpopular, on the attractiveness of the retail offerings in those towns. It is considered the would reduce the reliance on private cars in the longer wording of Policy TR6 on Parking in relation to a flexible approach to reduced term. However, for such a policy to work effectively, parking standards in highly accessible locations can have a similar affect as adequate public transport services need to be available designating AoPRs. This Policy, coupled with a new proactive Policy TR5 on Active in advance and a phased approach adopted for the Travel are considered to be more beneficial to the local context of market towns introduction of AoPRs. Investment and improvements than designating AoPRs, and as such fully align with the requirements of the SPPS to in public transport could be achieved throughout the encourage more sustainable modes of transport. Borough via developer contributions or legal 2. Although not answered by the majority of statutory consultees, those few who agreements. responded were more in favour of designating AoPRs than not, however there were 2. Statutory consultees were more supportive of some conflicting views. Council consider the suite of Transportation policies in the designating AoPRs as a proactive measure towards draft Plan Strategy collectively contribute to place making and encouraging a modal bringing about successful place making, reducing private shift away from the private car and to other more sustainable modes of transport. car usage and encouraging more sustainable forms of transportation such as walking and cycling in the Borough. DfI highlighted the requirement for Council to promote parking policies necessary to bring this about in line with the SPPS. NIHE supported the aim to promote more sustainable modes of travel and the designation of AoPRs. However, somewhat contrary to this view, they also would like to see adequate parking provision for those living in town centres and above shops 1. DfI was supportive of the preferred option and 1. Since publication of the POP, DfI were no longer able to commit to producing a Local confirmed the Local Transport Strategy will identify Transport Strategy or identifying road/transport schemes within the Borough. The proposed transport schemes for the Borough. Whilst Council held numerous meetings with DfI Roads and DfI TPMU on this since 2016 they state it would be prejudicial to rule in or out any right up until publication of the draft Plan Strategy. The published draft Local transport schemes at this stage, DfI acknowledge, given Transport Study (DfI, 2019) did not contain any detail on these and as such Policy the time that has passed since these non-strategic roads TR3 is written to take account of the DfI Local Transport Plan and the BMTP when were designated in area plans, that it is not published. Both DfI Roads and DfI TPMU were instrumental in the formulation of the unreasonable to test these routes before committing to wording of this Policy. Council continue to work with DfI to identify transport them for the duration of the new LDP. DfI contend that schemes which need to be protected in the Local Transport Plan in conjunction with these non-strategic schemes are not just for vehicles the Local Policies Plan process. but also provide connectivity between developments and other existing network assets for cyclists and 32

Key Issue 23 Facilitating Renewable Energy

pedestrians. Suitable cycle, pedestrian and public transport facilities should be incorporated into the design for these routes, in the event that they are retained in the LDP. HED and NIEA both advised caution given that some of these non-strategic road schemes were designated some 20+ years ago and therefore were not considered in the policy context of PPS6, PPS2 or SPPS. Pointless protecting land for schemes that are not going to be implemented or funded by the DfI and continues the sterilisation of land for wish list schemes. Only schemes which are on a current DfI Roads Programme should be included in the LDP for protection. This enables the Council to seek developer led nonstrategic road improvement schemes. However, with some schemes nowhere near Housing zonings there is no private sector impetus to deliver these. Translink stated the LTS must also include requirements for bus routes, bus stops, turning circles, etc. for each road scheme, particularly if it is to facilitate new housing development. Respondents and statutory consultees views were mixed. Comments included the Borough generally, and AONB in particular, is ruined by turbines. An even more cautious and restrictive approach than alternative option 23(b) should therefore be considered. Others stated that sensitive coastal landscapes with strategic viewpoints, particularly the unique pattern of headlands, need protection from turbines. RSPB added the preferred option was not sufficiently ambitious and should seek to identify the most sensitive landscape zones remaining for protection (including species and habitats – not just visual quality) and incorporate elements of alternative option 23(b). HED had concerns regarding existing cumulative impact of renewable energy structures on landscapes and

2. Any transport schemes due to be protected through the Local Transport Plan and Local Policies Plan will be considered by the Council against current Policy and assessed for sustainability through the SA process. 3. All the legacy road schemes within the Borough are considered to be non-strategic and therefore will not be included within a DfI Roads Programme. These will therefore be required to be developer led and include active travel and sustainable transport connectivity as appropriate. 4. This will be a matter for consideration as part of the Local Policies Plan process. 5. Council will continue to work with DfI and Translink in relation to future schemes as part of the DfI Local Transport Plan and LDP Local Policies Plan processes.

1. Council are aware of the mixed views to renewable energy developments however, it is essential that renewables are welcomed and accommodated within the Borough in order to contribute to meeting the renewable energy and climate change targets. The responses and feedback from this Key Issue along the alternative option being supported by respondents to Key Issues 30 and 33 relating to the protection of the Islandmagee Coast and Antrim Coast and Glens AONB were further researched and discussed with numerous stakeholders and Councillors in the formulating of draft Plan Strategy Policies RE1 – Renewable Energy, Policy CS2 – SCAs and Policy CS3 – ACHSs. 2. Council have considered RSPBs comment both at POP stage and draft Plan Strategy and would state that the LDP designations are primarily landscape designations, however they can help support the aims and objectives of nature conservation designations and thereby contribute to conservation of biodiversity and help the LDP to meet the aims of the NI, EU and Council's own biodiversity strategies. Justification and amplification paragraph 5.9.22 in the draft Plan Strategy states 33

historic environment assets and consider benefits in alternative option 23(b) whilst HMC recommended alternative option 23(b) to ensure the protection of designated landscapes from inappropriate renewables development 4. Large scale ground mounted solar PV considered particularly inappropriate in open, upland landscape locations. 5. The LDP should prevent a growing concentration of turbines in certain areas. Others added LDP should identify and designate areas for turbines rather than allow for random development throughout the Borough. 6. The LDP should include renewable energy targets and support the contribution of renewables to combating climate change. 7. Quarry operators sought policy provision for renewable energy development associated with minerals operations to be considered generally acceptable. 8. NIHE agreed with preferred option and highlighted opportunity for LDP to take a holistic approach, developing energy policy that encompasses renewable energy development, energy efficiency and a reduction in energy demand. 9. Mid Ulster District Council encouraged consideration of a Special Countryside Area along Lough Beg as this would add further protection to this shared environmental asset. 10. SSE stated renewable energy developments should be considered on their individual merits as regional policy contains no suggestion that area-wide prohibitions on development would be appropriate whilst ABO Wind highlighted a need for flexibility in the LDP so that all renewable options remain open for consideration given that renewable energy technology is rapidly evolving.

4. 5.

6. 7.

