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Blackpool Local Plan Review – Inspector’s Report

APPENDIX B

INSPECTOR’S REPORT AND RECOMMENDATIONS AND OFFICER COMMENTS AND RECOMMENDATIONS TO THE COUNCIL ON THE PROPOSED MODIFICATIONS TO THE LOCAL PLAN.

1.1 Introduction and Strategy Paragraph 1.7The Objections326/1 CPRE (Lancashire Branch)

327/6 Miss A J Gray

Summary of the ObjectionsInclude maintaining and enhancing the natural environment in the Borough’s vision. (326)

Include protecting / enhancing the natural environment and waste reduction in the vision. (327)

Inspector’s Reasoning and Conclusions 1. This paragraph in the Local Plan reports what is currently in the Borough

Council’s Community Plan. Simply to add new considerations to the vision as described in the Local Plan without altering the Community Plan would make this paragraph inaccurate, which I do not recommend.

2. However, in the Second Deposit paragraph 1.8 was amended to say that the Borough’s vision is to be reviewed, although it also says that no fundamental changes are anticipated. It seems a little less than helpful for the Council not to have offered to consider these objectors’ views in that context. Be that as it may, I consider the Local Plan could usefully say that consideration will be given to these issues the next time the Community Plan is reviewed.

3. I conclude that Local Plan paragraph 1.8 could usefully refer to the possibility that protecting the natural environment and reducing levels of waste creation will be considered for inclusion in the Borough’s vision statement when it is next reviewed.

Recommendation4. I recommend that paragraph 1.8 in the Local Plan is modified by replacing

the last sentence with: In this review consideration will be given to adding protecting the natural environment and reducing levels of waste creation to the Borough’s vision statement.

Officer Comments

The review referred to in the Plan has subsequently been undertaken and a new Blackpool Community Plan vision for Blackpool 2004-2020 has been adopted by Blackpool Council and the Local Strategic Partnership.

1Introduction and Strategy Chapter 1


In these circumstances to make the paragraph accurate it is considered that rather than the amendment recommended by the Inspector it would now be better to replace paragraphs 1.7 and 1.8 with appropriate reference to the new vision statement as set out below.

With regard to the specific comments made in the objection concerning the natural environment and reducing levels of waste creation, it is considered these matters are fully embraced in the new vision statement which refers to the need “to ensure a sustainable environment” as one of two cross-cutting commitments, integral to the delivery of all six themes of the Community Plan – one of which is “quality homes in clean and green residential areas”. Direct reference is also made in the Community Plan to the objectives of ‘more environmentally sustainable practises’ and ‘less waste going to landfill and less fly-tipping in Blackpool’.

These factual changes to reflect the new Community Plan are up to date and therefore more accurate, but otherwise do not fundamentally change the position set out in the Local Plan. The Local Plan will establish the framework within which the Council ensures that Blackpool’s physical development contributes towards the ambitions of the Community Plan.

Officer Recommendations

That the Inspector’s modification is not accepted That the need for modification to reflect the updated Community Plan is accepted, and that

paragraphs 1.17 and 1.8 be amended to state:

1.7 The vision of the Council and its partners in the Local Strategic Partnership, expressed in Blackpool’s Community Plan 2004-2020, is that:

“Blackpool will have inclusive, healthy and safe communities, living in a regenerated, attractive and prosperous resort”

and that this should be achieved by delivering on six community themes. “The Community Plan states that in 2020 we want the residents of Blackpool to have:

o Quality education and trainingo Healthy liveso Safer communitieso Quality homes in clean and green residential areaso Strong and vibrant communitieso A prosperous town.

1.8 Within all these six themes are cross-cutting commitments, which are integral to the delivery of all six themes:

To ensure a sustainable environment To support vulnerable people

The Local Plan will establish the framework within which the Council ensures that Blackpool’s physical development contributes towards these ambitions



1.2 Introduction & Strategy Paragraph 1.22The Objection89/1 Countryside Agency (N W Division) (Conditionally Withdrawn)

Summary of the ObjectionMore attention should be given to the remaining natural environment in the Borough, the urban fringe and the needs of the surrounding rural areas in the Local Plan’s strategy.

Inspector’s Reasoning and Conclusions 1. It is not clear to me why this objection has been conditionally withdrawn, as

opposed to withdrawn completely. By this I mean only that I do not know what the withdrawal is conditional upon.

2. The Objector acknowledges that most of the Borough is already built up and that inner area regeneration is a key issue for the Council. Nevertheless the Objector wants more attention paid to rural and urban fringe issues and to sustainable regeneration that would not harm the natural environment.

3. In my view the Council has clearly (and correctly) identified the main elements of its planning strategy in Local Plan paragraph 1.22. These include all aspects of environmental quality, although the urban and built environment is correctly identified as the main focus. This recognises the built-up character of the area and its tightly drawn boundary. I consider that to include references to the natural environment merely for completeness would dilute and reduce the clarity of what is being said.

4. As to the needs of the surrounding rural hinterland, the Council says these are reflected in the policies to regenerate Blackpool town centre in order to provide a thriving sub-regional centre. However, in general the policies in this Local Plan cannot extend beyond the Borough boundary.

5. I conclude that no modification to the Local Plan is needed.

Recommendation6. I recommend no modification to the Local Plan in response to this

objection.


That the Inspector’s recommendation is accepted.



2.1 Reshaping the Resort Paragraph 2.6: Chapter ObjectivesThe Objection287/28 Tesco Stores Limited

370/ 1 / 2 The Noble Organisation

Summary of the ObjectionThe Local Plan should make reference to the need to ensure the Borough has the necessary infrastructure and facilities to support new tourism attractions and accommodation. These should include retailing, especially convenience retailing, to cater for self-catering visitors. (287)

The objectives relating to family attractions (deleted in the Second Deposit) should be reinstated. (370)

Inspector’s Reasoning and Conclusions 1. Paragraph 2.6 sets out objectives for the Resort Regeneration chapter.

Objector 287

2. Tesco’s objection is one of several they made to the effect that the Local Plan should reflect the need for, and importance of, shopping facilities – especially convenience shopping to meet the needs of visitors.

3. I do not dispute the importance of shopping facilities to the town as a resort or as a place to live. I also accept that shopping policies should reflect the characteristics and needs of the town as well as government guidance. But there are already policies in the Local Plan to guide retailing development.

4. I consider it is unnecessary and undesirable that references to the need to provide adequate shopping facilities are scattered throughout the Local Plan. To draw an analogy, other requirements for development (such as adequate access, adequate drainage and good design) need not be repeated in every policy that guides development. If every policy listed every requirement that might arise, the Local Plan would be very long and cumbersome.

5. I conclude that, as a general rule, consideration of retailing should be confined to the shopping policies in the Local Plan and that no modification arises from this objection.

Objector 370

6. In support of their objections to other policies in this chapter (to the effect that the Local Plan pays insufficient regard to the existing family orientated leisure market in Blackpool) it is suggested that the two objectives deleted from paragraph 2.6 in the Second Deposit should be reinstated. I note that other objectors take issue with the Local Plan because they consider it pays insufficient regard to Blackpool’s attractiveness for families.

7. As far as the first of the two deleted objectives is concerned, this said (in the First Deposit) that the appeal of existing major visitor attractions should be safeguarded. In my view this creates a difficulty because some existing facilities may need to be redeveloped for other purposes. For example, this Objector proposes that the Coral Island site should be the location for a casino. There may be other examples of existing facilities that will need to be replaced because of redevelopment. I therefore consider it would be inappropriate to have a blanket objective that could be read as protecting all existing attractions.



8. It is also the case that it is not the proper role of the planning system to protect one business from competition from another business and the objective as it was in the First Deposit could be seen as having that effect.

9. In any event, the last two objectives in the Second Deposit already refer to maintaining a broad appeal to a full range of holiday visitors and ensuring that regeneration creates a sustainable and inclusive resort.

10.For these reasons I conclude it is not necessary or desirable to reinstate the first of the deleted objectives.

11.As far as the second deleted objective is concerned, this refers to making the resort and its attractions conveniently accessible. In my view this is, in principle and on the face of it, a reasonable and important objective. At the Local Plan Inquiry the Council did not argue to the contrary.

12.However, I note that some objectors argue that this objective can only be achieved by retaining (or increasing) the amount of car parking in the Resort Core. In my view such an approach could be in conflict with government guidance on transport and car parking. But in my view this objective need not be interpreted to mean this and only this – for example I was told that alternative approaches, including park and ride, have not yet been fully explored. There are also other proposals that could relate to this objective, such as improving pedestrian links within the Resort Core.

13. I therefore conclude that, notwithstanding that some may seek interpret it in a narrow or misleading way, the First Deposit objective relating to accessibility should be reinstated.

Recommendations14. I recommend that the First Deposit objective relating to accessibility that

was deleted in the Second Deposit should be reinstated. 15.Otherwise I recommend no modification to paragraph 2.6.


That the Inspector’s recommendations are accepted, and that the First Deposit Objective relating to accessibility is reinstated in Paragraph 2.6 as follows:

“To make the resort and its attractions conveniently accessible”



2.2 Reshaping the Resort Policy RR1The Objections009/1 Jenny Allcock

287/1 Tesco Stores Limited

306/ 1 / 11 Leisure Parcs Limited

Summary of the ObjectionsBlackpool should maintain its appeal as a family resort. The Objector would like to see more facilities for children in the Promenade area, such as static play equipment, crazy golf, putting, picnic areas, good toilets and baby changing facilities. (009)

The policy should make reference to the need to ensure that Blackpool has the necessary infrastructure and facilities to support new tourism attractions and accommodation. These should include retailing, especially convenience retailing, to cater for self-catering visitors. (287)

Include all of Blackpool Tower, together with Bank Hey Street, in the Resort Core. (306)

Inspector’s Reasoning and Conclusions 1. This policy and its accompanying text were deleted in the Second Deposit. At

one level this meets these objections but I do not think this would necessarily satisfy the objectors.

Objector 9 (Ms J Allcock)

2. As well as Ms Allcock, other objectors have made similar comments in relation to other parts of the Local Plan.

3. In response the Council says the Local Plan is not a brochure or marketing document and should not be read as one. However, it is acknowledged that one of the objectives is to maintain a broad appeal and a full range of facilities, including catering for the family market.

4. The Council says the areas covered by policies RR13 and RR14 (the Central and other Promenades) are the most appropriate places for the sort of facility the Objector suggests. Policy RR13 refers to improved information, toilet, seating and refreshment facilities and policy RR14 refers to the provision of shelter(s), seating, amenities and environmental improvements. The Council has also added a reference to facilities for children in paragraph 2.65 and PC3 suggests that the following is added to paragraph 2.15a: “The Council in applying the policy criteria, will take account of the need to sustain and encourage Blackpool’s existing family-orientated day-trip and visitor markets, as well as develop new attractions and seek to cater for new visitor markets.”

5. In these ways, it seems to me, the Council is moving in the direction suggested by this Objector. However, I suspect that in her mind it is as much a question of tone and balance as counting the number of references to families, children or the facilities that appeal to them. I can see why a reader might feel that the Local Plan concentrates unduly on large facilities and new markets at the expense of modest facilities for established visitors. However, the Local Plan is primarily concerned with the development of land at a rather general level. It is less concerned with small details even though these may be the things that affect the way an area works and who it appeals to.

6. I am therefore inclined to sympathise with the Objector without being able to identify anything specific that I should do about it. In the circumstances I invite the Council to consider whether it might not be appropriate to include a new

6Reshaping the Resort Chapter 2

Blackpool Local Plan Review – Inspector’s Reportpolicy directed specifically at the provision of small scale facilities suitable for families and children as indicated in this objection.

Objector 287 (Tesco Stores)

7. Tesco’s objection to this policy is one of several they have made to the effect that Local Plan policies should reflect the need for, and importance of, shopping facilities – especially for convenience shopping to meet the needs of visitors.


9. I consider it is unnecessary and undesirable that references to the need to provide adequate shopping facilities are scattered throughout the Local Plan. To draw an analogy, other requirements for development such as adequate access, adequate drainage and good design need not be repeated in every policy that guides development. If every policy listed every requirement that might arise, the Local Plan would be very long and cumbersome.

10. I conclude that, in general, consideration of retailing should be kept to the shopping policies and that no modification arises from this objection.

Objector 306 (Leisure Parcs)

11.These objections (one to the text and one to the Proposals Map) have been met by map RR2.7.8PM1 in the Second Deposit. At the Local Plan Inquiry the Objector confirmed that no further change is sought.

Recommendations12. I recommend that the Council considers whether a new policy dealing

with small scale facilities suitable for families and children would form a useful addition to the Local Plan.

13. I recommend no modification to the Local Plan in response to objection 287/1.

14. I recommend no modification to the Local Plan in response to objections 306/1 and 306/11.

Officer Comments

The first recommendation is to consider whether a new policy dealing with small scale facilities for families and children would be a useful addition to the Plan.

Most of the resort policies are site specific and your officers view is that it is not appropriate to make more detailed reference to the kind of facilities sought to be provided beyond that already set out in these policies. The objectors concerns are most focussed on the Promenade areas and Policies RR13 and RR14 include specific references to ‘including facilities for children’ in the supporting text.

Policy RR2 is the main policy which deals ‘generally’ with proposals for new visitor attractions. Again, specific reference is already included in a proposed change to the


Blackpool Local Plan Review – Inspector’s Reportsupporting text put forward by the Council to directly refer to the need to sustain and encourage Blackpool’s existing family visitor market. Within the main policy RR2 wording criterion (b) requires that

“the proposal would increase the range and/or quality of facilities available to the visitor and contribute to safeguarding and growing Blackpool’s visitor market”.

It is considered it would not be appropriate to go further than this in the main policy text and require that each individual development should do more than contribute to safeguarding and growing Blackpool’s visitor market.

OfficerRecommendations

The inspector’s recommendations are accepted

That having given further consideration, it is not considered appropriate to include an additional policy dealing with small scale facilities for families and children.

2.3 Reshaping the Resort Paragraph 2.7The Objection277/6 Brian J Dougherty

Summary of the ObjectionDelete the word "dependant" and replace it with "dependent". (277)

Inspector’s Reasoning and Conclusions 1. The spelling mistake was corrected in the Second Deposit.

Recommendations2. I recommend no modification in response to this objection.

Officer Recommendation

The inspector’s recommendation is accepted

2.4 Reshaping the Resort Paragraph 2.8 and Proposals MapThe Objection248/ 1 / 2 Blackpool Pleasure Beach (Conditionally Withdrawn)

Summary of the ObjectionThe Proposals Map should be amended to include all of the Pleasure Beach and its car parks in the Resort Core and the Defined Inner Area. The Resort Core should be extended to Harrow Place. As a result, paragraph 2.8 should also be amended to reflect this. (248) (First Deposit)


Blackpool Local Plan Review – Inspector’s ReportInspector’s Reasoning and Conclusions

1. Changes were made in the Second Deposit which, as confirmed at the Local Plan Inquiry, satisfies the Objector as far as these objections are concerned.

2. I conclude that no modification to the Local Plan arises.

Recommendation3. I recommend no modification to the Local Plan in response to objections

248/1 and 248/2.


The inspector’s recommendation is accepted

2.5 Reshaping the Resort Policy RR2The Objections254/1 The Gables Balmoral Hotel (Blackpool) Limited

278/2 D Whitfield



370/1 The Noble Organisation

Summary of the ObjectionsReplace the last paragraph of RR2 with "Planning obligations may be sought from major developments within the Resort Core to provide for necessary infrastructure and/or to address adverse impacts on the environment, if any". (254)

More information, more specifics and more urgency are required. Dates and proposals for this area are needed now. The process being followed is creating uncertainty and is doing irreparable damage to businesses, investment and property prices in the area. (278)

The policy should make reference to the need to ensure the Borough has the necessary infrastructure and facilities to support new tourism attractions and accommodation. These should include retailing, especially convenience retailing, to cater for self-catering visitors. (287)

The desirability of concentrating major tourist developments in the Resort Core is accepted. But each development should be assessed on its viability and regeneration merits to determine whether it is necessary to require a planning obligation. On this basis it is considered that the final section of this Policy should be amended to read: "Where appropriate the Council may seek planning obligations from major development within the Resort Core towards the cost of schemes introduced under the Quality Management Initiative for the area. Each proposal will be assessed on its contribution to the town centre in determining whether a planning obligation is required." (306/2)

Amend the first criterion to: `The proposal makes a strong positive contribution to the physical and economic regeneration of the Resort Core, targeting, as far as possible those areas/sites in greatest need of investment and renewal'. (306/19)

Recommend the following alternative to criterion (c): The development proposal and associated activities, including the trip generation, will not undermine existing major visitor attractions in terms of their pedestrian and vehicular accessibility (including car parking) and will otherwise relate well to them and to other adjoining uses as well as other existing visitor attractions and facilities, holiday and residential accommodation. (370)


Blackpool Local Plan Review – Inspector’s ReportRecommend the following as an addition to the end of paragraph 2.15(b): `The Council, in applying the Policy criteria, will take account of the need to sustain and encourage Blackpool's existing family orientated day trip and visitor markets, the facilities that currently attract those markets and the risks of undermining those facilities particularly where public sector funding may provide a direct or indirect subsidy to commercial schemes competing with existing attractions'. (370)

Proposed ChangesPC1 suggests that criterion (a) in the policy should refer to economic regeneration as well as physical regeneration.

PC2 suggests that paragraph 2.11 should be expanded to list the Pleasure Beach, three piers and the Tower as major attractions.

PC3 suggests paragraph 2.15a should be expanded with “The Council in applying the policy criteria, will take account of the need to sustain and encourage Blackpool’s existing family orientated day trip and visitor markets, as well as develop new attractions and seek to cater for new visitor markets.”

Objections to the Proposed Changes370/7 The Noble Organisation

Summary of the Objection to the Proposed Changes The Proposed Change does not meet the Noble Organisation’s objection which is maintained. (370)

Inspector’s Reasoning and Conclusions Objector 254 (The Gables Balmoral Hotel)

1. As far as the reference in the First Deposit policy RR2 to planning obligations is concerned, this was deleted from the policy in the Second Deposit and in one sense this met this objection. However, the Second Deposit also added paragraphs 2.15b and 2.15c to the accompanying text and these refer to planning obligations. This added text does not use the form of words suggested by this Objector, although they did not object to the new text by making an objection to the Second Deposit.

2. Be that as it may, taken together (deleting part of the policy and adding to the text), the changes are, in my view, moving towards what the Objector was seeking, although I recognise that the Objector wanted a far more restricted approach to the subject.

3. In my view it is legitimate for the text in the Local Plan to refer to such matters and it is not necessary for such references to be restricted to providing infrastructure. In the last analysis, such matters can only be determined on a case by case basis depending on the nature of the development proposal involved, the nature of the obligations sought or offered and the rules and conventions in place at the time (currently Circular 1/97). The Objector views this as involving a time consuming and wasteful appeal process that may deter would-be investors. However, this is the back-stop that, in my view, cannot be avoided.

4. In the circumstances I conclude that no (further) changes to the Local Plan are needed in response to objection 254/1.

Objector 278 (D Whitfield)

5. Other than more rapid progress it is not clear what would satisfy this objection. However, major regeneration takes time to formulate and implement. In any event the Local Plan is not necessarily the right place for detailed plans and (possibly spurious) target dates and I cannot invent or impose these if none are suggested to me.


Blackpool Local Plan Review – Inspector’s Report6. I note this Objector has objections to other parts of the Local Plan (especially

relating to the desirability – or not – of resort casinos and the future of the Foxhall / Rigby Road area). I therefore deal with the specific issues of concern to this Objector under those headings.

7. I conclude that no modification to policy RR2 arises from this objection.


8. Tesco’s objection to this policy is one of several they have made to the effect that Local Plan policies should reflect the need for, and importance of, shopping facilities – especially for convenience shopping to meet the needs of visitors.


10.However, I consider it is unnecessary and undesirable that references to the need to provide adequate shopping facilities are scattered throughout the Local Plan. To draw an analogy, requirements for development such as adequate access, adequate drainage and good design need not be repeated in every policy to guide development. If every policy listed every requirement that might arise, the Local Plan would be very long and cumbersome.

11. I conclude that, in general, consideration of retailing should be confined to the shopping policies and that no modification arises from this objection.


12.This Objector’s suggested wording for the first part of policy RR2 was included in the Second Deposit. I therefore conclude that objection 306/19 has been met and that no further changes arise.

13.As far as the reference in the First Deposit policy RR2 to planning obligations is concerned, this was deleted from the policy in the Second Deposit and in one sense this meets this objection. However, in the Second Deposit paragraphs 2.15b and 2.15c dealing with planning obligations were added to the text. This added text does not use the form of words suggested by this Objector but they have not objected to the new text and it is, in my view, in keeping with what the Objector was seeking.

14. In the circumstances I conclude that no (further) changes to the Local Plan are needed in response to objection 306/2.

Objector 370 (The Noble Organisation)

15.At the Local Plan Inquiry this Objector suggested a major redrafting of this policy, largely to accommodate material currently included in policy RR6 which could then be deleted. Whilst I concede that such a comprehensive approach has its attractions, it would make for a rather unwieldy policy. Also, in view of the importance the Council and others attach to casinos, I consider the balance of advantage lies with leaving RR6 as a separate policy. In the last analysis whether this material appears in the Local Plan in one policy or two should not affect its content and meaning and is, in my view, a matter that can be left to the Council to decide.

16. I therefore conclude that this policy should not be modified to incorporate material now in policy RR6. Therefore I deal here only with the specific issues


Blackpool Local Plan Review – Inspector’s Reportraised by this Objector in relation to policy RR2 (as in the Second Deposit but bearing in mind PC1, PC2 and PC3). At the Second Deposit stage this Objector sought specific changes to policy RR2 and the accompanying text and expanded on their objections at the Local Plan Inquiry.

17.The first of the objections relates to criterion (c) in the first part of the policy, which the Objector wants modified to contain specific references to existing major visitor attractions not being undermined in terms of pedestrian and vehicular accessibility (including car parking).

16. In my view there are difficulties with what the Objector is seeking here. First, not undermining (all) existing major visitor attractions is problematic because some existing facilities may be redeveloped as part of the wider resort regeneration and redevelopment. Indeed, this Objector proposes that the Coral Island site should be the location of a regional casino. There may be other examples of existing facilities that need to be replaced by redevelopment. I therefore consider it would be inappropriate to have a blanket criterion that could be read as protecting all existing (major) attractions in this or any other respect. It is also the case that it is not the proper role of the planning system to protect one business from competition from another business.

17.Whilst I see benefits in referring to pedestrian and vehicular accessibility, it is not clear what this would add to the existing wording that already refers to trip generation. Moreover, referring explicitly to car parking in a way that is designed to secure its retention as a matter of policy and principle is not in accord with current government guidance. These are matters I return to in several places in relation to other objections later.

18.On balance, therefore, I conclude that there are difficulties with the wording changes for criterion (c) suggested by the Objector and I do not recommend them.

19.However, when I come to consider Nobles’ objection to policy RR7, I conclude that policy RR2 should have an additional clause indicating that new attractions should reinforce the existing concentrations of such uses rather than leading to a dispersed distribution of attractions.

20.The Objector also wants Coral Island mentioned by name in paragraph 2.11 along with the other major attractions that are listed. Whether or not the Council’s doubts about the Objector’s estimate of the number of visitors to Coral Island are right, it is clearly a major attraction. Even so, my first instinctive reaction to the Objector’s suggested change was that Coral Island is different from the other attractions listed in this paragraph because the others are reasons why visitors come to Blackpool, whereas Coral Island is “merely” somewhere they go when they are already in the town. But on reflection I have no evidence that this is the case and it may not be true; people may come to Blackpool (at least in part) in order to visit Coral Island.

21.Therefore, I conclude that Coral Island should be added to the list of attractions listed in paragraph 2.11.

18.Finally, the Objector wants some text added to paragraph 2.15a. To an extent this would mirror the changes sought in criterion (c) that I have already dealt with (and rejected) above. In addition it is suggested that a specific reference is made to the possibility of public sector subsidy for new attractions. At the Local Plan Inquiry it was explained that this arose from fears that, in complex land


Blackpool Local Plan Review – Inspector’s Reportand funding arrangements, casinos might (in effect) be subsidised by other uses on the same site. The Council found this hard to accept even as a possibility and I also do not accept that it is likely to arise in practice.

19. I conclude that no modification to paragraph 2.15a arises.

Recommendations20. I recommend no modifications to the Local Plan in response to objections

254/1, 278/2, 287/2, 306/2 and 306/19.21. I recommend that PC1, PC2 and PC3 are advertised as modifications to

the Local Plan.22. I recommend no modification to criterion (c) in policy RR2 in response to

objection 370/1.23. I recommend no modification to paragraph 2.15a.24. I recommend that Coral Island should be added to the list of attractions to

be listed in paragraph 2.11.25.NB: I recommend a modification to this policy arising from my

consideration of an objection to policy RR7. I recommend that policy RR2 should have an additional clause indicating that new attractions should reinforce the existing concentrations of such uses rather than leading to a dispersed distribution of attractions.

Officer CommentsIt is recommended that the Inspector’s recommendation that Coral Island is added to the list of attractions is not accepted. There is no disagreement with the Inspector’s conclusions that people may come to Blackpool (at least in part) in order to visit Coral Island.

However, whilst accepting this your officers view is that this does not mean that Coral island should therefore be referred to as part of “the magnet that attracts most visitors into the resort” as set out in paragraph 2.11 (as amended). Those facilities referred to in paragraph 2.11 (the Pleasure Beach, three piers and the Tower) are all longstanding attractions that have fundamentally been the foundation on which visitors have come to Blackpool for over a hundred years. The Tower and Piers are also important facilities effectively safeguarded by other policies of the Plan, whereas the Pleasure Beach comprises a whole range of buildings, rides and facilities.

Viewed in these terms, although the Coral Island is a major entertainments complex, it is of a lesser scale. It is also not safeguarded in the Plan and indeed may itself become a redevelopment site – as potentially sought by the Objector and the Council under Policy RR7. Coral Island forms (perhaps the biggest) but just one of a number of existing other major attractions along the Golden Mile. In these terms it is considered it is the more generic “Golden Mile” that should be added to the list of attractions in paragraph 2.11 rather than Coral Island.

Officer Recommendations Recommendations (20 –23) are accepted and that PC1, PC2, and PC3 are accordingly

advertised as modifications to the Plan:


Blackpool Local Plan Review – Inspector’s Report PC1

Amend the first criterion to:

‘(a) the proposal makes a strong positive contribution to the physical and economic regeneration of the Resort Core, targeting, as far as possible those areas/sites in greatest need of investment and renewal.

PC2

Amend first sentence in paragraph 2.11:

‘The attractions and facilities within the Resort Core such as the Pleasure Beach, three Piers, and the Tower are the magnet that attracts most visitors, both day-trippers and staying guests, to the resort.’

PC3New sentence added to end of paragraph 2.15(a):

‘Where development proposals meet the policy criteria and other policies of the plan the Council will be prepared to assist in site assembly. The Council in applying the Policy criteria, will take account of the need to sustain and encourage Blackpool’s existing family orientated day trip and visitor markets, as well as develop new attractions and seek to cater for new visitor markets.’

Recommendation (24) is not accepted, but instead it is recommended that ‘the Golden Mile’ should be added to the list of attractions to be listed in paragraph 2.11.

Recommendation 25 is accepted, with an additional criterion (d) to therefore be added to Policy RR2 to state:

(d) New attractions should reinforce the existing concentrations of such uses rather than leading to a dispersed distribution of attractions

2.6 Reshaping the Resort Paragraph 2.12The Objections213/6 Mr I Gray

335/6 Mrs Gray

Summary of the ObjectionsThe area including Tyldesley Road should not be transformed. The Resort Core should extend no further than the gas holders site and should not include the coach parking area or Blundell Street car park. More information about development is urgently required for people living and working in this area (213) (335)

Inspector’s Reasoning and Conclusions 1. These identical objections take exception to the idea expressed in this

paragraph that the Resort Core should be transformed. In my view the use of this term in this paragraph is unexceptionable. I conclude that paragraph 2.12 of the Local Plan does not need to be changed.

2. However, also contained within this objection are criticisms of the extent of Key Tourism Investment Sites RR7.2 and/or RR7.3 as well as an objection seeking the retention of two existing car / coach parks. I deal with coach parking under policy RR17 and other aspects of the objections are best considered in relation to policy RR7.

Recommendations3. I recommend no modification to paragraph 2.12 in response to these


Blackpool Local Plan Review – Inspector’s Reportobjections.

4. For more on coach parking see under RR17 and for more on policy RR7.2, see under that policy.


The Inspector’s recommendation is accepted

2.7 Reshaping the Resort Policy RR3The Objections194/ 2 / 76 Government Office for the North West (194/2 Partially Withdrawn)

213/1 Mr I Gray

255/1 Beverley Moy

278/1 D Whitfield


306/3 Leisure Parcs Limited

335/5 Mrs Gray

365/4 Threadneedle Property Investments Ltd (Conditionally Withdrawn)

366/1 Bourne Leisure

Summary of the ObjectionsThe policy needs to be more precisely worded and explained more fully. The only unresolved aspect of this objection relates to the last sentence in the policy. The Objector says it is not clear that there is a planning justification for requiring en-suite facilities in each bedroom. Neither is it clear what a “high standard in terms of size and layout” means. (194)

If there is already a surplus of low quality accommodation, it should be improved to bring it up to the desired standards. Therefore invest in existing accommodation so that hoteliers who live and work in the town are able to improve and bring the visitor accommodation up to the high standard that is required for the Blackpool of the future. Hotel Investment Grants are the solution. (213) (278) (335)

The threshold used to establish liability for VAT may deter small businesses (including hotels) from improving their facilities. No specific modification to the Local Plan is suggested. (255)


Leisure Parcs objected to this policy in the First Deposit but changed to supporting it in the Second Deposit. (306)

Holiday accommodation should be directed towards the most sustainable locations. The penultimate sentence of paragraph 2.18 should read `...Blackpool's resort neighbourhoods, Resort Core and town centre'. (Second Deposit) (365)

Blackpool has a range of accommodation for visitors, including caravan and camping facilities that should be properly planned for. The part of the policy that requires new accommodation to provide en-suite facilities is not practical for camping and caravan sites and this should be recognised. The policy should clarify that the extension or improvement of caravan and camping accommodation, including holiday parks, will be permitted subject to clauses (i) - (iii) of the policy but recognise that such sites cannot comply with the requirement for en-suite bedroom accommodation. (366)


Blackpool Local Plan Review – Inspector’s ReportProposed ChangesPC4; suggests altering criterion (A) (iii) to “in the town centre”.

PC85; suggests reinstating the original criterion (A) (iii) in addition to the one suggested in PC4.

Objections to the Proposed Changes306/27 Leisure Parcs

Summary of the Objections to the Proposed ChangesPC4: While supporting the recognition of the town centre as a suitable location for hotels, the loss of the original criterion A (iii) is objected to. (306) (But this was reversed in PC85.)

Inspector’s Reasoning and Conclusions Objector 194 (Government Office for the North West)

1. The only unresolved aspect of this objection relates to the last sentence in the policy. The Objector says it is not clear there is a planning justification for requiring en-suite facilities in each bedroom. Neither is it clear what a “high standard in terms of size and layout” means.

