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Update on Belfast draft Plan Strategy

The Belfast City Council (BCC) draft Plan Strategy was submitted to the Department of Infrastructure (DfI) on 30 August 2019 for consideration. This summary provides an update on the status of the draft Plan Strategy, comments on the number of Representations received and their content, and outlines where the draft Plan Strategy is in the Plan making process.

Executive Summary

Belfast City Council received 108 Representations and 14 Counter Representations to the Belfast draft Plan Strategy, with the Plan’s housing policies attracting the highest level of comments.

In its capacity of oversight and scrutiny, DfI is currently reviewing the draft Plan package, and is expected to confirm before the end of the year that the draft Plan Strategy has been referred to the Planning Appeals Commission (PAC) for an Independent Examination.

The Draft Plan Strategy

108 Representations were received to the BCC draft Plan Strategy following an eight week consultation period which ran from 20 September 2018 to 15 November 2018. The council’s schedule of Representations can be viewed here (all Representations can be viewed in their entirety).

Having reviewed and categorised the Representations, the council made all Representations available for viewing and provided a period for the submission of Site Specific Representations from 1 March 2019 to 26 April 2019. In total, 14 Site Specific Representations were received; they can also be accessed via the above link.

Representations

Of the 108 Representations to the draft Plan approximately 40% of responses were received from private sector organisations, and just over 30% from community and voluntary sector organisations and interest groups. The remaining 30% consisted of responses submitted by statutory consultees, individuals and housing associations. 60% of representations found the Plan to be unsound, 25% did not comment, and 15% considered the draft Plan to be sound.

The main issues raised within Representations relate to:

The Growth Strategy

While there was broad support for the approach of linking housing growth to economic and employment growth, and recognition of Belfast’s important role as the driver of the regional economy, a number of concerns were raised in relation to:

  • the cumulative impact of growth alongside the growth proposed by other councils within the wider Belfast Metropolitan Urban Area;
  • technical questions regarding the methodology for the underpinning Housing Growth Study;
  • lack of recognition that the functional Housing Market Area is broader than Belfast’s district;
  • whether the scale of growth proposed is realistic and deliverable; and
  • the wider impact on the wider transport and infrastructure networks.
Windfall Housing (HOU 2)

Low level of support for the policy as currently worded. The majority of respondents noted that it was not possible to accommodate all new residential development on brownfield sites and queried whether the policy should be removed.

Affordable Housing (HOU 5)

This policy attracted the highest number of responses. Whilst the majority were supportive of the policy intent, most raised queries with the outworkings of the policy including the rationale behind the policy triggers and thresholds, and sought details on how viability had been considered. 

Tall Buildings (DES 3)

Similar to HOU 5, this policy attracted a high number of responses with most respondents seeking further clarification on the policy wording and querying the evidence base to support the policy.

Transport infrastructure

A number of issues were raised in relation to transport generally, including:

  • the absence of an up to date Transport Plan/Strategy;
  • lack of capacity in the existing transport networks;
  • lack of reference to the need to change how people travel to enable planned growth to be delivered in line with the other council objectives; and
  • no recognition of the existing BCC Parking Strategy.
Broader Infrastructure networks

A number of issues were raised in relation to the infrastructure required to deliver the growth ambition including: 

  • the absence of an Infrastructure Plan to clarify how required infrastructure will be provided; and
  • lack of capacity in wastewater treatment and its impact on delivery.

Having reviewed the Representations received, the council is content that they have sufficient information to support the policy position outlined in the draft Plan Strategy and no focused changes are required. Whilst they have collated further information to support their evidence base, which was not available during the public consultation, the council is of the opinion that no further consultation is required. The council advises that the further information collated clarifies the current policy position. 

The council has prepared a consultation report which provides a detailed review of all Representations, categorised on a policy by policy basis.  The report is available here.

The Plan Process

The draft Plan Strategy was submitted to the Department for Infrastructure (DfI) on 30 August 2019 for consideration. In its capacity of oversight, DfI is currently reviewing the draft Plan package, and is expected to confirm before the end of the year that the draft Plan Strategy has been referred to the Planning Appeals Commission (PAC) for an Independent Examination.

For more information please contact Angela Wiggam or Emma Walker.

5 November 2019

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