Comment

A guided review of BCP Council’s Draft Publication Local Plan 2024 – 2039

BCP Council has published its full Publication Draft Local Plan 2024 – 2039 as part of the agenda for the Overview and Scrutiny Committee which met on 4th December 2023. This document outlines the strategic direction and development plans for Bournemouth, Christchurch and Poole (BCP) over the next 15 years.

Work on the draft plan began shortly after April 2019, when Bournemouth, Christchurch and Poole combined to form a Joint Unitary Authority. The emerging Local Plan 2024 – 2039 will, when adopted, replace the existing Local Plans which cover the individual areas of Bournemouth, Christchurch and Poole. 

Timeline

Before the Publication (Reg.19) Local Plan 2024 – 2039 is published for public consultation, it must be approved through the council’s committee system. Following this week’s consideration by the Overview and Scrutiny Committee, it will go to Cabinet on 13th December, and finally Full Council on 9 January 2024.

Following this, BCP intends to formally publish the Draft Local Plan 2024 – 2039 for consultation at the end of January 2024. This consultation will take place for 6-weeks, closing at the end of March 2024.

The evidence base, including a range of information such as viability assessments, housing needs assessment and tall buildings studies, is not available to review during the committee cycle, and will only be published as part of the formal consultation in January 2024. 

BCP’s Timetable post-consultation programme anticipates a very quick turnaround as they plan to submit the Local Plan for examination at the beginning of April 2024. Essentially - immediately after the public consultation on the Draft Plan ends.

Adherence to this timetable would mean that the council is unlikely to make any significant changes to the Draft Plan in response to consultation feedback. There is simply not enough time built into the programme for the council to review and consider responses to the Draft Plan, and make any substantial changes, before the Plan is submitted. 

The timescale for early submission of the plan seems in part to be driven by recognition that significant numbers of policies in the existing plans are out-of-date as well as a desire to ensure the plan is submitted for examination under the current system, well ahead of the June 2025 deadline.  

BCP anticipate adoption of the Local Plan 2024 – 2039 in April 2025. It has already been acknowledged that an early review of the Local Plan will need to take place soon after adoption. 

Alongside the Local Plan, the council will be consulting on a borough-wide CIL Charging Schedule which will replace the separate Charging Schedules which currently operate for each of the former local authority areas.

Key Issues and Challenges

In exploring the intricacies of the BCP Council’s Draft Local Plan, we have reviewed the key issues and challenges currently shaping the plan's framework and impacting its execution. These details are available below.

Climate and environmental focus

The emerging Local Plan puts responding to the Climate Emergency front and centre of its approach and policies.

The strategic objectives of the plan include:

• Achieving climate neutrality ahead of 2050
• Conserving and Enhancing the boroughs outstanding natural environment
• Improving health and wellbeing
• Growing the economy and supporting the creation of new jobs
• Providing new market and affordable homes to meet the needs of different communities
• Improving town centres and building strong and inclusive communities

Whilst the objectives can be broadly supported, the underlying detail, highlighted within the following housing headings, provide cause for some concern.

Housing Delivery 

The Local Plan sets targets for housing delivery, considering environmental concerns with development needs. A locally derived housing delivery target of 1,600 homes per annum is proposed, equating to 24,000 homes over the plan period. This contrasts with a ‘standard method’ derived need for 2,800 homes per annum, or 42,000 homes over the plan period. The justification for this lower figure is put forward as environmental constraints, such as the Green Belt, Flood Zones and Protected Habitats, which limit the location of development and availability of developable greenfield land.

Of the 24,000 homes to be delivered, some 9,110 homes already benefit from planning permission, a figure which is discounted by 10% for non-implementation, leaving sites for some 16,000 homes to be identified in the Local Plan. The plan identifies sites for 8,830 new homes with the remainder to be delivered as ‘Windfalls’.

In terms of trajectory, it is anticipated that 1,200 homes per annum will be delivered over the first five years of the plan period, rising to 1,800 per annum over the later years of the plan. The 1,200 figure reflects actual delivery over the past few years.  

Housing is to be focused on well-located brownfield sites.

Housing Mix

The Publication Local Plan also sets a more prescribed housing mix requirement, with Strategic Policy H3 setting out the required mix for new developments. 

There is a proposal to restrict the proportion of 1-bedroom flats in town centre redevelopments to 40%, and to require the inclusion of a minimum proportion of 3-bedroom homes to reflect identified needs and create more balanced communities.

Affordable Housing

The acute need for affordable homes is recognised and it is proposed to retain the requirement for 40% affordable housing delivery on greenfield sites.

For brownfield sites, the affordable housing requirement will range between 10% and 15%, other than within Bournemouth and Poole town centres where, for viability reasons it will be set at zero. Where there is a requirement, a tariff-based approach is proposed to provide certainty as to the level of contribution required towards off-site provision.

Location of Development

The Draft Local Plan focuses on brownfield sites, with no allocation of sites for development within the Green Belt, which covers a large area of the borough. 

This is likely in response to the emerging National Planning Policy Framework (NPPF) which is expecting to restrict new development within the Green Belt and the council is therefore encouraging the vast majority of new development to take place on brownfield sites within the built-up areas. This approach within the Draft Local Plan will clearly have an impact on the number of dwellings which can be delivered. 