2. There may be something of a difficulty here because one thing a Planning Inspector has wide experience of is hotel rooms in all their infinite variety. I cannot entirely put aside this personal experience in dealing with this objection.

3. The Council says the requirement for en-suite facilities arises because there is already a lot of holiday accommodation in Blackpool without such facilities and there is a need to redress this imbalance. This seems to me to be a legitimate planning concern. I would also add that, in this day and age, en-suite facilities are regarded by many as a basic requirement and that to provide new accommodation without them could do nothing to enhance the attractiveness and reputation of Blackpool as a resort. I consider that this is also a material planning consideration. Lastly, to be creating new accommodation that is in some sense unsuitable or marginal for holiday use could cause planning problems in the future as this new but marginal holiday accommodation falls out of use. I therefore consider that this aspect of the policy is reasonable, reasonably related to planning and important for the future of the resort.

4. As to the other high standards referred to in the policy (size and layout) the Objector may be right that these can be difficult to define. Having said that, in my experience, recognising low standards when one encounters them is never difficult. Be that as it may, I note that paragraph 2.19a says Supplementary Planning Guidance will be produced to address this issue and I consider that this will resolve matters.

5. I conclude that no (further) changes to the Local Plan arise from the objections 194/2 and 194/76.

Objectors 213, 278 and 335 (Mr Gray, D Whitfield, Mrs Gray)

6. The Council’s response to these objections is that both approaches are needed. The Council says that there are grant schemes available for hoteliers seeking to improve their accommodation but this is not directly a matter for the Local Plan. At the same time it would not be sensible for the Local Plan to resist the provision of new accommodation if this is of a high quality.

7. I accept that the Local Plan, whilst in general trying to deal with a problem of low quality accommodation and over-provision, cannot turn its back on


Blackpool Local Plan Review – Inspector’s Reportinvestment in new accommodation. What this policy seeks to do, is limit the areas in which this can take place and ensure that any new accommodation is of a high standard. In my view this is in the overall best interests of the resort and those who depend on it for their livelihoods.

8. I conclude that no modifications arise from these objections.

Objector 255 (Mrs Moy)

9. The Objector is concerned the threshold used to establish liability for VAT may deter some small businesses (including hotels) from upgrading and increasing their turnover. The Council did not dispute this but said that it lies beyond the remit of the Local Plan. I agree with this. The Objector does not suggest any specific modification to the Local Plan that could meet this objection.

10. I conclude the Local Plan should not be modified in response to objection 255/1.


11.Tesco’s objection to this policy is one of several to the effect that Local Plan policies should reflect the need to, and importance of, providing shopping facilities – especially for convenience shopping to meet the needs of visitors.


13. I consider it is unnecessary and undesirable that references to the need to provide adequate shopping facilities are scattered throughout the Local Plan. To draw an analogy, requirements for development such as adequate access, adequate drainage and good design need not be repeated in every policy to guide development. If every policy listed every requirement that might arise, the Local Plan would be very long and cumbersome.

14. I conclude that, in general, retailing should be left to the shopping policies in the Local Plan and that no modification arises from this objection.

Objector 306 (Leisure Parcs) Objector 365 (Threadneedle Property)

15. I consider that these Objectors’ concerns about this policy would be met if PC4 and PC 85 are advertised as modifications to the Local Plan. I conclude that this should be done. In any event objection 365/4 has been conditionally withdrawn in view of PC4 and PC85.

Objector 366 (Bourne Leisure)

16.The Objector complains that the policy does not deal appropriately with camping and caravan sites and holiday parks. In response to the objection paragraph 2.19a was added to the text but in my view this does not address the issues raised by the objection. I consider this is a distinct sector of the tourist market that may warrant special consideration.

17.The Objector says that Blackpool has caravan and camping facilities, which I accept is the case. However, I am not aware of any proposals to provide new sites or to extend existing ones and in the circumstances I am not convinced that I should recommend an alteration to the policy to cater for extending such sites (as suggested in the objection). However, it may be appropriate to provide a policy context for dealing with proposals to improve the existing facilities,


Blackpool Local Plan Review – Inspector’s Reportalthough a general policy about hotels and other forms of “built” holiday development may not be the best place to do this.

18. I feel I have insufficient information on this matter to decide the best way forward. Much will depend on the number of sites involved and whether there are likely to be proposals to improve them that involve development. In the circumstances I conclude that further consideration should be given to including a new policy in the Local Plan to deal specifically with camping, caravan and holiday park facilities in Blackpool.

Recommendations19. I recommend no modifications to the Local Plan in response to objections

194/2, 194/76, 213/1, 278/1, 287/3 and 335/5.20. I recommend that PC4 and PC85 are advertised as modifications to the

Local Plan.21. I recommend that consideration is given to including a new policy in the

Local Plan to deal specifically with camping, caravan and holiday park facilities in Blackpool.

Officer Comments

The Inspector recommends that consideration is given to a new policy to deal with camping, caravanning, and holiday park facilities which he considers a distinct sector of the tourist market. This matter was not discussed in detail at the Inquiry and the Inspector feels he had insufficient information on this matter to decide the best way forward.

The position is that there are two main holiday visitor caravan parks in Blackpool at Marton Mere and at Newton Hall. The latter site straddles the boundary and the potential for development proposals on this site is focused on the lands outside of Blackpool. The Marton Mere caravan park is on land on long term lease from Blackpool Council and the Council thus has estates control in addition to caravan site licensing control over any further development of this site.


The Inspector’s recommendation 19 and 20 are accepted and PC4 and PC85 are accordingly advertised as modifications to the Plan:

PC4/PC85Criterion (A) (iii) deleted and replaced with: (A) (iii) on other sites where specifically indicated in the plan

(iv) in the town centre

In accordance with the Inspector’s recommendation 21, following consideration it is not considered there is a requirement for a new policy in the Local Plan specifically to deal with camping, caravan, and holiday park facilities.



2.8 Reshaping the Resort Policy RR4 also Paragraph 2.22 and the first Paragraph 2.23

Objections to Policy RR4287/4 Tesco Stores Limited


367/2 Hilton Group PLC


Objection to Paragraph 2.22326/3 CPRE (Lancashire Branch)

Objection to Paragraph 2.23367/3 Hilton Group PLC

Summary of the ObjectionsThe policy should make reference to the need to ensure the Borough has the necessary infrastructure and facilities to support new tourism attractions and accommodation. These should include retailing, especially convenience retailing, to cater for self-catering visitors. (287) (First Deposit)

The Objector supports providing new conference facilities, which can no longer be at the Winter Gardens. But these should be in the town centre or Resort Core. Conference and exhibition facilities in other locations should only be permitted where they are provided as an ancillary facility to hotel accommodation or when a sequential appraisal has been carried out which demonstrates there are no sites within the town centre or Resort Core. (306) (First Deposit)

The Objector supported the more positive approach to conference facilities in the First Deposit that, while focussing major conference facilities in and adjacent to the town centre, allowed for smaller scale facilities in the Resort Neighbourhoods and elsewhere on the Promenade. Conference facilities are fundamental to the viability of hotels and investment in hotels because they allow all-year operation. The Second Deposit policy is too restrictive because it limits conference facilities away from the town centre to an ancillary role and scale. Particular objection is made to imposing a 1000 sq m ceiling on the size of ancillary conference facilities at hotels outside the town centre. The Hilton site should be seen as a major anchor and attraction on the northern side of the town with commensurate facilities. Policy RR4 should be modified to be more positive and more flexible to allow the development of high quality hotel and conference facilities in the Resort Neighbourhood areas. Policy RR4 should be revised to say: (a) new conference and exhibition facilities should be located on sites within or on the edge of Blackpool town centre; (b) conference and exhibition facilities will be permitted in Resort Neighbourhoods and elsewhere on the Promenade, provided they are ancillary to the main visitor accommodation use; (c) the former Central Station Site (RR7.1) is allocated for comprehensive redevelopment incorporating a new National Conference/Exhibition Centre. (367) (Second Deposit)

The final part of policy RR4 should say: while the former Central Station site (RR7.1) is allocated for comprehensive redevelopment including the new National Conference/Exhibition Centre, the siting, design and configuration of the proposed facilities will be expected to sustain and enhance the pedestrian and vehicular accessibility (including car parking) to the area to the north of the site and to avoid any fragmentation or isolation of the attractions between the Blackpool Tower and Central Pier. (The extent of site RR7.1 is also objected to but this is dealt with at RR7.1.) (370) (Second Deposit)

Summary of the Objection to Paragraph 2.22Add a paragraph justifying the presumption against out-of-town-centre conference facilities. A definition of 'major' development would also be useful as a guide to potential developers. (326) (First Deposit)

Summary of the Objection to Paragraph 2.23Amend Paragraph 2.23 to remove the maximum threshold for conference facilities of 1,000 sq m by deleting the second sentence in the paragraph. (367) (Second Deposit)

Proposed ChangesPC7 suggests adding a formula to paragraph 2.23 for assessing what constitutes an acceptable scale of


Blackpool Local Plan Review – Inspector’s Reportconference facility provided ancillary to a hotel but retains the 1000 sq m ceiling.

Objection to the Proposed Changes367/5 Hilton Group PLC

Summary of the Objection to the Proposed ChangeThe objection to a 1000 sq m ceiling is maintained – delete this aspect of the text. (367)

Inspector’s Reasoning and Conclusions 1. In the Second Deposit Local Plan there are two paragraphs numbered 2.23.

This section of my report refers to the first of these.

2. It is not disputed that Blackpool needs a major new exhibition/conference centre (hereafter conference, for brevity) and that the best site is at the former Central Station (RR7.1). That site, as currently defined, is partly within but mainly on the edge of the town centre. It is also within the Resort Core and on the seafront.

3. The main issue that arises is what policies should guide and/or regulate proposals for other conference facilities in addition to those at the RR7.1 site.

Away from the Town Centre (Objectors 306, 326 and 367)

4. As matters stand in the Second Deposit, policy RR4 says that new conference facilities should be in or on the edge of the town centre. The Resort Core, Resort Neighbourhoods and other parts of the Promenade are no longer identified as priority locations, as some had been in the First Deposit.

5. There is no dispute that the town centre (and edge-of-centre sites) are suitable locations for conference facilities. PPG6 (paragraph 2.12) indicates this and it is confirmed in Draft PPS6 (paragraph 1.7). In my view, the policy is therefore correct to identify these as the preferred location for new conference facilities.

6. What remains to be resolved is whether (and to what extent) other locations should be allowed. I consider there are two principles that should be followed in resolving this matter. The first arises directly from Blackpool’s circumstances. It is that no facilities should be allowed that could, by virtue of their scale or location, threaten the provision (or subsequent viability) of the proposed new national conference centre at the Central Station site. The second principle also reflects the situation in Blackpool but is partly derived from national guidance. It is that every opportunity should be taken to bolster the viability of the town centre as a focus of activity, investment and trips.

7. It follows from these two principles that some limitation on the scale of facility that can be provided elsewhere is justified and necessary. The principles are also of assistance in evaluating possible locations for conference facilities.

8. Objector 306 suggests that (anywhere in) the Resort Core should, in principle, be regarded as a suitable location for conference facilities. The Objector says this is because the nature of the Resort Core and its uses are analogous to the town centre to an extent that makes it hard to know where one stops and the other starts. The fact the two designations overlap demonstrates this.

9. However, the Resort Core stretches some way south of the town centre and is the focus for entertainment and leisure uses, as well as holiday accommodation. Some of the resort Core is a considerable distance from the town centre and its southern end is not at all like the town centre. Whilst it may be difficult to differentiate between the town centre and the Resort Core where they meet, a general aim of the Local Plan is to foster the differences between


Blackpool Local Plan Review – Inspector’s Reportthe two areas with different planning policies in each area. Whilst the situation in Blackpool is unusual, in my view there is no reason to regard (all) the Resort Core as a surrogate town centre when interpreting or applying national guidance. I therefore consider that the Resort Core should not be regarded as an appropriate or priority location for conference facilities.

10.Objector 367 wants Resort Neighbourhoods identified as locations for new conference facilities, as was the case in the First Deposit. These areas extend considerable distances along the sea front to the north and south of the town centre and inland in some instances. Overall the Resort Neighbourhoods cover an extensive area and this alone indicates that to treat them (all) as a suitable location for conference facilities would amount to a considerable dilution of the priority being given to the town centre. Moreover, the nature of the areas and the reasons for defining them (as in policy RR9 and RR11) does not indicate to me that they are necessarily suitable for conference developments. They are mixed-use areas in which the protection of residential amenity and character is of as much importance as supporting tourism. I therefore consider that the areas defined as Resort Neighbourhoods do not provide a satisfactory basis for deciding where conference facilities should be located.

11.The Promenade is the other location that has been suggested as an especially suitable location for these facilities. Whilst I acknowledge that there may be some logic in regarding the sea front as a better location than inland sites, it is nevertheless a very extensive area. Sites at either extreme end of the sea front would not, in my view, be suitable conference locations just because they face the sea, although access to the sea-front tram link would be an advantage. Again, I consider that to regard all of the Promenade as, in principle, a suitable location would amount to a serious dilution of the priority that ought to be afforded to the town centre.

12.To summarise, none of the defined areas (outside the town centre and RR7.1) that have been suggested as suitable locations for conference facilities are in my view suitable for unfettered development of this sort. They would all amount to a considerable dilution of the emphasis currently afforded to the town centre. I conclude none should be identified as areas to which conference facilities should be guided or directed.

13.This leaves the suggestion from Objector 306 that the policy should explicitly set up a sequential test procedure for assessing sites and proposals that may arise outside the town centre. I see no need for, or merit in, this proposal for the following reasons. I accept that the need for facilities and the availability of town centre sites are difficult areas that may have to be explored in detail in relation to any particular proposal. However, such evidence as I have at this stage does not indicate that there is either a level of need that cannot be met within the parameters of the existing policy or that sufficient sites cannot be found in or on the edge of the town centre. It does not seem to me that there is any reason to expect such arguments to be convincing, so to include this in the policy would be an unnecessary complication. In any event not including such a procedure in the policy would not preclude it being applied if it were thought to be necessary because it is part of national guidance.

14.However, none of what I have said so far should be seen as denying the legitimate aspirations of hotel operators to provide on-site facilities that are


Blackpool Local Plan Review – Inspector’s Reportcommensurate in scale and function with the hotels to which they would be attached. Rather, the above conclusions relate to the provision of stand-alone facilities or conferencing accommodation at hotel sites that would be disproportionately large in relation to the hotel to which they are attached.

15. I also see no need to expand on the reasons for the policy’s emphasis on the town centre as suggested by Objector 326.

16. I therefore conclude that the general form and wording of policy RR4 and its accompanying text should remain as they are in the Second Deposit.

Defining “Ancillary” (Objectors 306, 326 and 367)

17.However, so far I have put to one side the question of defining “ancillary” conference facilities at hotels. The principle is not contested; what is at issue is how this should be done and/or controlled. As things stand in the Second Deposit, the policy states the principle involved and the accompanying text (at paragraph 2.23) goes into greater detail. PC7 would add even more detail on how the acceptability of proposals would be assessed.

18.The question of assessing what is an ancillary use is a difficult one and not only in this context. However, in my view it is a necessary tool if the two principles identified above are to be maintained. I therefore consider that it should be retained. But attempts to refine and define it in the abstract are, in my view, not especially helpful. The contents of PC7 may (or may not) be helpful in any particular case but in my view they are not sufficiently clear or robust to apply to every situation or to be included in the Local Plan. I therefore conclude that the general principle of ancillary should be retained but that the detail in PC7 adds little and should not be pursued in the Local Plan.

19.The remaining issue is whether a ceiling (of 1000 sq m) should be retained. Again in this context its meaning may not always be clear because some shared spaces (dining rooms, toilets and circulation spaces for example) may serve both the hotel and any conference facilities. Nevertheless I take the view that the imposition of a ceiling is necessary if the two principles set out above are to be maintained. How it is to be applied is a matter to be resolved in relation to each proposal as it comes forward. In any event it is a generous ceiling and anything approaching this figure could only be regarded as ancillary to the very largest hotels.

20. I note that, although the current 1000 sq m ceiling is criticised I have no evidence at all on what might be a more acceptable figure. In the absence of such evidence, and noting that it is not an inconsiderable floor area, I have no reason to recommend that it should be altered.

21. I therefore conclude that the Local Plan should not be changed.

Retailing (Objector 287)

22.Tesco’s objection to this policy is one of several to the effect that Local Plan policies should reflect the need to, and importance of, providing shopping facilities – especially for convenience shopping to meet the needs of visitors.


24. I consider it is unnecessary and undesirable that references to the need to


Blackpool Local Plan Review – Inspector’s Reportprovide adequate shopping facilities are scattered throughout the Local Plan. To draw an analogy, requirements for development such as adequate access, adequate drainage and good design need not be repeated in every policy to guide development. If every policy listed every requirement that might arise, the Local Plan would be very long and cumbersome.

25. I conclude that, in general, consideration of retailing should be confined to the shopping policies and that no modification arises from this objection.

The Central Station Site (Objector 370)

26. In my view the matters raised in this objection are best dealt with in the context of policy RR7.1 and I deal with this objection in that part of my report.

Recommendations27. I recommend that the paragraphs are renumbered because at the moment

there are two numbered 2.23.28. I recommend no modification to the Local Plan in response to objection

287/4, 306/4, 326/3, 367/2 and 367/3.29. I recommend that PC7 is not pursued and that this deals with objection

367/5.30.For my recommendation on objection 370/2 see under policy RR7.1.

Officer Recommendations The Inspector’s recommendations are accepted:

2.9 Reshaping the Resort Paragraph 2.20The Objections091/1 South Shore Focus Group

255/2 Beverley Moy

Summary of the ObjectionsA purpose built independent conference/exhibition centre in a central location free from ties to any other interests (such as hotels, casinos or retail development) would re-establish Blackpool as the major northern conference/exhibition venue. (091)

Concern is expressed about public the funding for any improvements to the Winter Gardens. No specific modification to the Local Plan is sought. (255)

Inspector’s Reasoning and Conclusions South Shore Focus Group

1. This objection was made to the First Deposit but the wording that was objected to has been changed in the Second Deposit. The effect of the changes was to delete the possibility that the Winter Gardens would be refurbished as Blackpool’s national conference centre and to indicate that a new centre would be built close to the town centre with the Central Station site identified as the favoured location.

2. Although I do not have the Objector’s views on these changes, it seems to me that they are in some respects in line with what the Objector wanted. However,


Blackpool Local Plan Review – Inspector’s Reportin one respect they do not meet the objection because the Objector believes that any new national conference centre should be “independent” of any other interest, such as hotels, casinos or retail development. To my mind there are two senses in which this call for “independence” could be intended – physical and financial – and it is not clear from the objection which is of most concern.

3. As far as physical independence is concerned, I see no reason why a conference centre should necessarily be on a site of its own with no other uses or facilities on the same site. There are economies that can be achieved if different uses share a site, for example car parking and public spaces can also be shared. Combining several uses on a site can also lead to interesting architectural designs. A mix of uses can also lead to public activity being spread through the day (and night), which some see as an advantage in (or close to) town centres. In any event government guidance is in favour of mixed developments in principle and I have been given no reasons why such an approach would be inappropriate in this situation.

4. As to financial independence, this is not really a planning matter. Suffice it to say that it is my understanding that the Council believes a national conference centre would not be financially viable on its own and hope that the funding can be secured on the back of another development, and in particular a regional casino. The Council does not say that a casino is the only way of (or essential to) achieving a new conference centre but that it could make a contribution in this respect. Whilst I recognise that some people oppose regional casinos in principle; I have not been told of any planning reasons why, if there are to be any, they should not contribute towards the provision of other facilities.

5. I therefore conclude that no (further) changes to the Local Plan are needed in response to this objection.

Mrs Moy

6. This objection was to the First Deposit, which talked in terms of either regenerating the Winter Gardens or providing a new conference and exhibition centre (Local Plan paragraph 2.20). The Second Deposit points to constraints on improving the Winter Gardens and talks about an early new-build solution elsewhere, as indicated in the New Horizons Masterplan. At the Local Plan Inquiry Mrs Moy said this matter was still in a state of flux and did not identify any specific modification she is now seeking.

7. I also note that the material Mrs Moy objected to in the First Deposit was removed and/or replaced in the Second Deposit. I consider that no further modification to the Local Plan is needed.

8. I conclude that no modifications to the Local Plan arise from objection 255/2.

Recommendation9. I recommend no modifications to the Local Plan in response to objections

091/1 and 255/2.


The Inspector’s recommendation is accepted:



2.10 Reshaping the Resort Policy RR5The Objections248/ 3 / 13 Blackpool Pleasure Beach


295/1 MacKeith Dickinson & Partners Ltd


Summary of the ObjectionsThe Pleasure Beach is, and should remain, the only location for major fun fair rides in Blackpool. The policy should be amended to differentiate between major and minor funfair rides and specifically limit the location for major rides to: (a) Blackpool Pleasure Beach (b) existing and new piers (c) the promenade frontage between the junctions with Adelaide Street West and Princes Street. The Promenade Parade, the Sandcastle forecourt and other sites the Council's control should be excluded from the area where major rides can be located. (248)


Add a paragraph on the provision of children's rides. There are many opportunities for such facilities in the resort and pedestrian areas. (295)

Amend Policy RR5 to say: Development proposals comprising or including Arcade Amusement Centres and Funfair Rides will only be permitted in the context of improvements to existing facilities, as part of planned comprehensive development proposals within the Resort Core or as part of incremental development in the following locations (a) Blackpool pleasure Beach (b) The Piers (excluding the Promenade Deck at North Pier) (c) The Promenade Frontage between its junctions with Adelaide Street West and Princes Street (370)

Recommended changes to Para 2.24(a): Gambling deregulation could have a profound effect upon Blackpool's existing traditional amusement arcade sector as a consequence of the industry's response to deregulation and associated redevelopment proposals. The Council recognises that Blackpool's existing Arcade Amusement Centres attract visitors of all ages and will need to evolve in accordance with the new legislation to meet particular markets to which they may appear. (370)

Recommended changes to Para to 2.24(b): Other policies within this plan (see RR7) provide for the redevelopment for tourism uses of parts of the `Golden Mile' within which many of Blackpool's existing traditional amusement arcades are concentrated. Policies of the plan, in conjunction with the introduction of appropriate planning controls for resort casino development, are intended to provide a basis for ensuring that existing Arcade Amusement Centres can evolve and develop, within the context of gambling legislation from time to time, to offer the facilities required by visitors of all ages. (370)

Proposed ChangesPC8; suggests that the arrangement and wording of the policy should be changed. (The effect would be to revert largely to the First Deposit wording and to allow small scale improvements to existing facilities.)

Objection to the Proposed Changes370/8 The Noble Organisation

Summary of the Objection to the Proposed ChangesThe Proposed Change does not address our original objection, which is maintained. There is no objection to concentrating amusement arcades in the areas indicated but restricting the evolution of arcades is objected to. This could give resort casinos an unfair advantage and ignores the fact that many already have adult only areas and activities. (370)

Inspector’s Reasoning and Conclusions1. In the context of these objections I consider it is sensible to structure my

reasoning and conclusions on the basis that PC8 is the basis for further consideration of this policy.


Blackpool Local Plan Review – Inspector’s ReportObjector 248/3 and 248/13 (Blackpool Pleasure Beach)

2. Blackpool Pleasure Beach (hereafter BPB) claims to be the largest visitor attraction in the country, let alone Blackpool. Much of the attraction involves large and sometimes terror inducing “fairground rides” (hereafter rides). The Objector is anxious that the unique attraction of BPB as the pre-eminent centre for such rides should be maintained and protected. I do not necessarily see this as based on narrow self interest because it may have important ramifications for the resort as a whole. There may be merits in reinforcing the distinctiveness of the various parts of the resort. However, the Local Plan (and the planning system as a whole) cannot be used protect a commercial interest from competition. It is a fine line that needs to be kept to in this case.

3. In fact the difference between what the objections sought and what is in PC8 is relatively small. However, the Objector still expresses concern about the possible inclusion of major rides in comprehensive redevelopment schemes in the Resort Core (perhaps at Rigby Road) and about rides being installed by a competitor on (Council owned land) in front of the Sandcastle complex or between BPB and the sea.

4. As far as the first of these possibilities is concerned, my understanding of what is intended at the Rigby Road site (from the Resort Masterplan) is that it would not be an attraction based on a variety of rides in the style of BPB. However, if a theme park at this site had a particular character or theme (say “space” or “water”) it might have a ride appropriate to that theme. Be that as it may, it seems to me that the commercial viability of such a project would depend on it offering something distinctively different from what already exists nearby. But even if I am wrong about this, it does not seem to me that this is a matter upon which the Local Plan can or should intervene.

5. As to the introduction of rides closer to BPB (on Council owned land between BPB and the sea) this clearly had not occurred to the Council who expressed no interest in pursuing the idea and said they were willing to exclude the possibility. However, in purely planning terms it is difficult to see a reason for doing this. This area is suitable for rides in as far as it would reflect the existing character of the area, although it might be ruled out because of the harm that could be caused to the public realm and seafront.

6. On balance, and all things considered, I take the view that any change to the Local Plan in response to these objections would be impossible to justify for planning reasons.

7. I conclude that the Local Plan should not be modified in response to these objections.


8. Tesco’s objection to this policy is one of several they have made to the effect that the Local Plan should reflect the need for, and importance of, shopping facilities – especially for convenience shopping to meet the needs of visitors.


10. I consider it is unnecessary and undesirable that references to providing


Blackpool Local Plan Review – Inspector’s Reportadequate shopping facilities are scattered throughout the Local Plan. To draw an analogy, requirements for development such as adequate access, adequate drainage and good design need not be repeated in every policy to guide development. If every policy listed every requirement that might arise, the Local Plan would be very long and cumbersome.

11. I conclude that, in general, retailing should be dealt with in the shopping policies in the Local Plan and that no modification arises from this objection.

Objector 295 (MacKeith Dickinson & Partners)

12.The Objector is clearly in favour of children’s rides being located in pedestrian areas and other well used public places. This is partly based on observations abroad, although such facilities are becoming more common in this country.

13.The Council’s negative response is based only on a wish to keep the plan short and to avoid trying to address every development control issue that could arise.

14. I have to say my instincts are on the side of the Objector because I too find that such facilities can and do enliven the street scene. This is reinforced by considering other parts of the Local Plan and objections to the effect that there is not enough emphasis on providing simple facilities for children and families.

15.Therefore, for the avoidance of doubt I consider it would be beneficial if it were made clear that this policy was not intended to restrict the provision of individual outdoor children’s rides and round-abouts in pedestrianised streets and public places.

16. I conclude that a paragraph to this effect should be added to the text accompanying this policy.

Objector 370 (The Noble Organisation)

17.As the owners of two large amusement arcades on the seafront in Blackpool, including the country’s largest at Coral Island; the Objector has a direct and important interest in this policy.

18.As discussed at the Local Plan Inquiry (and using the Objector’s useful compendium of successive wording changes) it would appear that only relatively minor changes to the wording of the policy are sought if PC8 is progressed. Although a change had been sought to the reworded part 1 of the policy, it was agreed at the Local Plan Inquiry that this is not now considered necessary. Which leaves only, as far as the policy itself is concerned, the suggested replacement in part 3 of the policy of “as small scale” by “in the context of”. In relation to this suggestion the Council did not advance any evidence, although I am also alert to the sensitivities of BPB.

19.The following matters are agreed:

(a) that Coral Island is a very large amusement arcade,

(b) that Coral Island may be retained (whether or not its site is included in RR7.1 as part of the wider Central Station site), and

(c) if it is retained considerable changes and/or refurbishment could be needed.

20. In these circumstances it does not seem to me to be sensible for the policy to be limited to small scale improvements, at least as far as amusement centres


Blackpool Local Plan Review – Inspector’s Reportare concerned.

21. I conclude that in part 3 of the policy (as reworded by PC8) “as small scale improvements to existing facilities” should be replaced by “in the context of improvements to existing amusement centres”.

22.More far-reaching changes are sought in the text that accompanies policy RR5, especially in relation to paragraphs 2.24a and 2.24b. In the Second Deposit the Council were intent on explaining the impact that the introduction of (high prize) slot machines in casinos could have on nearby existing amusement arcades and expressed the view that the transformation of existing arcades into adult-only facilities should be resisted. The Objector accepts that the competition from casinos may have profound impacts but points out that the sort of change identified by the Council is subject to licensing control rather than planning control. They suggest that the text should be more general, more enabling and should not seek to introduce planning controls where none exist now.

23.Much of the evidence on the impact of casinos on arcades is conjecture, although I acknowledge there is likely to be an impact if and when regional casinos are developed. However, it is by no means certain that a shift within existing arcades towards adult-only machines would be the result – the arcade operators may see their best prospects for the future as expanding their attractions for families and young people. (It is, I suppose, a matter of whether they decide to chase the shrinking adult pound or the buoyant family 50 pence.)

24.Be that as it may, much of this is irrelevant to understanding or implementing policy RR5, which restricts itself to planning issues and, given the prevailing uncertainty, sets out only general principles and indicates locations where development will (and conversely will not) be permitted. In my view neither the policy nor the text should seek to trespass into matters that are controlled by the licensing legislation or attempt to encompass outcomes that can only be speculated on.

25. In all these circumstances it is my view that paragraphs 2.24a and 2.24b should be greatly reduced in length and should neither express the concerns currently proposed by the Council nor the open-ended commitment suggested by the Objector. With this in mind I conclude that these two paragraphs should be replaced by a single paragraph as follows: “Gambling deregulation could have a profound effect on Blackpool’s existing traditional amusement arcades as these respond to the increased competition that may result from the new gambling regime as it manifests itself in Blackpool or further afield. Other policies in the Local Plan (for example RR7) could result in the redevelopment of existing arcades for other tourism uses in parts of the “Golden Mile” where many of the existing traditional arcades for tourists are concentrated. Policy RR5 is intended to provide a basis for the future planning of development proposals involving existing or new amusement arcades to serve tourists in the town.”

Recommendations26. I recommend that PC8 is advertised as a modification to the Local Plan.27. I recommend no modification to the Local Plan in response to objections

248/3 and 248/13. 28. I recommend no modification to the Local Plan in response to objection

287/5.


Blackpool Local Plan Review – Inspector’s Report29. I recommend that a paragraph is added to the text accompanying this

policy to make it clear that the policy is not intended to restrict the provision of individual outdoor children’s rides and round-abouts in pedestrianised streets and public places in the town centre or Resort Core.

30. I recommend that, when PC8 is advertised as a modification to the Local Plan, in part 3 of the policy “as small scale improvements to existing facilities” should be replaced by “in the context of improvements to existing amusement centres”.

31. I recommend that paragraphs 2.24a and 2.24b should be replaced by a single paragraph as follows: “Gambling deregulation could have a profound effect on Blackpool’s existing traditional amusement arcades as these respond to the increased competition that may result from the new gambling regime as it manifests itself in Blackpool or further afield. Other policies in the Local Plan (for example RR7) could result in the redevelopment of existing arcades for other tourism uses in parts of the “Golden Mile” where many of the existing traditional arcades for tourists are concentrated. Policy RR5 is intended to provide a basis for the future planning of development proposals involving existing or new amusement arcades to serve tourists in the town.”