9. 10.

that, 'Any development proposals which individually or cumulatively prejudice the overall integrity of the ACHS will be refused.' Criteria within Policy RE1 on Renewable Energy will also ensure the presence of a priority species or nature conservation sites will be given due regard in the decision-making process as each proposal will also be assessed against the Council's Natural Heritage policies and relevant European legislation. The LDP designations are primarily landscape designations which seek to protect from inappropriate development. Policy RE1 requires cumulative assessment of proposals, which along with criteria in RE1 and the General Policy will help ensure no unacceptable adverse impacts. The LDP Policies CS2, CS3, CS5, RE1, TOC1 and GP1 all seek to ensure that open, upland landscapes are protected from inappropriate developments. Council do not consider it a matter for the LDP to designate areas for wind turbines as this is largely market led with so many external factors such as land ownership, wind regime and connection issues. Council have instead outlined the landscape designations which may restrict certain types of development, with a presumption in favour for renewable energy developments elsewhere in the Borough outside these designated landscapes. The LDP includes renewable energy targets and seeks to support the contribution of renewable energy developments to combating climate change. It is considered the Policies on both Minerals and Renewable Energy are written in a flexible manner so that existing or former quarries can facilitate renewable energy schemes. Many of these issues are outside the remit of the LDP, however where it can, Council consider the LDP contributes positively through Policies RE1, TOC1 and GP1(e) v. The Council have worked closely with MUDC in drawing up the SCA boundary and Policy to ensure it aligns, where appropriate, with the neighbouring council area. All development proposals, including renewable energy developments are assessed on their own merits as part of the development management process. However, a Plan-led system is also required to give assurance and certainty to developers and the public. It is therefore appropriate for the LDP to set out policies and designations to apply within the Borough for various types of development. Paragraph 6.223 of the SPPS states a cautious approach for renewable energy development proposals will apply within designated landscapes which are of significant value, and their wider settings. Paragraph 6.75 of the SPPS also states that local policies may be

Key Issue 24 Sustainable Drainage Systems (SuDS)

Key Issue 25 Cemeteries

1. There was a positive response to this Key Issue with some respondents stating that SuDS policy and practices should apply in all new developments regardless of location or flood risk. Statutory consultees were supportive of the preferred option as a proactive measure to manage and mitigate flood risk with DfI Planning welcoming the change in emphasis from ‘encouraging’ to ‘promoting’ SuDs in a more proactive manner, and DfI Rivers endorsing the general comments on SuDS. 2. Other respondents suggested further opportunities for SuDS such as combining with renewable energy technology e.g. hydro schemes; in new road development or large surface car parks; on upland farms; and ensuring hard standing in developments allows drainage. 3. MUDC recognised the important role of SuDS but highlighted the absence of a statutory or legislative requirement to implement SuDS, whilst HED advised Council to carefully consider the impact of SuDS on any archaeological sites and heritage assets.

1. Consider the potential impact of cemetery extensions on buried archaeological deposits associated with earlier activity on ecclesiastical sites, and the impact on the character and setting of such sites. Carefully consider impact of facilitating future cemeteries through policy,

brought forward to maintain the landscape quality and character of Areas of High Scenic Value. ACHSs are designated to provide protection for landscapes of high scenic quality and of high amenity value from the adverse visual impacts of high or obtrusive structures. Whilst these policies may restrict certain types of developments, none of these policies preclude wind energy development. It is considered the policies as drafted ensure flexibility for emerging technologies. The monitoring and review mechanisms of the new LDP system will also ensure any shortfalls in policy to assess new renewable energy technologies or initiatives can be rectified at plan review stage. Council welcomed the very strong support given to the preferred option to promote rather than just encourage SuDS in new developments, and this has now been carried through into a new bespoke policy on Sustainable Drainage (Policy FRD4). This policy has been drafted in conjunction with DfI WDPD, DfI Rivers and NI Water and requires any new development triggering a drainage assessment must include a sustainable drainage solution, unless it is demonstrated through that drainage assessment that the site is fundamentally unsuitable for SuDS. The justification and amplification of the policy recognised the opportunities and benefits or SuDS and also acknowledges the difficulties of implementing SuDS, particularly ‘soft SuDS’ in some developments or locations. These suggestions were welcomed and considered in formulating not only Policy FRD4 on SuDs, but also policy TR7 on Car Parks and RE1 on Renewable Energy. It is also hoped that as experience of SuDS grows, more types of developments will be able to avail of SuDS solutions and technologies in the future. This will be monitored as part of the ongoing monitor and review process with further steps envisaged as Plan Review stage on taking SuDS to the next level. Council are fully aware of the issues in relation to management and maintenance and in particular the absence of a regulatory body for consultation on and adoption of SuDS schemes. Since the publication of the POP, a member of the LDP team has sat on the DfI Stormwater Management Group in order to gain knowledge of SuDS and input into the formulation of the SuDS Manual for Northern Ireland and the formation of a regulatory body for advising on and approving SuDS. Under Policy OSL7 Cemeteries and Burial Space, paragraph 8.2.42 highlights that applicants should consider any potential impact on the historic environment, in particular in the re-use of, or extension to, historic church sites and graveyards.

Key Issue 26 Protecting regionally significant archaeological sites and harmful development

particularly in relation to heritage assets and historic graveyards and their settings which are an extremely important part of the historic landscape. 1. ABO Wind NI Ltd acknowledged the importance of conserving and protecting the Borough’s built heritage and archaeological features but were strongly opposed to the preferred option stating that the existing policy provision within the Larne Plan Area Plan Policy MAN EN 1 is sufficient. 2. The existing policy provision was sufficient and that any additional protection may act as a barrier to appropriate development proposals thereby discouraging investment.

Key Issue 27 1. The removal of certain permitted development rights Protecting should be extended to include small settlements where architectural existing architectural features are threatened. and historical 2. Care should be taken to ensure that the introduction of character within Article 4 Directions does not lead to properties of our architectural significance being neglected if regulations conservation are too strict and Translink advised caution in the areas wording of this policy to ensure that Ticket Vending Machines at key locations are not precluded. Key Issue 28 1. Concerns were raised that this would simply add an Safeguard our unnecessary layer of uncertainty and subjectivity and Non-Designated that there is a need for a more flexible approach by Heritage Assets statutory agencies to allow for appropriate sympathetic alterations to historic buildings so as to act as a catalyst for regeneration.

Strategic Focus Areas

1. RSPB suggested that biodiversity considerations should be included within this approach to ensure that the protection and enhancement of urban biodiversity can be achieved.

1.-2. Council considers that the SPPS provides scope for the designation of ACHS. Paragraph 6.75 of the SPPS states that local policies may be brought forward to maintain the landscape quality and character of Areas of High Scenic Value. The Council’s Landscape Character Assessment review has identified the areas within these designations as landscapes of high sensitivity and value. ACHS do not preclude any type of development. Where the principle of development is considered acceptable, each proposal will be assessed on its own merits. The policy allows for structures over 15 metres in exceptional circumstances where there is a demonstrable need for the structure, where there are no alternative sites outside of the designated area and when all other relevant policy tests are met, which ensures an appropriate level of flexibility is built into the policy. 1.-2. Council may consider the imposition of Article 4 Directions at the Local Plan Polices stage to restrict the range of permitted development rights within a particular area. The identification of any potential area(s) and which types of development may require planning permission will be informed and determined through detailed surveys and public consultation exercises.