The Part 2 of the Publication Plan addresses the development needs of the borough at the level of each individual ward and each Ward includes site allocations for mixed use sites, housing and employment. These site allocations include key details and parameters such as housing numbers, building heights and key design features. 

The Plan also identifies ‘Strategic Opportunity Areas’, ‘Local Opportunity Areas’ and ‘Local Opportunity Streets’. These are areas which have been earmarked for development and where the council will support a change in the local character, including increased building heights and densities, to deliver the required housing across the Plan period. These Areas have been identified as sustainable locations for development and are mainly focused on high streets.

This demonstrates a more proactive approach from the council to support development, however, it is likely that all applications within the opportunity areas would be assessed on a site-by-site basis, and it cannot therefore be assumed that all development proposals in these areas will be accepted. 

Town Centres

It is positive that the council, through the emerging Local Plan, is encouraging and supporting development within the town centres. This is fundamental for the regeneration and revitalisation of these areas which have seen significant decline, and change in function, in recent years.

The strong brownfield focus, coupled with the lower affordable housing requirements and significantly lower CIL rate in the town centres will help create a framework within which meaningful regeneration, including the creation of new town centre communities, can take place.

Policy E11: Retail and Town Centres indicates an increased flexibility regarding the use of ground floor premises in town centres, district centres, local centres; and neighbourhood parades provided there is no over-concentration of such uses.  There is limited detail on how over-concentration will be defined.    

Nitrates

Since 2017 Poole has had a strategy in place to deal with Nitrogen Reduction Mitigation in the Poole Harbour Catchment. Following the increase in phosphates and nitrates impact, BCP are now changing their approach towards mitigation and will set up a credit scheme for credits to be purchased by developers up-front (and no longer through the council and CIL). Prospective developers should note that the council is requiring details and evidence of these mitigation credits BEFORE they will validate relevant planning applications.

CIL Charging Schedule

The CIL Charging Schedule proposes an area-based approach to the levy, dividing the borough into 5 zones with Bournemouth and Poole town centres forming one Zone and four further charging zones of “Value Areas” identified.

As well as differentiation by Zone, there is also differentiation by nature of site (brownfield or greenfield) and, for residential development, by scale of proposal – with separate rates identified for developments of 1-9 dwellings and 10 dwellings and above.

The evidence base to support the proposed charging levels is not yet available however it is notable that there is very significant variation in charging rates between areas. The levy on residential development, for example, would vary from £20 per sq m in the lowest charging zone (for brownfield development of more than 10 units in Bournemouth or Poole town centres) to an eye-watering £850 per sq m for greenfield residential development in Zone 4.

It is proposed that CIL will be charged in the previously ‘zero rated’ areas of Bournemouth town centre and the Poole Regeneration Area.

The residential charging rate refers specifically to Class C3 developments – so Purpose-Built Student Accommodation and Co-Living Accommodation would not be liable.

A levy of £100 sq m is proposed for Class B2 industrial and Class B8 Warehousing (Storage and Distribution) across the borough. Both uses are zero rated under the current CIL Charging Schedules.

Without access to the evidence-base which supports the proposed charging schedule it is difficult to comment meaningfully on the charging rates proposed. The changes will affect areas and types of development which are not currently affected by CIL. The lower rates proposed within Bournemouth and Poole town centres appear consistent with the council’s intention to maximise brownfield development and regeneration in these areas.  

We will post-further on CIL once the evidence-base for the Charging Schedule is made available.

Summary 

There is much to commend in the Draft Local Plan and indeed the engagement that BCP has undertaken to progress it to this point. It will provide a more relevant policy framework than the three legacy plans and a consistent policy basis across the borough is very much welcomed.

Contrary to the council’s somewhat optimistic intentions, the plan is unlikely to pass through its consultation stage without significant comment and scrutiny, leading to the need for post-consultation changes. Whilst acknowledging the council’s desire to ensure that the plan can be submitted under the current regime, a longer-period of consideration of post-consultation amendments and changes seems inevitable and is likely to make the eventual submission version more robust.   

The debate around the appropriate level of housing provision will no doubt be to the fore in a situation where housing need, including affordable housing need, is acknowledged to be significant. The decision to aim to provide less than 60% of the Standard Method identified need will doubtless be challenged and, without sight of the council’s evidence base it is not clear how this can be justified, notwithstanding the acknowledged environmental constraints in the borough.

With many projects having stalled, or struggled to get off the ground in recent years, due to viability issues, understanding the evidence base in relation to viability, affordable housing, CIL and infrastructure will be critical and it is unfortunate that it is not being released in parallel with the Committee Papers to allow proper interrogation.

The ward-based approach, whilst reflective of local democratic sensibilities does not necessarily reflect the contribution which some wards make, or should be required to make, to the wider delivery of development for the borough as a whole and there is a danger that the approach within individual wards becomes too prescriptive.

Continuing the conversation

As BCP Council navigates through the stages of public consultation and policy formation, the role of community feedback and expert analysis is key. We will therefore continue to monitor, and post on, the emerging plan. If you have interests in land within BCP that you would like to discuss in the context of the emerging plan please contact Sarah Hockin or Mervyn McFarland. 

5 December 2023