The Inspector’s recommendations (26-28 and 30) are accepted, and that an amended version of PC8 should be advertised as a modification to the Local Plan to state:

‘Development proposals comprising or including Arcade Amusement Centres and Funfair rides will only be permitted as part of planned comprehensive development proposals within the Resort Core or as part of incremental development/improvements in the following locations:1. In the following locations

a) Blackpool Pleasure Beachb) The Piers (excluding the Promenade deck of North Pier)c) The Promenade frontage between its junctions with Adelaide Street and Princess

StreetOr

2. As part of planned comprehensive development proposals elsewhere within the Resort Core Or

3. “in the context of improvements to existing amusement centres”.

The Inspector’s recommendation (29) is accepted and the following additional paragraph added to the end of the supporting text to state:

Para 2.24c “For clarification, it is not the intention of this policy to restrict the provision of individual small scale outdoor children’s rides and roundabouts in pedestrianised streets and public places in appropriate locations elsewhere outside these areas. The provision of small scale facilities on the forecourt ancillary to existing shops and associated uses is important in providing simple facilities for children and families and can and do enliven the street scene. Such small-scale provision of ancillary forecourt facilities is subject to highway authority control and does not require planning permission”.



32. The Inspector’s recommendation (31) is accepted that paragraphs 2.24a and 2.24b should be replaced by a single paragraph as follows: “Gambling deregulation could have a profound effect on Blackpool’s existing traditional amusement arcades as these respond to the increased competition that may result from the new gambling regime as it manifests itself in Blackpool or further afield. Other policies in the Local Plan (for example RR7) could result in the redevelopment of existing arcades for other tourism uses in parts of the “Golden Mile” where many of the existing traditional arcades for tourists are concentrated. Policy RR5 is intended to provide a basis for the future planning of development proposals involving existing or new amusement arcades to serve tourists in the town.”

2.11 Reshaping the Resort Paragraph 2.24The Objection143/3 Blackpool Coalition Against Gambling Expansion

Summary of the ObjectionHaving "flexible planning policies" is not acceptable, it is an official way of admitting the Council has not got a clue what will happen to existing amusement arcades. (143) (First Deposit)

Inspector’s Reasoning and Conclusions 1. Policy RR5 is concerned with controlling new or improved amusement arcades;

although it appears to me that this Objector’s primary concern is with the possible adverse impacts of casinos on existing arcades. I also note that this objection relates to the text in the Local Plan and not to the policy itself. The wording that led to the objection was much altered in the Second Deposit. Even so, from the evidence presented at the Local Plan Inquiry, it is apparent the Objector has unresolved concerns about amusement arcades and wishes them to be retained, possibly as the lesser of two evils.

2. As things stand (in the Second Deposit) the policy is concerned with development proposals that comprise or include (new, proposed or improved) amusement arcades. The policy limits the locations in which these will be permitted as part of planned comprehensive development proposals or as part of incremental developments or improvements. It does not seem to me that the Second Deposit policy is unduly flexible because it stipulates where and under what conditions such proposals will be allowed.

3. In the Second Deposit the text accompanying this policy was also expanded, although I have recommended above that it is changed (and shortened).

4. The first addition (paragraph 2.24a) in the Second Deposit was concerned with the possibility that, if gambling is deregulated, amusement arcades might evolve into adult gaming attractions at the expense of family activities. The Local Plan says that this is now unlikely to be possible given the emerging legislation. None of the evidence presented by the Objector disagreed with this view and from the evidence it seems to me that the Objector would also be hostile to such a possibility. It does not seem to me that the Objector has a sound basis for objection in this regard. Be that as it may, I see no need for the Local Plan to deal with this matter, partly because it is said to be an unlikely outcome and partly because it relates more to licensing than to planning decisions. I therefore consider that no modification arises in this respect.


Blackpool Local Plan Review – Inspector’s Report5. The other addition in the Second Deposit addressed the danger that family

amusement facilities could be displaced by adult gaming to the detriment of the range of attractions on offer to visitors. This is also the concern of the Objector for whom the maintenance of Blackpool as a family resort is important. In particular the Objector is concerned at the possibility that adult customers at amusement arcades will be attracted to “big prize” slot machines in casinos to such an extent as to undermine the viability of existing arcades. It is feared that this would lead to the abandonment and dereliction of the existing sites to the detriment of the resort’s attractiveness, especially for families and visually.

6. As I said at the Local Plan Inquiry, I find it a little strange that a group that is against the spread of gambling and that contains some people who oppose gambling in principle should be concerned to retain or protect amusement arcades. Be that as it may, it is not clear that increased competition from large prize slot machines elsewhere in the town would lead to the demise of existing amusement arcades – it might equally lead the existing facilities to change their emphasis to offer more family orientated activities of one sort or another.

7. I also consider it is significant that, in general, the arcade operators do not object to the Local Plan on this basis. Indeed the revised wording of the policy in the Second Deposit owed a lot to an objection to the First Deposit from one of the arcade operators.

8. I also take the view that, from a townscape point of view, the existing arcades (and especially those in peripheral locations) are not so visually important or attractive as to warrant protection for this reason.

9. Therefore, whatever the outcome (with or without changes to the gambling legislation and whether or not some arcades close) it seems to me that the policy as it stands provides a satisfactory context for planning decisions relating to proposed or improved arcades. Proposals to change existing arcades to other uses would be dealt with under other policies in the Local Plan.

10. In any event it is not clear what modifications to this part of the Local Plan the Objector seeks. At the Local Plan Inquiry the Objector put forward some additional text for inclusion here but it related to the conditions under which casinos would be permitted rather than to controlling the location of amusement arcades, so it would more appropriately be included in policy RR6, if at all.

11.Moreover, the Objector’s suggested text is framed in such terms (“will not approve any casino development that may seriously damage the financial survival of any significant amusement arcade or bingo facility within ten miles”, “estimated to lead to the closure of competing family facilities on the Fylde coast”) that it is my view that it is aimed to undermine the approval of any casinos. Whilst I respect the view that large new casinos should not be permitted, I consider such an ambition should be pursued within the relevant policy rather than through the text accompanying another policy.

12.There is also the difficulty for me, as a Local Plan Inspector, that planning legislation is not meant to be directed at controlling competition between various facilities. In purely planning terms, the suggested focus on competition and its effects is, to say the least, suspect.

13.Thus, I regard the arguments raised here as being primarily objections to the possibility of casinos rather than objections to the policy (or text) relating to amusement arcades. To this extent the objection relates more to policy RR6


Blackpool Local Plan Review – Inspector’s Reportthan to policy RR5 and does not lead me to alter my recommended modifications to paragraphs 2.24a or 2.24b.

14.For these reasons I conclude that no modification to this part of the Local Plan arises from this objection.

Recommendation15. I recommend no modification to the Local Plan in response to objection

143/3.

Officer RecommendationThe Inspector’s recommendation is accepted,

2.12 Reshaping the Resort Policy RR6The Objections031/1 J M Rigg

091/3 South Shore Focus Group

143/ 1 / 2 / 7 / 10 Blackpool Coalition Against Gambling Expansion

194/64 Government Office for the North West

(Objection Conditionally Withdrawn subject to PC9, PC10 and PC11)

213/2 Mr I Gray

235/1 Margaret Barrett

254/ 2 / 8 The Gables Balmoral Hotel (Blackpool) Limited

277/2 Brian J Dougherty

278/5 D Whitfield




335/4 Mrs Gray

367/4 Hilton Group PLC


Summary of the ObjectionsThe expansion of casinos and gambling is opposed. “Resort casinos” would create problem gamblers and harm the town. (031) (143) (213) (235) (277) (278) (335)

Any casino development should not include hotel accommodation, conference/exhibition facilities or retail outlets, these uses should be kept apart. A proliferation of casinos should be avoided. (091) (143) (235) (277) (278)

Resort casinos are unlikely to viable in Blackpool and would not benefit the town. Policy RR6 should say that casinos and casino hotels will only be permitted in the Resort Core where:- [a] detailed research and analysis of all the negative and positive economic and social costs have been put to Blackpool residents and approved in a full postal referendum of all residents wishing to respond. The policy should also specify the measures to be taken to combat problem gambling. (143) (First Deposit)

Expanding gambling will have far-reaching effects on Blackpool. References to development that is dependent on slot machines should be deleted or the Local Plan should be delayed until the legislative framework is clear. There are too many unresolved questions to proceed. A clear (government endorsed) definition of “resort casino” should be included. The changes to part (d) of the policy weaken


Blackpool Local Plan Review – Inspector’s Reportit. More details of the measures needed to combat the problems of addicted gamblers are needed and should be included here. (143) (Second Deposit)

Objections to policy RR6 in the First Deposit are withdrawn due to changes made in the Second Deposit. However: (a) the meaning of “resort casino” needs to be explained in the supporting text; (b) the reference to development briefs should be moved from the policy to the supporting text. (194) (Second Deposit) (Objection Conditionally Withdrawn subject to PC9, PC10 and PC11)

Casino hotels will bring problems and not enhance the attraction of Blackpool for families. Therefore any casino hotels should not be in the Resort Core (or at Central Station). (143) (213) (277) (278) (335)

Delete the reference in the policy to site assembly. (254) (295) (First Deposit)

Replace “large resort casinos” with “resort casinos and casinos”. (254) (Second Deposit)


Expand (and relax) the policy to say that existing casinos and small casino proposals in hotels will be allowed outside the Resort Core. Avoid large “inward looking” casinos. (295)

The provision of casinos, and using site assembly powers, are supported and these should be in the Resort Core. But the attempt to restrict “one-stop” destinations is unduly restrictive on mixed-use attractions. (First Deposit) The revised policy should require that sufficient on and off-site car parking will be provided, in addition to new or improved coach and bus drop-off points. (Second Deposit) (306)

Add the Hilton Hotel to the list of sites where resort casinos will be permitted. (367) (Second Deposit)

Add land between New Bonny Street and the Palatine building to the list of sites where resort casinos will be permitted. (370) (Second Deposit)

Proposed ChangesPC9 would remove the word “large” from the first sentence of the policy.

PC11 says criterion (e) should be deleted from the policy but referred to in the text at paragraph 2.31.

PC86 suggests a comprehensive redrafting of policy RR6.

PC87 does the same for the accompanying text.

Objections to the Proposed Changes248/14 Blackpool Pleasure Beach

254/ 11 to 18 The Gables Balmoral Hotel (Blackpool) Limited


348/2 North West Regional Assembly

367/ 6 / 7 / 8 Hilton Group


Summary of Objections to Proposed ChangesParticular objection is raised to the ordering of potential casino sites to indicate a preference, certainly as between the potential site at Rigby Road and the Pleasure Beach. (248)

The policy should be more flexible and not restricted to “resort casinos”. References to resort casinos should therefore be deleted to allow for a range of casino developments. (254)

In response to the more comprehensive rewriting in PC86, general objection is raised to: the specification of a minimum size of casino, the introduction of two tiers of site and an over-prescriptive adherence to the Draft Gambling Bill as it now stands. Also, paragraph (a) in the redrafted policy should refer to the Resort Core, paragraph 2.32(k) in the revised text should relate the scale of any impact assessment to the scale of the proposal and planning obligations need not be mentioned. (254)

Leisure Parcs reiterate their preferred wording for policy RR6. They also wish a reference to site assembly to be retained in the policy. Criteria (e) should be kept in the policy, not in the text. (306)

In response to the more comprehensive redrafting suggested in PC86, Leisure Parcs object, including: criticism of the prioritisation of casino sites, the failure to allow for related development on adjoining


Blackpool Local Plan Review – Inspector’s Reportsites, the proposed restrictions on smaller casino developments elsewhere, the failure to require adequate car parking, the removal of site assembly from the policy and the loss Development Briefs for these sites. Objections are also raised in relation to the text as it is now proposed; including that insufficient emphasis is put on mixed leisure uses and integrating these with other attractions. (306)

The term “regional casino” is preferred to “leisure destination casino”. (348)

Preference for the Hilton Group’s proposed casino site is reiterated. In addition, whilst accepting priority can be given to the site at Central Station, no priority should be afforded to the Rigby Road site. A revised form of words for policy RR6 to reflect these comments is suggested. A revision to the wording of paragraph 2.32 (i) is also suggested to reflect these views. (367)

The site at New Bonny Street should not be included in the Central Station site but should be regarded as a separate site. In any event, the situation with regard to casinos is uncertain and the Local Plan should maintain flexibility with regard to sites, avoid sterilising sites and avoid the provision of a new regional casino being at the expense of existing tourist attractions. (370)

Inspector’s Reasoning and Conclusions 1. For the avoidance of doubt I record that my reasoning and conclusions on these

matters is based on the evidence presented to me at the Local Plan Inquiry. It follows that what I have to say relates to the emerging legislation as it stood when the Local Plan Inquiry closed.

2. I know that things have changed and advanced since then. However, I consider that what has happened since does not invalidate my recommendations and, in my view, only serves to strengthen them in some important respects.

Background and the Relationship to Legislation (Objector 143)

3. There is concern that the Local Plan is premature to include a policy making provision for new kinds of casinos, which rely on changes to the law that are not yet enacted. There is concern that the form (and number of) new casinos cannot be known before the legislation is finalised and possibly after that. This means neither site requirements nor the impact of casinos can be assessed. It is also suggested that the change in the law may not happen, in which case Blackpool would be left with a Local Plan and tourism strategy in tatters.

4. At the time of the Local Plan Inquiry no new regime for the regulation of gambling had been enacted. Since the Gambling Bill was first published there have been several changes to it. In general these have amounted to increased control and reduced numbers, certainly as far as the largest sort of new casino is concerned. Unless there is to be a complete change in direction, I consider the changes so far represent movement towards what is likely to be enacted; so that things are clearer now than they were when the draft Local Plan was first published and the objections to it were made. In my view the situation is now clear enough for it to be sensible to include proposals in the Local Plan with a realistic prospect of anticipating what will be in the Act.

5. Moreover, I am satisfied that a policy with the general form and content now suggested in PC86 is robust enough to encompass the likely outcome of the parliamentary process. PC86 is not wedded to particular forms or definitions of new casinos. But even if I am wrong about this, there will be the opportunity to adjust the Local Plan at the modification stage if the Council thinks this is necessary or desirable, although BBC will no doubt be mindful of the delay this could cause if further objections arise.

6. As to the possibility that there will be no change at all to the law for the foreseeable future, I accept this could be the case. I also accept this would necessitate reappraisal of the resort policies in the Local Plan. However, if this


Blackpool Local Plan Review – Inspector’s Reportwere to occur, although policy RR6 would become a dead letter the other policies in the Local Plan would still provide a useful framework for guiding development. In particular, the sites identified in policy RR7 as Key Tourism Investment Sites would still be the right locations for investment, even if their redevelopment could no longer contain new sorts of casino and the amount of money available for investment would be reduced accordingly. In my view, therefore, the Council is not imprudent to prepare for the new legislation, although opponents to the changes can take comfort from the fact that nothing can be implemented before the law is changed.

7. I therefore conclude that, in principle, policy RR6 should be retained in the Local Plan.

Definitions (Objectors 143, 194, 254, 348, 370)

8. One matter raised by several objectors is the need for clear (and if possible legally endorsed) definitions. Others express a preference for a particular terminology.

9. I have some sympathy with the search for an agreed terminology, although I recognise there may be no finality until any legislation is passed. However, at the time of the Local Plan Inquiry it seemed likely that the legislation would be passed before the Local Plan is ready for adoption. In the meantime, and especially in the light of PC86 and PC87, I do not believe that confusion is being caused or that the reader is being misled as to the intended meaning of the Local Plan.

10.At the time of writing this report the anticipated outcome is that there will be three sizes of new casino allowed by law: “regional”, “large” and “small” (in descending order of size). Even though these are not the terms used throughout the Local Plan and Proposed Changes, these are the terms I will use and, pending changes to the law that may define new terms, these are the terms and definitions I would recommend are used in the Local Plan.

11. I conclude that the Local Plan should be reviewed and, if necessary, up-dated at the modifications stage to reflect and incorporate the definitions and terminology relating to casinos contained in the new or emerging legislation.

The Licensing Regime and Regulation (Objector 143)

12.The Council says, and BCAGE accepts, that some of their detailed objections relate to the future licensing of casinos rather than to land-use planning. I have in mind here the means of operating the casinos, the mix of activities on offer, who may take part in what, the scope of measures to help problem gamblers and several other matters that BCAGE has suggested should be included in the Local Plan as a way of securing “belt and braces” control.

13. It is expected that the extent of licensing requirements will be determined before planning permission can be granted, either in the legislation or because a license will be needed before a planning application can be made. The Council takes the view (in this case, if not in relation to policy RR5) that such duplication of regulation is both unnecessary and against the normal practice of assuming that separate legal codes will be applied independently (and adequately in both instances). This is supported by government guidance, for example in relation to planning conditions, that planning should not seek to overlap or intrude into matters covered by other legislation.


Blackpool Local Plan Review – Inspector’s Report14. I consider this is the correct approach for the Local Plan to adopt and conclude

that the Local Plan should not refer to detailed matters of regulation that are likely to be the subject of licensing or other legal requirements.

Research Results and Impact (Objectors 031, 143, 235, 277, 278)

15.Another complaint from BCAGE is that the research they have accessed does not support the views expressed in the text of the Local Plan or the basis on which policy RR6 is formulated. They take the view that the process should be halted until the Council responds to this research, produces other research to refute it or commissions research of its own.

16.Other Objectors share the concerns about the impact of casinos, especially regional casinos, in the town. The concerns include:

(a) the social implications of large numbers of big prize gaming machines, especially because of an anticipated increase in gambling addiction;

(b) the nature of resort casinos;

(c) the effects of inducements to gamblers (accommodation, drinks, food);

(d) the effects of competition on other gambling and amusement facilities;

(e) the impact on the appeal of Blackpool to families.

17.The Council has not sought to convince the objectors (or me) by producing counter research or by seeking to undermine the research relied on by BCAGE. As things stand, therefore, the evidence before me points to the real possibility that regional casinos with numerous high-prize slot machines could have adverse social impacts. I describe this as a “real possibility” (and no more) because the great majority of the research that is available necessarily draws on experience abroad. This means that the systems of regulation and cultural influences in which the research took place are (very) different from the situation that would exist in Britain and Blackpool if the law is changed to allow regional casinos here.

18.Some of the differences between the Council and objectors arise not so much from any research findings as from different assumptions and expectations:

(a) for example, the objectors say that “resort casinos” are (by definition) inward looking and designed to capture and retain their customers on site, thus minimising the extent to which any expenditure is diffused into the town’s wider economy. The Council says that the casinos it has in mind can be designed (and made to operate) in such a way as to create wider benefits in terms of expenditure on accommodation, entertainment and refreshment;

(b) the objectors say that there will be an increase in “problem gambling” but the Council does not regard this as a planning matter because they anticipate it will be dealt with by other means than planning;

(c) the objectors say that the competition effects on other gambling and amusement facilities will be very severe, although the Council appears not to be overly concerned about this, presumably because it does not see its planning role as being a regulator of competition between various sorts of gambling establishment;


Blackpool Local Plan Review – Inspector’s Report(d) the impact that a proliferation of casinos would have on the appeal of

Blackpool to families, which the objectors say would be harmed irreparably but the Council does not accept.

19.As far as this latter is concerned there is a fundamental difference of opinion on the robustness of the resort’s economy at present and the best way forward for the town. The objectors are hopeful that the traditional attractiveness and character of Blackpool can be retained and revived. The Council takes the view that decline has gone too far for that and, in any event, family holidays provide a peak in demand during the summer whilst what is needed is a customer base that extends throughout the year. In my view, the data I have supports the Council’s (more bleak and radical) analysis of the existing health of the resort.

20. I have come to the view that what is at issue is not so much a difference based on research elsewhere as a difference about expectations for Blackpool in the future and how radical an approach needs to be adopted to revive the resort. Having said that, I note that at the time of the Local Plan Inquiry the emerging legislation was couched in terms of allowing a few regional casinos in the short term to enable the impacts to be assessed before a decision is taken on whether to allow more in the longer term. Objector 143 finds this unacceptable (partly because they think it casts Blackpool in the role of a guinea pig in an experiment, partly because they believe they know the answer already and partly because they think the framework for future research and its assessment needs to be settled to their satisfaction before any trial begins). This is consistent with their calls for more research but can equally be seen as a recipe for delay.

21.Be that as it may, if the law of the land (if and when it is altered) allows new forms of casino and the Council seeks them, I have not heard any planning arguments that would lead me to recommend against regional casinos in principle.

The Balance of Harm / Benefits for Regeneration (Objectors 031, 143, 235, 277, 278)

22.So, in the final analysis a balance has to be struck between the real possibility that regional casinos with numerous high-prize slot machines could have adverse social impacts and the positive regeneration effects that the Council hopes for. I have already set out the fears of the objectors and for them deciding where the balance of advantage lies is a simple matter because they see many disadvantages and no likely advantages.

23.As far as the Council is concerned, the likely advantages include:

(a) regional casinos could be used as the catalyst to secure investment in a new national conference centre (they do not say that a conference centre is dependent on casinos, but the available funds could be augmented in this way);

(b) other investment (in the entertainment and accommodation sectors) could also be encouraged or secured;

(c) large sites that are underused and currently harm Blackpool’s image and environment would be redeveloped in the process;

(d) the resort would be rejuvenated and in such a way as to extend the number of visitors and the time of year during which they visit;

(e) employment would be created in casino developments and indirectly


Blackpool Local Plan Review – Inspector’s Reportin the wider community.

24.Whilst recognising that my view of the matter may be thought to be too narrowly focussed on land-use and planning matters (rather than on wider societal or moral values), I conclude that the balance of (planning) advantages lies with retaining policy RR6 in the Local Plan in order to facilitate the development of a new type of casino in Blackpool.

25. I also conclude that there would be no point in retaining the policy in a modified form (with all references to casinos removed) as suggested by Objector 143.

Mixed Developments (or Not) (Objectors 091, 143, 235, 277, 278, 306)

26.Several objectors take the view that casinos, hotels and the proposed conference centre should be kept apart; separate and distinct. In some cases this is to reduce the risk of people being seduced into compulsive gambling too easily. In other cases the reason is less clear but I suspect that it is to ensure that no hotel gains an unfair advantage because it is integrated with other facilities. Others display a mistrust of joint financing arrangements. Others start from the position that any new national conference centre (in particular) should be “independent” of any other interest, such as hotels, casinos or retail development. To my mind there are two senses in which this call for “independence” could be interpreted – physical and financial.

27.As far as physical independence is concerned, I see no planning reason why a casino should necessarily be on a site of its own with no other uses on the same site. There are economies that can be achieved if different uses share a site, for example parking and public spaces can be shared. Combining several uses on a site can also lead to more interesting architecture. A mix of uses can lead to public activity being spread through the year, week and day (and night), which some see as an advantage in (or close to) town centres. In any event government guidance is in favour of mixed development in principle and I have been given no sound planning reasons why this would be inappropriate in this situation.

28.As to financial independence, this is not really a planning matter. Suffice it to say that it is my understanding that the Council believes regional casinos can contribute financially to regeneration and the provision of, amongst other things, a national conference centre. The Council does not say that a casino is the only or necessary way of achieving a new conference centre but that casinos could make a contribution to the funding. Whilst I recognise that some people oppose regional casinos in principle; I have not been told of any planning reasons why, if there are to be casinos, they should not contribute towards the provision of other facilities and regeneration generally.

29.The Council clearly favours such integration as a means of maximising investment and increasing the synergy in the provision and use of facilities. Government guidance is also in favour of mixed uses as a matter of land-use planning policy. None of the reasons given for opposing mixed development of the sites in question amounts to a sufficient planning reason for ruling it out in the face of the government’s general encouragement of mixed uses.

30.Objector 306, contrary to the views of the other objectors wants greater emphasis put on mixed use developments. However, it is difficult to see what changes to the Local Plan could be made to further this objective.


Blackpool Local Plan Review – Inspector’s Report31.Overall I conclude that the Local Plan (as in the Second Deposit or in PC86 and

PC87) should not be modified to meet any of these objections.

Referenda (Objector 143)

32.As to the suggestion that planning applications for casinos should be subject to local referenda, I see no scope for this in the current planning system. I say this because, if a planning application was refused solely because it was unpopular even though it complied with every legitimate planning concern, an appeal would be bound to succeed.

The Number, Type and Size of Casinos (Objectors 143, 254, 295, 306, 370)

33.My understanding is that the Council’s decision to seek the largest possible type of casino was made when it was thought that the new law would allow a large number of such casinos in Britain as a whole. In that context the intention was to attract a “cluster” of “resort” (now regional) casinos to Blackpool.

34.Following on from the Resort Masterplan prepared for the Council, the Local Plan identifies three Key Tourism Investment Sites in policy RR7. In each of these and the Winter Gardens the largest possible type of casino would be allowed (or encouraged). At least three of these sites could accommodate more than one casino, so the Local Plan allows for the possibility of at least seven regional casinos. However the Council has, as far as I know, always envisaged attracting only the largest “resort” (now regional) casino to Blackpool.

35.Meanwhile three things have happened:

(a) there has been a movement towards an accepted terminology of “regional casino”, “large casino” and “small casino” as defined in the emerging legislation;

(b) it is anticipated that there will be no more than eight of each sort of casino in the United Kingdom, at least in the first instance;

(c) increased numbers above 8 + 8 + 8 are only likely after a trial period of some years in which monitoring will take place.

36.The Council’s best (that is, most optimistic) estimate (or hope) is that Blackpool will be allocated two of the eight possible regional casinos initially. I have not heard or seen any evidence from anyone to indicate that more than this can be expected or hoped for with any chance of success.

37.As to subsequent developments, these are at the earliest likely to be towards the end of the current Local Plan period and will be dependent on the outcome of monitoring in the intervening period. Thus, by the time any further casino development becomes a live issue, BBC will (necessarily) have had to review its Development Plan, possibly more than once.

38. In these circumstances I consider it is unrealistic (and unreasonable) for this Local Plan to continue to provide sites for seven or more regional casinos. To do so can only be a source of unnecessary uncertainty and blight. I therefore conclude that only one of the Key Tourism Investment Sites (as currently defined) and/or the Winter Gardens should be identified as having the potential to accommodate regional casinos. My purpose behind this is to allow for up to two regional casinos in the town in the first instance and to remove uncertainty and blight from all the other sites. Subsequent events, after the initial introduction of any regional casinos, are at best some way off and at worst uncertain and can be left to subsequent Local Plan reviews.


Blackpool Local Plan Review – Inspector’s Report39. In reaching this conclusion I have taken into account that, under the proposed

licensing and bidding arrangements envisaged in the draft legislation, it would not appear to be necessary for a casino to be on a particular site for it to make some (financial) contribution towards that site’s redevelopment. It is my understanding that, in the licensing and bidding situation that will surround planning applications for regional casinos, contributions towards regeneration may be sought and taken from casino operators and used elsewhere in the town. In the regime controlled by (current) planning legislation it is necessary for any links between a development and its benefits to be reasonably related in a direct way. This often means that the two are on the same site. It is my understanding that such direct links will not be required in relation to the licensing and bidding situation that would apply to regional casinos. There is thus no particular need to spread casinos around in order to achieve a spread in their associated benefits.

40.Another issue that has attracted some attention and objection is whether Blackpool should seek to attract large and small casinos in addition to any regional casinos. This is a matter pursued by several objectors. The Council and Local Plan are quite clear on this matter, stating that these will not be pursued or allowed. The Council says this is because such casinos would have little or no “spin off” in terms of regeneration benefits for the resort as a whole; unlike regional casinos from which wider effects are expected. It is my understanding from the evidence that BBC has set its face firmly against seeking any large or small casinos during the licensing process.

41.BBC are supported in this by some (for example Objector 370 who wants policy RR6 “tightened up” in this respect to prevent large and small casinos expanding up the scale). But others object to the embargo on large and small casinos in policy RR6 (for example Objectors 254, 295 and 306). Objector 143 sees smaller casinos as less damaging than larger ones but has not expressed a view about having them in addition to regional casinos.

42. In one sense, if the Council has set its face against the possibility of seeking licenses for any large or small casinos, that is the end of the matter. Without BBC putting itself forward, Blackpool will not be identified as a suitable location, no license will be issued and planning applications will not arise. For this reason there may be no need for the Local Plan to address the issue.

43.However, there are objections on this matter that need to be resolved on their planning merits. Furthermore, the Council may change its mind, perhaps in the light of a recommendation from me that not all the Key Tourism Investment Sites should be identified as potential sites for regional casinos or if the supply of regional casinos is restricted to an even greater extent than was anticipated during the Local Plan Inquiry.

44. It is said that the size thresholds anticipated in the draft legislation may not be enacted. It is also said that several smaller casinos may have the cumulative impact of one large one. Especially in a situation in which the supply of regional casinos is restricted, smaller casinos may have a role in creating the “cluster effect” that was originally suggested would change the resort’s image and attractiveness. The Council dispute all this and says that only regional casinos could have the wider regenerative effects for the town as a whole.

45.Evidence on both sides of this argument is absent (in my view necessarily so, given the novelty of the situation). I am therefore reduced to working from first


Blackpool Local Plan Review – Inspector’s Reportprinciples, although this is made simpler by my wish to concentrate on the planning issues involved. But it also has to be recognised that the supply of “less than regional” casinos is likely to be limited (to 8 + 8 nationwide).

46.As a matter of logic, the larger the casino, the larger the possible impact (for good or ill, in attractiveness, in traffic terms and in terms of any contribution that can be made to wider regeneration) and the converse is true. I consider the prospect of obtaining enough large and small casinos for Blackpool to create a significant “cluster effect” is unrealistic if the national total is to be 8 + 8. It therefore seems to me that the merits (or otherwise) of potential large and small casinos have to be assessed more or less in isolation.

47.By way of an example, I have in mind the situation at the Winter Gardens where there is a large, important and increasingly underused listed building in the town centre. Whether or not a smaller than regional casino in the Winter Gardens would have wider regenerating effects for the resort as a whole, it could nevertheless have worthwhile planning benefits for this important building and (thus) the town centre. In contrast the situation at the Gables Balmoral Hotel is less compelling, both in terms of the quality of the building involved and its out-of-town-centre location.

48. It is also important that the current government view is that casinos should be located in accordance with the sequential approach set out in its guidance on town centres. This indicates that if there is a need for a facility it should be located in a town centre if possible, on the edge of a town centre if there are no sites in the centre and only in an out-of-centre location if no sequentially preferable sites can be found. This would reinforce the suitability of a town centre site in preference to sites elsewhere.

49.Taking all these matters into account I conclude that the restriction on small and large casinos currently in policy RR6 and PC86 should be retained largely as it is in recognition of BBC’s stated intention not to seek or apply for such casinos. Because the restriction is unambiguous I also conclude there is no need to strengthen it as suggested by Objector 370. However, at this stage I would not rule out the possibility that an individual site may emerge with sufficient planning merits for it to be regarded as a candidate for a large or small casino.

The Identification of Preferences Between Sites for Regional Casinos

50.There are several objections to the expressed priorities between the four casino sites as put forward in the re-written policy RR6 contained in PC86. Whilst there is some (but not universal) acceptance that site RR7.1 (the expanded Central Station site) may be the first choice, there is less agreement about Rigby Road being preferred to the Winter Gardens or Sandcastle / Balmoral Road / Pleasure Beach. (For the purposes of this discussion I am treating the expanded Central Station site in the Second Deposit as one site and will deal with the objection that seeks to divide it into two under policy RR7.1.)

