Local Development Plan 2030
Rural Needs Impact Assessment of the Draft Plan Strategy September 2019
www.midandeastantrim.gov.uk/planning
Rural Needs Impact Assessment
Contents Have your say
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How to respond
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1.0 Introduction
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2.0 What is meant by ‘rural’ and ‘rural needs’?
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3.0 Draft Plan Strategy Approach to the Countryside
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4.0 Main Issues Arising From Rural Needs Impact Assessment
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5.0 Rural Needs Impact Assessment
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Appendices Appendix A: Population Totals
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Appendix B: Information sources used to identify the social and economic needs of people in rural areas
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Have your say Mid and East Antrim Borough Council is consulting on the Mid and East Antrim Local Development Plan – Draft Plan Strategy 2030. The consultation arrangements and protocol are outlined on Page 7 of the draft Plan Strategy and on the Council’s website. A period of pre-consultation will run from 17 September 2019 to 15 October 2019. Thereafter, a period of formal public consultation will be open for eight weeks, commencing on 16 October 2019 and ending at 5pm on 11 December 2019, during which time formal representations to the draft Plan Strategy and associated documents can be submitted to the Council’s Local Development Plan Team. This formal consultation period offers an opportunity for everyone to submit a formal representation(s) to this Rural Needs Impact Assessment. Please note that representations received after the closing date on 11 December 2019 will not be considered. We welcome your comments on any aspects of the Rural Needs Impact Assessment. Such comments may include any consideration or reference to economic and social needs of the rural community, including any economic or social rural needs that have not been addressed within this assessment. All formal representations received will be given due consideration during the process of progressing the draft Plan Strategy through to formal adoption.
How to respond Representations should be submitted to the Local Development Plan Team via the following options: Online consultation portal: consult.midandeastantrim.gov.uk By email: planning@midandeastantrim.gov.uk By post: Local Development Plan Team County Hall 182 Galgorm Road Ballymena BT42 1QF We would encourage you to use the online consultation portal and to carefully read the accompanying guidance before completing your representation. Note: your responses are public documents that will be made available for public inspection and Independent
Examination. All responses will therefore be held on a database in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 (GDPR).
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1.0 Introduction 1.1
The Plan Strategy is the first main stage of the new two-stage Local Development Plan (LDP) process. The draft Plan Strategy sets out a vision to improve the quality of life for everyone through delivering high quality, sustainable and connected places. The vision will be pursued through the strategic objectives and policies and proposals in the Plan Strategy. The adopted Plan Strategy will provide a framework for the Local Policies Plan, the second stage of the LDP process. Once adopted in full, the LDP will be the primary consideration in decision making under the new plan-led system.
1.2
The draft Plan Strategy has been prepared with regard to the Regional Development Strategy (RDS) 2035, the Strategic Planning Policy Statement (SPPS) 2015 and our Community Plan. It has also been developed using a robust evidence base and has involved extensive engagement with statutory consultees including neighbouring Councils. The responses received in relation to our Preferred Option Paper (POP) have also informed the development of the draft Plan Strategy.
1.3
The Rural Needs Act (Northern Ireland) 2016 (‘the Rural Needs Act’) places a duty on councils to have due regard to the needs of people in rural areas (referred to as the ‘due regard duty’) when developing, adopting, implementing or revising a policy, strategy or plan, and when designing and delivering public services. In such cases, the DAERA publication ‘A Guide to the Rural Needs Act (Northern Ireland) 2016 for Public Authorities (Revised)’ (April 2018) (hereafter referred to as ‘the DAERA guidance’) recommends that a Rural Needs Impact Assessment (RNIA) should be conducted. Through the ‘due regard duty’, the Rural Needs Act seeks to ensure that consideration of the needs of people in rural areas is embedded within public policy making, thereby helping to deliver better outcomes for people in rural areas and encourage more sustainable rural communities.
1.4
This document sets out the RNIA for the draft Plan Strategy of our Local Development Plan 2030. The principles of rural proofing are incorporated in the RNIA process. These principles require the identification of the potential impacts that a policy or strategy would have on a rural area, a proper assessment of those impacts if they are deemed to be significant and, where appropriate, adjustments to the policy or strategy to take account of rural circumstances.
1.5
The DAERA guidance highlights that conducting a RNIA in itself does not equate to having due regard to rural needs. However, it does emphasise that the RNIA process can help public authorities ensure that the due regard duty is fulfilled. This RNIA uses the recommended RNIA template contained within Appendix 1 of the DAERA guidance.
1.6
The Rural Needs Act does not specifically require consultation in relation to rural needs. However, in line with the DAERA guidance, the Council will include this RNIA as part of the public consultation documentation for the draft Plan Strategy. In this context, this RNIA should be read in conjunction with the draft Plan Strategy, associated technical supplements and other publications and documents that have informed both the draft Plan Strategy and this RNIA. At the Preferred Option Paper (POP) stage, we consulted a number of specific rural groups as part of consultation and engagement with ‘Section 75 groups’. These rural groups will be consulted again as part of the consultation on the draft Plan Strategy and include the following:
NI Rural Women’s Network Rural Community Network Rural Support
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2.0 What is meant by ‘rural’ and ‘rural needs’? 2.1
Rural: The default definition of ‘rural’ used in Northern Ireland is that developed by the Inter-Departmental Urban-Rural Definition Group which classifies those settlements with populations of less than 5,000 together with the open countryside as rural (DAERA, 2018). However, the DAERA guidance recognises that alternative definitions of ‘rural’ may be appropriate for different projects and programmes.