1. Policy BH15 of PPS6: The Re-use of Non-Listed Vernacular Buildings already applies and there is scope within Policy HE8 to allow for the sympathetic conversion of Nonlisted Locally Important Buildings or Vernacular Buildings. The SPPS widens the scope as it refers to ‘Non-Designated Heritage Assets’. Such assets include not only vernacular buildings, but also historic buildings of local importance. The SPPS also goes beyond the ‘re-use’ of the assets, by requiring the planning authority, to consider the impact of any application on the significance of a non-designated heritage asset. The SPPS does not provide any specific criteria but does suggest that it may be prudent to bring forward bespoke policies in the LDP for such buildings. 1.-3. The overall aim of Strategic Focus Areas is to support the successful and sustainable development of discrete urban areas that are strategically important for our Borough, in regard to sustainable tourism, economic growth, heritage and unique amenity value. Policy SF 01 is not intended to be overly prescriptive, rather the 36

Key Issue 29 The Southern Glens Coast

Key Issue 30 The Islandmagee Peninsula and Gobbins Coast

2. Translink indicated that their operational requirements need to be catered for within this preferred approach to place-making. 3. One respondent suggested that whilst this approach would result in a high quality built environment and public realm any design criteria should not be overly prescriptive or constraining. 1. The majority of respondents were generally supportive of the preferred option, however, there was some support for alternative option (b) which was to retain the existing SCA designation and associated policy. 2. Policy should make provision for some small, discrete sites with facilities. 3. The requirements of people living in the area should be taken into consideration in any policy amendments. 4. A representation on behalf of quarry companies state that there is no requirement for an ACMD designation to be implemented along the coastline with the AONB and SCA providing adequate policy protection for the landscape and other natural and heritage assets within this part of the Borough.

1. Generally, it was expressed that there is a need to protect sensitive areas on the peninsula from inappropriate development. Some comments referred specifically to the adverse visual impacts that wind turbines and electricity infrastructure has had on the landscape in this area. However, it was also recognised

purpose of this policy is to allow for the identification of key characteristics, landscape features, views and routes for sustainable transport modes at Local Polices Stage to ensure that these assets and their settings are protected and enhanced within the context of a spatial framework which has specific strategic aims and objectives for each area identified. The identification of any potential Strategic Focus Areas will be informed and determined through detailed surveys and public consultation exercises as part of the Local Plan Policies Stage. 1. Given that 85% of respondents supported the Preferred Option, which included considering amendment of the policy to allow for some minor development, Council considered this heavily outweighed the respondents that did not want the policy relaxed in any way and so went with the preferred option. 2. Policy CS2 includes exception e) which permits a proposed development, which relates to the provision of appropriate open space, pathways or recreational facilities or the enjoyment of the public and exception f) which permits council led or supported tourism projects at an existing tourist/ visitor site. All exceptions are subject to no adverse impact on the landscape quality, landscape character, unique amenity value, or environmental assets of the SCA. 3. Policy CS2 includes exception b) which permits in-situ replacement dwellings or buildings of the same use and similar in size and height as the existing. Exception c) also permits minor extension or alteration of existing dwellings provided they are sympathetic in character and scale to the original dwelling. All exceptions are subject to no adverse impact on the landscape quality, landscape character, unique amenity value, or environmental assets of the SCA. 4. Existing ACMDs were designated under Larne Area Plan 2010, which went through a public inquiry process. Council have taken a precautionary approach to maintain the existing ACMDs and not seek to identify new ACMDs or MRAs until a sufficient evidence base is in place. Council have removed from the ACMD designation, the one quarry that lies within the existing ACMD. DFE advised there was no immediate demand for new quarries in the borough. 1. Policy CS2 ‘SCAs’ and Policy CS3 ‘ACHSs’ in the draft Plan Strategy both offer protection for these sensitive areas from inappropriate development which may have an adverse impact on those landscapes. Policy CS2 offers an exception for ‘proposals of national or regional importance’, whilst Policy CS3 offers exceptions for ‘where there is a need for a structure of this height’ and ‘where the proposal is of such regional importance (significance)’. It is considered these exceptions recognise the strategic role of electricity/energy infrastructure in these parts of the Borough. 37

Key Issue 31 The Belfast Lough Shoreline Key Issue 32 Lough Beg and the Lower River Bann Corridor

by some respondents that Islandmagee has an important strategic role for the NI energy sector. Some respondents stressed the importance of Larne Lough and the surrounding area as a valuable wildlife area, noting the designations in regard to sites of international and national importance for nature conservation. They therefore argued for increased policy protection through the LDP. One respondent, whilst supporting the preferred option, stressed the need to give due consideration to the needs of residents in the area. NIEA were supportive but highlighted that any appropriate designation(s) and policy to protect sensitive areas on the Islandmagee peninsula would need further consideration and clarification HED highlighted the importance of an evidence base to indicate how the historic environment has been considered in any new policy approach.

1. DfI Planning stated that they support the intention to retain the existing BMA Coastal Area designation. NIEA expressed support also and agreed that spatial amendments may be required. 1. Comments received stressed the need to protect these areas from inappropriate and unnecessary development, particularly residential development. Others stated there needs to be consideration given to the people of the area who want to develop their land. 2. RSPB contend that peat extraction be terminated and appropriate management of this habitat pursued.

2. The draft Plan Strategy recognises and replicates the extent of all international and national environmental designations around Larne Lough and the Natural Heritage policies NAT1-NAT5 support these designations. 3. Policy CS2 considers residents in the areas as it includes exception b) which permits in-situ replacement dwellings or buildings of the same use and similar in size and height as the existing and exception c) which permits minor extension or alteration of existing dwellings provided they are sympathetic in character and scale to the original dwelling. All exceptions are subject to no adverse impact on the landscape quality, landscape character, unique amenity value, or environmental assets of the SCA. Policy CS3 permits structures such as domestic wind turbines subject to meeting selected criteria. 4. Various sources of evidence have informed the need for, and extent of any designation on the Islandmagee Peninsula. These documents include the Council’s Landscape Character Assessment and Candidate Sensitive Landscape Report (part of Technical Supplement 10 of the draft Plan Strategy) and other publications such as the NI Regional Landscape Character Assessment, NI Regional Seascape Character Assessment and 'Wind Energy Development in NI Landscapes'. Council consider that these documents represent a robust and informed evidence base for assessing the landscape sensitivity and value of the Borough’s landscapes. 5. Technical Supplement 10 – Appendix A -Landscape Character Assessment, page 145 includes information on the Historical and Cultural Influences on the Islandmagee Peninsula and Gobbins Coast. 1. Policy CS6 – The Developed Coast - has been retained from BMAP and renamed ‘Belfast Lough Shore’. The designation was amended to reflect the new SCA at the Gobbins and prevent overlapping. It was also refined in a small number of places to better align with a fixed/prominent feature on the ground e.g. the railway line. 1. Council considers it has struck an appropriate balance between protection of Special Countryside Areas and consideration for people living in these areas. The eastern fringes of Lough Beg have been designated a Special Countryside Area to protect its unique amenity value and international status as a wetland habitat. There is a presumption against all new development in SCAs, however, the exceptional circumstances listed, permit similar sized in-situ replacements and sympathetically scaled minor extensions or alterations to existing dwellings. 2. Policy MIN7 – Peat Extraction – has a presumption against commercial peat extraction except where peat is already degraded and not capable of restoration or