51.These objections have arisen in a situation in which four potential casino sites were being identified as suitable for casino development and I am now recommending only one, or at most two, if the Winter Gardens are included. It remains to be seen whether this makes matters less contentious. In any event I do not accept that four potential sites should remain with no preference at all expressed between them – it is the proper function of the Local Plan to guide development to preferred locations.


Blackpool Local Plan Review – Inspector’s Report52.To my mind the government view is clear. Casinos are an entertainment use

that should be located in the town centre if there are suitable sites available for them there. After that, preference should be given to sites on the edge of the town centre. (I acknowledge this is a very brief reduction of the very considerable amount of guidance, evidence and debate on the subject but I consider it captures the salient points.)

53. In my view the Council was not being as single-minded as this when it chose regional casino locations in the town, selected Key Tourism Investment Sites or ranked sites in PC86. In particular Rigby Road and Sandcastle/Pleasure Beach are not within or on the edge of the town centre.

54.However, I accept that a case can be made for regarding Blackpool as a rather special case because it has a dual and overlapping town centre and Resort Core. It seems to me to be legitimate to argue that the overlapping of these functions causes some unnecessary stresses and problems in the town that are particularly apparent in relation to distributing traffic and competing demands for car parking. Such considerations could, in theory at least, lead one to favour sites in the Resort Core and close to the Central Corridor access to the town above sites in the town centre that are less well related to the corridor.

55.Thus, there may be some reasons to depart from government guidance on town centres as far as casinos in Blackpool are concerned. Such considerations may have been particularly important when looking for a cluster of several regional casino sites, although in my view they are less compelling when realistically looking for a far lower number of sites. Be that as it may, in view of government guidance on the sequential test, I regard the Resort Core considerations as material but less important than the town centre ones in the present context.

56.With all this in mind, my assessment of the competing sites is as follows:

(Wider) Central Station: within the town centre (part) or on the edge of it (part), within the Resort Core, has a Promenade frontage (making it a prime tourism site), accessible from the Central Corridor (at least in part), site assembly started and well advanced (so site availability progressing with a reasonable expectation of early implementation), could contribute to and be part of a mixed development including a national conference / exhibition centre and hotels, would contribute directly to the redevelopment of an area in considerable need of redevelopment;

Winter Gardens: within the town centre but not the Resort Core, no Promenade frontage, not easily accessible from the Central Corridor with unresolved access and parking problems, otherwise site assembly complete but site not immediately available, could lead to and be part of a mixed resort development including a hotel but other uses (such as a subsidiary conference centre) less certain, would contribute directly to the rehabilitation of an important listed building with an established tourist/leisure use;

Rigby Road: not in the town centre or on the edge of it but within the Resort Core, has a Promenade frontage (making it a prime tourism site), very accessible from the Central Corridor, large parts of site in a few ownerships (including BBC) indicating that site assembly has, in effect, started (so site availability starting from good base) but many small ownerships remaining (although there is only one objection from an


Blackpool Local Plan Review – Inspector’s Reportaffected landowner to the designation in the Second Deposit Local Plan), relocation of existing uses required. All in all, early implementation is not likely, could lead to and be part of a mixed development including hotels and leisure uses, would contribute directly to the redevelopment of an area in considerable need of redevelopment;

Sandcastle / Balmoral Road / Pleasure Beach: not in the town centre or on the edge of it but within the Resort Core, has a Promenade frontage and includes an existing major tourist attraction (making it a prime tourism site), moderately accessible from the Central Corridor, regional casino and large hotel only deliverable with extensive assembly of many small ownerships with many objections to designation in the Local Plan (so site availability difficult and likely to be prolonged), could lead to and be part of a mixed development including a hotel and could be linked to a major existing tourist attraction, would contribute to the redevelopment of an area moderately in need of redevelopment, would involve the loss of an existing public open space.

57. It is clear to me from the above that the (wider) Central Station site is far and away the best site for a regional casino in Blackpool. It is unique in satisfying town centre guidance, being in the Resort Core, with good road access and having a Promenade frontage. Site assembly has started. I am told it is capable of accommodating two casinos as well as a hotel and the much needed (national scale) conference/exhibition centre. All this being the case, there is no need to look further at sequentially inferior sites for regional casinos.

58.As to small and large casinos, only one of these four sites recommends itself. This is the Winter Gardens both because of its town centre location and because of the contribution such a new use could make to preserving an important listed building. The other two potential sites suffer in any comparison because they are remote from the town centre, notwithstanding their location in the Resort Core with frontages to the Promenade.

59.Although Blackpool Pleasure Beach, Leisure Parcs, the Hilton Group and the Gables Balmoral Hotel all took exception to the way the Council justified its ranking of the sites in PC86, it seems to me that these criticisms have most force when comparing the ranking of the Rigby Road site above the Winter Gardens and Pleasure Beach / Sandcastle sites. However, in view of the evidence I conclude that the primacy of the Central Station site is very clear.

60. I conclude that the (wider) Central Station site should be identified in the Local Plan as the only site for one or two regional casinos.

61. I conclude that the Winter Gardens should be identified in the Local Plan as the only site for a large or small casino.

Other Comments on the Location and Number of Sites

(Objectors 143, 213, 277, 278, 295, 335, 367)

62.Objector 295 argues for a less rigid location policy in relation to casinos, suggesting that they should be allowed in hotels outside the Resort Core. This includes a great many potential sites. No doubt the objection was made before the limited number of casinos now likely to materialise was known. In my view such a liberal policy is not appropriate now even if it was when there was no limit on numbers anticipated. Be that as it may, it also ignores current government guidance that the PPG6 sequential approach should be applied to


Blackpool Local Plan Review – Inspector’s Reportcasinos. I conclude that the general relaxation called for is not justified.

63.BCAGE suggests that casinos should be in remote locations away from places where people live and work. They acknowledge this would rule out new casinos in Blackpool, directing them to more isolated places like Barrow-in-Furness or the Isle of Man. In my view this is a rather clumsy attempt to exclude them from Blackpool. Because it would result in no sites being identified in Blackpool, such a policy has no place in this Local Plan; this is the Blackpool Local Plan not the Barrow-in-Furness Local Plan. In any event the government has expressly said that it does not favour such an approach to casino location.

64.Others say that casinos should be outside the Resort Core, mainly to limit the harm that would be caused to Blackpool’s image as a family resort. However, in my view this relies on a belief that the family resort can successfully be regenerated without some major new impetus. The evidence I have on the decline of the resort in recent decades does not lead me to share this view.

Other Suitable Locations / Sites (Objector 367)

65.The Hilton Group want their hotel site added to the list of potential casino sites. As will be apparent I am minded to recommend reducing the number of sites not increasing it. Be that as it may, the objection site does not compare favourably with other sites that are under consideration: it is not in or adjacent to the town centre, nor is it in the Resort Core. In addition it is on the “wrong” side of the town centre both in relation to traffic distribution from the Central Corridor and in relation to the other main tourist attractions in the resort. Neither is it a site in obvious need of redevelopment or a listed building. In any event, the Objector appears to accept the primacy of the Central Station site.

66.For these reasons I conclude that the Hilton Hotel site should not be referred to as a potential casino site in policy RR6.

Other Suitable Locations / Sites (Objectors 254)

67.The Gables Balmoral Hotel takes issue with RR6 in the Second Deposit Local Plan and PC 86 and PC87 on three counts:

(a) the fact that size limits are laid down for casinos in the text;

(b) the failure to allow for smaller than regional casinos in general;

(c) but especially at Key Tourism Investment Site RR7.4.

68.As far as size limits are concerned, it is clear that the Council and the Local Plan envisage pursuing (and allowing for) only regional casinos. This being the case, I am not, in principle, opposed to including references to size in the policy and/or the text in order to make the policy clear and precise. My only stipulation would be that any size thresholds included in the Local Plan should reflect the (emerging) legislation and the definitions used therein. If Gables Balmoral cannot satisfy any of the size criteria that are being used (because, after all, by itself the hotel is a relatively small site) then there would be little point in putting the site forward because other legislation would preclude it being selected. I believe it is self evident that the Gables Balmoral Hotel could not by itself accommodate a regional casino.

69.However, the Objector questions whether the matter of size is properly a planning matter, or should be seen purely as a licensing consideration. Whilst I would normally have some sympathy for the distinction that is being made in this respect, my understanding of the emerging legislation is that it envisages


Blackpool Local Plan Review – Inspector’s Reportthe rather unusual procedure of licenses being granted (although not confirmed) before planning permission can be sought. In my view this makes size a planning consideration even if it is also subject to licensing control.

70.Whilst it is said that the emerging legislation is too uncertain to form a sound basis for the Local Plan, I have already indicated that, although uncertainties remain, the emerging picture is clear enough to be taken into account.

71.As far as large and small casinos are concerned, I have already discussed these in general terms above and noted that it is the Council’s stated intention not to put Blackpool forward as a site for any smaller scale casinos. Whilst I do not entirely accept what they say in this respect, it seems to me that any proposal for additional sites would need to be able to point to some definite planning gain associated with the proposal and should be able to comply with government guidance on location by being in (or adjacent to) the town centre. The Gables Balmoral Hotel would fail on both counts. In addition without Flagstaff Gardens (the development of which is opposed by this Objector) the hotel site would not have a Promenade frontage, which is a factor I have taken into account in my earlier comparisons.

72. I have already dealt above with the issue of prioritising the Key Tourism Investment Sites in policy RR6. In this I specifically say that whilst a location in the Resort Core is a material consideration it is, in my view, of less weight than a town centre location. I do not accept that sites in the Resort Core should be regarded in general as suitable locations for casinos.

73.Therefore, in my view a case of sufficient weight has not been made for including site RR7.4 as a potential location for casinos; regional, large or small.

74. I conclude that no modification arises from these objections.

Parking and Coach Drop-Offs (Objector 306)

75.Leisure Parcs want the provision of adequate car and coach access and parking written into the policy for casino sites as a requirement. The Objector clearly accepts that existing difficulties with car and coach access and parking at the Winter Gardens are a problem, especially in the context of attracting new uses (such as a casino) to the site. Presumably the Objector considers it would help them to improve the existing situation if such a requirement were included in the Local Plan.

76. I discuss Blackpool’s (and the Local Plan’s) parking policies in general elsewhere but in my view there are several difficulties with what the Objector wants in this particular context:

(a) the Council’s resort regeneration strategy accords great importance to attracting visitors to the town by car (especially) and by coach;

(b) this does not sit easily with current government guidance on transportation and parking, which seeks to reduce reliance on the private car;

(c) for policy and practical reasons the Council wishes to separate resort parking and traffic from town centre parking and traffic;

(d) in addition I have come to the view that BBC’s and the Local Plan’s parking policies are inadequately refined and developed and are not supported by a robust and comprehensive body of data and research.


Blackpool Local Plan Review – Inspector’s Report77. In these circumstances, and especially in the absence of an adequate factual

knowledge of demand and current usage, I am resisting all calls on me to endorse what I regard as premature and pre-emptive bids to secure any Local Plan proposal relating to specific areas of parking provision. These pre-emptive bids come in several forms:

(a) the Local Plan includes a proposal for a new town centre car park (policy SR13 in the First Deposit, SR4 in the Second Deposit);

(b) there are objections seeking the retention of particular car parks (e g at Central Station and Rigby Road);

(c) there are objections seeking the maintenance or an increase of parking spaces in the Central Corridor generally.

78. In my view all such specific requirements and bids are premature in advance of a soundly based parking policy and evidence of better management of the existing provision. I see the Leisure Parcs objection in relation to casino sites in the same light.

79.Furthermore, the policy and practical difficulties I have referred to come together most acutely at the Winter Gardens. This is a “resort facility” in the town centre. Would it be right (in policy or practical terms) to bring holiday car traffic to this location? If parking spaces are provided for holiday visitors here, what is to prevent the spaces being used by town centre users? How are such difficulties to be resolved in the context of national guidance and local town centre traffic management and parking policies?

80.Without these matters being resolved I am unwilling and unable to recommend modifying the Local Plan in a way that could be seen as requiring more parking to be provided at any particular site, especially the Winter Gardens.

81. I conclude that the Local Plan should not be modified in response to this objection.

Site Assembly and Development Briefs (Objectors 194, 254, 295, 306)

82.As far as Objector 306 is concerned, I imagine that this matter is not entirely divorced from the issue I have just discussed (parking and access). Be that as it may, for whatever reason Leisure Parcs want site assembly and Development Briefs referred to in the policy. However, there are other objectors, such as Objector 254, who want all references to site assembly deleted from the Local Plan.

83.Objector 194 (GONW) seeks a middle path, which is that such things may be referred to in the text of the Local Plan but not in the policies. This is an approach that in general terms I endorse, although I note that, as far as I can see, there is no mention of either Development Briefs or site assembly in PC86 (policy) or PC87 (text). I imagine this is an oversight and conclude that it should be rectified by an addition to the text (in PC87).

Retailing (Objector 287)

84.Tesco’s objection to this policy is one of several they have made to the effect that Local Plan policies should reflect the need to, and importance of, shopping facilities – especially for convenience shopping to meet the needs of visitors.

85. I do not dispute the importance of shopping facilities to the town as a resort or as a place to live. I also accept that shopping policies should reflect the


Blackpool Local Plan Review – Inspector’s Reportcharacteristics and needs of the town as well as government guidance. But there are already policies in the Local Plan to guide retailing development.

86. I consider it is unnecessary and undesirable that references to the need to provide adequate shopping facilities are scattered throughout the Local Plan. However, in this case I note that PC87 would introduce a reference to ancillary shopping in relation to this policy (see proposed paragraph 2.32j). Although I suspect that this does not go as far as this Objector would want, I consider it to be a reasonable policy statement.

87. I conclude that, in general, consideration of retailing should be kept to the shopping policies and that no modification arises specifically from this objection.

Other Matters (Objector 254)

88.This Objector also raises the issue of referring to planning obligations in the text as set out in PC87, albeit for what they say are largely “technical reasons”. Part of paragraph 2.32k says, “Where there is evidence that the proposed development is likely to give rise to issues of a physical, social, economic or environmental nature that can be resolved satisfactorily, this may be addressed through the planning process and particularly through planning obligations that will mitigate the impacts (see policy PO1).”

89. In my view this is an unexceptional statement that is quite properly included in the Local Plan. I conclude no modification is needed.

Other Matters (Objector 370)

90.At the Local Plan Inquiry Objector 370 suggested deleting policy RR6 and incorporating the material on casinos in a major redrafting of policy RR2. Whilst I concede that such a comprehensive approach has its attractions, it would make for a rather unwieldy policy. Also, in view of the importance that the Council and others attach to casinos, I consider that the balance of advantage is with leaving RR6 as a separate policy. In the last analysis whether these matters appear in the Local Plan in one policy or two should not affect their content and meaning and is, in my view, a matter that can be left to the Council to decide. I therefore conclude that this policy should not be deleted and incorporated in a modified policy RR2.

91.The other major change to policy RR6 sought by Objector 370 is the separation of their land north of New Bonny Street from the Central Station land to form two distinct sites on each of which a regional casino could be allowed. In my view the changes they seek to policy RR6 would follow from a satisfactory outcome to their objections to policy RR7.1. I therefore deal with this matter under policy RR7.1.

92.Other than the matters already discussed above, the Noble Organisation is relatively content with the policy as it emerges from PC86 and PC87. They suggest only the substitution of “adjacent” for “adjoining” (in criterion (b)), which is not a matter on which I have any evidence or feel is of great importance. I therefore conclude that in this respect the policy should be left as it is.

93.Objector 370 also suggests a variety of editing changes to the proposed wording of the text in PC87. Their proposed alterations amount, in the main, to changes to accommodate their RR7.1 aspirations and changes to the conditional tense to make the whole text read in a way that reflects current uncertainties. I deal with the RR7.1 issue below. As far as the tense changes


Blackpool Local Plan Review – Inspector’s Reportare concerned, I do not regard these as necessary or as an improvement and conclude that things should be left as they are.

Overall Conclusions

94.My overall conclusions are therefore as follows:

(a) that policy RR6 should be retained as a separate policy dealing with casinos;

(b) that, subject to my other recommendations, PC86 and PC87 should be used as the basis for the policy to be advertised as a modification to the Local Plan;

(c) that the policy and text are updated at the modification stage to reflect the current state of the emerging legislation on casinos and to incorporate the definitions contained therein;

(d) that matters concerned with licensing and regulation need not be duplicated in the Local Plan, except in so far as sizes and definitions are concerned;

(e) that casinos should be included in mixed development schemes;

(f) only one Key Tourism Investment Site should be identified in the Local Plan as a suitable location for regional casinos and that should be the (wider) Central Station site (RR7.1);

(g) only one site should be identified as suitable for a large or small casino and that that should be the Winter Gardens;

(h) otherwise, the Local Plan should make no allowance for the development of the new types of casinos envisaged in emerging legislation;

(i) no particular mention or requirement needs to be added to this policy or text concerning car parking and coach accessibility;

(j) a reference to site assembly and Development Briefs should be added to the text in PC87;

(k) otherwise there is no need to modify policy RR6 and the accompanying text.

Recommendations


Blackpool Local Plan Review – Inspector’s Report95. I recommend that policy RR6 is retained as a separate policy in the Local

Plan and that it continues to be concerned with casino development.96. I recommend PC86 and PC87 are used as the basis for policy RR6 and the

accompanying text when modifications to the Local Plan area advertised. However, I also recommend that these are revised to reflect not only my recommendations but the state of the emerging gambling legislation at the time of the modifications.

97. In particular I recommend that the definitions and terminology used in the policy and text (and throughout the Local Plan) are reviewed and standardised at the modifications stage to reflect the emerging legislation.

98. I recommend that only one site is identified as a potential site for a regional casino (albeit that this site could accommodate two such casinos).

99. I further recommend that only one Key Tourism Investment Site should be identified in the Local Plan as a suitable location for casinos and that should be the (wider) Central Station site (RR7.1) (I deal with whether this should be regarded as one or two sites under policy RR7.1).

100. I recommend that only one site should be identified in the Local Plan as suitable for a large or small casino and that that should be the Winter Gardens.

101. I recommend that the casinos referred to in recommendations 98, 99 and 100 above should be included in mixed development schemes.

102. Otherwise, I recommend that the Local Plan makes no allowance elsewhere for the development of the new types of casinos envisaged in emerging legislation.

103. I recommend that no particular mention or requirement needs to be added to this policy or text concerning car parking and coach accessibility.

104. I recommend that matters concerned with licensing and regulation need not in general be duplicated in the Local Plan, except in so far as sizes and definitions are concerned.

105. I recommend that a reference to site assembly and Development Briefs should be added to the text in PC87.

106. Otherwise I recommend that there is no need to modify policy RR6 and the accompanying text in response to these objections.


Blackpool Local Plan Review – Inspector’s ReportOfficer Comments

There are significant changes proposed to Policy RR6 as a result of the Inspector’s detailed considerations. However in principle the Inspector supports the approach of the Council in including a policy specifically related to Casino development and that its inclusion is not premature to the final outcome of the parliamentary process and the identification of casino locations through the process established by central government.

It is considered that the Inspector’s recommendation to identify only one site, namely the Former Central Station site, as the potential site for one or two regional casinos is acceptable, particularly in light of the further restrictions by Government on the number of regional casinos that initially will be developed. However, further restrictions on regional casino development (which were published post the Inquiry by Government ) may preclude the allocation of more than one regional casino to Blackpool in the initial phase. It is therefore considered that the possibility of large casino development in conjunction with regional casino development on the Former Central Station site should not be precluded in policy to assist in creating a critical mass of casino development on the site to underpin wider resort regeneration. (Paragraphs 43 and 44 of the Inspector’s Report potentially invites reconsideration of the possibility of seeking additional licenses for large casinos in the light of the reduced potential sites for Regional casinos).

The stance of the Inspector with respect to the potential of large/small casino development to secure the viability of the Winter Gardens which is an important Grade II* listed building located in the town centre is supported. However it is considered that large casino development should also be acceptable on the Former Central Station Site, as well as at the Winter Gardens, for reasons set out above.

With respect to the inspector’s recommendation (105) that a reference to site assembly and Development Briefs be added to the supporting text in PC87, this is accepted – reference to Development Briefs is accordingly newly included in the recommended amended supporting text set out below. Reference to site assembly is already included and will be retained in the amended PC87 supporting text.

At paragraph 77 the Inspector makes wider recommendations on “the need for a soundly based parking policy and evidence of better management of the existing provision”. The need for a more fully developed parking strategy is accepted and this is being addressed through the full Local Transport Plan that will be submitted in March 2006. .


The Inspector’s recommendations 95 to 99 and 101 to 106 are all accepted.

With respect to the Inspector’s recommendation (100), the main thrust of the recommendation is accepted that the Winter Gardens should be identified as the ‘only’ site suitable for a large or small casino. However, reflecting the comments above, it is further recommended that the Central Station Regional Casino site is identified as a site also with potential for supporting development of large casinos.

With respect to recommendations (96) to use PC86 and PC87 as the basis for Policy


Blackpool Local Plan Review – Inspector’s ReportRR6, but revised to reflect recommendations (97) to (101), it is recommended that Policy RR6 is amended and advertised as a proposed modification to the Plan to state:

PC 086 RR6 – Casinos

Regional Casinos which form part of a large scale mixed leisuredevelopment will be permitted on the Former Central Station Site (RR7.1)

In developing the site, large casino development may also be permitted but only in support of and in association with Regional casino development . Any casino proposal for the site will need to:

(a) make a strong positive contribution to the physical and economic regeneration of the resort, by introducing a diverse entertainment venue, enhanced high quality visitor experience, and wider regeneration benefits in addition to the benefit of the development itself.

(b) be well integrated with adjoining buildings, uses and circulation patterns and contribute to a balance of attractions and facilities within the overall Resort Core that is consistent with developing the widest possible staying and day visitor market

(c) demonstrate that the proposed development and associated activities including trip generation can be accommodated satisfactorily in a manner that relates well to adjoining uses; other existing and proposed visitor attractions and facilities, holiday accommodation and residential areas

(d) be supported by assessments of the economic, environmental, transport and social impact of the development.

No other casino development will be permitted in Blackpool except for the following:

i) large or small casino development at the Winter Gardens and

ii) small scale extension of and/or improvements to existing casinos

PC 086 RR6 – Casinos, supporting text

Paras 2.25 – 2.32b inclusive deleted and replaced by the following new paragraphs 2.32C – 2.32L:

2.32c Development of regional Casinos” in Blackpool presents a unique opportunity to reposition the town in the UK leisure market and regenerate the Victorian resort core. Such development would form an integrated part of a broader resort strategy, which aims to turn Blackpool into a year-roundtourism destination with wide market appeal.

2.32d Regional Casinos will combine large-scale leisure, entertainment and cultural facilities within developments which would range from 7,500m2 to 15,000m2 floor area. To maximise the regeneration benefits, which will accrue from such development, the Council has identified ‘The Former Central Station site’ as the key site for such development. The site lies within/ on the edge of the Town Centre and within the Resort Core in accordance with the wider plan strategy (see Policy RR2).

2.32e With further Government restrictions on the number of Regional Casinos that will initially be developed, large casino development may be permitted on the Former Central


Blackpool Local Plan Review – Inspector’s ReportStation Site provided that such development is in association with Regional Casino development and is part of a mixed use proposal which will act as a catalyst for wider resort regeneration.

2.32f Policy RR6 does not allow casino development of any scale on any other site with two exceptions. Large or small casinos may be developed at the Winter Gardens where this will assist in securing a viable use for this important Grade II* listed building in the town centre, which is an increasingly underused building. In addition to the exception of the Winter Gardens existing casinos will be able to continue to operate under ‘Grandfather Rights’ provided for through the new gambling legislation and improve and develop, provided such development is of small scale.

2.32g Underpinning this approach to casino development is the Council’s ambition to promote a cluster of ‘Regional Casinos’ within the heart of the resort, which will act as a catalyst for muchwider resort regeneration. Casino development of this scale will attract visitors from further afield ensuring Blackpool’s revival as a national and international visitor destination thereby, fulfilling itsrole as identified in RPG13, the Regional Tourism Strategy and Regional Economic Strategy. Smaller scale dispersed casino development within Blackpool would not provide wider regeneration benefits.

2.32h Applications for Casino development will be required to demonstrate that the proposed development will contribute to the physical and economic regeneration of the resort. It is important that the location, composition and physical form of the development does not create a one-stop visitordestination but is integrated into the wider resort. In addition where the development incorporates shopping facilities, such facilities will only be allowed where they are ancillary to the main use and take the form of speciality shopping which will complement rather than compete with the town centre. Thisapproach accords with other provisions of the Plan and national planning policy.

2.32i The provision of a full range of impact assessments will be required in support of development proposals so that the Council can make an informed decision in the full knowledge of any likelysignificant effects of the proposed development upon the environment and the community. Where there is evidence that the proposed development is likely to give rise to issues of a physical, social, economic or environmental nature that can be resolved satisfactorily; planning permission will only be granted if the Council is satisfied that the adverse impact can be mitigated through the use of a planning condition or planning obligation.

2.32j A development brief for the Former Central Station site will be prepared by the Council to provide planning and urban design guidance for the comprehensive redevelopment of the site, to ensure that the development of the site fulfils it role as a catalyst for Blackpool’s wider regeneration.

2.32k In addition, where casino proposals fully satisfy the criteria set out in this policy and other provisions of the Plan the Council will be prepared to assist in site assembly in order to facilitate development.

2.13 Reshaping the Resort Paragraphs 2.26 to 2.32The Objections143/ 4 / 5 / 6 / 8 / 9 / 11 Blackpool Coalition Against Gambling Expansion

361/1 Grosvenor

Summary of the ObjectionParagraph 2.26: the Council has undertaken a long bogus sham of consideration and fake consultation. It has avoided genuine public debates, has ensured that not one public meeting took place where the


Blackpool Local Plan Review – Inspector’s Reportpublic could hear the case for and the case against resort casinos and ask questions of both sides. (143/4) (First Deposit)

Paragraph 2.27: a clear (Government endorsed) definition of “resort casino” should be included. The Local Plan should reflect government and parliamentary reports. Many questions on the operation of the largest casinos remain unanswered. (143/7 and 143/8) (Second Deposit)

Paragraph 2.29: this paragraph is not supported by evidence. There is no evidence that a larger number of smaller casinos could not attract visitors. There is evidence to suggest that large casinos attract customers away from smaller gambling facilities such as arcades, bookies and bingo. (143/11) (Second Deposit)

Paragraph 2.29a: this paragraph flies in the face of the evidence. Casinos are designed and operated to retain their customers not to encourage them to visit other parts of the town. This they do by offering food, dinks and accommodation as inducements. In any event the operators would not choose to come to Blackpool. (143/8) (Second Deposit)

Paragraph 2.30: more evidence and detail should be contained in this paragraph. It is not substantiated that many small casinos cause more problems than a few large ones, the opposite is true (143/5) (First Deposit)

Paragraph 2.31: resort casinos are self-contained. They are designed and operated to keep customers from leaving. The term needs definition. (143/6) (First Deposit)

Delete paragraph 2.30a, other sites in the region may be more appropriate. (361) (Second Deposit)

Proposed ChangesPC10 would add a definition of resort casinos to paragraph 2.27.

PC11 says criterion (e) should be deleted from the policy but referred to in the text at paragraph 2.31.

PC87 suggests a comprehensive redrafting of all the text supporting policy RR6.

Objections to the Proposed Change254/12 Gables Balmoral Hotel

306/33 / 34 / 40 Leisure Parcs

Summary of the Objections to the Proposed ChangeThe policy should be more flexible and not restricted to “resort casinos”. References to resort casinos should therefore be deleted to allow for a range of casino developments. Objection is also made to the reference in PC87 to planning obligations. (254)

The term “regional casino” is preferred to “resort casino”. Paragraph 2.32j, as proposed in PC87, is objected to. Site assembly should be referred to in the policy and not just the text. Criterion (e) should be retained in the policy, not moved to the text. The loss of Development Briefs in PC87 is particularly objected to. (306)

Inspector’s Reasoning and Conclusions General

1. Although the text in the Local Plan carries less weight than the policies, it is nevertheless part of the development plan and influences the outcome of planning decisions. It therefore warrants careful attention. As I see it, the primary role of the text is to:

(a) explain how the policies have been derived;

(b) to indicate what the policies are seeking to achieve;

(c) to indicate how the policies are to be interpreted and implemented.

2. However, it seems to me only logical to expect the text in the plan to be consistent with the policies. It is also clear from government guidance that the text should not be used to alter or extend what the policies say or to introduce


Blackpool Local Plan Review – Inspector’s Reportnew policies into the plan by (as it were) the back door.

3. In my view some of the objections I am considering here seek alterations to the text that do not fall within the parameters I have set out above.

Blackpool Coalition Against Gambling Expansion (Objector 143)

4. BCAGE want the text accompanying policy RR6 altered to reflect their concerns about the proposed extension of gambling in Blackpool and their opposition to it. However as I have said, the text needs to be consistent with the policy it is supporting and cannot introduce additional policies or controls that are not either explicit or implicit in the policy itself.

5. I have therefore dealt with some of the matters raised in objections to the text in the context of the policy itself because it is there that the Objector needed to win the main arguments in order to achieve what they want. I do not repeat all these arguments and my conclusions here.

BCAGE: The Adequacy of Consultation

6. This Objector mounted a concerted attack on the adequacy of the consultation and public participation undertaken by the Council during the preparation of the Local Plan. In particular the following complaints were made:

(a) BBC (and its officials) had failed to engage in public debate about the dangers (as well as the alleged merits) of “resort casinos” and the proliferation of “big prize” gaming machines;

(b) BBC had failed to consult all the groups that might have wished to be involved;

(c) BBC had failed to use public meetings or meetings with organised groups to allow open debate or to gauge opinion (for example by votes at meetings);

(d) BBC in publicising the Local Plan (at meetings) had not always made it clear how and when responses were required;

(e) “faith groups” had not been included in the early stages.

7. The Council’s response was that this is not a matter for me or, to the extent that it is, all the statutory requirements had been more than adequately met.

8. Having heard (and read) the evidence from both sides on the matter, my view is that the Council is justified in saying that it has met its statutory duties for public consultation during the preparation of the Local Plan and has, indeed, gone further than it was bound to do in publicising the plan.

9. Furthermore, and although the Objector will not thank me for saying so, I have reached the conclusion that neither the public nor the local business community are highly motivated by a deep and “in principle” opposition to the gambling aspects of the Local Plan. This is not to say that the Objector is wrong about all or some of what they say about gambling but only that the public and the business community are not so concerned about the issue that they are moved to make formal objections to the Local Plan. I am firmly of the view that the low number of objections on this topic has not been caused by the Council (deliberately or otherwise) denying people the opportunity to object.

10. I suspect that the conflicting views on this matter arise partly because of the emphasis the Objector wants placed on public meetings, public debates at


Blackpool Local Plan Review – Inspector’s Reportmeetings and expressions of opinion at meetings. The Council clearly does not share their view on this and is under no obligation to do so. I too am bound to restrict my considerations to duly made objections that have been made in writing. BBC is entitled not to share this Objector’s views and is not under any obligation to help propagate them as part of the Local Plan process.

11. I therefore conclude that the Local Plan is not invalidated by any shortcomings in the way it was publicised and that the text of the Local Plan does not need to be changed to express any misgivings or reservations in this respect. I therefore conclude that no modification to the Local Plan should be made in response to the objection 143/4.