2.2
For the purposes of this RNIA, the Council adopts the default definition used by the Inter-Departmental Urban-Rural Definition Group. Therefore, the rural area within Mid and East Antrim includes settlements which have a population less than 5,000 and areas of the countryside outside of settlement development limits1 (in accordance with SPPS para 6.61).
2.3
Based on the population figures for settlements published in the 2011 Northern Ireland Census2, the following settlements within Mid and East Antrim have a population of less than 5,000 and are considered part of the rural area:
Ahoghill Ballycarry Ballygalley Ballystrudder Broughshane Buckna (proposed) Cargan Carnalbanagh Carncastle Carnlough Clough Craigywarren (proposed) Crosshill Cullybackey Glarryford (proposed) Glenarm
Glenoe Glynn Grange Corner Kells/Connor Magheramorne Martinstown Milltown (proposed) Moorfields (proposed) Mounthill Mullaghboy Newtowncrommelin (proposed) Portglenone Raloo Slaght (proposed) Whitehead Woodgreen (proposed)
2.4
Note: the draft Plan Strategy proposes to designate eight new small settlements and de-designate 12 existing small settlements. The rationale for designating and de-designating these small settlements is contained in Technical Supplement 2 ‘Settlement Hierarchy and Strategic Settlement Evaluation’. The draft Plan Strategy defines the countryside as any land outside of designated settlement limits.
2.5
Rural needs: ‘rural needs’ means the social and economic needs of persons in rural areas (DAERA, 2018). The DAERA guidance states that, “a ‘need’ can be considered to be something that is essential to achieve a standard of living comparable with that of the population in general”.
1
For the purposes of this assessment, settlement development limits are those located in Mid and East Antrim and designated within the following extant development plans: Ballymena Area Plan 1986-2001, Carrickfergus Area Plan 2001 and Larne Area Plan 2010, and excluding any settlement development limit associated with a small settlement that is proposed for de-designation within the draft Plan Strategy. 2 https://www.ninis2.nisra.gov.uk/public/Home.aspx
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3.0 Draft Plan Strategy Approach to the Countryside 3.1
The Borough of Mid and East Antrim is a predominantly rural area. The open countryside is home to some 22% of the population of the Borough. It is an important resource for a number of economic activities, mainly in the agricultural, tourism, renewable energy and minerals sectors. Council recognises the need to sustain these rural communities by ensuring a healthy rural economy.
3.2
The countryside is also an important environmental resource. There are a number of sites designated at international, national and local levels on the basis of their importance for nature conservation and/or scientific interest. Landscape and seascape is often of high quality, particularly within the 370 square kilometres of the Antrim Coast and Glens Area of Outstanding Natural Beauty (AONB) that falls within the Borough. Council recognises the importance of safeguarding these areas not only because of their intrinsic value, but also because of their importance in underpinning a growing tourism sector in Mid and East Antrim.
3.3
Building on our POP and in line with the SPPS, the overarching approach embedded in the draft Plan Strategy in regard to the countryside, is to manage development in a manner which strikes a sustainable balance between protection of the environment from inappropriate development, while supporting and sustaining rural communities.
3.4
The Spatial Growth Strategy, Countryside Strategy and a range of the strategic subject policies pertaining in whole or in part to the rural area, are all directed at achieving this sustainable balance in the countryside.
4.0 Main Issues Arising From Rural Needs Impact Assessment 4.1
After undertaking the RNIA in accordance with the DAERA guidance, the following social and economic issues were identified as being particularly relevant for the rural areas of the Borough: With a significant rural population, it is important that the draft Plan Strategy aims to meet the economic and social needs of rural communities through facilitating appropriate forms of growth and development in rural areas within the context of sustainable development. There is continuing demand to reside in the rural area and it is important to provide housing opportunities for rural communities within villages, small settlements and the open countryside. Some types of economic activity are normally carried out in the countryside. Examples include agriculture and forestry, quarrying, renewable energy development and certain types of tourism and leisure activities. These sectors should be supported and appropriate growth accommodated within the context of sustainable development. Some rural communities can experience difficulty accessing facilities and services which can lead to a sense of social exclusion and isolation. Within densely populated urban areas the advantages of economies of scale can be exploited in relation to the provision of facilities and services. However, in the rural area where the population density is less, these economies of scale cannot be realised and the provision of facilities and services becomes more expensive. Therefore given public expenditure constraints, the standard of provision of facilities and services is inevitably lower in rural areas than in urban areas. Public transport provision is a good example. Some rural areas within our Borough also experience difficulty with telecommunications connectivity. However, it is important to strive to maintain and improve the delivery of public facilities, services and utilities in rural areas in order to help sustain a vibrant rural community and reduce a sense of social exclusion and isolation in these areas. 6
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 It is increasingly recognised that the natural environment of rural areas can deliver social benefits in terms of improving human health and wellbeing. Health and wellbeing can be enhanced through the opportunities that the rural area provides for active and passive recreation, while mental health can be helped by the tranquillity, scenic beauty and sense of place offered by some parts of the countryside. Given these benefits, the landscape, environmental and heritage assets of rural areas should be protected in accordance with their relative importance and significance.