Key Issue 33 Antrim Coast and Glens Area of Outstanding Natural Beauty

1. Some locations put forward for inclusion within spatial policy areas included the Coast Road, coastal villages and headlands, Feystown/Glenarm area, the Garron Plateau, the Glenwherry area, Sallagh Braes and Slemish. 2. Reasons received for opposition to the preferred option included the need for more flexible design policy. 3. The preferred option is too precautionary in terms of stifling opportunities for minerals development. One representation on behalf of eight quarry companies advocated removal of existing Areas of Constraint on Minerals Development and stated that the limited availability of high-grade Ulster White limestone in NI to be worked in areas within the AONB. 4. NIEA state that parts of the AONB have been, and continue to be, impacted by the cumulative impacts of development over time, including pressure from wind energy development. They welcome the proposal to designate part of the AONB as a SCA. However, they have concerns that, by, implication, protection for the remaining parts of the AONB may be diminished. 5. HED state that protection of the unique landscape setting of Slemish is desirable and both HED and Historic Monuments Council recommend that Knockdhu ASAI would benefit from additional policy protectionHED indicate that Knockdhu has strong tourism potential as part of the Ulster Way. 6. ABO Wind NI Ltd and RES Ltd were unsupportive of the preferred option because of their overriding aims to further promote renewable energy. Justification for this position was the importance attached to renewable energy projects in mitigating against climate change, for producing clean competitively -priced energy ensuring security of energy supply, and in attracting inward

where extraction is linked to a long term management and restoration plan to deliver improved peatlands. The whole Borough has been assessed with various sources of evidence having informed the need for, and extent of the areas designated under policies CS2 – Special Countryside Areas and CS3 - Areas of Constraint on High Structures. These documents include the Council’s Landscape Character Assessment and Candidate Sensitive Landscape Report (Technical Supplement 10 Appendix A and E) and other publications such as the NI Regional Landscape Character Assessment, NI Regional Seascape Character Assessment and 'Wind Energy Development in NI Landscapes'. Policy CS5 – Antrim Coast and Glens Area of Outstanding Natural Beauty seeks to protect, conserve and where possible enhance the scenic quality and distinctive character of this area as a landscape of National importance that is designated under the Nature Conservation and Amenity Lands (NI) Order 1985. The policy allows for development which reflects the design characteristics of local vernacular buildings which are carefully sited and designed. Council consider that this along with details such as materials, finishes and boundary treatment are necessary to ensure satisfactory integration of development into this important landscape. Existing ACMDs were designated under Larne Area Plan 2010, which went through a public inquiry process. Council have taken a precautionary approach to maintain the existing ACMDs and not seek to identify new ACMDs or MRAs until a sufficient evidence base on supply and demand is in place. Council have removed the Ulster White Limestone quarry which lies within the existing ACMD from the designation. Council are aware that another Ulster white limestone quarry lies within the AONB and advise that the AONB policy (CS5), does not preclude mineral development subject to criteria listed. Council have carefully assessed the whole borough and carefully selected the limited landscapes which are particularly vulnerable to the visual impact of high structures, using sources of evidence outlined in point 4 of Key Issue 30 above. Roughly, one third of the Antrim Coast and Glens AONB that falls within MEA borough has been designated as an Area of Constraint on High Structures. Council consider that the revised criteria in AONB policy CS5 offers an appropriate level of protection to the remainder of the AONB. J&A paragraph 5.9.34 explains that new development including infrastructure must respect the natural beauty of the area by relating well to local landscape character. Both Slemish and Knockdhu ASAI have been included as Areas of Constraint on High Structures. 39

investment. It was suggested that robust assessments of proposals should be done on a case-by-case basis against current regional planning policy. 7. RES Ltd expressed concern that areas of constraint on wind turbines in areas considered to be sensitive could significantly reduce the likelihood of viable wind farms coming forward, particularly if these designations include upland areas.

Key Issue 34 Areas of Scenic Quality

1. These areas need protection from the adverse impacts of inappropriate development and the cumulative impacts of development. Also, perceived threats to the landscape character of these sensitive areas include wind turbines, tall utilities infrastructure, large-scale solar projects and industrial structures. 2. NIEA state that any appropriate designation and policy would require further consideration and clarification and indicate that existing AOHSV boundaries may need reviewed.

6. and 7. All development proposals, including renewable energy developments are assessed on their own merits as part of the development management process. However, a Plan-led system is also required to give assurance and certainty to developers and the public. It is therefore appropriate for the LDP to set out policies and designations to apply within the Borough for various types of developments. Paragraph 6.223 of the SPPS states a cautious approach for renewable energy development proposals will apply within designated landscapes which are of significant value, and their wider settings. Paragraph 6.75 of the SPPS also states that local policies may be brought forward to maintain the landscape quality and character of Areas of High Scenic Value. ACHSs are designated to provide protection for landscapes of high scenic quality and of high amenity value from the adverse visual impacts of high or obtrusive structures. Whilst these policies may restrict certain types of development, none of these policies precludes wind energy development. The draft Plan Strategy retains the presumption for renewable energy developments in the rest of the Borough. In addition, the monitoring and review mechanisms of the new LDP system will also ensure any Policy shortfalls in being able to assess new renewable energy technologies, initiatives or meet renewables/climate change targets can be rectified at plan review stage. 1. Given the cautious approach to renewable energy development within designated landscapes and their wider settings, which are of significant value, stated in paragraph 6.223 of the SPPS, and the direction that paragraph 6.75 of SPPS gives to protecting the landscape quality and character of Areas of High Scenic Value, the areas named in this Key Issue have been included as locations where policy CS3 – Areas of Constraint on High Structures’ applies. This policy requires structures of increasing height to meet tighter visual and need criteria as well as the need for other forms of infrastructure to not be visually prominent or impactful on the landscape character of these areas. 2. These areas, along with others were examined using various sources of evidence to inform the need for them and their extent. These documents include the Council’s Landscape Character Assessment and Candidate Sensitive Landscape Report (part of Technical Supplement 10 of the draft Plan Strategy) and other publications such as the NI Regional Landscape Character Assessment, NI Regional Seascape Character Assessment and 'Wind Energy Development in NI Landscapes'.

