Comment

Belfast Local Development Plan: draft Plan Strategy

The vision within Belfast City Council’s draft Plan Strategy is bold, ambitious and at its heart seeks to deliver transformational change. The key question is whether the draft policies meet the tests of Soundness and assist in unlocking the council’s vision.

Rather than opting to revert to a blank sheet of paper in preparing the draft Plan Strategy, much of the substance of the draft Plan Strategy resonates with the draft Belfast Metropolitan Area Plan (BMAP) 2015.  

The draft Plan Strategy largely incorporates the hierarchies, designations and associated policies formerly set out in dBMAP, albeit the policies have been tweaked. This has then been strengthened through the introduction of new policies which aim to deliver on the cross cutting themes stemming from the Belfast Agenda and changes in planning legislation. The new policies primarily focus on sustainable development, health & wellbeing and addressing climate change.

A few of the most notable new policies include:

• An affordable/social housing policy, applicable to all developments of five units or more, or on sites of .1 hectare or greater. With the requirement that 20% of the units should be for affordable/social housing.
• The introduction of the Lifetime Home Standards to all new residential developments.
• A housing mix policy which would require developers to demonstrate that the type and size of units they are proposing is directly related to an unmet requirement in the area.
• The submission of a Health Impact Assessment on all major development proposals in order to demonstrate that a new proposal does not give rise to significant adverse effects on the health and wellbeing of people living and working in the immediate area.
• The inclusion of Community Cohesion policies which support new developments within proximity of peacelines.
• A subtle change in the exceptions tests to be applied to development proposals on zoned employment land and the introduction of a permissive policy which would support office development of up to 400 sq m at district and local centres.
• Within the city centre, support for mixed-use developments on sites identified within Masterplans and Special Action Areas, subject to normal planning criteria being addressed.
• The introduction of Environmental Quality policies which will place the onus on applicants to demonstrate that the new development does not give rise to unacceptable impacts upon the environment with a specific focus on ground contamination, air quality, water quality, noise and light pollution.
• That new developments should incorporate green infrastructure as an integral part of the proposals e.g. green walls or roofs, SuDS, tree and hedgerow planting.
• A natural heritage policy that would require that all planning applications should be accompanied by the appropriate site surveys and assessments.

Unlike submissions to previous draft Plan Strategies, all representations must be crafted on the basis of Soundness. It is not sufficient to simply register your objection to the plan. You need to explain why the Plan is unsound and identify the change you are seeking.

The tests of Soundness focus on:

• Procedural conformity – has the council followed its LDP timetable? Has the draft Plan Strategy been formulated in line with the legislative requirements?
• Consistency  - is the draft Plan Strategy in line with  planning policy and legislation and key council documents?
• Coherence and effectiveness – is there a robust evidence basis to support a draft policy/designation; are the policies realistic?

The period for the submission of representations to the draft Plan Strategy opened on Thursday 20 September, 2018 and will run until 15 November, 2018.

A detailed summary of the draft Plan Strategy can be found in the below downloadable PDF.

For more information or to discuss making representations, please contact Angela Wiggam or Emma Walker.

15 October 2018