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5.0 Rural Needs Impact Assessment SECTION 1 - Defining the activity subject to Section 1(1) of the Rural Needs Act (NI) 2016 1A. Name of Public Authority: Mid and East Antrim Borough Council 1B. Please provide a short title which describes the activity being undertaken by the Public Authority that is subject to Section 1(1) of the Rural Needs Act (NI) 2016. Mid and East Antrim Local Development Plan 2030 – Draft Plan Strategy The Plan Strategy is one of two Local Development Plan documents to be produced in accordance with Part 2 of the Planning Act (Northern Ireland) 2011. 1C. Please indicate which category the activity specified in Section 1B above relates to. Policy Strategy Plan 1D. Please provide the official title (if any) of the Policy, Strategy, Plan or Public Service document or initiative relating to the category indicated in Section 1C above. Mid and East Antrim Local Development Plan 2030 draft Plan Strategy. 1E. Please provide details of the aims and/or objectives of the Policy, Strategy, Plan or Public Service. The LDP Vision (as set out in paragraph 1.1) is to improve the quality of life for all who live, work, enjoy, invest and visit Mid and East Antrim – to the extent that this can be delivered through the planning system; with the emphasis on delivering high quality and sustainable development and good place-making. The Vision is supported by 25 strategic objectives which are framed around the three themes (economic, social and environmental) of sustainable development. 1F. What definition of “rural” is the Public Authority using in response of the Policy, Strategy, Plan or Public Service? Please refer to Part 2.0 “What is meant by ‘rural’ and ‘rural needs’?” of this report for details on the definition of “rural” adopted by this report.
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SECTION 2 – Understanding the impact of the Policy, Strategy, Plan or Public Service 2A. Is the Policy, Strategy, Plan or Public Service likely to impact on people in rural areas? Yes 2B. Please explain how the Policy, Strategy, Plan or Public Service is likely to impact on people in rural areas. Urban-Rural Divide This RNIA has adopted the default definition of “rural” used in Northern Ireland developed by the Inter-Departmental Urban-Rural Definition Group which defines the rural area as those settlements with populations of less than 5,000 together with the open countryside (DAERA, 2018). Therefore, all areas within the Borough and outside of the settlement development limits of Ballymena, Carrickfergus, Larne and Greenisland are considered rural in the RNIA context. Based on this demarcation of the urban-rural divide, approximately 40% (53,548) of the Borough’s population reside in the rural area (see Table 2 of Appendix A). Draft Plan Strategy Strategic Proposals and Policies The draft Plan Strategy takes account of the RDS 2035 and the overarching aim is to further sustainable development. The draft Plan Strategy Spatial Growth Strategy and Countryside Strategy seek to direct and manage growth, whilst the strategic subject policies will provide the policy framework for decision making on planning applications. An explanation of how these various elements are likely to impact on people in rural areas is provided below. Spatial Growth Strategy The Spatial Growth Strategy (SGS) sets out the broad locations where new growth (housing, economic development, retail etc.) will be directed over the Plan period to 2030. The SGS takes account of the RDS and is linked to the Settlement Hierarchy set out in the draft Plan Strategy, which provides the spatial framework for delivery of the SGS through strategic spatial proposals and operational policies. The SGS will impact differentially on people in rural areas depending on where they live, work or visit. All our small towns with the exception of Greenisland fall within the RNIA definition of ‘rural’. Here the SGS aims to “facilitate appropriate growth in our small towns to provide opportunities for business, retail, housing and services.” Below this settlement tier, the SGS aims to ‘sustain rural communities living in and around villages and small settlements’. The open countryside, for the purposes of the LDP, consists of all other land outside designated settlement development limits. Here, the SGS aims to ‘facilitate sustainable development, balancing the need to protect the environment and rural character, while sustaining a strong and vibrant rural community’. In summary, the SGS will provide for a ‘tiered’ approach to development in the rural area, with greater provision in the small town tier relative to the village and small settlement tiers. Countryside Strategy The Countryside Strategy sets out what types of development are acceptable in principle in the countryside. It also sets out a range of strategic policy designations and associated policies which aim to protect landscapes which are of exceptional quality or of unique amenity value, or which are important for the setting of settlements. As these designations are located in the countryside they are likely to have an impact on the Borough’s rural community. Special Countryside Areas (SCAs) have been designated in order to protect exceptional landscapes along the coast, around Slemish and adjacent to Lough Beg. The SCAs are very restrictive in relation to the types of development permitted. However, it should be noted that in the context of the Borough, they cover a relatively small area and will impact on a very low percentage of the population. Other designations such as Areas of Constraint on High Structures (ACHS) are larger in extent but are less restrictive as they only seek to restrict the height of wind turbines, pylons and masts as well as other obtrusive types of development. In a similar manner, the three Areas of Constraint on Mineral Development 9
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(ACMD) only apply to the extraction and processing of hard rock and aggregates from quarries, in the interest of protecting sensitive landscape and heritage assets within the AONB. Rural Landscape Wedges, which are relatively small in extent, are designated at Carrickfergus and Greenisland in order to protect their settings and to ensure coalescence of settlements does not occur in these areas. Again, these designations will not impact significantly on the rural population as a whole. Strategic Subject Policies The strategic subject policies are largely topic related, i.e. relative to various types of development (such as housing, retail or transportation). They also include policies that aim to restrict or carefully manage development in the public interest. Examples include policies for flood risk, the historic environment and the natural environment. Many of these policies will have some impact on rural dwellers, depending upon the way in which they seek to manage development in the countryside. However, in general, these policies contribute positive net benefits for the wider community through helping to secure sustainable patterns of development. As previously stated, the overarching approach in determining planning applications is to manage development in a manner which strikes a sustainable balance between protection of the environment from inappropriate development, while supporting and sustaining rural communities. For example, helping to conserve and protect valuable heritage and landscape assets in the countryside can stimulate and sustain economic growth through tourism and enhance health and wellbeing benefits for everyone. Where appropriate, the draft Plan Strategy does allow for development opportunities in the countryside if the relevant policy tests are met, for example, policies allowing for residential development, farm diversification, tourism development, renewable energy development and minerals development. Overall, it is considered that the draft Plan Strategy strikes a balance between accommodating appropriate development and sustainable growth in the rural area whilst offering a sufficient level of protection for our natural and historic heritage assets and landscapes commensurate with their significance and value to the wider community. 