Key Issue 35 Local Landscape Policy Areas

1. Whilst supportive, some respondents including NIEA stated that it would be prudent to review existing LLPAs, particularly where there is existing industry. 2. Within settlements, regional planning policy is sufficient to ensure sympathetic development. 3. HED considered it important to demonstrate how historic environment evidence has been taken into account in informing appropriate designations.

Key Issue 36 Landscape Wedges

1. 64% of respondents were of the opinion that there are no Landscape Wedges that should be considered for designation. Although areas around the settlements of Broughshane, Carrickfergus and Larne were suggested for designation, the support for additional Rural Landscape Wedge designations was weak. In addition, 75% of public respondents did not consider there to be areas within our settlements that could perform the strategic function of an Urban Landscape Wedge. Although Bashfordsland Wood and areas within Ballymena and Broughshane were put forward for designation, support for the introduction of Urban Landscape Wedge designations was weak. 2. NIEA suggest that the boundaries of existing landscape wedges may need reviewed. 1. DfI Planning highlighted the “precautionary principle” and stated that Council must ensure they take account of policy in relation to natural heritage detailed in paragraphs 6.172 - 6.198 of the SPPS.

Existing Planning Policy Review

1. Justification & Amplification paragraph 5.9.42 of Policy CS7 –Local Landscape Policy Areas – explains that existing LLPAs designated in the Carrickfergus area through the draft BMAP will be reviewed and other LLPAs in the legacy Larne and Ballymena areas will be considered at the Local Policies Plan stage. 2. LLPAs are often designated to protect those areas adjoining as well as within settlements, which are considered to be of the greatest amenity value, landscape quality or local significance, so regional planning policy within settlements would not be enough in these instances. 3. J&A paragraph 5.9.43 explains that the policy seeks to protect those features and qualities that are of intrinsic environmental value or local significance in regard to amenity or historic environment and refers to SPPS advice that LLPAs can include, among others, archaeological sites and monuments, listed or other locally important buildings. 1. Following the lack of support for additional rural or urban landscape wedges, Policy CS4 has only retained the existing rural landscape wedges on either side of Greenisland, identified in BMAP. 2. Should the development limits of Carrickfergus or Greenisland which abut the Rural Landscape wedges, change at Local Policies stage, the extent of the designation will adjust accordingly to prevent the coalescence between these settlements.

1. The wording of NAT1 is carried forward from NH1 with no changes save from replacing ‘Department’ with ‘Council’. The stronger wording of SPPS is not included in policy wording as NIEA advised wording of existing Policy NH1 should remain as it ensures that it meets the very high level of statutory provision for European and RAMSAR sites. NIEA confirm that policy does not have to say ‘required by law’ as long as council recognise that it is a legal requirement.

2. In response to, PPS 8 policies OS 3: Outdoor Recreation in the Countryside and OS 7: The Floodlighting of Sports 41

and Outdoor Recreational Facilities, NIEA requested that the impact of floodlighting on bats is highlighted. NH 5- NIEA highlighted the following issues:  unsure of the definition of “species-rich grasslands” as it differs to the grassland priority habitats. They stress that if an additional category is being considered, it is advisable for Council to review the Habitat Action Plans (HAPS) to ensure there is no or little overlap with existing categories and to provide an equivalent level of detail at species level to support this category;  note that “green and blue infrastructure” can include manmade infrastructure, and stress that it will be important to provide a definition of what features this category will protect; and  further consideration should be given to what features the “Undeveloped Coastal Areas” category is considering to protect, as there is likely to be significant overlap with this category and priority habitats. DfI Roads expressed opposition to any additions to the list of exceptions provided in AMP 3 and requested further discussions with LDP team on this and any amendments to wording of (b). A further respondent suggested additional criteria that may be beneficial to Policy AMP 3 in specific cases DfI TPMU supported expanding the wording of AMP 5, suggested additional wording. DfI Planning also advised that the LDP should take into account the importance of protecting linear open spaces such as pedestrian and cycle routes, community greenways and amongst others, former railway lines. DfI TPMU supported expanding the wording of AMP 8 and suggested additional wording and offered to hold further discussion with the Plan team

2. Paragraph 8.2.36 in the justification and amplification of Policy OSL5 Sport and Outdoor Recreation Facilities highlights that bats are sensitive to floodlighting and proposals should ensure no significant impact on them. 3. Taking account comments received from NIEA, Council did not bring forward the categories “Species-rich grasslands”, “Undeveloped Coastal areas” or ‘Green and Blue Infrastructure’.

4. Since the POP, we have worked closely with DfI Roads both in one to one meetings and through the Project Management Team to ensure the re-drafting of AMP 3 of PPS 3 into Policy TR2 of the draft Plan Strategy addressed DfI Roads’ concerns. DfI Roads’ response to the draft Plan Strategy confirmed they are content with the Policy.

5. Policy TR4 – Disused Transport Routes and Policy OSL2 – Greenways ensure the protection of such for future transport, recreational, community, nature conversation or tourism related uses.

7. BH 13- Care should be taken relating to interactive displays which enable the appropriate enjoyment of the area.

10.

11.

12.

6. Policy TR5 – Active Travel updates AMP 8 of PPS 3 to include a requirement for all new development in urban areas to take into account the needs of both cyclists and pedestrians by providing safe and convenient access, secure parking, and links to active travel networks and public transport from the proposed development. 7. The majority of statutory consultees and public respondents were supportive of the BH 13- Translink advised caution in the wording of this introduction of specific policy wording relating to the control of flashing, scrolling, policy to ensure that passenger information signage at animated, intermittent or moving digital signage. Policy AD1 of the draft Plan Strategy bus stops are not precluded. has introduced additional policy criteria relating to digital advertising screens and it is considered that the proposed amendments are sufficient to protect amenity. Consideration should be given to the introduction of 8. The Planning (General Permitted Development) Order (Northern Ireland) 2015 under ‘protection of amenity’ within BH 13 to ensure adequate Class E Road Passenger Transport Undertakings provides permitted development protection from potential light nuisance. relating to; (a) the installation of telephone cables and apparatus, huts, stop posts and signs required in connection with the operation of public service vehicles. BH 15- HED acknowledged non-listed vernacular 9. Policy AD1 of the draft Plan Strategy under sub-heading, ‘All Advertisements’ criterion properties may lend themselves for use for a variety of (b) stipulates that consent will be refused if it is determined that the effect of any class types (dwellings and others). In addition, they state illumination used on the advertisement, particularly on the locality or a neighbouring that the conservation and reuse of vacant historic property, is detrimental to amenity. buildings should be heritage led to safeguard the 10. Council consider that further engagement with HED and other relevant bodies is property and its setting from inappropriate necessary to take account of the deliverability of the creating a ‘Local List’ and its interventions. HED advocates councils identifying workability in terms of identifying historic buildings of local importance. historic buildings of local importance in their area and referred to recently published guidance on the topic “Historic Buildings of Local Importance, A Guide to their Identification and Protection – May 2017”. BH 15- In regard to extensions, HED suggested that any amended policy should require such a proposal to be subservient to the parent building and respect the essential character and architectural and historic interest of the parent building and its setting.’ 11. Policy HE8 of the draft Plan Strategy includes criteria that ensures that any conversion and/or re-use of a non-listed locally important building or vernacular building has to maintain or enhance the form, character, architectural features and setting of the existing building and not have an adverse effect on the character or NIHE stated that they supported the amendments to QD appearance of the locality, be subservient to the existing and adjacent buildings with 1 to introduce additional criteria to promote energy regard to height, scale, form and massing and that any new extensions, alterations efficient design and the use of SuDS. They repeated or adaptations should not significantly alter the integrity of the existing building or their aspirations for all new housing to be beyond its setting and must be of high quality. 43