BCAGE: Summary and Conclusion

12.As I have said above, I have dealt with most of the objections from BCAGE under policy RR6, rather than in relation to the text that accompanies it. I have done this because in my view the objections to the text were in reality directed at altering or extending the policy. If the proposed alterations to the text are adopted in isolation, they would make the text inconsistent with the policy.

13.However, at the Local Plan Inquiry the Objector put forward some possible changes to the revised text in PC87. In as far as these amount to the deletion of any reference to “resort casinos” I consider these would be at odds with the policy as I am recommending it and for this reason I do not support them.

14.But BCAGE also suggested changes to the wording of proposed paragraph 2.32k, which I find convincing. In the absence of any argument to the contrary from the Council I consider that they should be taken on board. Accordingly, I conclude that the last sentence of this paragraph should be: Where there is evidence that the proposed development is likely to give rise to adverse effects of a physical, social, economic, transportation or environmental nature that can be resolved satisfactorily; planning permission will only be granted if the Council is satisfied that the adverse impact can be mitigated through the use of a planning condition or a planning obligation.

15. In common with others BCAGE also suggest a clear (government endorsed) definition of “resort casino” should be included. I have already recommended that definitions and terminology are reviewed at the modification stage.

Grosvenor (Objector 361)

16. I am not entirely clear what this Objector is trying to achieve but they criticised paragraph 2.30a in the Second Deposit because it claims that Blackpool is a uniquely suitable location for regional casinos in the northwest. The Objector says that other sites in the northwest may be equally suitable and may have the same regenerative benefits as Blackpool. I note that the redrafting in PC87 omits the claim that Blackpool is uniquely placed in the northwest to reap the benefits of regional casinos. To this extent PC87 would appear to meet this objection. In any event I do not believe that this Local Plan is the right forum for deciding regional priorities between competing areas.

17. I conclude that, in this regard, PC87 is an improvement on the Second Deposit Local Plan.

Gables Balmoral

18. I consider I have already dealt with the substance of this objection under policy RR6, above. It is unnecessary to repeat this here. I conclude that no


Blackpool Local Plan Review – Inspector’s Reportmodifications arise.

Leisure Parcs

19. I consider I have already dealt with the substance of this objection under policy RR6, above. It is unnecessary to repeat this here. I conclude that no modifications arise.

Recommendations20. I have already made recommendations relating to this part of the Local

Plan under policy RR6. I do not repeat these recommendations here. 21. In addition I recommend that the last sentence of paragraph 2.32k (in

PC87) should be: Where there is evidence that the proposed development is likely to give rise to adverse effects of a physical, social, economic, transportation or environmental nature that can be resolved satisfactorily; planning permission will only be granted if the Council is satisfied that the adverse impact can be mitigated through the use of a planning condition or planning obligation.

22.Otherwise I recommend that no modifications are made to the Local Plan in response to these objections.

Officer Recommendations The Inspector’s recommendations (20-22) are accepted and in accordance with

recommendation (21) the last sentence of paragraph 2.32k (in PC87) is amended to state:

“Where there is evidence that the proposed development is likely to give rise to adverse effects of a physical, social, economic, transportation or environmental nature that can be resolved satisfactorily; planning permission will only be granted if the Council is satisfied that the adverse impact can be mitigated through the use of a planning condition or planning obligation”.

2.14 Reshaping the Resort Policy RR7The Objections254/3 The Gables Balmoral Hotel (Blackpool) Limited

287/ 7 / 29 Tesco Stores Limited



Summary of the ObjectionsThe identification of a Key Tourism Investment Site at Balmoral Road / Promenade is supported. But the reference to site assembly should be deleted from the policy. Part of the RR7.4 site should be identified as a casino location and Flagstaff Gardens should remain as public open space. (254) (The site specific aspects of the objection are dealt with under policy RR7.4, below)

The potential for new retail development should be kept in mind as more detailed guidance is prepared for the sites identified in policy RR7. (First Deposit) The scope to include other uses than those specified, for the benefit of future occupiers and visitors, should be widened. (Second Deposit) (287)

The definition of the Key Tourism Investment Sites should match those proposed in the Resort Masterplan. (306)


Blackpool Local Plan Review – Inspector’s ReportThe bold approach of the policy is welcomed but there is a danger that new visitor attractions will be spread too widely in the resort. The focus should be between the Tower and Central Pier. The policy should therefore start by setting out a sequential test focussing on this area. The New Bonny Street to Palatine Building frontage should be identified as a separate Key Tourism Investment Site (with its own policy and specified uses but not part of the Central Station site. The separate site would need its own policy to set out the uses it would contain (including resort casino, entertainment, hotel and parking) planned to be complementary to the adjoining conference centre. The text would need to be amended to reflect this and to set out the sequential preference for sites close to the town centre. Policy RR7.4 and its text should also be amended to reflect the sequential priority being given to the area nearer to the town centre. (370) (The site specific aspects of this objection are dealt with under policies RR7.1 and RR7.4.)

Inspector’s Reasoning and Conclusions 1. Where these objections relate specifically to one of the Key Tourism Investment

Sites I deal with them in connection with that particular site.

Objector 254

2. Much of this objection relates specifically to site RR7. 4 and is dealt with under that heading. The reference in the First Deposit policy to site assembly was deleted in the Second Deposit, which I consider meets the remainder of the objection. I conclude that no modification arises from this objection.

Objector 287

3. The Council view (as reflected in policy RR7) is that these policies should list only the major uses anticipated at the Key Tourism Investment Sites. Retailing and other uses are allowed for in as far as they are ancillary to and support the main uses. I consider that this approach is justified and reasonable. I also consider it would be wrong to widen the scope for other uses on these sites because this could dilute the impact of the main uses. In any event, any more substantial retail development on these sites would need to comply with the shopping policies in the Local Plan and with government guidance on the sequential approach to shopping development.


Objector 306

5. As far as Objector 306 is concerned and their suggestion that the definition of the Key Tourism Investment Sites should match those proposed in the Resort Masterplan, they did not pursue this at the Local Plan Inquiry. I am not aware that any difficulties arise in this connection and conclude that no modification to the Local Plan arises.

Objector 370

6. The Objector wants policy RR7 expanded to identify the Promenade between the Tower and Central Pier as an area in which particular regard will be paid to the vitality and viability of the area and the major attractions within it. I shall call this area the “core of the Resort Core”.

7. In my view this objection relates to policies RR2, RR5 and RR7A as well as policy RR7. The policies need to be considered together to fully appreciate the point that is being made. I note that Nobles have consistent but not identical duly made objections to policies RR2 and RR5.

8. My understanding of the way the policies interact is as follows:

RR2 establishes an area defined as the Resort Core. It is a long and


Blackpool Local Plan Review – Inspector’s Report(variably) narrow designation on the seafront from the Pleasure Beach in the south to just beyond the North Pier. Subject to criteria, in this area proposals for the development, extension or improvement of tourist attractions that draw large numbers of visitors will be permitted and encouraged. The criteria relate to physical regeneration within the Resort Core, targeting the areas in greatest need of renewal, increasing the range and quality of facilities and the ability of the area to absorb the development and its traffic. I read the policy as saying that, in principle, new attractions will be allowed and encouraged anywhere in the Resort Core but that priority is to be given to areas in need of renewal.

RR5 says that new and improved amusement arcades and funfair rides will only be permitted at the Pleasure Beach, on the piers and on the seafront between Adelaide Street West and Princess Street. There is a considerable overlap between the last of these areas and Nobles’ core of the Resort Core. The Local Plan area is somewhat larger than the area identified by Nobles and is slightly further to the south at both ends. Nobles did not object to this definition in the context of policy RR5.

RR7 (in the Second Deposit) is little more than an introduction to policies RR7.1, RR7.2 and RR7.4 (RR7.3 in the First Deposit having fallen by the wayside). The policy says that proposals to improve the identified Key Tourism Investment Sites will be permitted subject to the parameters set for each site in what follows and the rest of the Local Plan. Visitor attractions are included in the specification for all three Key Tourism Investment Sites. The Key Tourism Investment Sites are not prioritised.

RR7.A deals more generally with Promenade frontages within the Resort Core. Subject to criteria the introduction of new contemporary visitor attractions (as well as accommodation or other “facilities”) will be permitted and encouraged.

9. As I have said the Resort Core is a long area. It is also a varied area in which concentrations of attractions are interspersed with frontages largely made up of hotels. There are concentrations of attractions in the core of the Resort Core, at and around each pier and at the Pleasure Beach. In between the predominant use is hotel accommodation. Nobles are concerned that visitor attractions (as opposed to visitor accommodation) could become too thinly spread within the Resort Core as currently defined.

10. It is a long walk from one end of the Resort Core to the other. In my view this means that, although the Resort Core can be regarded as the main visitor area and may be perceived as a single entity, it is unlikely that it is enjoyed by many visitors in that way – even allowing for the unifying effect of the trams. By this I mean that I doubt whether many visitors visit the whole of the Resort Core and all its attractions in one day, although some walkers may hike from one end to other for the enjoyment of doing so. It seems to me far more likely that visitors tend to spend each visiting day primarily in or near one concentration of attractions or another or possibly in two of them. If I am right about this, there would be merit in new attractions being located so as to reinforce the concentrations of attractions rather than attempting to create a continuous or more intermittent distribution. In particular, I would see little merit in creating a new isolated attraction (to make this tangible, say a new museum or exhibition or a new amusement arcade) in one of the areas where hotels currently


Blackpool Local Plan Review – Inspector’s Reportpredominate. This could be achieved either by converting an existing hotel building to a different use or by a piecemeal redevelopment. To this extent I am therefore inclined to agree with what Nobles are saying.

11.An undue spread of attractions could be avoided by limiting the locations in which new attractions could be located to those that would reinforce the existing concentrations of such uses. A major comprehensive redevelopment might also be acceptable because it could create its own concentration. However, I remain wary of the wording that Nobles suggest in as far as it relates to maintaining existing attractions as an end in itself and this could be seen as an attempt to protect existing facilities from competition from new attractions.

12.With all this in mind it is worth revisiting the polices under examination:

RR2 at the moment does not appear to differentiate between different parts of the Resort Core as far as new attractions are concerned other than to “target” the areas in greatest need of renewal. I consider this policy would benefit from the addition of a caveat to the effect that new attractions should reinforce the existing concentrations of such uses.

RR5, in effect, already limits new and improved amusement arcades and funfair rides to specific areas where there are already concentrations of them. There is some discrepancy between Nobles’ core of the Resort Core and the area defined in the policy but in my view either definition is acceptable and workable. Indeed in my view the Council’s definition is clearer and therefore preferable. I see no reason to change this policy.

RR7, RR7.1, RR7.2 and RR7.4 all allow for major comprehensive redevelopment schemes. It seems to me that by definition this contributes to reinforcing or creating concentrations of attractions. I see no need to change this policy.

RR7.A does not differentiate between parts of the Resort Core. As such it could lead to the dispersed and intermittent siting of attractions along the seafront anywhere in the Resort Core. I consider this policy would also benefit from the addition of a caveat to the effect that the location of new attractions should reinforce existing concentrations of such uses.

13. I conclude that policies RR2 and RR7A should have additional clauses indicating that new attractions should reinforce the existing concentrations of such uses rather than leading to a dispersed distribution of attractions.

14.However, Nobles want me to go further than this because they want priority accorded to their core of the Resort Core. There are two possible reasons for doing so: because (they say) this is already the pre-eminent location and because it is near the town centre. Blackpool Pleasure Beach and others would dispute the first of these reasons. But even if it were true, it does not seem to me that the other concentrations of attractions in the Resort Core should be deprived and starved of new investment and development. As to the town centre, there are – as I have indicated above – reasons for wanting to disentangle the town centre and the Resort Core as far as holiday attractions are concerned. Although I have accorded greater priority to the town centre in considering possible resort casino locations, it does not seem to me that there is either the space or the transport capacity to do this for all future resort facilities. I conclude that the core of the Resort Core should not be given priority in the location of new and improved tourist attractions (other than casinos).


Blackpool Local Plan Review – Inspector’s Report15.Nobles also want RR7 to include a sequential approach to development within

the Resort Core. This would give their core of the Resort Core primacy but could also be used to differentiate between the other parts of the Resort Core. As indicated above, whilst I accept the applicability of such an approach in relation to regional casinos and conference / exhibition centres, it does not seem to me that it should be applied to all possible tourist development. My main reason for saying this is that the Resort Core is already established as an out-of-town-centre location that owes as much to its relationship to the seafront and piers as it does to its links with the town centre. In any event the Pleasure Beach is a very important magnet or anchor that should not be ignored or diminished. Similarly it would be unfortunate if the piers and their immediate environs were to be deprived of investment and new attractions.

16.Nobles are also concerned about preserving pedestrian and vehicular accessibility within (and to) their sites within the core of the Resort Core. I consider this matter further in relation to policy RR7.1.

Recommendations17. I recommend that policies RR2 and RR7A should have additional clauses

indicating that new attractions should reinforce the existing concentrations of such uses rather than leading to a dispersed distribution of attractions.

18. I recommend no modification to the Local Plan in response to objections 254/3, 287/7, 287/29 and 306/7.


The Inspector’s recommendations are accepted with an additional criterion (d) to therefore be added to Policy RR7Aand RR2) to state:

(d) New attractions should reinforce the existing concentrations of such uses rather than leading to a dispersed distribution of attractions

2.15 Reshaping the Resort Policy RR7.1The Objections213/3 Mr I Gray

291/1 M G Allen

335/3 Mrs Gray


Summary of the ObjectionsMore specific information is required on this and other developments and the impact on hotels and small businesses. The retention of the existing parking at Central Station is important for local hotels and businesses. (213) (335)

The retention of long-stay and affordable parking at Central Station is important to local hotels and businesses. Proposals for the site so far do not suggest this will be the case. A private car park attached to a new hotel would not provide this. (291) (370)

There is a danger that new visitor attractions will be spread too widely in the resort. The focus should be


Blackpool Local Plan Review – Inspector’s Reportbetween the Tower and Central Pier. The New Bonny Street to Palatine Building frontage should be identified as a separate Key Tourism Investment Site not part of the Central Station site. The separate frontage site would need its own policy to set out the uses it would contain (including resort casino, entertainment, hotel and parking) planned to be complementary to the adjoining conference centre. The text would need to be amended to reflect this and to set out the sequential preference for sites close to the town centre. (370) (All the site specific aspects of this Objector’s objections are dealt with here.)

Inspector’s Reasoning and Conclusions Car Parking

1. All four of the objectors to this policy are concerned to secure the retention of (affordable and accessible) car parking at the Central Station site.

2. The Council’s starting point is that, even though it came into being as a resort as part of the railway age, Blackpool is now dependent on access by road and predominantly by car. In particular the Council does not foresee any scope for the rail network to accommodate a significant increase in the number of visitors arriving by train. The Council therefore attaches importance to retaining the amount of parking for visitors and on facilitating access to the resort by car.

3. To this (important) extent the Council and these four objectors share common assumptions and aspirations, at least at a generalised policy level.

4. I feel bound to say at this point that this shared position does not sit easily with current government guidance on parking and transport policy. The government wishes to reduce dependence on the use of the private car and sees controlling the supply and management of car parking as one way to achieve this.

5. It may be that a case can be made for regarding Blackpool (as a resort) as an exception to this overall approach which, because of its history, function and geography, should be treated differently. However before this could be accepted as the basis for local policy, far more work would be needed to look at refinements in the current parking regime. These might include such initiatives as park and ride, green transport plans, schemes to increase accessibility by coach and the attractiveness of coaches as well as different parking management and charging policies.

6. As yet, investigations of these alternative approaches appear to be absent, as indeed is any reliable or sophisticated data on the occupancy of spaces or the duration of parking in the town centre and/or resort. This being the case, I am unable to accept, in principle, that a policy based on retaining or increasing the amount of parking in order to maintain or stimulate visitor numbers is either soundly based or consistent with current guidance.

7. Moving to more detail, the Council says that part of the local problem is that pressures arising from town centre uses (for example, shoppers and people working in the centre) and tourism (day trippers and staying visitors) overlap in time and place. These various parking demands sometimes peak together and put pressure on the same car parks. Whilst as a general rule the dual or shared use of parking is to be encouraged as an efficient use of land, in the particular circumstances of Blackpool the Council sees some merits in trying to separate how these various demands are met. This may well have some merit but it is worth noting that the parking at the Central Station site is a prime example of where these various demands coincide. The site is conveniently located for shops in the town centre, there are many small hotels in the vicinity and Coral


Blackpool Local Plan Review – Inspector’s ReportIsland is just across the road. These objectors, although small in number, give some indication of this diversity of interests.

8. Looking at the Central Station site itself, I do not believe the Council purchased it with the intention of providing ground level car parking here indefinitely. Nor can the site, in its present use, be described as a visual or townscape asset to the town. In short, the site is a prime candidate for redevelopment and is so well located that its present use, although a useful stop-gap, is a waste of a valuable land near the town centre and in the Resort Core.

9. I recognise the importance the existing availability of car parking here may have for businesses near the site. However, in view of all I have already said I do not consider this can be allowed to stand in the way of the redevelopment that is needed. Neither do I consider a case has been made (at a general level or in relation to this particular site) that any redevelopment should seek, as a matter of policy, to retain (or increase) the existing amount of parking.

10.As far as coach parking is concerned, I discuss this in more detail under policy RR17. However, I note that policy 7.1 includes a reference to the need for coach drop-off and pick-up facilities.

11. I conclude that no modifications to the Local Plan arise from these objections.

The Noble Organisation

12. I also deal here with all the other objections from the Noble Organisation that were made to other policies but which reflect the site specific changes they seek in this policy.

13. In the First Deposit site RR7.1 did not include Coral Island or land to the north of it. In the Second Deposit the RR7.1 site was extended northwards to include Coral Island and the Palatine building, both owned by Nobles. For simplicity I shall refer to the combined Coral Island and Palatine site as the Coral Island site and the rest of the RR7.1 site (as presently defined) as Central Station even though the latter encompasses more land than the site of Central Station itself. There are no other objections to the extent of site RR7.1.

14.Since the change to the extent of site RR7.1 in the Second Deposit, Nobles have pursued two main objections to the policy (apart from their concerns about the potential loss of parking already dealt with above):

first, they are anxious to ensure that easy and direct pedestrian and vehicular access is retained for the Coral Island site through the Central Station site;

second, they say that the Coral Island site should be designated as a separate and distinct Key Tourism Investment Site capable of accommodating a regional casino and hotel. Indeed they go on to argue that this site is sequentially preferable to all other Key Tourism Investment Sites and should given priority accordingly.

15. In my view there is some tension between these two main objections (seeking to keep the Coral Island site separate whilst wishing to secure access to it through the Central Station site). I say this because the simplest way to achieve what they want in terms of access would be to include all the land in one comprehensive redevelopment scheme. Be that as it may, they say that their objectives relating to access could be secured through a Development Brief or


Blackpool Local Plan Review – Inspector’s Reportthe development control process, although both would rely on the matter being included as a requirement in the policy for the Central Station redevelopment.

16.The Council and the Objector agree that whether or not the Coral Island site is included in RR7.1, the eventual outcome may be that the land is redeveloped as a casino/hotel or that Coral Island and the Palatine are retained and developed separately. However, there are some caveats on the Council’s side.

17.At the Local Plan Inquiry the Objector produced an outline Masterplan for the Coral Island site to demonstrate it could accommodate a mixed-use scheme including a regional casino and hotel. However, the scheme incorporated (and therefore closed) New Bonny Street. Neither was it apparent how the public pedestrian access between Coral Island itself and the Palatine building would be incorporated into the scheme (although it seemed to be accepted by the Council that this could be achieved at the detailed design stage). However, BBC said that closure of New Bonny Street was a far greater impediment to the Noble Masterplan scheme because this street is an important link in the (one-way) traffic circulation system for the town centre and, as such, critical to the routing of a large number of bus services coming to and through the centre.

18.Nobles’ response to these difficulties was twofold. First, although neither side produced any detailed analysis of bus routes, was to suggest that the Council was exaggerating the problem and that bus services could be re-routed or reorganised. Second was to say that their scheme was not dependent on closing New Bonny Street and that all the necessary floorspace could be accommodated on the Coral Island site without encroaching onto the road. In the last analysis the problem could be solved by building higher.

19.The other matter on which there is a divergence of opinion is the arrangements that should be made for car parking in the event of redevelopment. (This relates to the location of parking as much as numbers, which I have discussed above.) For the Objector any problem in this respect could be easily solved either by retaining adequate parking on Central Station or by relocating it onto the Coral Island site (and again building higher to accommodate it).

20. I will not repeat all I have said about parking above, but the following matters are relevant here.

First, the Council anticipates that a regional casino (and any associated hotel) will be a very large traffic generator and that provision should be made for parking on or very close to the site. (I have expressed reservations about how the Council’s approach to parking relates to government guidance but this is not a matter disputed by the Objector and, although there may be differences about the amount of parking needed, this seems to me to be a reasonable working hypothesis.)

Second, the Council says that casino visitors’ cars should approach the site along the Central Corridor (that is along the line of the railway that used to lead to Central Station) in order to achieve direct access from the motorway and to separate resort traffic and parking from town centre traffic and parking. (Again, I have expressed doubts about the adequacy of the justification for this approach to traffic and parking in the town and resort as a whole but for this site and these uses it makes sense.)

The implications of this are that either there would have to be a (busy) vehicle route across the Central Station site to reach the Coral Island


Blackpool Local Plan Review – Inspector’s Reportsite or all the parking would have to be on the Central Station site. Alternatively, traffic would have to use existing streets to reach the Coral Island site. Whether New Bonny Street is to be closed or not this latter option would lead to the intermingling of traffic heading for the casino / hotel with town centre traffic. I consider the first two of these possibilities to waste space and/or to impose an undue constraint on the planning of the Central Station site. I consider the last option would have an undesirable impact on the town centre and access to it.

21. I have already said when considering policy RR6 that, under the proposed licensing and bidding arrangements envisaged in the draft gambling legislation, it would not appear to be necessary for a casino to be on a particular site for it to make a (financial) contribution towards that site’s redevelopment. It is my understanding that, in the licensing and bidding situation that will surround planning applications for regional casinos, contributions towards regeneration may be sought and taken from would-be casino operators and used elsewhere in the town. In the regime controlled by (current) planning legislation it is necessary for any links between a development and its benefits to be reasonably related in a direct way. This often means that the two are on the same site. It is my understanding that such direct links will not be required in relation to the licensing and bidding situation that would apply to casinos.

22.This may mean that in purely financial terms a satisfactory arrangement could be arrived at if the Coral Island and Central Station sites were developed separately. However, in my view this objection should be determined on its planning merits.

23.The Objector is also concerned that the Local Plan is too prescriptive and too dependent on one or more regional casinos being allocated to Blackpool. However in my view, the Local Plan policies are enabling rather than dependent on regional casinos. In any event for as long as Nobles retain aspirations to have a regional casino on their site they are subject to the uncertainties surrounding these, whether their site is included within the wider Central Station site or not. I have done what I can to limit the extent of any uncertainty surrounding regional casinos by clearly identifying one preferred site (for one or two; and nobody expects more than that) in the Local Plan which means there is no longer any uncertainty as to which site within Blackpool would be suitable.

24. I take the view that the above considerations, taken in the round, point to the two sites being planned and/or redeveloped as one. The arrangements to be made for access, parking, any street closures and traffic management will be complex. The issues should be resolved in such a way as to produce the best overall result in terms of the disposition of uses and access/parking arrangements. Separate planning and development of the Coral Island site would impose very great and unreasonable planning constraints on the Central Station site that would be better (and necessarily) resolved in a unified planning exercise. In my view the complexity (and uneven distribution of beneficial uses between the sites) would be such that this is not a matter that could be left to a Development Brief or the normal workings of development control.

25. I conclude that the boundaries of the RR7.1 site in the Second Deposit should not be modified in response to the objections from the Noble Organisation.

26.As to the relative priority of the RR7 sites, I have already concluded on this matter as far as regional casinos are concerned. If the Coral Island site is not to


Blackpool Local Plan Review – Inspector’s Reportbe taken out of the RR7.1 site there is no need or reason to look at priorities as between Coral Island and Central Station. I conclude that no modification arises from this aspect of the objection.

More Detail and Speed (Objectors 213, 335)

27.Other than more rapid progress it is not clear what would satisfy these objections. However, major regeneration takes time to formulate and implement. In any event the Local Plan is not necessarily the right place for detailed plans and (possibly spurious) target dates and I cannot invent or impose these if none are suggested to me.

28. I note that these objectors have objections to other parts of the Local Plan and I deal with the specific issues of concern to them under those headings.

29. I conclude that no modification arises from these objections to policy RR7.1.

Overall Conclusion

30. I conclude that policy RR7.1 should not be modified. For the avoidance of doubt this means that no consequential modifications arise in relation to the Noble Organisation objections to other policies.

Recommendations31. I recommend that policy RR7.1 should not be modified. 32.For the avoidance of doubt I also recommend that no consequential

modifications arise in relation to the Noble Organisation objections to other policies.

Officers Recommendation The Inspector’s recommendations are accepted

2.16 Reshaping the Resort Policy RR7.2The Objections025/1 Kevin Jolliffe (Avalon Hotel, 18 Tyldesley Road) (*1)

036/1 Terry Porter (Hotel, 28 Tyldesley Road) (*1)

074/1 Mrs Jane Bury (Applethwaite Hotel, 12-14 Tyldesley Road) (*1)

075/1 Teresa L Germaine (Shelborn Hotel, 10 Tyldesley Road) (*1)

102/1 Mr and Mrs B L Wilkinson (Sandwell Guest House, 8 Tyldesley Road) (*1)

118/1 Brooklyn Hotel (20 Tyldesley Road) (*1)

213/ 4 / 6 Mr I Gray (Delamere Hotel, 34-36 Tyldesley Road) (*1)

278/3 D Whitfield (23 Tyldesley Road) (*1)

335/ 2 / 6 Mrs Gray (Delamere Hotel, 34-36 Tyldesley Road) (*1)

336/1 Heidi Jolliffe (Avalon Hotel, 18 Tyldesley Road) (*1)

344/1 Christine Unwin (Shelborn Hotel, 10 Tyldesley Road) (*1)

356/1 SecondSite Property (Gas Holder Site) (Second Deposit) (*2)

*1 was in RR7.2 in First Deposit, removed from RR7.2 in Second Deposit


Blackpool Local Plan Review – Inspector’s Report“2 was in RR7.2 in First Deposit, still in RR7.2 in Second Deposit

Summary of the ObjectionsMore information about what is proposed in this area is needed urgently, especially relating to Tyldesley Road, Rigby Road, Blundell Street and the Promenade. Businesses are in limbo not knowing whether to invest. (025) (036) (102) (118) (213) (278) (335) (336) (344)

Grant assist property improvement to make Blackpool the popular and successful holiday resort it once was rather than proposing demolition and redevelopment. (036) (075) (102) (118) (213) (335) (344)

Tyldesley Road hotels have been the subject of substantial improvement and hoteliers recognise the importance of guest comfort and improved facilities. Clarify proposals for this area. (074) (075)

The car and coach parks in this area should be retained (especially the coach park and the Blundell Street car park). (213) (278) (335)

Blackpool needs more family attractions. (075), (344)

Paragraph 2.40 is too vague about the poor condition and appearance of properties in this area and should indicate these properties clearly. (074)

The objectors have recently invested all their savings in 18 Tyldesley Road as their home and business. They seek more information on what the Local Plan means for them. But they do not seek any change to the Local Plan. (025) (336) (Inspector’s comment: it appears to me that these representations relate to RR7.2 rather than to RR7.3, although there are similar objections to that policy.)

There is no need for more new hotels. (213) (335)

Policy RR7.2 is objected to because paragraph 2.39d says that the gas holders in Rigby Road will be removed to provide additional parking. But the gas holders are still in use and it would cost a great deal to remove and/or replace them and remediate the land. The objection is made to “protect the position” of the owner of the land and user of the facility. (356)

The area including Tyldesley Road should not be transformed. The Resort Core should extend no further than the gas holder site. (213) (335)

Inspector’s Reasoning and Conclusions 1. In order to better understand these objections I have listed the affected

addresses and related these to the designated areas in the First Deposit and Second Deposit versions of the Local Plan.

2. One observation that arises from this exercise is that most (indeed, all but one) of the objections are primarily concerned with properties that were included in the RR7.2 designation in the First Deposit but are no longer included in it after the designated area was changed in the Second Deposit. It is clear that this change meets some of the objections that specifically sought removal of properties from the designated area and from the threat of redevelopment. However, in other respects some of the general comments are still applicable whether a particular property is directly affected or not.

More Information Needed

3. The most common complaint about this policy in the First Deposit was the lack of specific information. The Council has acknowledged this deficiency and the Second Deposit includes more information. Even so, the objections have not been withdrawn, although I now consider there is an appropriate amount of information in the Local Plan. It would not be appropriate for the Local Plan to contain as much detail as a Development Brief or planning application.

4. I conclude that no (further) modification arise from this aspect of the objections.

Improvement or Redevelopment


Blackpool Local Plan Review – Inspector’s Report5. As I have said, the area designated by this policy was changed between the

First and Second Deposits. Apart from extending the area to the south and east, the major change is to take two-thirds of Tyldesley Road and the Promenade between Princess Street and Lytham Road out of the designated area. This will no doubt satisfy many of the objectors, especially those who own and operate businesses in that area and who expressed a preference for property improvement rather than wholesale redevelopment. I therefore consider that many of these objections were met by the Second Deposit.

6. However, when I consider the (now deleted) policy RR7.3 below; I conclude that more should be done to stimulate regeneration and environmental improvements in the Foxhall area. I consider this part of Tyldesley Road and the Promenade should be included in any measures taken to improve Foxhall.

7. I conclude that urgent consideration should be given to bringing forward the area deleted from RR7.2 in the Second Deposit as part of the Foxhall area for Resort Neighbourhood Improvement under policy RR9 (B). (See also under policy RR7.3).

The Need for New Hotels

8. Some of the objectors say that there is no need for new hotels in Blackpool, especially as the Council acknowledges that there is too much holiday accommodation in the resort already. The Council argues there is a need to improve the standard of much of the existing accommodation in the town and the best way to achieve this is a by a mixed approach that includes providing new hotels of a high standard and raising standards in existing premises. The case for new hotels is thus a qualitative one as much as a quantitative one.

9. I consider that such a dual approach is justified and is the most likely to succeed for the overall good of the resort. I therefore take the view that whilst improvements should be encouraged in appropriately located existing hotels, this is not a reason to prevent new hotels being built.

10. I conclude that no modification to the Local Plan arises from these objections.

Parking

11.The Council also says that it has addressed the issue of car and coach parking in paragraph 2.70a. It is my understanding that no overall reduction in car parking is proposed in this area.

12.However as I have remarked elsewhere, it is my view that the car parking policies and proposals in the Local Plan are not based on comprehensive survey data about the current use of car parks. It is also the case that the implications of the Local Plan for car parking are not precise and may not be in very close alignment with current government guidance on parking policy. In these circumstances I am not endorsing the parking policies in the Local Plan. However for the same reasons, I do not feel able to endorse the objections that are based on arguments that all the existing parking in the town should be retained or that the overall amount of parking should be increased.

13. It may be that much of the car parking in the Resort Core is to serve visitors to the resort and that its provision should be seen as an instrument of regeneration rather than as an aspect of transportation policy. However, I do not have enough information to conclude that this is the case.