2C. If the Policy, Strategy, Plan or Public Service is likely to impact on people in rural areas differently from people in urban areas, please explain how it is likely to impact on people in rural areas differently. Draft Plan Strategy - Spatial Growth Strategy The draft Plan Strategy Spatial Growth Strategy (SGS) and the Settlement Hierarchy will set the broad parameters for the distribution of housing, economic development and retail growth across the Borough over the plan period. There are 36 settlements identified in the draft Plan Strategy and these have been categorised across four tiers of settlement type based on their role, facilities and services available and their potential for accommodating development. The draft Plan Strategy SGS identifies the three main towns of Ballymena, Carrickfergus and Larne as a focus for population growth and economic development in order to strengthen their roles as prime locations for business, retail, housing, administration, leisure and cultural facilities. In accordance with the RDS Spatial Framework Guidance, there will be diminishing opportunities for growth within respective settlements as the strategic importance and size of the settlement decreases and, consequently, there will be more opportunities for development in urban areas than rural areas. Although the ‘main hubs’ of Ballymena and Larne, as well as Carrickfergus will be the focus of growth, the draft Plan Strategy seeks to support and facilitate appropriate growth in rural areas in order to sustain a vibrant rural community. For example, villages, which function as local service centres and help meet the daily needs of the rural community, will be consolidated and sustained. In more isolated parts of the Borough, small settlements will act as a focal point for housing and may provide access to community facilities or make provision for rural businesses. Further, there will be opportunities for single dwellings and appropriate types of economic development in the open countryside provided they are sustainable and avoid harmful impacts on rural character and the environment. Importantly, it is considered that the urban settlements also contribute to meeting the economic and social needs of the rural community in relation to the provision of community services, opportunities for leisure and recreation and as hubs of employment.
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Draft Plan Strategy - Countryside Strategy The Countryside Strategy will also impact people in rural areas differently from people in urban areas because the various designations previously referred to will not generally apply within settlements. However, such designations are deemed to be in the overall public interest and often only seek to restrict or carefully manage particular forms of development in the countryside which does not affect the day to day lives of most rural dwellers. Further, Special Countryside Areas which are the most restrictive designations are relatively limited in extent and are located in areas of sparse population. It is important to note that the LDP will also seek to restrict or carefully manage development in the public interest within some urban areas through other appropriate mechanisms, for example within Conservation Areas, Areas of Townscape or Village Character, or Local Landscape Policy Areas. Draft Plan Strategy – Strategic Subject Policies The strategic subject policies are operational in nature and apply across the Borough. These will form the basis for assessing development proposals, including those within rural settlements or the open countryside. Some strategic subject policies are shaped differently and contain different policy criteria for the open countryside visà-vis designated settlements. For example, such differential approaches apply to policy areas for economic development, housing and tourism. Policies which seek to protect the landscape and heritage assets may be more restrictive in some rural areas than others, depending on the quality of the landscape and the heritage assets present. It is also accepted that where strategic subject policies are shaped differently for the open countryside than for settlements that they generally tend to be more restrictive. For example, within settlements there is a general presumption in favour of tourism development which does not apply universally outside of settlements. With regard to housing, the draft Plan Strategy does not generally cater for the development of multiple housing units in the countryside and places significant restrictions on opportunities for single dwellings. This policy approach differs from that which applies to settlements, where there is a general presumption in favour of all types of residential development. However, it should be noted that such differentiation aligns with the draft Plan Strategy SGS and also the Regional Development Strategy, the SPPS and the thrust of existing Planning Policy Statements relating to the particular subject area, all of which are primarily directed to furthering sustainable patterns of development. For the draft Plan Strategy to significantly depart from this regional direction would render it vulnerable to being found to be ‘unsound’. Again, it should be noted that all but one of our settlements below the ‘main town’ level fall within the RNIA definition of the rural area. Accordingly, the differential impacts of the policies per se, are limited to those who live, work or visit the open countryside. Further, even within the open countryside, some of the strategic subject policies will have differential impacts. A good example is tourism development, which will be restricted in some vulnerable areas, or required to be carefully managed elsewhere in the countryside, or actively promoted in particular ‘opportunity sites’ in the countryside. 2D. Please indicate which of the following rural policy areas the Policy, Strategy, Plan or Public Service is likely to primarily impact on. Given the scope of the topic areas contained within the draft Plan Strategy, it is likely to have a direct or indirect impact on the following areas of interest to the rural community:
Rural business;
Rural tourism;
Rural housing;
Jobs or employment in the rural area;
Education or training in rural areas;
Telecommunications (broadband or mobile) in rural areas;
Transport services or infrastructure in rural areas;
Poverty in rural areas; 11
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Deprivation in rural areas;
Rural crime or community safety;
Rural development;
Agri-Environment; and
Other (please state) – natural heritage, historic environment, landscape character, minerals development, renewable energy development.
2E. Please explain why the Policy, Strategy, Plan or Public Service is NOT likely to impact on people in rural areas. N/A
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SECTION 3 – Identifying the Social and Economic Needs of Persons in Rural Areas 3A. Has the Public Authority taken steps to identify the social and economic needs of people in rural areas that are relevant to the Policy, Strategy, Plan or Public Service and whom it is likely to impact on. Yes 3B. Please indicate which of the following methods or information sources were used by the Public Authority to identify the social and economic needs of people in rural areas. The following methods and information sources were used to identify the social and economic needs of people in rural areas:
Consultation with rural stakeholders; Consultation with other organisations; Published statistics; Research papers; Integrated Village Plans produced as part of the Rural Development Programme 2014 – 2020; Other publications; and Other methods or information sources (details included in Section 3C below).