current building control standards to achieve SAP rating 12. Rather than applying criteria regarding energy efficiency and use of SuDs to housing A and promote the use of renewable energy within developments only, such criteria have been added to Policy GP1 in the draft Plan developments. Strategy so it will apply to all new buildings– see GP1 criteria e) iii and v. 13. OS 3- NIEA raised concerns regarding possible night time lighting which could potentially impact upon foraging and roosting bats. NIEA requested that the protected species policy is signposted within the plan to ensure due consideration throughout the planning process. 13. and 14. Paragraph 8.2.36 in the justification and amplification of Policy OSL5 Sport 14. OS 7- NIEA request that the policy signposts the and Outdoor Recreation Facilities highlights that bats are sensitive to floodlighting protected species policy in the plan to ensure the and proposals should ensure no significant impact on them. Policy NAT2 of the draft impact of floodlighting on bats is considered. Plan Strategy is signposted. 15. HS 1- NIHE suggested an amendment to this policy to incorporate reductions in parking standards for dwellings over a shop. 16. DfI advised that Council should clearly demonstrate how 15. Policy TR6 Parking and Servicing in the draft Plan Strategy allows for reduced the general principles in PPS 13 have been incorporated parking standard in certain circumstances, including in highly accessible locations into the transportation policies in the LDP. and where there is capacity in nearby public car parks of adjacent on street car parking. 16. The 12 General Principles of PPS13 have been taken into account in the Transportation policies in the draft Plan Strategy as follows:  General Principle 1 - The integration of transportation policy and land use planning should be taken forward through the preparation of development plans and transport plans informed by transport studies. o Council have worked closely with DfI Roads and DfI TPMU in the formulation of both the Local Transport Study (DfI, 2019) and the Transportation Policies in the draft Plan Strategy through numerous one to one meetings as well as DfI Roads, TPMU and DfI Planning being involved in all the LDP Project Management Team meetings. Council will continue to do so in the formulation of DfI’s Local Transport Plan which will help inform the LDP Local Policies Plan.  General Principle 2 - Accessibility by modes of transport other than the private car should be a key consideration in the location and design of development. o Transportation policies TR1, TR3, TR5, TR6 and TR7 all contain elements in relation to accessibility by modes of transport other than the private car. In addition, accessibility and design will be considerations when identifying the locations of

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lands to be zoned for various types of development, however this is a matter for the Local Policies Plan process. General Principle 3 - The process of Transport Assessment (TA) should be employed to review the potential transport impacts of a development proposal. o Criteria c) iii. of General Policy GP1 states that development proposals will have to demonstrate the existing road network has sufficient capacity or can be adequately upgraded to safely manage any extra vehicular traffic that the proposed development will generate. Paragraph 6.1.9 of the justification and amplification of that policy then states that a development proposal generating significant travel movements must be accompanied by a Transport Assessment as a means of demonstrating the proposal meets criteria c) iii. General Principle 4 - Travel Plans should be developed for all significant travel generating uses. o Paragraph 6.1.9 of the justification and amplification of General Policy GP1 criteria c), goes on to state that ‘where appropriate, a Travel Plan setting out complimentary measures to help mitigate any adverse impacts highlighted by the Transport Assessment should be submitted as part of the assessment of that development proposal’. General Principle 5 - Developers should bear the costs of transport infrastructure necessitated by their development. o Paragraph 6.1.9 of the justification and amplification of General Policy GP1 criteria c), also states ‘where a Transport Assessment concludes that a development necessitates the provision of additional infrastructure or improvements to existing infrastructure, these costs shall be borne by the developer. General Principle 6 - Controls on parking should be employed to encourage more responsible use of the private car and to bring about a change in travel behaviour. o Policy TR6 on Parking and Servicing, whilst ensuring there is adequate provision for parking, also offers a reduced level of parking in highly accessible locations or where through a Transport Assessment a package of measures to promote alternative transport modes. Policy TR7 on Provision of Car Park also seeks to tightly control the development of car parks, including temporary car parks, whilst promoting those identified as a need such as Park and Ride/Park and Share schemes. In addition, Policy TR3 – Active Travel seeks to encourage a change in travel behaviour in new developments.

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17. DfI Rivers advised Council should have a Local Policies Plan policy dealing with reservoir flood risk that complies with the SPPS and suggested that they will liaise closely with all councils regarding any departure or additions to FLD 5 to ensure soundness at IE.

18. TSM 8 - HED recommend the wording should be amended to include reference to the historic environment.

General Principle 7 - Park and ride and park and share sites should be developed in appropriate locations to reduce the need to travel by car and encourage use of public transport. o Policy TR7 on Provision of Car Park seeks to tightly control the development of car parks, including temporary car parks, whilst promoting those identified as a need such as Park and Ride/Park and Share schemes.  General Principle 8 - Land required to facilitate improvements in the transport network should be afforded protection. o Policy TR3 New Transport Schemes in the draft Plan Strategy seeks to safeguard lands required for the implementation of a transport scheme.  General Principle 9 - Private car should be reduced through a modal shift to walking, cycling and public transport. o Policy TR3 – Active Travel seeks to encourage a change in travel behaviour in new developments.  General Principle 10 Rural public transport schemes should be developed to link rural dwellers to essential facilities and larger settlements. o The Council and the LDP have limited control over rural transport schemes.  General Principle 11 Innovative measures should be developed for the safe and effective management of traffic. o Although the role of Council is somewhat limited in this aspect, new Policies in the draft Plan Strategy on Active Travel (Policy TR5) and the delivery of transport schemes (Policy TR3) seek to play their part in influencing the management of traffic locally. Council will continue to work closely with DfI Roads and DfI TMPU in the formulation of the Local Transport Plan as part of the Local Policies Plan process. This DfI LTP is envisaged to include a car parking strategy which may contain innovative measures to manage traffic within the 3 main towns.  General Principle 12 The integration of transport and land use planning should seek to create a more accessible environment for all. o It is considered the Transportation policies collectively along with criteria c) of General Policy GP1 significantly contribute to the integration of transport and land use planning. In addition, there will be further opportunity to consider accessibility and integration of (sustainable) transport as part of the Local Transport Plan and Local Policies Plan process. 17. Council have worked closely with DfI WDPD and DfI Rivers in developing Policy FRD6 – Development in Proximity to Controlled Reservoirs’ to replace FLD5 of Revised PPS15. DfI Rivers responded to the consultation on the draft Plan Strategy 46