14. I therefore conclude that no modifications to the Local Plan arise from


Blackpool Local Plan Review – Inspector’s Reportobjections relating to the retention of car parking in this area.

15.As far as coach parking is concerned, I discuss this in more detail under policy RR17 where I conclude that coach parking, drop-off and pick-up facilities should all be included as supporting development in policy RR7.2.

The Gas Holders

16.This appears to be the only objection to this policy from a landowner within the Second Deposit RR7.2 site. I do not appear to have a detailed response to this objection from the Council. Neither do I have anything from the Objector since their objection dated 16 March 2004. From this I note that the gas holders were in use at that time and that moving them to another site was expected to be a difficult (and costly) operation involving decontamination of the site. However, the extent and cost of any works to make good the land would depend to some extent on the intended after use, which could involve parking (which is perhaps not the most expensive possibility).

17.From the way the objection is put (“to protect our position”) and from the lack of further representations I form the impression that this is not an objection to the principle of including the site in a Key Tourism Investment Site. Be that as it may, I have no reason to suppose that – if including the site is important enough (and the sizable area does look to be an important part of the eastern limb of the designated area) – then the appropriate technology could be harnessed and the cost afforded even if it were to prove expensive.

18.At this stage, therefore, I do not have information that would lead to me conclude that the inclusion of this land in the RR7.2 site is out of the question.

19.There are other relocations (including Council depots) that are required before the RR7.2 site can be assembled and redeveloped. No doubt the Council will be looking in detail at all the land that is subject to this sort of constraint.

20.On the information available to me, I conclude that the gas holder site should not be excluded from the RR7.2 designated area.

Other Matters

21.Some objectors argue that what is need in Blackpool are new family attractions. In the Council’s evidence, based on the Resort Masterplan, I note that the intention is to provide just such attractions on this site. These could include a tropical paradise, water theme park and/or an interactive science and technology museum. I therefore consider that the intention is to meet these objections through the comprehensive redevelopment of this area.

22. In addition it will be noted that in considering policy RR6 I have concluded that there will be no realistic scope for including a regional casino in this area. It is because I consider that redevelopment here should not be dependent on, or held up by, the pursuit of a casino that I consider the possibility should be removed from this policy in the Local Plan.

23.None of the other matters raised in the objections are, in my view, of sufficient weight or importance to lead to the modification or deletion of this policy. Indeed, now that the area has been altered, the lack of objections is remarkable even though people had the chance to object to the Second Deposit. I consider that the successful implementation of policy RR7.2 in the Local Plan is an essential element of the wider plans to regenerate the resort.

Overall Conclusions


Blackpool Local Plan Review – Inspector’s Report24. I have already concluded that references to casinos should be removed from

policy RR7.2. Otherwise I conclude that facilities for coaches should be included in the description of the development intended at this site. I am also concerned that the area deleted from this Key Tourism Investment Site in the Second Deposit should be assisted to regenerate.

Recommendations25. I have already recommended (see policy RR6) that references to casinos

should be removed from policy RR7.2. 26. I recommend that coach parking, drop-off and pick-up facilities should all

be included as supporting development in policy RR7.2.27. I recommend urgent consideration is given to bringing forward the area

deleted from RR7.2 in the Second Deposit as part of the Foxhall area for Resort Neighbourhood Improvement under policy RR9(B). (See also under policy RR7.3).

28.Otherwise I recommend no modification to policy RR7.2.

Officers Recommendations The Inspector’s recommendation (25) is accepted, and accordingly the first item in the

list of supporting developments in Policy RR7.2 to be amended to refer to “Other major tourism development”, with the words in brackets “(potentially including resort casinos and entertainment facilities)” to be deleted.

The Inspector’s recommendation (26) is accepted and accordingly “coach parking, drop-off and pick-up facilities” should be added to the list of potential supporting developments in Policy RR7.2.

The Inspector’s recommendations (27) and (28) are accepted. For Recommendation (27) see implications under Policy RR7.3.

2.17 Reshaping the Resort Policy RR7.3The Objections010/1 Alan and Christine Hawcroft (Dalebrook Hotel, 16 York Street) (*1)

025/2 Kevin Jolliffe (Avalon Hotel, 18 Tyldesley Road) (*2)

207/1 Dawood Asmal (1-3 York Street and Foxhall Market) (*3)

208/1 Nicholas Joannou (Foxhall Market) (*3)

209/1 Mr U Atcha (Foxhall Market) (*3)

210/1 Abdul Patel (Foxhall Market) (*3)

211/1 Haroon Asmal (Foxhall Market?) (*3?)

212/1 Ayub Ingar (Foxhall Market?) (*3?)

216/1 Miss Madelaine Plits (Foxhall Market) (*3)

248/4 Blackpool Pleasure Beach (Conditionally Withdrawn)

288/1 Mr A Moavia (52 Foxhall Road) (*3)

293/1 J Phillips (11b Dale Street) (*3)

336/2 Heidi Jolliffe (Avalon Hotel, 18 Tyldesley Road) (*2)


Blackpool Local Plan Review – Inspector’s Report*1 not in Key Tourism Investment Site, First Deposit or Second Deposit

*2 was in RR7.2 in First Deposit, removed from RR7.2 in Second Deposit

*3 was in RR7.3 in First Deposit but RR7.3 deleted in Second Deposit

Summary of the ObjectionsExtend the boundary of site RR 7.3 to include York Street and all the Foxhall area. (010)

Grants should be made available to renovate properties in this area. (207)

Delete any proposals to redevelop this area and provide grants to renovate properties. Foxhall Market should be retained. (208) (210) (216)

Delete any proposals to redevelop this area and provide grants for improvement, tidy up the tourist areas, promenade and beaches and provide free parking. Keep Foxhall Market. (209)

Delete any proposals that promote potential redevelopment; retain Foxhall Market. (211), (212)

The objectors have recently invested all their savings in 18 Tyldesley Road as their home and business. They seek more information on what the Local Plan means for them. But they do not seek any change to the Local Plan. (025) (336)

Extend the Key Tourism Site RR7.3 to include Princess Street to Chapel Street and Dale Street to Coop Street. The properties are old and run-down and should be redeveloped to support the major developments planned to the north and south. (248)

Delete development proposals for Foxhall Road to retain existing business but pedestrianise the street. (288)

The proposal for investment and development is welcomed but it should be left in the hands of existing owners. Therefore, delete the reference to site assembly which is not a matter for the Local Plan. Add a note to paragraph 2.40 encouraging individual owners to improve their property. (293)

Inspector’s Reasoning and Conclusions1. In the First Deposit there was one policy (RR7) which listed four “Key Tourism

Investment Sites including RR7.3 Promenade / Dale Street / Foxhall Road. These objections were to that aspect of policy RR7. In the Second Deposit the policy was considerably expanded and laid out somewhat differently but the part of the policy previously listed as RR7.3 was deleted. Nevertheless none of these objections have been withdrawn.

2. In order to better understand the objections I have listed the affected addresses and related these to the designations in the First and Second Deposits.

3. One observation that arises from this exercise is that most of the objections are primarily concerned with properties that were included in the RR7.3 designation in the First Deposit but are no longer directly affected now that the designation has been deleted in the Second Deposit. It is clear that this change meets some of the objections that specifically sought removal from the designated area and the threat of redevelopment. However, in other respects some of the general comments are still applicable whether a property is directly affected or not.

Objectors Arguing Against Major Redevelopment

4. The majority of the objections are against a major redevelopment in this area, at least if this involves the disruption or removal of existing businesses. Particular objection is made to the loss of businesses in Foxhall Market.

5. As things stand in the Second Deposit, this aspect of the policy is no longer part of the Local Plan. In these circumstances these objections appear to me to have been met and there is no need for me to consider them further.

6. In addition Objector 293 sought the deletion of any reference to site assembly and indicated that redevelopment should be left in the hands of existing owners.


Blackpool Local Plan Review – Inspector’s ReportIn my view this objection has also been met by the deletion of RR7.3.

7. I conclude that no modifications arise from the objections that opposed redevelopment that would disrupt or remove existing businesses.

Objector Arguing For a Larger Redevelopment Area

8. Objection 10/1 seeks an extension of the Key Tourism Investment Site to include a property in York Street that was not in the designated area in the First Deposit. However, as the designated area was deleted in the Second Deposit and this property is no longer near or adjoining any of the remaining Key Tourism Investment Sites, it would not be appropriate to designate it as such. Therefore I conclude that no modification arises from this objection.

Other Matters

9. Notwithstanding what I have said about policy RR7.3 being deleted, thus removing the prospect of large scale redevelopment in this area from the Local Plan, several of the objectors to the First Deposit put forward positive suggestions for the regeneration of the area. These included a programme of improvements to existing premises, introducing improvement grants and pedestrianising Foxhall Road. It does not seem to me that the deletion of RR7.3 has met these aspects of the objections.

10. It is true that the Second Deposit policy RR7A would apply to part of this area and would allow for some development and redevelopment near the seafront. It is also true that the area is in a Resort Neighbourhood (Foxhall) which (under policy RR9 is to be the subject of Neighbourhood Planning Guidance to make the area more attractive as a place in which to live and work. But there is a danger that the area could be left, in effect, to its own devices for the duration of the Local Plan (until 2016). Given the period of uncertainty it has suffered the need for action is, in my view, urgent if a collapse in confidence is to be averted.

11.There is a relatively large area at Foxhall sandwiched between two proposed redevelopment areas RR7.1 and RR7.2. This contains many businesses and homes. Many of the buildings in the area are not in very good condition and in many respects the area has a poor appearance and environment. Confidence and environmental conditions in the area will not have been helped by the uncertainties arising during the preparation of the Local Plan. The area is, because of its location and the nature of the uses within it, prominent for many tourists and visitors and is thus likely to have an important impact on the way the resort as a whole is perceived. People also live in the area. For all these reasons I consider this area is (at the very least) a strong candidate for a neighbourhood or environmental improvement initiative.

12. I conclude that (urgent) consideration should be given to bringing forward the Foxhall area for Resort Neighbourhood Improvement under policy RR9 (B). In my view this applies to a wider area than that covered by the deleted policy RR7.3; it should extend further inland and should also include the adjacent area deleted from site RR7.2 in the Second Deposit.

Overall Conclusions


Blackpool Local Plan Review – Inspector’s Report13. I conclude that the deletion of Key Tourism Investment Site 7.3 in the Second

Deposit met many of these objections. However, some of the objections rightly pointed to the need for investment and environmental improvements. To respond to these objections and the needs of the area, I conclude that urgent consideration should be given to bringing forward the Foxhall area for Resort Neighbourhood Improvement under policy RR9 (B).

14.This consideration and action should include the area deleted from Key Tourism Investment Site 7.2 in the Second Deposit.

Recommendations

15. I recommend that urgent consideration is given to bringing forward the Foxhall area for Resort Neighbourhood Improvement under policy RR9 (B).

16.This consideration and action should include the area deleted from Key Tourism Investment Site 7.2 in the Second Deposit.

17.Otherwise I recommend no modification to the Local Plan as it now stands in response to these objections.

Officers CommentsThe Inspector’s recommendation that urgent consideration is given to bringing forward preparation of resort neighbourhood improvements (under Policy RR9) for the areas deleted from RR7.3 (and from RR7.2) requires no proposed modifications to the plan. This comprises Tyldesley Road, Foxhall Road and Dale Street (west) frontages between Chapel Street and Rigby Road

Reflecting the Inspector’s concern the programming of work on Neighbourhood Action Area Plans will be considered at the next review of the Council’s adopted Local Development Scheme.

Officers Recommendations The Inspector’s recommendations are accepted.

2.18 Reshaping the Resort Policy RR7.4The Objections024/1 Mr Lance Croot

027/1 Mrs Angela Croot

037/1 Mr K J Richardson

038/1 D McPartling

040/1 K Banks

041/ 1 / 2 Mrs O Robinson

042/ 1 / 2 D Banks

044/3 Mrs Pamela Ruddy

048/ 1 / 2 M Banks

049/1 / 2 Mr P Banks

087/1 Mrs Lawton

91/2 South Shore Focus Group


Blackpool Local Plan Review – Inspector’s Report098/ 1 / 2 / 3 Mrs Jill Parker

111/1 Mr D J Payne

112/1 Mr Leslie Griffiths

113/1 Mrs Patricia Griffiths

114/1 Gloria Griffiths

115/1 T Hopkins

116/1 Mr G Lloyd

141/1 South Beach Area Focus Group

148/1 Mr D L Lawton

170/1 Mr T Young

171/1 Mrs E Webb

172/1 Mr D Webb

173/1 Mrs D Hanson

174/1 Mr J L Hanson

175/1 Miss D Hanson

184/1 Ms Loretta Miles-Hayes

214/ 1 / 2 / 3 Martin Allen

215/1 Mrs L M Plits (Conditionally Withdrawn)

223/1 Alan Wrigley

248/ 1 / 5 / 6 / 10 / 11 Blackpool Pleasure Beach

254/ 3 / 9 The Gables Balmoral Hotel (Blackpool) Limited


280/1 Geoffrey Seal (Conditionally Withdrawn)

314/ 1 / 2 Mr and Mrs Charlston

317/1 Mrs D Young

324/1 Mr and Mrs Hutchison

370/ 5 / 6 The Noble Organisation

Summary of the ObjectionsThere are no firm plans for this area, so its designation under policy RR7.4 is not justified at this time. Large scale redevelopment is not needed or justified. More detail and control would be needed to justify the proposal. (024) (027) (048) (087) (098) (112) (141) (148) (214) (314) (324)

Small businesses and homes are badly affected by this policy. (024)(027)(037)(038)(040)(041)(042) (048)(049)(087)(098)(111)(112)(113)(114)(115)(116)(148)(170)(171)(173)(174)(175)(314)(317)(324)

Remove all or part of Balmoral Rd and/or Osborne Rd from the designated area. (024) (027) (040) (041) (042) (048) (049) (098) (114) (171) (172) (173) (174) (175) (184) (280) (314) (324)

Delete the whole designation. (037) (087) (141) (148)

There are better locations for development (e g near the end of Yeadon Way / Seasiders Way or on the Bond Street car park, within the existing Pleasure Beach). (024) (112) (113) (114) (116) (314)

Flagstaff Gardens should be retained as public open space. (041) (042) (044) (049) (091) (098) (171) (172) (173) (174) (175) (214) (223) (254) (277) (314)

The garages at the end of Brighton Avenue should be retained. (041) (042) (048) (049) (214) (215)

Any new building here would need to be low-rise and sensitive to the surroundings. (044) (091) (098)

There is concern about blight due to uncertainty. (141)

The Compulsory Purchase of properties in this area should be explicitly ruled out. (254) (280) (324)


Blackpool Local Plan Review – Inspector’s ReportConcern is expressed about the loss of access to properties. (170) (184) (317)

The revised policy is still no more than an aspiration and contains no clear guidance for future development. The objection to the First Deposit is reiterated. (314) (Second Deposit)

Other approaches to regeneration are required. (038) (314)

The extension of the RR7.4 designation to include the whole of the Pleasure Beach is opposed. The policy should remain focussed on a smaller area (Balmoral Road, the Promenade and Bond Street). The Pleasure Beach should be dealt with separately. A revised wording for the policy is suggested. (254) (Second Deposit)

There is a need for a phased and sequential approach to major tourist development to ensure that the area at the centre of the town is not diluted or harmed. The focus should be between the Tower and Central Pier. Policy RR7.4 and its text should be amended to reflect the sequential priority being given to the area nearer to the town centre. (370) (Second Deposit)

The Key Tourism Investment Site at South Shore should be extended to include all the land between Balmoral Road and Station Road, and Lytham Road to the East (including all Osborne Road, Withnell Road, Station Terrace, and Station Road - south side). (248) (First Deposit)

Pending redevelopment in the longer term, Blackpool Pleasure Beach should be permitted to use any existing properties for essential staff accommodation. The policy and paragraph 2.41 should reflect this. (248) (First Deposit) The clause in the revised policy RR7.4 that would allow staff accommodation does not go far enough because of the needs of seasonal artistes appearing in shows. Specific allowance should be made to allow the temporary use of acquired properties pending redevelopment for this purpose. (248) (Second Deposit)

Revised policy RR7.4: the second part of sub-paragraph (a) should be deleted and appropriate amendments made to paragraphs 2.41a and 2.43 to remove references to the replacement of open space and introducing additional public areas. There are already enough areas open to the public in this vicinity. Controlling public access and security are of overriding importance, as is achieving a spacious layout within the Pleasure Beach. (248) (Second Deposit)

(Although listed by the Council as relating to this policy objection 248/1 is concerned with the definition and extent of the inner area and Resort Core on the Proposals Map.)

(Also dealt with here is objection 254/3, recorded by the Council as relating to policy RR7.) The identification of a Key Tourism Investment Site at Balmoral Road / Promenade is supported but Flagstaff Gardens should remain as public open space. (254/3)

Proposed ChangesPC12 would remove the garage court at the southern end of Brighton Avenue (previously in the northeast corner of the designated area) from the RR7.4 designation. (see map RR7.4PMC1)

PC13 would alter the wording of policy RR7.4 (a), which would now talk about creating a high quality public realm.

Inspector’s Reasoning and Conclusions The Principle of Designating this Key Investment Site

1. In the First Deposit the extent of this site was relatively small; it was an area north of Blackpool Pleasure Beach (BPB) including Flagstaff Gardens, the north side of Balmoral Road and both sides of Osbourne Road west of Bond Street. The First Deposit Local Plan said little about the purposes of the policy, although many Objectors assumed it was to facilitate the northward expansion of the Pleasure Beach in order to allow BPB to build a new hotel.

2. In the Second Deposit the designated area was greatly expanded by the inclusion of the Pleasure Beach itself and the area between the Promenade and the sea, including the Sand Castle complex. However, the north side of Osbourne Road was deleted from the area. The Second Deposit version of the Local Plan also went into more detail about the purposes of designation, identifying the main development/use of the area as an amusement park and


Blackpool Local Plan Review – Inspector’s Reportmajor visitor attractions. Supporting development was identified as possibly including other major tourism development (such as a resort casino and entertainment facilities), hotel development, high quality public realm, private and public car parking and staff accommodation.

3. It is true that the area as currently defined has seen some of the major investments in the resort in recent years, whether at Sand Castle or within the Pleasure Beach complex. I have not been told of any forthcoming investment at Sand Castle but it is clear that BPB envisages a continuing process of investment and renewal on its site. They would want this to include new (and ever more exciting) “rides” from time to time and new hotel accommodation linked to the Pleasure Beach. To this extent the designation of this area as a Key Tourism Investment Site is understandable.

4. However, neither the Council, nor BPB (or anyone else) provided any evidence that continued investment in the existing facilities in this part of the resort is dependent on the designation of this area as a Key Tourism Investment Site.

5. A major justification for this Key Tourism Investment Site is to be found in the Resort Masterplan, but to my mind it is noteworthy that the redevelopment area envisaged in that document was more than twice as large as the area envisaged now. The reasons advanced for the designation in the Second Deposit Local Plan are contained in paragraphs 2.41 and 2.41a. Major investment here is seen as a catalyst for wider regeneration in the surrounding area creating a balance to tourist development and investment nearer the town centre. In particular it is seen as important that provision is made for the ongoing development and investment needed to continually refresh the appeal of the Pleasure Beach to ensure that it remains a major attraction drawing visitors to the town. The possibility of extending northwards is seen as an important contribution to achieving this so the present boundaries of the Pleasure Beach do not become an undue constraint on continuous renewal.

6. I have already concluded that there is no realistic prospect of being able to obtain a regional casino for this site within the foreseeable future. I have also taken the view that smaller “new” casinos should be nearer to the town centre, although any “old” casinos that either exist or have planning permission may be pursued. The net effect is that casinos need not and should not be mentioned in policy RR7.4. For my full reasoning on these matters see under policy RR6; I consider it is unnecessary to repeat my reasoning here. However, these conclusions have ramifications for this Key Tourism Investment Site and the plans for this area.

A Larger or Smaller Designation

7. At the Local Plan Inquiry BPB argued for a larger area to be designated as the Key Tourism Investment Site, albeit a smaller area than they identified in their original objection. They sought to justify this larger area in the following way:

(a) they wish to provide an integrated regional casino / hotel within the confines of an extended Pleasure Beach. BPB presented an outline scheme to the Local Plan Inquiry to show how this could be done and to demonstrate that more land is needed than is currently designated;

(b) in any event, they have been impressed by the success of their own recent hotel investment and want to provide more hotel accommodation on their own (extended) site;


Blackpool Local Plan Review – Inspector’s Report(c) there is no room for another new hotel within the existing Pleasure

Beach but a larger designated area to the north of Balmoral Road would make this possible;

(d) they are also concerned to provide more secure staff accommodation close to their site;

(e) at no point did BPB indicate that any part of the extra land to the north of Balmoral Road is needed to accommodate new “rides” or similar attractions.

8. As I have said above, the prospects for bringing a regional casino to this part of the resort are, at best, remote. My recommendations on policy RR6 formalise the situation as I see it but I consider this is true whether or not what I have recommended on policy RR6 is followed. As to a new hotel, whilst this may be desirable in principle in my view it does not provide an overwhelming case for extending the confines of the Pleasure Beach northwards. I say this because it is not clear why such a hotel has to be on land that is contiguous with the Pleasure Beach site, let alone to the north of it. If BPB wish to develop, own and operate hotels, it can pursue this ambition on other sites in the area.

9. The Council’s view of the BPB hotel/casino scheme presented to the Local Plan Inquiry was that it was insubstantial and not sufficiently worked up to provide a convincing case for an extended RR7.4 site. Little detailed examination lay behind the scheme and it provides no information on construction costs and viability. The Council is also unconvinced that there is not enough land within the existing Pleasure Beach for a new hotel, although on the basis of my site inspection it does seem to me the existing site is fully developed.

10.However, quite apart from the difference of view about the scheme put to the Local Plan Inquiry, what was revealed were far deeper differences on the reasons for wishing to designate a Key Tourism Investment Site north of Balmoral Road. The Council (as set out in the Local Plan) sees the main purpose of the designation as providing scope for more Pleasure Beach rides and improvements to the area’s environment. In addition RR7.4 included the possibility of a hotel (and casino). In contrast BPB sees the main purpose of the designation as the only way to achieve a hotel/casino development. They also wish to provide accommodation for their staff. They do not mention new rides in this area at all and oppose any suggestion in the Local Plan that land is needed to improve the local environment or public realm. In my view such contrasting priorities form a very poor and unsound basis for the RR7.4 designation north of Balmoral Road, whether extended to include all the land BPB want or not.

11. I would also point out that, if I were to recommend that a larger area is designated and this were to be advertised as a modification; further new objections must be anticipated. These would be likely to lead to another Local Plan Inquiry before this Local Plan could be adopted. This would throw the whole programme of Local Plan preparation into doubt to such an extent that the ability and willingness of the Council to proceed is by no means certain. The BPB aspirations are not, in my view, realistic.

12.Even as things are, with the extent of the RR7.4 designation proposed by the Council, several individual property owners argue that their properties should be left out of the designated area. They are concerned about uncertainty and blight and ultimately about the prospect of losing their homes and/or businesses. In my view, before a designation affecting individual property rights can be


Blackpool Local Plan Review – Inspector’s Reportconfirmed, a very compelling case has to be put forward. Such a case would necessarily demonstrate a unity of will and purpose shared between the Council and the only likely implementer of any proposals. As indicated above, this is singularly lacking in this instance.

13.As to whether a smaller area should be designated, there are objections from those affected seeking removal from the designated area. Businesses and residents in the area want to be left to develop and invest as they see fit. Particular objection is made to the possibility of compulsory purchase being used as those affected have all their capital tied up in their properties.

14. I have given some thought to whether just the frontage of Balmoral Road should be designated. This would to some extent reflect the fact that BPB have already purchased several properties in that street. However, there are still privately owned properties (and objectors) who would be affected. At the Local Plan Inquiry BPB’s stance was that an area smaller than the one they sought was of little benefit to them because it could not accommodate their expansion plans. In any event the basic differences between the BPB and the Council as to the purposes of designation remain. On balance, therefore, I am not inclined to recommend such a course of action.

15.However, this assessment also involves considering the position of the Gables Balmoral Hotel, to which I now turn.

The Gables Balmoral Hotel (Objector 254)

16.The Gables Balmoral Hotel argues for the smaller RR7.4 designation that was included in the First Deposit and have objected to the larger area identified in the Second Deposit. However, whilst supporting the Key Tourism Investment Site in principle, they have consistently opposed both the development of Flagstaff Gardens and any mention of the Council assisting with site assembly. Based on this and their objections relating to casinos, I draw the following conclusions as far as Gables Balmoral are concerned:

(a) this Objector has no ambitions to expand beyond their present site (unless the opportunity arises to do so by a purchase on the open market);

(b) they also do not see their site as contributing to the enlargement of the Pleasure Beach (again unless this arises from a sale on the open market);

(c) rather they wish to develop and improve their own site and do not want the possibility of some form of (small) casino ruled out;

(d) indeed in evidence they go further and say that a mixed use development including a (small) casino is essential to the viability of a hotel expansion on this site;

(e) they see the Key Tourism Investment Site as part of a carefully targeted improvement strategy for a very limited area that should not include the Pleasure Beach or Sandcastle for fear that the effect will be diluted;

17. It is clear that, like BPB, Gables Balmoral do not share the Council’s vision for this designation as set out in paragraphs 2.41 and 2.41a of the Local Plan.

18. I have already given my reasons for concluding that no allowance should be made for casinos (of any size) in this area. Apart from that, it is not clear what advantage this Objector envisages could be gained from the RR7.4


Blackpool Local Plan Review – Inspector’s Reportdesignation.

19. I therefore conclude that no modification arises as far as policy RR7.4 and this Objector are concerned.

Flagstaff Gardens

20.The Council takes the view that this matter is now resolved because in the Second Deposit the revised policy RR7.4 says that future proposals for this area should include proposals for the enhancement or replacement of existing public open space. However, I note that objections which specifically mentioned this open space have not been withdrawn and I do not imagine this will satisfy the remaining objectors, many of whom say they value the open space where it is. I also note that BPB object to that aspect of the revised policy and consider the replacement of open space would not be appropriate.

21.For my part, it is clear that the existing public open space is valued because of the number of objections that seek its retention. It is also clear, notwithstanding the lack of an audit of existing open spaces, that this is an area which is short of such facilities. For these two reasons it is impossible to regard the gardens as being surplus to requirements. Neither has any replacement or alternative been suggested to me and it is difficult to see how this could be found locally. Public open space is a locally scarce and valued resource such as current government guidance indicates should be protected from development.

22.For these reasons, and in the absence of an agreed and overriding need to develop this land, I conclude that Flagstaff Gardens should not be included in a Key Tourism Investment Site but should be designated as Protected Public Open Space under policy BH5.

23.Several objectors are very concerned by what they describe as “illegal trading” in Flagstaff Gardens. I have to admit that I have not seen or experienced this, so I am unsure whether by this they mean unlicensed trading in lawful goods or trading in illegal goods (such as drugs). Either way, in my view this is a matter for proper enforcement and not a Local Plan matter.

Improving the Public Realm

24.Quite apart from whether Flagstaff Gardens need to be replaced, there is a dispute between the Council and BPB as to whether policy RR7.4 and text need to refer to “improvements to the public realm” in this area. However, at the Local Plan Inquiry the Council accepted that this matter could be pursued under other policies whether or not it is referred to explicitly here.

25. I conclude there is no need for this matter to be mentioned in this policy, although I note that this was one of the reasons the Council had for this designation in the Local Plan.

Height Restrictions

26.Restrictions on the heights of any new buildings are subject to similar considerations. Whether or not this matter is explicitly referred to in policy RR7.4, the protection of residential (and other) amenity would be a legitimate concern here, as elsewhere, because of other policies in the Local Plan.

27. I conclude there is no need for this matter to be mentioned in this policy.

BPB Staff Accommodation

28. I deal with the issue of BPB staff accommodation under policy RR11 below.


Blackpool Local Plan Review – Inspector’s Report29.Suffice it say here that, in my view, the needs of BPB in this respect do not

provide a sufficiently strong argument for either designating or extending the RR7.4 Key Tourism Investment Site. Indeed, the vigour with which BPB pursued this aspect of their objections gave the impression that they were more interested in this matter than in the wider aims of regeneration and investment. This impression could have weakened my assessment of their case for extending the RR7.4 area had I not made the conscious effort to separate the two considerations.

30.Be that as it may, I take the view that, on the evidence available, the need to provide staff accommodation for BPB is not a sufficient reason to designate (or extend) an area for redevelopment (and possible compulsory purchase).

The Garage Court at the Southern End of Brighton Avenue

31.The Council agrees that the garages at the end of Brighton Avenue should be taken out of the area affected by policy RR7.4. This is the subject of PC12.

32.As there are no objections to this Proposed Change, I conclude that – whatever the future of the wider designation – this garage court should not be included in a designated Key Tourism Investment Site,

The Prioritisation of Key Tourism Investment Sites for Casinos

33.The Noble Organisation (Objector 370) wants changes to policy RR7.4 and the text that accompanies it to indicate that greater priority will be given to Key Tourism Investment Sites closer to the town centre. Conversely BPB (Objector 248) argued that, at least as far as the location of regional casinos is concerned, the Local Plan should express no priority between the various Key Tourism Investment Sites.

34. I consider that I have already dealt elsewhere with the substantive issues that arise from these objections. To summarise:

as far as regional casinos are concerned, I agree with the Objector 370 and for this reason I am recommending that these should not be mentioned in relation to this site;

as far as other tourist attractions are concerned, I have recommended some modifications that indicate where in the Resort Core attractions should be allowed but I am not recommending that priority should necessarily be given to sites closer to the town centre.

35. I conclude that no further modifications arise from these objections.

Overall Conclusions on RR7.4

36.My overall conclusions on this policy are not straightforward. Having already determined that this is not a suitable site to be allocated for casino development it seems to me that one of the main reasons why the Council and others wanted this designation no longer applies. Beyond this, there is little agreement between the Council and the most likely large investors in the area (BPB and Gables Balmoral) as to what the designation ought to achieve. Indeed, the idea of extending the Pleasure Beach to the north, whether for a new BPB hotel or for rides is objected to by many and not supported by BPB unless a much larger area is included. Gables Balmoral support RR7.4 in principle but only for their own purposes and not to facilitate BPB expansion onto their land.

37. I accept that the wider designated area (as in the Second Deposit) has seen


Blackpool Local Plan Review – Inspector’s Reportmuch of the resort’s investment in recent years but it does not seem to me that there is any prospect of future investment either being stimulated by this policy or being dependent on it. A policy such as this should be justified on future expectations rather than awarded as a prize for past performance. In the circumstances where there are many legitimate and forceful objections to the policy without any clear, agreed and compelling reasons for including it in the Local Plan, I have come to doubt whether there is any useful purpose in keeping this policy in the Local Plan.

38.On balance, therefore, I conclude that policy RR7.4 should be deleted from the Local Plan.

Recommendations39. I recommend that policy RR7.4 is deleted from the Local Plan.40. I recommend that Flagstaff Gardens are designated as Protected Public

Open Space under policy BH5. 41. I recommend the PC12 and PC13 are not pursued.