3C. Please provide details of the methods and information sources used to identify the social and economic needs of people in rural areas including relevant dates, names of organisations, titles of publications, website references, details of surveys or consultations undertaken etc. Information Sources: Publications, Reports and Statistics Various sources of information and publications were used to generate an evidence base that has informed our Preferred Options Paper (POP) and the draft Plan Strategy. In particular, maps, statistics and publications produced by central government departments such as Department for Communities (DfC), Department of Finance (DoF), Department for Infrastructure (DfI) and Department for Agriculture, Environment and Rural Affairs (DAERA) were utilised. Appendix B of this RNIA includes a list of some of the sources of information used to identify the social and economic needs of people in rural areas. Research Papers During the initial preparatory stage of the LDP, 14 position papers were produced to provide baseline evidence for the various topic areas falling within the scope of the draft Plan Strategy. These position papers have informed the production of our POP, draft Plan Strategy and the Sustainability Appraisal (SA). Each position paper sets out the planning policy context, establishes a baseline position regarding the topic area and identifies key issues that need to be addressed. Each position paper considers the whole Borough and, therefore, all are to some extent of relevance to the rural area. Following public consultation on the POP, the evidence base for various topics was reviewed and updated where necessary. The updated evidence base was used to inform the production of a series of Technical Supplements which support the draft Plan Strategy. The Countryside Assessment, Settlement Hierarchy and Strategic Settlement Evaluation and a range of other Technical Supplements relating to particular forms of development have all, to various degrees, informed policy development for the open countryside. The Countryside Assessment includes a review of the baseline data for the Borough’s environmental assets (outside of settlement development limits), a review of the Northern Ireland Landscape Character Assessment (NILCA) 2000 and an analysis of the development pressure experienced in the open countryside from residential and renewable energy development. The Sustainability Appraisal assessed each policy and proposal in the draft Plan Strategy against a range of indicators of 13
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sustainability and considered rural impacts generally, as part of this process. Consultation and Stakeholder Engagement The first stage of the LDP process was the publication of our POP in June 2017. The main purpose of the POP was to identify the main planning issues for our Borough and through public consultation to obtain feedback from statutory consultees, various interest groups and the general public on our ‘Preferred Options’ for addressing these key issues. The POP and responses to it have informed the draft Plan Strategy. Prior to publication of the POP engagement took place with overarching bodies who represent the 9 identified Section 75 groups. Some 120 groups were contacted in writing, offering them the opportunity to identify any particular issues or needs that they considered the Plan should address. Key Section 75 groups were also consulted again on publication of the POP. Groups representing the rural community were included in the list of Section 75 groups, for example, the NI Rural Women’s Network, the Rural Community Network, the Rural Development Council and Rural Support. Publication of the POP was advertised in local newspapers, in the Borough’s ‘Connections’ magazine, on the Council’s website and social media platforms. Targeted letters were also sent to various consultees, political representatives, business and interest groups and planning agents. The POP and the Sustainability Appraisal Interim Report were subject to 12 weeks public consultation, during which, there were nine public engagement events which consisted of six ‘public events’ held in the three main towns and three ‘drop-in sessions’ held in three villages across the Borough. Further, during the consultation period, comments were welcomed from the public and interest groups via email, letter and through an online survey. The public events, drop-in sessions and consultation period arrangements gave statutory consultees, interest groups and the general public an opportunity to actively participate in and inform the LDP process and a total of 132 responses were received. The Council received six specific responses in relation to the POP’s Sustainability Appraisal (SA) Scoping and Interim Report, including two from statutory consultees. A total of 45 responses to the POP commented on the SA. All consultation responses, including those that raised issues specific to rural communities and the rural area, were considered in a public consultation report on the POP that was published in November 2017 (available at https://www.midandeastantrim.gov.uk/downloads/POP_Public_Consultation_Report.pdf), and these consultation responses have informed the policy approach of the draft Plan Strategy. During the SA process, the approach and policies of the draft Plan Strategy have been considered in detail with the aim of ensuring that the overarching aim of sustainable development is considered throughout the document. Elected Members of the Council, council departments and statutory consultees have extensive knowledge of the issues facing rural communities in the Borough. During the drafting stages of the POP and draft Plan Strategy, a series of workshops were held that gave Elected Members, council departments and statutory consultees the opportunity to discuss and contribute to the policy approach of both documents. Policy Review In preparing the POP, the Local Development Plan team carried out a review of the extant regional operational policies contained in the Planning Policy Statements and extant LDP policies. The policy review and recommended changes to the policies were discussed with the Elected Members before being published in the POP for public consultation. Further refinement of the policies subsequent to the POP was undertaken, taking account of the POP responses and input of statutory consultees and ongoing engagement with Elected Members. The result of the policy review process is a suite of strategic subject policies now contained in the draft Plan Strategy, which take account of the unique circumstances of Mid and East Antrim and address the economic and social needs of the Borough, including the rural community. This approach is balanced with cognisance of the regional direction and the obligation to further sustainable development.