19. RE 1- Mixed response in regards to the need for policy for development in close proximity to existing electricity infrastructure ‘wrapping around’ future network operations/ expansions. SONI wanted the policy to assess the impact of not only renewables but all development. 20. CTY 3- HED advocated a heritage led approach to the reuse and conservation of historic buildings. 21. CTY 3- NIHE were unsupportive of the proposed amendments to CTY3 as they felt that an unduly restrictive policy may promote greenfield development.

consultation stating the proposed Policy FRD6 reflected DfI current thinking on this matter. They also added they considered the draft Plan Strategy to be sound, with the proposed flood risk policies all aligning well with Policies FLD 1 to FLD 5 of Revised PPS15 and the Flood Risk section of the SPPS. 18. Policy TOU1 Safeguarding of Tourism Assets in the draft Plan Strategy expanded the wording in TSM 8 to state that development should not have an adverse impact on a tourism asset such as to significantly compromise its amenity, setting and tourism value. It is considered that the proposed amendments are sufficient to protect historic tourism assets, alongside the Historic Environment policies in section 10.1 of the draft Plan Strategy. 19. Council had highlighted SONI’s desire for this wording to be included in Policy in order to protect electricity/energy infrastructure from development which may compromise the maintenance and future operations of that infrastructure. This has been carried through into the draft Plan Strategy as a criterion (h) for all renewable energy development in Policy RE1.

22. CTY 5- Over prescriptive policy for affordable housing in the countryside would hinder the ability to meet future challenges.

20. Policy HOU9 Replacement Dwelling in the draft Plan Strategy sets out how listed dwellings and unlisted vernacular dwellings will be considered. 21. It is considered that the justification and amplification of Policy HOU9 Replacement Dwelling in the draft Plan Strategy requiring the applicant to demonstrate that the building to be replaced meets criteria a and b in the policy through the submission of detailed plans, photos or other verifiable evidence should not led to increased 23. CTY 5- private landowners should be permitted to make greenfield development in the countryside. applications for social housing on a voluntary basis, as 22. Council expect the affordable housing needs of rural communities will be met largely this could help release land for social housing. within villages and small settlements. However, where an affordable housing need has not be foreseen, Policy HOU16 Affordable Housing in the Countryside in the draft Plan Strategy permits proposals that meet its criteria to be approved. This policy balances meeting rural affordable housing needs whilst protecting the character of the rural area. 24. CTY 8- clarification requested on the term 'substantial 23. Statutory consultees agreed that applications for affordable/social housing in the buildings' in order to prevent uncertainty. countryside should only be made by a registered housing association. NIHE believed this will ensure that properties are allocated to those in housing need. 25. CTY 10- Mixed response to whether a stricter Policy HOU16 Affordable Housing in the Countryside in the draft Plan Strategy integration test should apply to exceptional sites located therefore requires applicants to be made by registered housing associations. Note elsewhere on a farm. Schedule of Proposed Modifications suggests this should be amended to also allow NIHE to make such applications. 47

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24. Paragraph 8.1.69 in the justification and amplification of Policy HOU13 Ribbon/Infill IC 15- There should be flexibility for local shopping Development in the draft Plan Strategy, sets out detail on the term ‘substantial facilities and petrol forecourts outside of development buildings’. limits. 25. Policy HOU10 Dwellings on a Farm Business require all proposals that meet the MIN 1- policy should require proposals to demonstrate policy criteria to also meet the General Policy. Policy GP1 includes criteria relating how their carbon footprint is interrogated in line with to Development in the Countryside – see part f) i-viii. This seeks to ensure all rural climate change aspirations and policy. proposals do not have a significant impact on rural character, are sited appropriately and integrate adequately. 26. Policy RET4 –Rural Shops and Roadside Service Facilities was developed to reflect MIN 1- RSPB recommended that planning permission the SPPS direction in regard to retail development in the countryside and also to should not be granted for new or existing peat sites nor carry forward the thrust of IC15 of PSRNI in regard to roadside service facilities. should extant permissions be renewed. It was suggested 27. Policy MIN1 cross refers to General Policy GP1, in particular (d) criteria relating to that policy should ensure that biodiversity, Safety and the Safeguarding of Human Health/Wellbeing, and (e) criteria relating to environmental integrity and priority habitats/species Sustainable Development, which both refer to climate change considerations and should be protected. also ‘Reduce causes of and adapt to Climate Change’ is included as one of our MIN 1- It was recommended that clear and robust policy Sustainability Appraisal Objectives against which this policy was assessed. tests must be set out so that a criterion can be 28. Policy MIN7 –Peat Extraction and the amplification and justification were developed effectively assessed and measured by the decision to reflect the SPPS direction. It permits commercial peat extraction only where the maker. Any tests for potential impact on sensitive sites peatland is already degraded and not reasonably capable of restoration. (including those set at European Level through the Habitats Directive) should be appropriately incorporated into any policy wording of the LDP. MIN 1- underground mining techniques should be 29. Reference to hydrology impacts on European sites was added to the Justification and recognised for their ability to exploit resources with less relevant wording amended to reflect SES terminology in HRAs. Further amendments surface disruption and should be considered are proposed in the Schedule of Modifications to policy MIN1 wording to advise that appropriately in policy development. all proposals must accord with Policy NAT1. MIN 3- It was suggested that clarification is required around what is meant by “short term”. 30. Reference to underground mining techniques was removed as it was accepted that techniques can have minimal impact.