Officers Comments

The reasons for recommending deletion of Site RR7.4 are fully accepted and in the context of its deletion it is logical that the designation of Flagstaff Gardens as Public Open Space in the existing adopted local plan be retained in the new local plan. The commitment in Policy RR9 to the preparation of a Resort Neighbourhood Area Action Plan for the wider South Beach Area will provide an opportunity to review the development needs and opportunities of this area working closely with the local business and residential community and other stakeholders.

Officer Recommendations The Inspector’s recommendations (39 –41) are accepted and accordingly:

Policy RR7.4 is deleted from the plan

The Flagstaff Gardens are designated as protected open space under Policy BH5

2.19 Reshaping the Resort Policy RR7AThe Objection254/10 The Gables Balmoral Hotel (Blackpool) Limited

Summary of the ObjectionThis policy should recognise and allow for the possibility that visitor attractions and new accommodation can be provided by changes of use provided such changes do not harm the amenity of the area. There should be no mention of the Council assisting site assembly (254)

Inspector’s Reasoning and Conclusions 1. When I considered objections to policy RR7, I conclude that policy RR7A

should have an additional clause indicating that new attractions should reinforce the existing concentrations of such uses rather than leading to a dispersed distribution of attractions.


Blackpool Local Plan Review – Inspector’s Report2. As far as objection 254/10 is concerned, the Council do not appear to oppose it,

although this could be because it may be based on a misunderstanding. It is, in my reading of planning law, the case that “development” includes “material changes of use”. It is therefore not necessary to add a reference to changes of use to the policy because these are already included in the term “development”. However, I see no harm in adding “including changes of use” after the first two words of the policy to make this clear.

3. I consider that the suggestion that any proposals should not harm the amenity of the area is a useful one. Indeed I would go further and refer to the character and appearance of the area as well to ensure that changes of use relate to existing buildings and uses sympathetically.

4. As to possible assistance in site assembly, this is referred to in the text rather than the policy, which is a practice I have been accepting in the context of similar objections to other parts of the Local Plan. However, in this instance I consider it would be wise to say that the Council “may” assist rather than “will” assist.

5. I conclude that the above modifications should be made to the policy and text.

Recommendations6. NB: I have already recommended a modification to this policy arising from

my consideration of an objection to policy RR7. I recommend that policy RR7A has an additional clause indicating that new attractions should “reinforce the existing concentrations of such uses rather than leading to a dispersed distribution of attractions”.

7. In addition I recommend that the policy starts “Development Proposals, including changes of use, to introduce . . . ”.

8. I recommend that a new clause is added to the policy to say that proposals should “maintain the amenity, character and appearance of the area”.

9. I recommend that the last sentence in paragraph 2.43e should say “It may also provide assistance with site assembly, where required, to facilitate such redevelopment.”

Officer Comments

The Inspector’s recommendations are considered should be accepted, subject to a minor amendment. Given the focus on the regeneration of the appearance, format and content of Blackpool’s promenade shop window seafront, it is considered misleading to express support for proposals which “maintain” its amenity, character and appearance. It is considered use of “enhance” rather than “maintain” is therefore more accurate and appropriate.


The Inspector’s recommendations (6), (7) and (8) are accepted, subject to the use of “enhance” instead of “maintain” in the recommended additional clause (e). Policy RR7.4 is accordingly amended to state:

Development Proposals, including changes of use, to introduce contemporary new Visitor Attractions, Accommodation and Facilities on the Promenade frontage within the Resort Core will be permitted and encouraged provided that they;



a) comprise high quality buildings of an appropriate scale b) provide an “active” frontage to the Promenade.

c) protect and enhance key pedestrian routes into the adjoining Resort Neighbourhoods.

d) reinforce the existing concentrations of such uses rather than leading to a dispersed distribution of attractions.

e) enhance the amenity, character and appearance of the area.

Proposals must be supported by detailed assessments of all significant impacts associated with the proposed development.

The Inspector’s recommendation (9) is accepted and accordingly the last sentence in paragraph 2.43e is amended to state “It may also provide assistance with site assembly, where required, to facilitate such redevelopment.”

2.20 Reshaping the Resort Paragraph 2.35The Objection255/3 Beverley Moy

Summary of the ObjectionA reference to the importance of large sporting facilities should be included in paragraph 2.35. (255)

Inspector’s Reasoning and Conclusions 1. The Objector believes that a major sporting facility or arena could be a

significant tourist attraction for the town. She also says that the town’s largest sporting venue in the past (the Derby Baths) was closed and has not been replaced by a facility of equivalent status. She also feels that opportunities to attract such facilities have been missed in the past.

2. The Council respond that policy RR7 is concerned with major investment sites and that it would be too limiting to restrict any of these to sporting arenas. They see no need for the Local Plan to be modified. The Council acknowledges that more work is needed on facilities to serve Blackpool residents and their sporting needs but this is not what this part of the Local Plan is about.

3. I accept that providing major sporting venues as tourist attractions and meeting the needs of local residents are distinct issues, even though there may be some overlap between the two. Also, whilst some sports may be able to share venues with other sports and activities (for example basket ball, tennis, indoor athletics) others need purpose built facilities (swimming, ice skating).

4. The sports that are able to share may be able to use the conference / exhibition centre proposed in the Local Plan and to this extent may be catered for. However, I see no need to specify in the Local Plan which sports should be accommodated as this is a matter that will need to be addressed in the detailed design of any building. It is a question of the design taking into account the constraints and costs imposed by each potential user and weighing these against any additional revenue that would be generated.

5. As far as sports that need specialised accommodation are concerned, I have no information at all about the sort of site that would be needed, potential funding or likely viability. Without a detailed study to support any proposals I consider it


Blackpool Local Plan Review – Inspector’s Reportwould be most unwise for the Local Plan to make any specific commitments of this sort, especially if it meant identifying (and sterilising) a large site.

6. Put simply, the objection suggests provision should be made for a large and important investment but this is not supported by any research or information. Even if the Objector is right that a sports arena could be an important part of Blackpool’s tourism base, there is insufficient substance and commitment to a scheme for it to be included in this Local Plan review.


Recommendations8. I recommend no modification in response to this objection.

Officers Recommendation The Inspector’s recommendation is accepted.

2.21 Reshaping the Resort Paragraph 2.36The Objection326/5 CPRE (Lancashire Branch)

Summary of the ObjectionAlter paragraph 2.36 to say that Resort Masterplanning will consider local needs and opportunities (as indicated in PPG17), will make best use of previously developed sites at sustainable locations and that all stages of the production of the Resort Masterplanning are open and transparent. (326)

Inspector’s Reasoning and Conclusions 1. This paragraph was altered in the Second Deposit so that it reports the results

of the Masterplanning exercise rather than anticipates them. To this extent the objection has been overtaken by events.

2. However, the Council is at pains to point out that this part of the plan is concerned with tourism development and that PPG17 is therefore not directly relevant. Whilst this is true, I also note that – by focussing the development proposals in the centre of the urban area – the Local Plan is doing what this Objector wants as far as the location of development is concerned. As to establishing the need for these proposals, it is not entirely clear how this can be done in a fluid and essentially competitive situation.

3. I conclude that no (further) changes to the Local Plan arise from this objection.

Recommendations4. I recommend no modification to the Local Plan in response to objection

326/5.

Officers Recommendations The Inspector’s recommendation is accepted.




Summary of the ObjectionThe Local Plan should identify and explore other options for the Central Station site. A casino/hotel on this site is not welcome. Any disposal must be on the most advantageous terms for the town both now and in the future. Full open market value must be seen to be achieved through competition. Failing this BBC should carry out redevelopment itself. (277)

Inspector’s Reasoning and Conclusions 1. In the Second Deposit the last sentence (which referred to a casino hotel on the

Central Station site) was deleted. In a narrow sense this meets this objection.

2. However, in a wider sense this may be more of an apparent victory than a real one because the Council still sees this site as suitable location for hotel(s) and casino(s) even though it says that the primary use of this site will be as a national conference/exhibition centre. I discuss the opposition to a mixture of uses on this site elsewhere and come to the conclusion that there is no planning objection to a mixed development on this site.

3. In addition the Objector seems to be as concerned about who will carry out any redevelopment and the price of the land as with what the site will be used for. In my view these are not Local Plan matters.

4. I therefore conclude that no modification arises from this objection.


objection.Officers Recommendations The Inspector’s recommendation is accepted.

2.23 Reshaping the Resort Policy RR8The Objection254/4 The Gables Balmoral Hotel (Blackpool) Limited

Summary of the ObjectionDelete "elsewhere" in title and "other than as provided for by Policy RR7" in line three. Delete the reference to site assembly. Delete “elsewhere” in line 4 of paragraph 2.45 (254)

Inspector’s Reasoning and Conclusions 1. This policy and the accompanying text were deleted in the Second Deposit. I

see no reason to consider this objection further.


objection. Officers Recommendations The Inspector’s recommendation is accepted.



2.24 Reshaping the Resort Policy RR9The Objections001/1 Mr Martin Charles Derek Riley (Conditionally Withdrawn)

017/1 Mr Kenneth Sheldon

032/1 Mrs Susan Sheldon

142/1 Mr N A Thomas

194/7 Government Office for the North West (First Deposit)

194/65 Government Office for the North West (Second Deposit)

(Conditionally Withdrawn in part in view of PC88)

240/2 Mr and Mrs A J Coundley

254/5 The Gables Balmoral Hotel (Blackpool) Limited

297/1 Mr Geoff Brankston

307/1 Mr Brian McAllister

337/1 Mrs J L Thomas

Summary of the ObjectionsSupport for the general approach of the Local Plan but concerned that regeneration could force up rents and make central accommodation too expensive. If rents and property prices spiral upwards, there should be safeguards so that local residents do not have to leave their homes or Blackpool. (001)

The boundary of the Resort Neighbourhood on Hornby Road should be extended from Regent Road to the junction with Park Road. (017) (032) (First Deposit)

The Resort Neighbourhood area from Gynn Square northwards should cover only the Promenade. The area behind contains many residential properties and allowing residential conversions would lead to an improvement of the area’s appearance and amenity. There is a surplus of holiday accommodation in the town, so the area of holiday accommodation needs to contract not expand. The Resort Core is shifting southwards, making this area more remote from holiday attractions. The area contains many under-used properties that should be encouraged to convert to residential use, as some are doing without planning permission. The area removed from the Resort Neighbourhood could become a buffer zone within which planning permission for either hotel or private accommodation would not be refused because of the proposed use but would be assessed only on the basis of the quality of accommodation proposed. (142) (337)

Move the last part of the policy referring to tackling poor existing sites/premises to the reasoned justification and make clear that supplementary planning guidance cannot amend the Local Plan and its polices. (194)

There should be less restriction on changing the use of holiday accommodation to residential use, especially in areas that are residential in character or where the property has residential neighbours. Some properties are being converted without the benefit of planning permission. Thus, such restrictions either lead to properties being underused or to unfairness. (Inspector’s note: when summarising this objection the Council saw it as a request that the Objectors’ property (16a Empress Drive) should be removed from the Resort Neighbourhood. In my view the objection goes further than this, although the other matters are dealt with under policy RR11) (240)

Delete the third paragraph of the policy and replace it with: "The Council will encourage the improvement of the Wider Resort Neighbourhood by encouraging developments which address the condition of existing sites and premises which are seriously detrimental to the amenity and enjoyment of visitors or residents. Also, delete paragraph 2.52 of the explanatory text because of the threat of Compulsory Purchase to secure improvements as this is unhelpful. (254)

Ours is a holiday business (15 – 17 Lord Street) and should be in an RR9 not an SR3 area. (297) (307)



Proposed ChangesPC15 suggests that the last two paragraphs in the policy should be deleted and incorporated in revised form in paragraph 2.53.

(As a result of PC15 Objector 194 has Conditionally Withdrawn their objection to the policy. They maintained their objection to paragraph 2.53.)

PC88 deletes the last part of PC15, which removes the reference to Supplementary Planning Guidance)

Objections to the Proposed Changes 194/79 Government Office for the North West (First Proposed Changes)

194/80 Government Office for the North West (Second Proposed Changes)

Summary of the Objections to the Proposed ChangeAs a result of PC15 Objector 194 has Conditionally Withdrawn their objection to the policy. They maintained their objection that the revised paragraph 2.53 does not go far enough in explaining the status and limitations of Neighbourhood Planning Guidance.)

Inspector’s Reasoning and Conclusions The Status of Neighbourhood Planning Guidance (Objector 194)

1. There have been several exchanges between the parties to try and resolve the objections from the Government Office. My understanding of the paper work is that the objection was partly met by changes in the Second Deposit and again in PC15. Now the Council says it is prepared not to add to paragraph 2.53 as suggested in PC15 but to use the abbreviated version indicated in PC88. This appears to me to meet the objections.

2. I conclude that PC15, as amended by PC88, should be advertised as a modification to the Local Plan.

Steps to Improve Premises that are Seriously Detrimental to the Area (Objector 254)

3. This Objector consistently opposes intervention by the Council to secure site assembly or improvements to the environment, especially by compulsory purchase. In some respects this repeats the position of the Government Office and goes somewhat further. GONW says that compulsory purchase and site assembly should not be referred to in Local Plan policies but may be referred to in the text of the Local Plan. This appears to me to be a suitable compromise (and more importantly a correct interpretation of the law and current guidance).

4. Be that as it may, the situation in some of the Resort Neighbourhoods and the negative impact of some sites and uses is such that some form of intervention may be justified if any real environmental improvement is to be achieved. In extreme cases compulsory purchase may be the only way to secure improvements. Thus I do not agree entirely with this Objector.

5. In this particular case, the net effect of the changes in the Second Deposit and now proposed in PC15 (as amended by PC88) removes the contentious material from the policy and revises the text in a way that I consider to be reasonable and justified. This Objector may regard the reference to compulsory purchase as “unhelpful” but in my view it is justified in this context.

6. I conclude that no further modifications arise from this objection.

Rents and Prices (Objector 001)


Blackpool Local Plan Review – Inspector’s Report7. This Objector has, I think, identified a conundrum. At present the town is rather

run-down so property values and rents are low. If regeneration is successful then values and rents could rise and this could harm some local people.

8. The Council says that property values and rents are outside its control because they are determined by market forces. But what the Local Plan can do (and does in policy HN9) is to attempt to secure a supply of affordable housing. These are, perhaps, the sort of safeguard that the Objector has in mind. In any event it is all the Local Plan can offer as reassurance. In the last analysis, however, such fears should not lead the community to turn its back on regeneration. There is something worse than an upward spiral and that is a downward spiral.

9. In any event I note that this objection was conditionally withdrawn as a result of the Second Deposit and there have been no further submissions since then. I surmise that the Objector was satisfied with the answer he received from the Council at the time. I conclude that no further modification to the Local Plan is needed in response to this objection.

Hornby Road (Objectors 017 and 032)

10.The boundary of the Resort Neighbourhood on Hornby Road was extended to the junction with Park Road in the Second Deposit (see map RR9-12PM4). I consider this meets objections 017/1 and 032/1 and conclude no (further) modification is required.

North of Gynn Square (Objector 142, 240 and 337)

11.Policy RR9 lists the Resort Neighbourhoods and sets out the general intention to protect and improve them both as holiday and residential areas, with the Council playing an active role in neighbourhood improvement. However, to understand the full implications of inclusion in a Resort Neighbourhood one also has to look at policy RR11 (see below) in which the policies governing changes of use (especially from holiday use to residential) are set out.

12.My reading of the Local Plan and other evidence is that, even though there is scope for new large-scale, high-quality hotel development, the decline in the amount of small-scale more traditional holiday accommodation is expected to continue. Thus a reduction in the extent of the “holiday accommodation areas” included in Resort Neighbourhoods would be consistent with both the expected trends and the strategy for the resort. However, as far as one can judge by external appearances, the area under discussion here has some relatively large traditional hotels of a higher standard than is sometimes found elsewhere.

13.There is no dispute that the sea front should be in the Resort Neighbourhood. However, I note that in the Second Deposit the extent of the resort designation to the north as far as Bispham (including a long stretch of the sea front) has been deleted. Thus the extent of the Resort Neighbourhood north of Gynn Square has already been considerably reduced by the deletion of all the area north of a point midway between Wolverton Avenue and Lowther Avenue. Whilst this is in the spirit of what these objectors are seeking, it does not meet their particular complaints which are about the area inland of The Promenade to the south of the area that has been deleted.

14.The area in dispute is mixed with hotels and homes as well as some holiday flats, although having seen the area in winter I may have underestimated the full extent of the holiday uses. Be that as it may, the mixture is a complex one.


Blackpool Local Plan Review – Inspector’s ReportSome streets, or parts of streets, appear to be almost entirely residential and other streets are predominantly in holiday uses (hotels and/or holiday flats), whilst on other frontages the mixture is very fine grained with hotels and homes intermixed. For example, it seems to me that the west end of King George Avenue is predominantly in hotel use and the east end of the street is residential. The same is true of Empress Drive.

15.The Council takes the view that this is an established and traditional location for hotels. I accept this is true. But the objectors are also correct to say that some of the area is predominantly residential in character and appearance. The Council says the area is conveniently located for the town centre and holiday attractions whilst the objectors say the main focus of the resort is shifting southwards and away from this area.

16.The Council has defined a clear cut (almost rectangular) block or area for designation. Whilst this has the merits of simplicity and clarity, it fails to reflect the finer grained distributions within the area. I consider that a re-survey of the area (in summer or using rating data) could produce a designated area that more accurately reflected the existing distribution of uses in the area, especially as between hotels and residential properties. (The holiday flats seem to me to be more of an intermediate use in terms of the impact that any change of use would have.) Such a resurvey and redefinition of the area would be likely to produce a less regular boundary on the inland side of the designated area but, in my view, this would be a fairer basis on which to apply the policies.

17. I conclude the Council should resurvey this area with a view to defining a smaller Resort Neighbourhood north of Gynn Square with a less regular boundary. A more detailed RR9 designation in this area would more accurately reflect the current distribution of hotels and dwellings in the area.

18. I recognise that this may not satisfy the particular concerns of these objectors. They appear to me to live in residential properties in frontages that are predominantly made up of hotels – so they are likely to be retained in even a reduced Resort Neighbourhood. However, I consider that the wholesale deletion of the Resort Neighbourhood in this area could lead to many objections from hoteliers who would have an opposite point of view.

Lord Street (Objectors 297 and 307)

19. I discuss the future of the holiday accommodation at the lower end of Lord Street in greater detail under policy SR3. I accept that, in principle, this is a suitable location for hotels. I also note the investment and effort the objectors have put into making their hotel a success. Nevertheless I conclude that the property is rightly included in the SR3 redevelopment area.

20.This being the case I consider it would not be appropriate to include the objection site in the adjoining Resort Neighbourhood. To do so could prejudice the proper evolution and design of the wider SR3 redevelopment.


Recommendations22. I recommend that PC15, as amended by PC88, should be advertised as a

modification to the Local Plan.23. I recommend the Council resurvey the area north of Gynn Square with a


Blackpool Local Plan Review – Inspector’s Reportview to defining a smaller Resort Neighbourhood area with a less regular boundary that more accurately reflects the current distribution of hotels and dwellings in this area.

24.Otherwise I recommend no modification to the Local Plan in response to these objections.

Officers Comments

The recommendation for resurvey of the area north of the Gynn is made in the context of specific objections from property owners seeking less restrictions on changes of use from holiday accommodation to residential use.

It is considered that this would conflict with the Council’s approach taken throughout the rest of the plan area in the absence of any wider review of Policy RR11, where there have been very few objections to the boundaries of the Resort Neighbourhoods.

This in your officers view is because:

The past designation of more precise “main holiday area” boundaries in the adopted plan (which were then subject to major physical change over the plan period) led to major controversies and debate about whether properties should be in or out of the holiday area.

The control of changes of use, which was in the past perceived to be more black and white (i.e. safeguarding holiday uses within the main holiday area, allowing change outside), has long since ceased to be the case. It is generally now accepted that the market will to a large extent determine the viability and continued level of holiday accommodation that can be supported in the Plan.

In these terms the purpose of Policy RR9 and RR11 is to provide the policy background for controlling where change most occurs and concentrating hotel uses in the most viable and appropriate locations – whilst allowing flexibility for change of use in other locations.

Detailed guidance set out in the Council’s SPG10 and which now forms the basis of Policy RR11 assists determination of whether a change of use is appropriate..

The effect of the guidance is that whether or not a change of use to residential is permissible is not determined by whether a property is within or outside the Resort Neighbourhoods, but by the detailed application of the criteria set out in the policy.

The flexibility now sought by some objectors north of the Gynn (and a minority of other objections) thus already exists within all the resort neighbourhoods, having full regard to the existing pattern of uses.

The Council has found this approach to be realistic, flexible and generally supported, including at appeal, removing controversy and not seeking to over-clarify a changing land use context.

Fundamentally, the whole basis of the drawing of the Resort Neighbourhood boundaries has been to include all areas that are the focus of ‘resort’ influence by virtue of their location within the resort neighbourhood – whether they are in residential, holiday or commercial use. The intent is that issues of traffic, parking, environment, the decline in holiday accommodation and future resort proposals do not just affect people in the more dominant holiday accommodation streets within resort neighbourhoods, but also affect people in adjoining residential areas.

The Council considers the redrawing of the boundaries of the area north of the Gynn (and in the longer term other areas) would conflict with the basic approach.

Officer Recommendations Inspector’s recommendations (22) is accepted that PC15, as amended by PC88,


Blackpool Local Plan Review – Inspector’s Reportshould be advertised as a modification to the Local Plan:

PC15, as amended by PC88:

‘Neighbourhood Planning Guidance (NPG) will be developed as a framework for investment and development to make holiday areas and adjoining mixed business/residential communities more attractive as places to visit and in which to live and work.

They will include proposals to secure the improvement, redevelopment or change of use of sites or premises, which by virtue of their use, condition or appearance are an obstacle to comprehensive improvement of the neighbourhood.’

The two deleted paragraphs can be rationalised and incorporated into an amended bullet point three in paragraph 2.53 as follows:

‘For securing the improvement, redevelopment or change of use of sites or premises, action where their condition and appearance or use of property is a deterrent to visitors and to investment

Additional text added to the end of paragraph 2.53 following the bullet points:

‘Where Neighbourhood Planning Guidance brings forward detailed policies and proposals, it will be prepared as a proposed alteration to the Local Plan.’

Inspector’s recommendation (23) that the Council resurvey the area north of Gynn Square with a view to redefining a smaller Resort Neighbourhood area is not accepted.

Inspector’s recommendation (24) is accepted

2.25 Reshaping the Resort Paragraph 2.50Paragraph 2.51

The Objections297/ 2 / 3 Mr Geoff Brankston

307/ 2 / 3 Mr Brian McAllister

Summary of the ObjectionsMove the Objector's property out of the SR3 area into a resort neighbourhood so that they can benefit as other holiday providers will do. (15 – 17 Lord Street) (297), (307)

Inspector’s Reasoning and Conclusions 1. I discuss the future of the holiday accommodation at the lower end of Lord

Street in greater detail under policy SR3. I accept that, in principle, this is a suitable location for hotels. I also note the investment and effort the objectors have put into making their hotel a success. Nevertheless I conclude that the property is rightly included in the SR3 redevelopment area.

2. This being the case I consider it would not be appropriate to include the objection site in the adjoining Resort Neighbourhood. To do so could prejudice the proper evolution and design of the wider SR3 redevelopment.



Blackpool Local Plan Review – Inspector’s ReportRecommendation

4. I recommend no modification to the Local Plan in response to these objections.


2.26 Reshaping the Resort Policy RR10The Objections295/3 MacKeith Dickinson & Partners Ltd



Summary of the ObjectionsThe policy is supported but the text should contain a statement that grants will be available for the improvement of tourist accommodation to create “boutique hotels”. These would improve the attractiveness of the resort. (295)

Move the Objector's property out of the SR3 area and into a Resort Neighbourhood so that they can benefit from the action plans. (15 – 17 Lord Street) (297) (307)

Inspector’s Reasoning and Conclusions Objector 295 (MacKeith Dickinson & Partners)

1. Policy RR10 was deleted in the Second Deposit but the idea of Neighbourhood Plans is retained in the form of Neighbourhood Planning Guidance in the revised policy RR9. I consider that the objection is still relevant.

2. In response to this objection the Council says that grants may have a role to play in securing comprehensive improvements in the Resort Neighbourhoods but as yet there are no funding arrangements in place.

3. This being the case it would be irresponsible to refer to these in the Local Plan. I conclude that this should not be done.

Objectors 297, 307 (Mr Brankston, Mr McAllister) (15 – 17 Lord Street)


5. This being the case I consider it would not be appropriate to include the objection site in the adjoining Resort Neighbourhood. To do so could prejudice the proper evolution and design of the wider SR3 redevelopment.


Recommendations7. I recommend no modification to the Local Plan in response to objections

295/3, 297/4 and 307/4.Officers Recommendations




2.27 Reshaping the Resort Paragraph 2.53The Objection195/1 Blackpool Combined Association

Summary of the ObjectionParagraph 2.53 should say that action will be taken to remove back alley garage type workshops, relocating these small businesses to more suitable premises outside the holiday neighbourhoods. (195)

Inspector’s Reasoning and Conclusions 1. The policy in the Local Plan to which this objection relates was deleted in the

Second Deposit. However, the idea of detailed programmes for the improvement of Resort Neighbourhoods is retained.

2. The original objection wanted action taken to remove back alley type workshops and the relocation of these small businesses away from Resort Neighbourhoods. In further submissions the Objector moved on to suggest that back alleys should be gated to prevent crime, noise, tipping and unauthorised vehicular access.

3. The problem with both these ideas is that they may be appropriate in some cases and situations but not in others. The Local Plan cannot therefore include a blanket policy saying that all businesses in garages will be moved or that all back alleys should be gated. Neither would it be appropriate for the Local Plan to go into detail by identifying individual small businesses that should be moved or particular alleys that should have gates. Cases such as this need to be examined and decided according to the detailed circumstances of each site and activity. In fact the Council is not averse to back alley gates where these are agreed by the owners and police but says it is inappropriate to include this in the Local Plan.

4. I accept that on occasions there would be benefits arising form these suggestions but the most the Local Plan should do, in my opinion, is set out the areas that will be subject to investigation and indicate the broad direction in which any future work will go.

5. I conclude that the Local Plan should not be changed in response to this objection.


195/1.

Officers RecommendationThe Inspector’s recommendation is accepted



2.28 Reshaping the Resort Policy RR11The Objections189/5 McCarthy and Stone (Developments) Limited

195/2 Blackpool Combined Association

206/2 C J Blackwell (Conditionally Withdrawn)

240/1 Mr and Mrs A J Coundley

248/7 Blackpool Pleasure Beach

253/3 / 10 Kensington Developments Ltd

254/6 The Gables Balmoral Hotel (Blackpool) Limited

294/1 Mr and Mrs V W & P Hughes




334/2 A McInerney (Conditionally Withdrawn)

Summary of the ObjectionsEconomic forces indicate that there is a reduced demand for holiday accommodation and PPG3 says the best use should be made of urban sites. Policy RR11 ignores these influences. The policy is therefore objected to in principle because it could frustrate the recycling of urban sites. If the policy is to be retained it should be reworded as: “The change of use or redevelopment of holiday accommodation within the Borough of Blackpool will not be permitted unless evidence exists to show that the current use is no longer a viable proposition, there is an oversupply of such accommodation in the Borough or the new use will overcome clear social, economic or environmental problems associated with the current use.” (189)

There should be greater flexibility for accommodation providers on the periphery of the Resort Neighbourhoods to revert to single private dwellings but with controls to protect against multiple-occupation or subletting. But on most of the Promenade changes of use from holiday accommodation to residential should only be allowed where the proposed use is of a very high standard. Even so, this should not to be allowed between Warley Road to the North and the Solarium to the South. (195)

Paragraph 2.55: new accommodation should be on a 'knock-for-knock' basis, with the removal of low grade bed stock. New hotels should not be sandwiched into small spaces and adequate land should be acquired to encourage open space and visual enhancement. There is a risk that those in unviable businesses will be trapped if conversions to residential use are not allowed. (195)

(Numbers 3, 9-11, 15-17) Lord Street should not be excluded from the Resort Neighbourhood. Exclusion causes uncertainty and hardship. (206) (297) (307) (334)

There should be less restriction on changing the use of holiday accommodation to residential use, especially in areas that are residential in character or where the property has residential neighbours. Some properties are being converted without the benefit of planning permission. Thus, such restrictions either lead to properties being under-used or to unfairness. (The site-specific aspects of this objection – relating to the Objectors’ property at 16a Empress Drive – are dealt with under policy RR9) (240)

There is a need for staff accommodation in connection with the Pleasure Beach. The policy should be amended so that dedicated staff accommodation for employees in the tourism industry can be provided close to the Pleasure Beach and in the Resort Core (but especially in South Shore, Balmoral Road and Osborne Road). Policy RR11 should be amended to allow existing holiday accommodation to be converted to staff accommodation for Pleasure Beach staff. (248)

Policy RR11 should be deleted and replaced by policies supporting and promoting Blackpool's holiday accommodation base. The loss of (all) holiday accommodation should be resisted. (253)

The test that the holiday use is no longer viable is too onerous and is likely to frustrate area improvements. Delete from the policy: "Where change of use of residential is proposed in or on the edge of an area of wholly or predominantly holiday accommodation, or anywhere on the Promenade frontage, planning permission will not be granted unless the applicant can also provide evidence


Blackpool Local Plan Review – Inspector’s Reportdemonstrating that there is no viable future for the property in holiday accommodation use."(254) (295)

Delete paragraph 2.57 from the explanatory text. (254) (295)

Reconsider seeking the removal of extensions as a condition of approval. (295)

Inspector’s Reasoning and Conclusions Restrictions on Conversions and Changes of Use

(Objectors 189, 195, 240, 254, 295 want less restriction)

(but Objector 253 wants more)

1. I consider this to be one of the most difficult issues to arise in my consideration of this Local Plan. This is especially so because many relatively small premises and businesses are involved that represent the owners’ livelihood, home and entire stock of capital. People can become locked into unviable situations with grave consequences for themselves and unfortunate effects on the wider area. It is also the case that decisions on one site can affect others nearby and that the cumulative impact of individual decisions can be considerable.

2. One issue that arises is that of the definition of the Resort Neighbourhood areas. This is a matter I have addressed in part under policy RR9 because that is where objections were made to the extent of one of the Resort Neighbourhoods. But Objector 195 raises the issue here also.

3. In general there seems to be an acceptance that the demand for (and viability of) small scale holiday providers is in decline and that it is realistic and prudent to plan for continued contraction in this sector. (I acknowledge this may not be the universal view but it is the view I, at least, have come to.) This being the case it would seem sensible for the areas in which changes of use away from holiday accommodation will be constrained should also shrink. I believe this is the route the Council has been travelling since the First Deposit, although not far or fast enough for some objectors. However, it is not for me to review all the boundaries and I have only done so where there is an objection (north of Gynn Square). In that instance I think there is scope for some contraction.

4. At the moment policy RR11 imposes two levels of control on changes of use away from holiday accommodation: the Promenade (very strict control) and the rest of the Resort Neighbourhoods (less strict). Objector 195 would want to go further by introducing a third area, suggesting that “on the fringe” an even more relaxed attitude to changes of use would be appropriate. In principle I see merit in this suggestion but in practice I am not in a position to do the necessary survey work to produce usable definitions of the areas where a less strict approach would be applied.