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3D. Please provide details of the social and economic needs of people in rural areas which have been identified by the Public Authority. Based on population figures of the 2011 Census (see Table 2, Appendix A), approximately 60% of the population of MEA is concentrated in the four towns of Ballymena, Carrickfergus, Larne and Greenisland. With approximately 40% of the population residing in rural settlements or the open countryside, it is recognised that there is a need to facilitate sustainable development within rural areas which can help meet the social and economic needs of the rural community. The population of Mid and East Antrim is projected to increase and reach a total of 142,114 by 2030 and this is likely to result in a modest increase in demand for residential development and facilities and services in the rural area. Going forward, it is also important to protect our environment, exceptional landscape features and heritage assets from the adverse impacts of inappropriate development as they provide net benefits for the rural community and the wider Borough, for example, through contributing positively to the proper functioning of ecosystem services and the continued growth of tourism. Mid and East Antrim has an active and vibrant rural community. From the collated evidence (see Section 3C) and engagement with Elected Members of the Council, various interest groups and stakeholders, including those representing the rural community, and the general public, the following economic and social needs of the rural community were identified:
The need for sustainable economic development and employment opportunities in the rural area in order to maintain and sustain the vibrancy of the rural community; The need to support rural businesses such as agriculture and forestry, farm diversification, minerals development and sustainable forms of tourism; The need to protect the natural environment in order to ensure that development does not adversely impact on biodiversity, ecosystem services or valued natural heritage assets; Within rural areas, there is a need for affordable housing provision and to accommodate sustainable patterns of residential development in order to help meet the housing needs of the rural community; The need to have access to leisure facilities, for example, in relation to sport, recreation, leisure, walking and cycling. Addressing this need can help alleviate social isolation in the rural area as well as enhancing health and wellbeing; The need to have access to services including health, education, transport (including public transport) and broadband. Addressing this need can help alleviate social isolation in the rural area as well as meet the need for good connectivity to necessary services; The need to adapt to climate change and utilise renewable energy sources where appropriate; The need to avoid new development in areas known to be at significant risk from flooding, coastal change or land instability, taking account of ‘increased vulnerability’ associated with climate change; The need to feel safe; The need to protect the natural beauty and/or character of the rural area, particularly where the landscape is of high scenic quality or unique amenity value; The need to safeguard the unique character and amenity of our coastline, loughs and river corridors; and The need to protect valued historic environment assets which are inextricably linked to the cultural heritage, evolution and identity of the rural area and community.
IF THE RESPONSE TO SECTION 3A WAS “YES” GO TO SECTION 4A. 3E. Please explain why no steps were taken by the Public Authority to identify the social and economic needs of people in rural areas? N/A 15
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SECTION 4 – Considering the Social and Economic Needs of Persons in Rural Areas 4A. Please provide details of the issues considered in relation to the social and economic needs of people in rural areas. Approximately 40% of the Borough’s population reside in settlements considered rural or in the open countryside. In accordance with the RDS and SPPS, the draft Plan Strategy aims to accommodate sustainable development within rural areas, whilst simultaneously protecting our environment, exceptional landscapes and historic and natural heritage assets from the adverse impacts of inappropriate development. The population of Mid and East Antrim is projected to increase and reach a total of 142,114 by 2030 and this is likely to result in some further pressure for residential development in the countryside and a modest increase in demand for services and facilities from the rural population. Housing Need In relation to an increase in demand for residential accommodation in the rural area, the draft Plan Strategy Strategic Housing Allocation and policies related to housing, are largely directed by the RDS, SPPS and the proposed LDPs Spatial Growth Strategy, with larger settlements being prioritised for growth. In the rural area, the draft Plan Strategy allows for appropriate growth within small towns, sufficient growth to sustain villages and small settlements, and there are opportunities for residential development (mainly single dwelling units) in the countryside. Given that the growth in the number of ‘approved’ single dwellings in the open countryside across Northern Ireland in the period pre-dating Planning Policy Statement 21 was considered to be unsustainable and having a significant adverse impact on the rural character of the countryside; the draft Plan Strategy seeks to consolidate the approach of PPS 21 by supporting sustainable patterns of residential development in the open countryside. The draft Plan Strategy also makes provision for affordable housing in rural areas and for meeting the needs of people with special personal or domestic circumstances. As part of the settlement evaluation process, it was concluded that 12 existing small settlements should be dedesignated (Trooperslane is to be subsumed into Carrickfergus settlement development limits) and eight new small settlements should be designated. On adoption of the draft Plan Strategy, any de-designated settlements will be considered as part of the open countryside with any new small settlements considered as open countryside until new settlement limits have been identified at Local Polices Plan stage. It is acknowledged this process may restrict some development opportunities until such time as settlement development limits are designated for the “new” small settlements. However, it is considered that this approach will lead to a more sustainable pattern of housing development with potential for some opportunities for new housing development in the “new” small settlements where this will serve to sustain their role in supporting the rural community. Economic Need The draft Plan Strategy recognises that the aim to support and sustain rural communities depends much on ensuring a vibrant and rural economy. Accordingly, the Spatial Growth Strategy will assist the rural economy through supporting sustainable economic development in both rural settlements and the open countryside. Tourism is expected to be a key economic driver for the Borough and in order to support the sustainable growth of this sector, the draft Plan Strategy seeks to direct tourism growth to the most appropriate locations and to provide protection for important heritage and landscape assets within the rural area that are attractive to tourists, for example, at Slemish, the Gobbins and along the Antrim Coast Road / Causeway Coastal Route. Outside of designated areas, the draft Plan Strategy will accommodate appropriate types of economic development in the countryside provided such proposals do not adversely impact the natural or historic environment, quality landscapes or rural character and accord with a sustainable pattern of development. Subject to these caveats, appropriate types of economic 16