32. MIN 3- DfE recommended that ACMDs should not be utilised to apply blanket bans on exploration activities for high value mineral. 33. MIN 4- It was recommended that SPPS paragraph 6.157 is replicated in full within the LDP in order to provide

31. Initial wording to include ‘short-term’ extraction and define it as ’15 years’, is removed following DFE comment that there is no evidence to support this timeframe. DfI comment that council should have sufficient rationale for this 48

clarity with respect to valuable minerals and unconventional hydrocarbon extraction. 34. MIN 4- DfE suggested there should not be a presumption against exploration of high value minerals in any area including in statutory policy areas. 35. It was suggested that the proposed updates to MIN 5 should be supported with definitive mineral safeguarding areas. 36. MIN 5- policy should not seek to promote minerals development in certain areas, as economic considerations should not override environmental or social obligations. 37. MIN 6- policy should be worded to ensure any significant environmental and amenity impacts arising from minerals development proposals can be mitigated, otherwise refused. 38. MIN 6- DfE recommended that considerations of safety and amenity should be made in the context of the nature, duration and proximity of any proposed development, and any mitigation measures should be included as part of the proposal. 39. MIN 8- policy should ensures that sites are restored in order to enhance biodiversity.

timeframe which would include construction, operation, decommissioning, restoration and aggregate type. 32. In line with the SPPS, there is no general presumption against the exploration and exploitation of valuable minerals in the ACMD. Policy MIN4 Justification paragraph 7.4.28 explains. 33-34. This policy now only addresses valuable minerals and carries across the thrust of PSRNI MIN4. DfI Planning and DfE strongly supported the policy replicating the wording of paragraph 6.157 of SPPS ‘there will not be a presumption against exploitation of valuable minerals in any area’. However, the draft Plan Strategy applies exceptions to this approach within SCAs and it applies a cautious approach in other areas designated for their landscape quality. Hydrocarbons are now accounted for in new Policy MIN 3 following DfE recommendation to differentiate between extraction of hydrocarbons and valuable minerals. 35-36. DfE agree with the LDP approach to delay the potential designation of Mineral Reserve Areas until there is a better understanding of required supply and demand patterns for aggregates in the Borough and regionally.

37. This Policy is now incorporated within new Policy MIN1 – Extraction and Processing of Hard Rock and Aggregates. The policy outlines that proposals cannot have an unacceptable adverse impact on several interests including environmental and social factors 38. The particular aspect of PSRNI MIN6 regarding managing development in proximity to existing minerals operations is specifically addressed in the draft Plan Strategy through the new policy MIN 6 – Development at risk of Subsidence associated with 40. MIN 8- DfE suggested that in all cases restoration should past or present underground mineral extraction. be designed to secure the long-term safety and stability of the site and to prevent pollution. 39. The thrust of PSRNI MIN 8 is carried forward, with some detail moved to Justification and additional detail added to address the preferred types of reclamation and after use cited in the SPPS. Biodiversity is not specifically mentioned in paragraph 6.161 41. PSU 3- DfI Planning highlighted the importance of of SPPS however ‘enhance biodiversity’ is included as an example of a benefit that promoting Larne Port as a Gateway and ensuring there should be secured through the restoration proposals. is sufficient land zoned for its expansion. DfI Planning 40. In line with paragraph 6.167 of SPPS, the policy includes more detail on the type of also noted that Chapter 10 of the POP did not include information to accompany applications (Restoration Proposals and Management 49

information relating to the Port of Larne. They stated that sea ports present both major economic and environmental issues which should be addressed through the LDP. 42. PSU 11- SONI recommended additional policy wording that areas of landscape sensitivity be avoided “where possible”, following a consideration and balancing of all issues. 43. PSU 11- DfI Planning recommended that any new bespoke policy on overhead cables should reflect wording of the SPPS and also include broadband infrastructure. 44. PSU 11- HED and public respondents highlighted concerns regarding protection of heritage assets and conservation areas from inappropriately sited infrastructure projects.

Plan) to ensure sustainable progressive restoration and addresses the SPPS requirement to underpin by attaching appropriate conditions/agreement to permission. 41. Both the Economic and Transportation Chapters of the draft Plan Strategy highlight the importance of Larne as a Key Gateway location and the opportunities that brings for economic growth. The actual identification of lands at Larne Port and other lands to be zoned for economic development in Larne will be matters for consideration in the Local Policies Plan process.

42. It is agreed this may not always be possible. Policy TOC1 in the draft Plan Strategy includes a criterion (c) on this and is worded as ‘the proposal should avoid sensitive locations or features, unless it is clearly demonstrated to the satisfaction of the Council as to why this cannot be achieved’. 43. Council consider Policy TOC1 aligns with the SPPS and caters for broadband infrastructure (fixed and mobile).

45. PSU 11- need to use more underground infrastructure when power lines pose a risk to scenery, wetlands and tourism.

Other Comments

44. Policies on infrastructure proposals such as RE1 Renewable Energy Development, TOC1 Telecommunications and Overhead Cables all refer to other provisions of the LDP (i.e. other Policies within the draft Plan Strategy) and the General Policy which includes criteria a) iv. relating to ‘Design Quality and Respecting Local Character and Distinctiveness’, which states ‘The development does not adversely affect features associated with the historic environment/setting….and should seek to retain or integrate such features wherever possible.’ 45. Policy TOC1 includes wording in relation to keeping wirescape to a minimum, however it only requires applicants of proposals in urban areas to demonstrate that cables/wires cannot be provided underground.’ 1. NIEA - take account of Air Quality problems, Air Quality 1. ‘Improving Air Quality’ is included as one of our Sustainability Appraisal Objectives. Management Areas and Smoke Control Areas within the Air quality is also included within General Policy GP1 (d) criteria relating to Safety Borough. and the Safeguarding of Human Health/Wellbeing. 2. Proactively incorporate processes to tackle climate 2. ‘Reduce causes of and adapt to Climate Change’ is also included as one of our change (with renewables and a low-carbon economy at Sustainability Appraisal Objectives. Climate Change is also included within General the centre). Policy GP1 (d) criteria relating to Safety and the Safeguarding of Human Health/Wellbeing, and (e) criteria relating to Sustainable Development. Furthermore, 50

3. HED - review Agricultural Permitted Development regarding agricultural buildings and their impact on the setting of heritage assets. 4. NIHE requested the inclusion of a development management policy in respect of supported housing within the LDP and acknowledge that applications for supported housing should be prioritised and flexibility applied in the application of residential design standards, due to the specific nature of supported accommodation. 5. NIHE - introduce planning agreements or conditions attached to planning permissions for major developments, requiring the inclusion of a social clause. These social clauses could provide employment or training opportunities to young people or the long-term unemployed.

some of the policies in the draft Plan Strategy such as the Flood Risk and Drainage policies, Policy RE1 – Renewable Energy and TR5 – Active Travel, all have a part to play in tackling climate change. 3. This would require a change in Planning Legislation rather than through the LDP. 4. Whilst the draft Plan Strategy does not include a specific policy for the assessment of supported/specialised accommodation applications, Council is of the opinion that there is nothing within the draft Plan Strategy that would prejudice or prevent their development. 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. In addition, the justification and amplification of Policy COM1 states that this policy applies to residential care homes and nursing homes. 5. Council consider any such agreements considered appropriate can be delivered through the proposed draft Plan Strategy Policies. In addition, a developer contribution framework will be considered by Council at some stage in the future.

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