Fylde's Local Plan: Re-Consultation
This is a really important article, but it takes a bit of following, so we hope you'll bear
We've made it as straightforward as we can.
It's about the procedure used for Fylde's new Local Plan, and it will affect the life of everyone in Fylde for the next 15 years or so.
When Fylde approved the Consultation version of the Local Plan (the 'Preferred Options' version), four important things happened.
- The Portfolio Holder (Cllr Trevor Fiddler) classed it as an 'Urgent' decision. This was a device to preclude it's being 'called-in' for debate at a Scrutiny Committee by those who opposed it.
- The Portfolio Holder had the right to (and did) approve the consultation version of the plan as an Individual Member Decision, but he (or David Eaves) chose to ask the Council to 'endorse' his decision.
He wanted the whole Council to buy in to it.
They did not.
At that Council meeting It was clear to all that the consultation version was using out of date information (the Regional Strategy), and that some of the other evidence (on the local housing market for example) had not even been received
from the consultants who were preparing it.
This meant that the public - who were being consulted - were being asked for their views on out-of-date, and inadequate information.
But the Conservative group on Fylde Council forced it through, using their majority in what looked to us like a pre-determined decision.
- Thirdly, most of the non-Conservative councillors at the meeting, - who had repeatedly sought to make amendments (which were voted down by the majority party) - issued a 'Minority
Report' a week or so later, setting out the reasons why 41% of councillors could not support this Consultation Version of the Local Plan.,
- Fourthly, shortly after the Minority Report, a statement was issued on behalf of ten major community groups concerned with planning matters in Fylde. Their
'Declaration of Unsound Planning
Consultation' deplored the failure of Fylde Borough Council to present for consultation an evidenced and justified assessment of the number of new homes required for the period to 2030.
They argued that the omission of the Council's own housing requirement figure was a most material factor in the current Consultation and it so critically compromised the ensuing policy they believed it rendered the consultation phase unsound.
The called on Fylde Borough Council to suspend the current consultation and withdraw the Preferred Options until it was able to support it with its own declared housing requirement together with its related evidence and reasoned justification.
They argued that an amended 'Preferred Options', together with the housing requirement, should only then be re-presented for public consultation.
Although we've no doubt Fylde will say they planned to do another consultation anyway, this is just what has happened.
Fylde is about to re-consult on the Preferred Options for its Local Plan.
But they're hiding the reason for doing so behind the responses they have just received to that original flawed consultation.
However, the covering letter with the 'consultation results' report that has just been released by the Council gives the game away.
"The Responses Report will be used to inform the next version of the Local Plan: Part 1, which will be a Revised Preferred Options Document.
Part 1 will be used to inform the preparation of a Revised Preferred Options Version, which is currently underway.
The Revised Preferred Option document will be issued for a six week consultation period upon acceptance by the Portfolio Holder."
Readers can follow this link to see the covering
letter in full.
What this means is that the original consultation was inappropriate and Fylde is having to do another one.
Informed opinion suggests this is an additional stage in the Local Plan process and it absolutely vindicates the stance taken by those who produced the Minority Report and the Statement of Unsound Consultation.
the Local Plan Timetable was to have been
- Publication Local Plan to Full Council July 2014
- Public Consultation September - October 2014
- Submission to SoS December 2014
- Examination in Public (EiP) February 2015
- Adoption April 2015
It is expected that this extra stage of a Revised Preferred Options Document will slip in before the 'presentation to Council' and it is thought that the extra stage will add about six months to the process to produce the Local Plan.
We believe it has had to be done because the original consultation was flawed and will not stand up to proper scrutiny, and because Fylde has been pushed into making so many changes to its flawed version, it could not claim it has properly consulted
on the plan's proposals.
One of the key things in the consultation will be the contentious (and to our mind wholly unjustified interpretation of evidence) that has become Fylde's housing figure.
This was approved, (yet again as an Individual Member Decision), by a single councillor (Cllr Trevor Fiddler).
His decision was called-in by Councillors who contested it, and it was (supposedly) considered by a Scrutiny Committee
But that Scrutiny Committee failed on so many levels, that we had to report it as a committee that was Not Fit For Purpose.
So we believe that, in addition to comments on the responses people made in the flawed consultation, the re-consultation will re-address also things like
- The Strategic Housing Market Assessment
- Fylde's Housing Requirement Paper
- The Employment Land and Premises Study 2012
These are the key issues that were complained about in the 'Minority Report' and we believe that report has been the catalyst that has brought about this re-consultation.
Whether sufficient changes have been made to these issues remains to be seen
when the revised 'Preferred Options' are published, but we suspect the changes won't be enough.
We believe this is because the majority Conservative Group, and the public at large, have differing views about the vision for Fylde's future.
Residents of this much-older-than-average borough mostly want to see little or no change. That's why so many object to new developments. They like Fylde as it is, and don't want to see it spoiled.
The leading political party seem intent on a future vision that features massively increased employment growth, and the houses that would be needed for all the additional workers.
The problem with this is that the Conservative vision is predicated on a fallacy about the scale of employment and economic growth that can be achieved.
Of the seven models that Consultants used to predict the future of employment in Fylde (and as we all know prophesy is not an exact science anyway), six of them said Fylde needed either the same or less land for employment in the future.
The seventh said Fylde needed twice as much employment land as they have now.
After explaining their findings to Fylde's officers, guess which of these models the consultants thought should be used.
You have it. The seventh.
The one that's contradicted by all the six others.
Readers will recall that in 'Local Plan Update' we said "it seems to us that Fylde's Local Plan is closer to needing a 'start all over again' than an 'update'" and we're still of that view.
At least the history of all these consultation comments will be visible to the Inspector when Fylde's plan is subjected to the Examination in Public, which now looks as though it will probably be next summer.
Notably, at Cabinet on 27 November last year, Cllr Fiddler put forward a report asking to spend an *extra* £105,000 preparing the Local Plan.
That's on top of the original budget provision of £368,000 - and before this additional re-consultation stage
(which will probably add another £10,000 plus officer time).
In Local Plan Update in December 2013, we quoted him telling the Cabinet "But we are confident at this stage that we can meet the existing timetable. There are issues that are outside our remit - things like the date for an inquiry and examination in
public that will mean that we have to fit in with the Planning Inspectorate's timetable and availability, but we have made representations to Government and they've given us assurance they will assist us all they can in a speedy agreement of a
suitable slot for the examination"
We also said "Despite his "we are confident at this stage" quote about meeting the timescale, we're much more sceptical."
Looks like we will be proved right, and the incompetence of a flawed original consultation which the Conservative group steadfastly refused to amend before it was issued, has not only insulted the people of Fylde by wasting their time on a consultation
that was unsound, the re-consultation will cost them more in cash, and it will delay the completion of the Local Plan.
Arrogance in action. You couldn't make it up, could you.
Dated: 12 Aug 2014