Rural Needs Impact Assessment
development can include farm diversification, agriculture and forestry development, sustainable tourism, small rural start-up projects, minerals development and renewable energy. The draft Plan Strategy recognises that telecommunications infrastructure and overhead cables are necessary for ensuring our homes, businesses and services throughout the Borough are well connected to a safe, secure and reliable communication network and energy supply. Enhanced access to reliable high speed digital infrastructure is an important factor in ensuring our businesses remain competitive and growth of the local economy is supported. However, some rural parts of our Borough continue to suffer from poor indoor mobile coverage and 4G access and experience relatively low broadband speeds. The draft Plan Strategy seeks to facilitate the provision of infrastructure necessary for modern telecommunications and other utilities, whilst protecting highly sensitive landscapes, in order that all the domestic and business needs of the Borough can be met, including those of the rural community. Social Need The draft Plan Strategy aims to help meet the social needs of the rural community and recognises that access to facilities and services can improve ‘quality of life’ and help reduce social isolation. Although major population growth and economic development is to be focused in the three main towns, it is recognised that the business, retail, administration, leisure and cultural facilities within these towns all contribute to serving the needs of the rural hinterland. Appropriate growth will also be accommodated in small towns and in villages and small settlements where this will help to sustain rural communities. These lower tier settlements, particularly small towns and villages, perform an important role as local centres of employment, facilities and services that help to meet the daily needs of the rural community. It is acknowledged that some remoter parts of the Borough are sparsely populated areas and can experience greater problems regarding access to facilities and services than in other rural areas. Directly addressing issues, such as a low level of public transport provision or a lack of community facilities within the rural area, is outside the scope of the draft Plan Strategy. However, the approach of the draft Plan Strategy is to support the provision of such facilities or services, where there is a firm commitment on the part of the service provider and where appropriate within the context of sustainable development. Consideration of Local Circumstances The approach of the draft Plan Strategy is to balance the needs of the rural community and the rural economy with other interests, including the need to protect the environment and respect rural character. Within rural settlements, specific local needs will be taken into account when assessing development proposals against the strategic proposals and policies set out in the Plan Strategy. Within the open countryside, the draft Plan Strategy aims to secure the sustainable balance referred to throughout this document. Within designated areas of high quality landscape, environmental or unique amenity value, the ‘balance’ will be in favour of protection and development proposals will be assessed against the bespoke policy for the particular type of designation. Elsewhere within the countryside, the strategic subject policies of the draft Plan Strategy will allow somewhat greater flexibility for the consideration of local circumstances – for example where there is a local need for a farm or craft shop or for a small rural start up project outside a village or small settlement.
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SECTION 5 – Influencing the Policy, Strategy, Plan or Public Service 5A. Has the development, adoption, implementation or revising of the Policy, Strategy or Plan, or the design or delivery of the Public Service, been influenced by the rural needs identified? Yes 5B. Please explain how the development, adoption, implementation or revising of the Policy, Strategy or Plan, or the design or delivery of the Public Service, has been influenced by the rural needs identified. The draft Plan Strategy seeks to take a holistic approach to development within the Borough, with a vision, strategic objectives and policy aims to support sustainable patterns of development. In this context, the draft Plan Strategy seeks to facilitate sustainable patterns of development which can meet the economic, social and environmental needs of the Borough as a whole. Meeting the identified needs of the rural community is addressed through the Countryside Strategy which sets out the forms of development that will be acceptable in principle in the countryside. It is also addressed through many of the strategic subject policies which help to facilitate appropriate economic development, the supply of housing and the delivery of facilities and services within the rural area. Housing Need The opportunity to live in the rural area is important for members of the rural community. In accordance with the RDS, SPPS and the LDP Spatial Growth Strategy, housing growth will be focused in our three main towns which are considered the most sustainable locations. However, where necessary, land will be allocated for housing within our small towns and there will be scope for new housing development within villages and small settlements. Opportunities for new housing in these lower tier settlements will help meet the demand for housing within the rural community. The draft Plan Strategy also provides opportunities for housing in the open countryside, subject to planning policies for housing applicable outside of settlement development limits. Accordingly, the draft Plan Strategy makes provision for farm dwellings, replacement dwellings, dwellings within an existing cluster of buildings, dwellings to meet a justified need in relation to personal or domestic circumstances or the essential needs of a non-agricultural business, the conversion of non-residential buildings to residential use, and for the provision of affordable housing and travellers accommodation. Economic Need The draft Plan Strategy aims to sustain rural communities and support rural economic development through facilitating the development of rural industry, business and enterprise in appropriate locations. It is recognised that the main towns provide employment opportunities for the rural hinterland and that small towns and some villages function as centres of employment and services for the rural community. In line with the regional approach of the RDS and SPPS, the draft Plan Strategy allocates economic development land within each of the three main towns. While there is no specific allocation of economic development land outside of the main towns, opportunities for appropriate economic development in the lower tier settlements will remain, particularly where they meet an identified local need and avoid detrimental impact to the character of the settlement. In order to further help meet the economic needs of the rural community, the draft Plan Strategy can facilitate economic development in the open countryside if such development is of an appropriate nature and scale and sympathetically located so as to avoid adverse impact on vulnerable landscapes, environmental quality, heritage assets and rural character. Opportunities for sustainable economic growth in the open countryside can include farm diversification, agriculture and forestry development, sustainable tourism, small rural start-up projects, roadside service facilities and minerals development. 18
Rural Needs Impact Assessment
The minerals development sector provides jobs for the rural economy directly and indirectly. The extant Areas of Constraint on Mineral Development (ACMD) in the Larne Area Plan 2010 are to be taken forward in the draft Plan Strategy. It is recognised that these strategic designations will restrict minerals development for aggregates within their spatial extent. However, they aim to protect highly sensitive environments and/or landscapes and it is considered that there is sufficient opportunity outside of these designations for minerals development. Social Need Connectivity and social isolation are key considerations for rural communities in Mid and East Antrim. However, it is recognised that these issues are more acute in some more remote areas of the Borough. The draft Plan Strategy recognises the need to ensure that rural areas remain connected with the wider Borough via physical road infrastructure, private and public transport and telecommunications infrastructure. The direct provision of such infrastructure is beyond the scope of the LDP. However, the draft Plan Strategy, through the relevant strategic subject policies, aims to help facilitate and support the delivery and enhancement of such infrastructure within the context of sustainable development. Further to this, sport and outdoor recreation facilities and greenways will be permitted in rural areas subject to the relevant policy provisions and public access points along the coast will be protected. These recreation opportunities can help improve health and wellbeing and reduce social isolation in the rural community. The Environment and Wider Benefits It is increasingly recognised that a healthy natural environment delivers real benefits in terms of improving human health and wellbeing and facilitating sustainable economic growth. In the context of Mid and East Antrim, the natural environment is fundamental to the success of the agricultural and forestry sectors and for the sustainable supply of drinking water alongside other vital ecosystem services. The environmental quality and variety of the landscapes and seascapes within Mid and East Antrim attracts visitors and tourists to our Borough for the benefit of the economy. Additionally, a healthy environment delivers a range of social benefits, including those related to health and wellbeing. The draft Plan Strategy seeks to provide a healthy natural environment through its’ Countryside Strategy and associated strategic designations. Areas of open countryside within such designations, will be subject to a higher policy test which may restrict some types of development. However, adopting a holistic approach, it is considered that the draft Plan Strategy offers sufficient opportunities for residential development, sustainable economic development and provision of facilities and services to support the maintenance and growth of a vibrant rural community.
IF THE RESPONSE TO SECTION 5A WAS “YES� GO TO SECTION 6A. 5C. Please explain why the development, adoption, implementation or revising of the Policy, Strategy or Plan, or the design or delivery of the Public Service, has NOT been influenced by the rural needs identified. N/A
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Rural Needs Impact Assessment
SECTION 6 – Documenting and Recording 6A. Please tick below to confirm that the RNIA Template will be retained by the Public Authority and relevant information on the Section 1 activity compiled in accordance with paragraph 6.7 of the guidance. I confirm that the RNIA Template will be retained and relevant information compiled. Rural Needs Impact Assessment undertaken by:
Michael Francey
Position/Grade:
Principal Planning Officer Planning and Building Control:
Division/Branch
Local Development Plan Team
Date:
12/09/2019
Rural Needs Impact Assessment approved by:
Paul Duffy
Position/Grade:
Head of Planning Planning and Building Control:
Division/Branch:
Local Development Plan Team
Date:
01/10/2019
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Appendices
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Appendix A: Population Totals Table 1: Population Totals for Mid and East Antrim and Northern Ireland Mid and East Antrim Borough Council
Northern Ireland
Mid-Year Total Population Estimate (2018)
138,7733
1,881,6413
Usual Resident Population (Census, 2011)
135,3384
1,810,8634
Estimated % Change in Total Population Between 2011 and 2018
2.54%
3.91%
Table 2: Mid and East Antrim Population 2011 (Urban/Rural split)
Usual Resident Population (2011)
Ballymena (urban settlement)
Carrickfergus (urban settlement)
Larne (urban settlement)
29,5516
27,9986
18,7556
Greenisland Rural (urban Remainder5 settlement)
5,4866
60.434%
3
All of Mid and East Antrim Borough Council
53,548
135,3384
39.566%
100%
Source: NISRA, 2018 Mid-Year Population Estimates for Northern Ireland (2019), Population Totals (administrative geographies) – LGD 2014.
4
Source: NISRA, 2011 Census, Usually Resident Population (administrative geographies) – LGD 2014. The Census collected information on the resident population of Northern Ireland on Census Day (27 March 2011). 5
Based on the default definition of ‘rural’ used in Northern Ireland is that developed by the Inter-Departmental Urban-Rural Definition Group which classifies those settlements with populations of less than 5,000 together with the open countryside as rural (DAERA, 2018). 6
Source: NISRA, 2011 Census, Usual Resident Population: KS101NI (Settlement 2015).
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Rural Needs Impact Assessment
Appendix B: Information sources used to identify the social and economic needs of people in rural areas
Ballymena Area Plan 1986 – 2001 and associated technical supplements; Belfast Metropolitan Area Plan 2015 (draft) and associated technical supplements; Carrickfergus Area Plan 2001 and associated technical supplements; Larne Area Plan 2010 and associated technical supplements; Mid and East Antrim Community Plan “Putting People First”; Mid and East Antrim Preferred Options Paper Public Consultation Report (November 2017); 2011 Census www.nisra.gov.uk; NI Neighbourhood Information Service www.ninis2.nisra.gov.uk/public/Home.aspx; Mid and East Antrim Housing Monitor; Department of Environment (DOE) Planning Statistics; Antrim Coast and Glens AONB Outline Management Plan 2017; Integrated Village Plans produced as part of the Rural Development Programme 2014 – 2020.
NB: This list is not intended to be an exhaustive list of sources used to identify the social and economic needs of people in rural areas.
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Local Development Plan Team County Hall 182 Galgorm Road Ballymena BT42 1QF Tel: 0300 124 5000 planning@midandeastantrim.gov.uk www.midandeastantrim.gov.uk/planning