5. However, I consider the idea of differentiating the level of control on changes of use within the Resort Neighbourhoods is worthy of exploration in the longer term. At the moment the Council has defined Resort Neighbourhoods and is using these areas as the basis for two policies: deciding where changes of use may be opposed and deciding where action is needed to improve the environment for residents and the holiday trade alike. I see no necessity for both these polices to rely on the same boundaries. Whether or not the Resort Neighbourhoods are retained as they are for the purposes of planning environmental and other improvements, a more restricted set of locations could be defined where changes of use away from holiday accommodation would be controlled. This could take the form of a boundary on the Proposals Map or a


Blackpool Local Plan Review – Inspector’s Reportlist of streets.

6. In recommending that such an approach be explored, I am not insistent that it is included in modifications to this Local Plan, for several reasons:

(a) this view is based on considering a small number of objections;

(b) it would involve a lot of work that could delay adopting the Local Plan;

(c) it might also give rise to a lot of objections that could delay adopting the Local Plan;

(d) it is an idea that warrants extensive discussion before it is introduced.

7. An alternative approach (but not one suggested by any objector) could be to use a size threshold to determine the level of control. Small hotels may often be easier to convert to residential accommodation than large ones and may also be the most vulnerable economically. I observe that the areas with large hotels, including the seafront, also often appear the most prosperous holiday areas.

8. In the meantime I am of the view that in future decisions as to where the Resort Neighbourhood boundaries should be; smaller areas should be preferred. However, in the absence of objections to this effect it is not a matter that I can pursue in this review of the Local Plan. As I have said, this is what I am recommending north of Gynn Square.

9. I note that the Council says that “Resort Neighbourhoods are intended to be drawn more widely than the Main Holiday Areas in the adopted Local Plan to encompass neighbouring mixed use streets”. I suppose that what I am saying is to doubt the wisdom of this at least as far as applying policy RR11 is concerned, although it may be appropriate in relation to policy RR9.

10.As to the criteria for assessing changes of use from holiday accommodation to residential use, some objectors suggest these should be less inhibiting. For example, Objector 189 takes this view but, whilst I generally sympathise with what they say, I think their suggested rewording is too sweeping because it fails to differentiate between the Promenade and the rest of the Resort Neighbourhoods. Two other objectors take issue with paragraph 2.57 and the imposition of a “viability test” to show that a property is no longer suitable for holiday accommodation. This arises in two situations in the policy (as well as in paragraphs 2.57 and 2.57a):

in part (B) of the policy as far as the Promenade is concerned;

in part (A) of the policy, elsewhere in Resort Neighbourhoods in areas of concentrated holiday accommodation.

11.As far as the Promenade is concerned, I accept that special considerations apply, although as worded the policy is not entirely clear whether this applies to the whole of the Promenade or just to those parts of it within Resort Neighbourhoods. (Paragraph 2.57a suggests the former.) I consider this should be clarified by modifying the first part of part (B) of the policy to read: “The change of use or redevelopment of holiday accommodation for other uses on the parts of the Promenade that are within the Resort Neighbourhoods will only be permitted: . . . .”. A consequential change to paragraph 2.57a will also be needed.

12.As to part (A) of the policy, which applies to areas behind the Promenade where there are concentrations of holiday accommodation, it seems to me that the


Blackpool Local Plan Review – Inspector’s Reportcriteria in (i), (ii) and (iii) already protect the character of the area and that an additional test of viability will often be unduly onerous and unnecessary. Paragraph 2.57 should also be deleted.

13.As to the part of the policy that may require hotel extensions to be removed when a conversion is being undertaken, it seems to me that this is entirely reasonable and necessary given the reasons (appropriateness, amenity and density) already stated in the policy itself. Some hotels display signs of being so overdeveloped as to be obtrusive and unsympathetic to their surroundings architecturally. Others now have so much accommodation on small sites that conversion without a reduction in the amount of accommodation could create problems for neighbours and/or the wider area. In any event some hotel extensions, such as forward projecting ground floor dining rooms, are designed in such a way as to make easy conversion to residential accommodation problematic. I therefore conclude that this part of the policy should be retained.

14.Objector 254 says that restrictions on changes of use should not apply in Key Tourism Investment Sites. I accept there is some logic to this suggestion, although I have recommended deleting the Key Tourism Investment Site that affects this Objector and this may solve the problem in this particular case. Elsewhere in the remaining Key Tourism Investment Sites I am not convinced that changes of use will be a live issue as wholesale redevelopment is more likely. On balance I consider there is no need to modify the policy as suggested.

15. I note that Objector 253 thinks the Council should actively resist the loss of (all) existing holiday accommodation, a view that is no doubt linked in a roundabout way to their objections seeking the release of greenfield land for housing development. However, the Objector supplies no reasoned case that their view is realistic or achievable. I am of the view that the established trend of a diminishing stock of tourist accommodation in the town will continue and that it would be unrealistic and misleading to assume otherwise. It could also lead to the unnecessary release of greenfield land for residential development. I conclude that this particular objection should not succeed.

Knock for Knock (Objector 195)

16. In as far as I understand the “knock for knock” principle being suggested, this would have the effect of maintaining the supply of holiday accommodation at present levels. I am not convinced this is the proper basis for this policy. Unless the policy is to be applied “site by site” as well as “knock for knock”, it would be impossibly complex to administer. It would also make it hard, if not impossible, to make the necessary arrangements for any large new hotel developments. This may be what the Objector would want but is not consistent with the overall strategy for resort renewal that is based on a mixed approach of improving existing hotels and providing new hotels of a high standard. In general terms I have accepted the necessity for this mixed approach. I conclude this idea should not be pursued or included in the Local Plan.

Lord Street (Objectors 206, 297, 307, 334)



Blackpool Local Plan Review – Inspector’s Report18.This being the case I consider it would not be appropriate to include the

objection sites in the adjoining Resort Neighbourhood. To do so could prejudice the proper evolution and design of the SR3 redevelopment. I conclude that the Local Plan should not be modified in response to these objections.

Pleasure Beach Staff Accommodation (Objector 248)

19.Blackpool Pleasure Beach (BPB) seek a special dispensation within the policy to enable them to provide staff accommodation (especially visiting performing artistes) close to BPB, either in the area covered by policy RR7.4 or in the Resort Neighbourhood. They employ staff from abroad who need communal accommodation close the Pleasure Beach because they are in a strange environment, often work unsocial hours and need a convenient location.

20.My understanding is that BPB’s current approach is to purchase suitable properties in the surrounding area (to the north of their site) and convert these to staff accommodation. My understanding is that this usually requires planning permission but that the Council has been helpful in this respect. BPB said that some of the accommodation they have to use is unsuitable, although in what respects it is unsuitable was never made clear, especially in view of the fact that they had gone as far as to purchase it. This argument was also weakened, in my view, by their wish to have this situation endorsed for properties within the RR7.4 designated area pending redevelopment. If such a situation were entirely inappropriate, it would not be acceptable even during a temporary period.

21.The Council maintained they were not unsympathetic (as had been shown by the granting of planning permissions) but were unwilling to have a commitment written into the policy. They would prefer to assess each potential staff hostel on a case by case and site by site basis, so that any undesirable impacts on neighbours or the area as a whole could be avoided and/or controlled.

22. In my view the Council’s stance is justified and reasonable and BPB failed to demonstrate any special (unmet) needs to warrant them being treated as a special case within the policy. However, they may be helped by the view I have taken above on the need to demonstrate that holiday accommodation is not viable before a change of use is approved.

23. I conclude that the BPB objection should not succeed.

Overall Conclusions

24.My overall conclusions in relation to policy RR11 are:

(a) there should not be a general presumption that holiday accommodation should be retained or dealt with on a “knock for knock” basis;

(b) longer term consideration should be given to differentiating between the areas needing environmental and other improvements and the areas in which changes of use will be controlled. The two purpose of the Resort Neighbourhoods are not necessarily best served by the same boundaries;

(c) in the longer term work should look into reducing the extent of the Resort Neighbourhoods, especially as far as controlling changes of use are concerned. Other ways of determining which holiday accommodation should be retained should also be considered;

(d) but as far as this Local Plan is concerned, adoption should not be delayed by a wholesale redrafting of the policies or redrawing the boundaries;


Blackpool Local Plan Review – Inspector’s Report(e) part (A) of the policy should be amended by deleting the clause requiring

changes of use to be justified by a demonstration that the property is not viable as holiday accommodation. Paragraph 2.57 should be deleted;

(f) part (B) of the policy should be amended to make it clear that the policy applies only to the parts of the Promenade that are within a Resort Neighbourhood. Paragraph 2.57a should be amended to reflect this;

(g) the part of the policy dealing with the removal of some hotel extensions during conversions should be retained;

(h) no special exception to this policy should be made for Blackpool Pleasure Beach staff accommodation, which should continue to be assessed on the merits of each proposal.

Recommendations25. I recommend that longer term consideration is given to differentiating

between the areas needing environmental and other improvements and the areas in which changes of use will be controlled.

26. I recommend longer term work looks into reducing the extent of the Resort Neighbourhoods, especially as far as controlling changes of use is concerned. Other ways of determining which holiday accommodation should be retained should also be considered.

27. I recommend that adoption of this Local Plan is not delayed by a wholesale redrafting of the policies or a redrawing of boundaries.

28. I recommend that part (A) of the policy is modified by the deletion of the clause requiring changes of use to be justified by a demonstration that the property is not viable as holiday accommodation. Paragraph 2.57 should be deleted.

29. I recommend that part (B) of the policy is modified to make it clear that the policy applies only to the parts of the Promenade within a Resort Neighbourhood. Paragraph 2.57a should be amended to reflect this.

30. I recommend that the part of the policy dealing with the removal of some hotel extensions during conversions is retained.

31. I recommend that no special exception within this policy is made for Blackpool Pleasure Beach staff accommodation, which should continue to be assessed on the merits of each proposal.

32. I recommend no modification to the Local Plan in response to the objections concerned with Lord Street.

33.Otherwise I recommend no modifications to policy RR11 (and the text accompanying it).

Officers Comments

Policy RR11 More detailed Boundaries Issue

The Inspector recommends consideration is given to exploring more detailed boundaries controlling the change of use out of holiday accommodation within different parts of the Resort Neighbourhoods. In recommending such an approach the Inspector, however, is not insistent on this being included in


Blackpool Local Plan Review – Inspector’s Reportmodifications to the Local Plan because his view he acknowledges is based on only a small number of objections.

His recommended approach he states will warrant extensive discussion. Effectively, however, in principle the approach he is advocating is more in line with the earlier closely defined main holiday area boundaries and, prior to that, the Council’s previous policy of primary and secondary holiday areas. Such an approach is not considered justified by your officers in the context of the purpose of Policy RR11, which is to control the change of use out of holiday accommodation.

Within the Resort Neighbourhoods the decision as to whether changes of use away from holiday accommodation is permitted is dependent on the detailed criteria not the boundaries. The criteria are flexible and are able and need to reflect changes in the holiday market.

In practise your officers view is that the relative lack of objections to the boundaries of the Resort Neighbourhoods means that this has been a much less contentious issue than might have been anticipated from experience from the adopted Local Plan and past appeals.

This view is based on the following factors:

The longstanding designation of more precise “main holiday area” boundaries in the adopted plan (which were then subject to major physical change over the plan period) led to major controversies and debate about whether properties should be in or out of the holiday area.

Prior to that the Council had designated prime holiday areas and secondary holiday areas and this was similarly contentious. Owners regularly took the view that if they were excluded from the prime areas they were being financially disadvantaged, with the value of their property being undermined by the Council’s planning policies.

The control of changes of use was in the past perceived to be black and white (i.e. safeguarding holiday uses within the main holiday area, allowing change outside), but this has long since ceased to be the case. It is now generally accepted that the market will to a large extent determine the viability and continued level of holiday accommodation that can be supported in the Plan.

In these terms the purpose of Policy RR9 and RR11 is to provide the policy background for controlling where change most occurs and concentrating hotel uses in the most viable and appropriate locations – whilst allowing flexibility for change of use in other locations.

Under the adopted plan more detailed guidance set out in the Council’s SPG10 which assists determination of whether a change of use is appropriate..

This SPG10 guidance now forms the basis of Policy RR11. The effect of the guidance is that whether or not a change of use to residential is permissible is

not determined by whether a property is within or outside the Resort Neighbourhoods, but by the detailed application of the criteria set out in the policy.

The Council has found this approach to be realistic, flexible and generally supported, including at appeal, removing controversy and not seeking to over-clarify a changing land use context.

Ultimately the Neighbourhood Action Plans will consider in detail planning policy to control change of use and wider issues to secure the comprehensive improvement of resort neighbourhoods, and will be undertaken in full consultation with all the community in these areas.

Policy RR11 Promenade Policy Issue

The Inspector accepts that special considerations apply on the Promenade and that the additional test of viability should apply, but considers that it is not clear whether RR11 (B) applies to the whole of the Promenade, or just that part within the Resort Neighbourhoods. The Inspector’s recommendation (29) applies Policy RR11(B) to the Resort Neighbourhoods.

The intent of Policy RR11(B) and Para 2.57(a), however, is to apply to the whole of the Promenade


Blackpool Local Plan Review – Inspector’s Reportfrontage, within and outside the resort neighbourhoods. The level of provision of holiday accommodation on the Promenade outside the resort neighbourhoods is limited, but such provision on the shop window seafront is important, often catering for a distinct holiday market clientele who wish to stay in Blackpool but prefer the quieter ambience of other Promenade locations. There is thus a need to ensure there is appropriate safeguarding of holiday accommodation elsewhere on the Promenade outside the resort neighbourhoods.

The Inspector’s recommendation of a need for clarification is therefore accepted, but not his specific recommendation. Instead alternative clarification is recommended to ensure that it is clear Policy RR11 (B) applies to the whole of the Promenade frontage as set out below:


The Inspector’s recommendations (25) to (27) are accepted insofar as ultimately the Neighbourhood Action Plans will further consider these issues in detail and that there should not be any current redrawing of the boundaries.

Recommendation 28 that part (A) of the Policy is modified by the deletion of the end clause and paragraph 2.57 as set out below is accepted:

“Where change of use to residential is proposed in or on the edge of an area of wholly or predominantly holiday accommodation, planning permission will not be granted unless the applicant can also provide evidence demonstrating that there is no viable future for the property in holiday accommodation use.” (To be deleted)

2.57 “A failing business in or on the edge of an area of otherwise stable and viable holiday properties can be a result of personal circumstances or poor management. For this reason it is appropriate in such instances that planning policy require that applicants demonstrate that they have fully explored all ways in which the property might be retained in holiday use.” (To be deleted).

Recommendation (29) is not accepted, but instead it is recommended that clarification is included in Policy RR11 to state:RR11(A) “Within Resort Neighbourhoods, including the Promenade frontage, changes of use or redevelopment of holiday accommodation premises will only be permitted where …. Etc”RR11(B) “The change of use or redevelopment of holiday accommodation anywhere on the Promenade frontage will only be permitted … etc”

Recommendations (30) to (33) are accepted.

2.29 Reshaping the Resort Paragraphs 2.54 – 2.55The Objections091/6 South Shore Focus Group

255/4 Beverley Moy (Conditionally Withdrawn)

Summary of the ObjectionsThe statement that there are more bed-spaces than there is demand is misleading. Demand is seasonal and so is the current surplus. Year round family attractions will reduce surplus availability and the extra income will facilitate improvements to the standard of accommodation on offer and reduce the need for conversions to residential use. (091)

The Objector would like to know how many new dwellings will be created by changes of use from holiday accommodation to residential use. Such changes of use could contribute to the number of new residential units required by the Lancashire Structure Plan. No specific modification to this part of the Local Plan is sought or suggested. (255)


Blackpool Local Plan Review – Inspector’s ReportInspector’s Reasoning and Conclusions South Shore Focus Group

1. The Council’s analysis of the situation is that there is a surplus of holiday accommodation in spite of past reductions and any plans that may increase demand outside the current peak periods.

2. The Objector takes the defiantly optimistic view that increasing year round attractions can fill all the beds that there are and that this will create the funds to improve the accommodation.

3. I am bound to say that I find that the Objector’s view flies in the face of experience and reality. In my view it would form a very unsound basis for future planning and lead to a very risky strategy. I prefer the Council’s more realistic analysis (which is soundly based on research), although I admit that it is, on the face of it, less attractive and can be portrayed as pessimistic.

4. I conclude that the Local Plan should not be altered as a response to this objection.

Mrs Moy

5. This is one of several similar objections in which the Objector seeks further information about the number of dwellings that could be created as a result of a (non-housing) policy in the Local Plan. My understanding is that she is less concerned to achieve some alteration to this part of the Local Plan than to reduce the number of dwellings that have to be provided in the Local Plan’s housing allocations.

6. The answer given at the Local Plan Inquiry was that it is estimated that there will be 372 dwellings provided as a result of holiday accommodation converting to dwellings. However, PC93 says there will be 800 conversions from all sources and uses between 2004 and 2016. This is based on past trends and contributes to the overall housing requirement.

7. The difficulties involved in arriving at this sort of estimate were discussed at the Inquiry, especially the complication that some hotel and guest house proprietors live on their premises and the incidence of vacant properties. These factors make it especially difficult to produce estimates. However, no alternative basis for calculating a revised figure was suggested.

8. The Objector thinks that – in view of the amount of holiday accommodation that is likely to be converted – the Council’s estimate is too low. This is in contrast to the more optimistic view of the holiday trade taken by the other Objector to this policy. The Council does not expect a higher figure, especially because the Local Plan envisages larger dwellings being created by such conversions in the future than has usually been the case in the past.

9. Having considered the matter, and on the basis of the evidence before me, I have no reason to suppose that a different estimate than the Council’s would be more reliable. Past trends are the best guide we have.

10. In any event, the Council’s overall housing figures are such that the Local Plan does not need to include the release of any greenfield land to meet the Borough’s Structure Plan requirement. So, increasing the allowance for new dwellings from this source and reducing the numbers to be found in housing allocations would have very little effect in practice on the housing policies in the Local Plan.


Blackpool Local Plan Review – Inspector’s Report11.Moreover, the Objector does not suggest or seek any specific modification to

paragraphs 2.54 and 2.55 in the Local Plan, even though the objection relates to these paragraphs.

12.For all these reasons I conclude that no modification to the Local Plan arises from objection 255/4.

Recommendations13. I conclude that the Local Plan should not be modified in response to

objections 91/6 and 255/4.

Officer Recommendation The Inspector’s recommendation is accepted

2.30 Reshaping the Resort Policy RR13 The Objection246/1 Mr Jeremy J Walker (Conditionally Withdrawn)

Summary of the ObjectionA cycle route should be incorporated into the Central Promenade between the Pleasure Beach and North Pier, linked to similar facilities both north and south. (246)

Inspector’s Reasoning and Conclusions 1. This proposal was included in the Second Deposit and the objection was

conditionally withdrawn as a result. I conclude no further action from me is required.

Recommendation2. I recommend no modification to the Local Plan as a result of this

objection.

Officer Recommendation The Inspector’s recommendation is accepted


Summary of the ObjectionBBC should revert to the town's traditional livery of green and cream to provide a balance to, for instance, the Golden Mile with its necessary but garish input to the town's appearance. (277)

Inspector’s Reasoning and Conclusions 1. I have to say that the visual improvements anticipated by this paragraph in the

Local Plan are already starting to be apparent. The Objector is entitled to his views about the best colours for the Borough’s livery but this is not a matter that


Blackpool Local Plan Review – Inspector’s Reportthe Local Plan can or should deal with.

Recommendations2. I recommend no modification to the Local Plan in response to this

objection.

Officer RecommendationThe Inspector’s recommendation is accepted

2.32 Reshaping the Resort Policy RR14The Objection246/2 Mr Jeremy J Walker (Conditionally Withdrawn)

Summary of the ObjectionA section of cycle route should be incorporated (retrospectively) into the southern Promenade, linked to similar facilities both north and south. (246)

Inspector’s Reasoning and Conclusions 1. This proposal was included in the Second Deposit and the objection was

conditionally withdrawn as a result. I conclude no further action from me is required.


objection.

Officer RecommendationThe Inspector’s recommendation is accepted

2.33 Reshaping the Resort Policy RR15The Objections192/1 Maurice Christian

246/3 Mr Jeremy J Walker (Conditionally Withdrawn)

248/ 8 / 12 Blackpool Pleasure Beach

Summary of the ObjectionsCare must be taken not to loose any car parking. A two way Park and Ride system could be set up from an improved Lonsdale bus station to the centre of town. (192)

Plans for the Central Corridor should include facilities for pedestrians and cyclists. (246)

There should be no loss of car and coach parking in the Central Corridor. (248)

Inspector’s Reasoning and Conclusions Car and Coach Parking

1. These objectors (192 and 248) are not alone in opposing any possibility that car


Blackpool Local Plan Review – Inspector’s Report(and coach) parking will be lost – others have made the same point in relation to other parts of the Local Plan. I deal in greater detail with coach parking under policy RR17.

2. Objector 248 (Blackpool Pleasure Beach – BPB), in particular, presented evidence at the Local Plan Inquiry which sought to demonstrate that:

(a) the previous Local Plan Inspector had accepted the case for (at least) retaining the amount of visitor car parking;

(b) there had nevertheless been a marked reduction in parking capacity for visitors over recent years (although the numbers were not agreed by the Council);

(c) the continued availability of parking remained vital to the continued success of the resort and the attractions within it.

3. The Council agrees that car parking is vital to the resort and expresses the intention to retain the present number of spaces. However, BBC does not assume that people are choosing to go to other leisure destinations because of a (perceived) lack of parking and says it has no data to support such a view.

4. However, there is a difference of view about the main objective of car parking policy between the Council and BPB. The Council sees it as being in the best interests of the resort as a whole to spread demand (thus using and filling existing spaces at times when they are currently underused). BPB, on the other hand, wishes to expand the number of spaces available for visitors in order to meet (existing and hopefully growing) peaks in demand.

5. There are, however, difficulties (for me at least) in relation to car parking policy as expressed in the Local Plan or as expressed by these and other objectors:

(a) government policy is based on a wish to reduce overall reliance on the use of the private car and sees controlling the number of car parking spaces as a means to this end;

(b) government guidance also wishes to see the amount of land used for parking reduced to free up land for more productive uses. It also wishes to see ideas for reducing car use (such as park and ride schemes and green transport plans) explored and exploited;

(c) the information upon which one could base a rational parking policy in Blackpool is almost entirely lacking (there is some data on usage but none on the origin and destination of trips, the reasons why trips are being made, the duration of stays or the levels of occupancy at various times of the day, week and year);

(d) parking policy in central Blackpool is bedevilled by the fact that there are several types of parking and parkers often competing for the same spaces and in the same or overlapping areas. These include: residents, shoppers, workers, day trippers and longer staying visitors;

(e) the parking polices in the Local Plan are extraordinarily unspecific about such matters as numbers, locations and charging regimes.

6. The Council expresses the general view that, although the resort may have been built up and prospered during the “railway age”, it can no longer depend on the railway to deliver the number of people that are needed for Blackpool to prosper as a resort. There is not the capacity for the railway to do this, even if


Blackpool Local Plan Review – Inspector’s Reportpotential visitors were willing to make rail their chosen mode of travel. Blackpool has, therefore, to depend on the car to deliver its customers (although I note as an aside that the potential of coach travel is less often referred to than might be expected). In general terms I am persuaded that the Council has a case at this general level and that, in these terms, it would be legitimate to regard parking policy in Blackpool, at least in part, as an instrument of resort regeneration and employment stimulation rather than simply as a component of transport planning.

7. However without more reliable information and without a policy that clearly differentiates between the various sorts of parking demand, it is not possible to endorse the Council’s rather nebulous intention to maintain car parking provision at current levels, far less to accept objectors’ calls for more specific and binding commitments in this direction. So in general terms the case for maintaining the existing parking provision and for increasing it are not substantiated in my view and I am unable to recommend altering policy RR15 in the ways these objectors want in order to secure this.

8. Turning in more detail to policy RR15, having noted and accepted the absence of a commitment to maintain numbers, what does it contain? It is concerned with improving the safety, operation, links and appearance of the parking areas in the Central Corridor. It also expresses the wish to free up some land for residential development. In my view, in general planning terms and given the amount of parking in the corridor and its current appearance, these are legitimate and desirable objectives. Large areas of surface level parking, whether full or not, can be mean and dispiriting places and I cannot exempt those in Blackpool’s Central Corridor from this description. Therefore the environmental and other improvements set out in policy RR15 are justified, even if there would be some loss of numbers, although as I have said this is not the Council’s stated intention.

9. As far as the suggestion that the Lonsdale coach station should become the focus for a park and ride service is concerned, the Council says this coach facility is unpopular with coach operators and is in decline. Although I have expressed some disappointment that park and ride has not been fully explored in this Local Plan, this facility is, perhaps, too close to the town centre or Resort Core to serve this purpose. In any event far more investigation and evidence would be needed before it could be included as a proposal in the Local Plan.

10. I return in greater detail to the issue of coach parking under policy RR17.

11. I conclude that no modification to the policy arises from these objections.

Pedestrians and Cyclists

12.The Council says that the removal of the Bloomfield Road Bridge and its replacement by an at-grade light-controlled junction will facilitate improved access for pedestrians and cyclists. Other than this the Council does not appear to have a view on objection 246/3.

13.However, it must be right (and in accord with government guidance) that any major improvements in this area should cater for pedestrians and cyclists.

14. I conclude that a fifth bullet point should be added to the first part of policy RR15 to read: improved facilities within, through and beyond the Resort Core for pedestrians and cyclists.


Blackpool Local Plan Review – Inspector’s ReportRecommendations

15. I recommend that a fifth bullet point is added to the first part of the policy to read: improved facilities within, through and beyond the Resort Core for pedestrians and cyclists.

16.Otherwise I recommend no modification to policy RR15.

Officer Comment

The Inspector’s recommendation to refer to improved facilities for cyclists and pedestrians is accepted. However, for ease of interpretation it is considered the additional criterion could more clearly refer to improved facilities within, through and beyond the Corridor itself without affecting the meaning or intent of the Policy. The wider priorities for improved cycling and pedestrian provision are set out under Policy AS3 of the Plan.

Officer Recommendations The Inspector’s recommendations are accepted, subject to the amendment for

clarification above, and accordingly a fifth bullet point is added to the first part of the Policy to state:

“improved facilities within, through and beyond the resort core Corridor for pedestrians and cyclists”.

2.34 Reshaping the Resort Paragraph 2.70The Objection126/2 Blackpool & Fylde Rail Users Association

Summary of the ObjectionConcern is expressed about the demolition of Bloomfield Road Bridge. The road layout there must allow for tram tracks to be installed and it may be that the seaward end of Bloomfield Road is blocked. (126)

Inspector’s Reasoning and Conclusions 1. Although the demolition of the Bloomfield Road Bridge is only referred to in

paragraph 2.70 as a “possibility”, by the time of the Local Plan Inquiry this had already occurred. In any event the Council says that a bridge is not necessary to secure a future tram link in this location. This is true because trams can cross streets at ground level.

2. I conclude that no modification to the Local Plan arises from this objection, although the reference to the bridge could be edited out of the text.


objection, although consideration should be given to removing the reference to demolishing the Bloomfield Road Bridge.

Officers Recommendation



The Inspectors Recommendation is accepted and paragraph 2.70 is accordingly amended to state:

2.70 A key element of proposals will be the enhancement of links between the Corridor car parking areas and adjoining holiday accommodation areas and the Promenade and Seafront. The Masterplan will consider pedestrian, cycle and vehicle links including the possible opportunity to create a new visitor gateway through the removal of Bloomfield Road bridge. There will be extensive public consultation as detailed proposals for the corridor are developed. Such consultation has already been undertaken on proposals for the enhancement of that section of the corridor between Waterloo Road and Bloomfield Road bridges. Outline planning permission has been granted and improvement works commenced should commence within the next twelve months.

2.35 Reshaping the Resort Policy RR16The Objections194/ 13 / 66 Government Office for the North West

(Objections Conditionally Withdrawn subject to PC16)

Summary of the ObjectionsThe policy should be reworded to become a more precise statement of land-use policy or deleted. (First Deposit) The reference in the policy to Resort Neighbourhood Action Plans should be moved to the text. (Second Deposit) (194)

Proposed ChangesPC16 suggests deleting the last sentence in the policy, which would then no longer refer to Neighbourhood Planning Guidance or Resort Neighbourhood Action Plans.

Inspector’s Reasoning and Conclusions 1. PC16 meets these objections which are conditionally withdrawn as a result. I

conclude that PC16 should be advertised as a modification to the Local Plan.

Recommendation2. I recommend that PC16 is advertised as a modification to the Local Plan.

Officers Recommendation The Inspectors Recommendation is accepted and PC16 deleting the last

sentence in the Policy should accordingly be advertised as a modification to the Plan as set out below:

‘Detailed proposals will be developed through the preparation of Neighbourhood Planning Guidance as part of Resort Neighbourhood Action Plans.


Last sentence of policy deleted:

Blackpool Local Plan Review – Inspector’s Report2.36 Reshaping the Resort Policy RR17

and Paragraph 2.74The Objections002/1 Blackpool Football Club

185/1 Rank Group Gaming Division Ltd

213/5 Mr I Gray


278/4 D Whitfield

335/1 Mrs Gray (Objection to paragraph 2.74)

Summary of the ObjectionsThe area identified for leisure and tourism redevelopment is not large enough to regenerate the area. (An expanded area is suggested with a boundary along Field Street, Henry Street, Bloomfield Road, Seymour Road and rear of St Heliers Road as far as Baron Road, and along the eastern side of Seasiders Way north to Rigby Road. (002)

The redevelopment should include complimentary leisure and retail uses. Reword paragraph 2.75 as follows: "The site provides an opportunity to meet the requirements of either a large space leisure user or a mixed leisure scheme and to complete the regeneration of this important and prominent frontage replacing unattractive industrial and commercial buildings with quality development. Lying to the landward side of the main visitor car parking areas and adjacent to the multiplex cinema and football ground the site is ideally situated for a major leisure development with supporting retail and catering use capable of serving a dual role for both Blackpool and Fylde Coast residents and visitors to the resort. (Proposed additions underlined) (185)

The existing coach park area should be excluded from the redevelopment site. (002) (213) (278) (335)

The proposed relocation of the “illuminations factory” prompts the call for a clear statement from BBC of its commitment to preserving and improving the illuminations with, if necessary, proposals to make them cost effective and financially viable. (277)

Inspector’s Reasoning and Conclusions1. Although policy RR17 and its supporting text have been deleted from the Local

Plan, the area designated under this policy in the First Deposit is included in the RR7.2 designation in the Second Deposit. I therefore consider that these objections have not been met and that I need to deal with them.

Coach Parking (Objectors 002, 213, 278, 335)

2. I note, as far as the objections relating to coach parking are concerned, that although policy RR7.2 allows for the provision of car parking within the proposed redevelopment, there is no mention of coach facilities in that policy.

3. The Council says that there are temporary coach parks at Sands Way and Rigby Road (in the policy RR17 area) and the Lonsdale Road coach station (in the RR7.2 area).

4. The Council says there are several types of demand for coach parking, including: “strategic” scheduled services (some seasonal, some of them from long distances), day trip arrivals and overnight trips to hotels in the area.

5. It is proposed to relocate “strategic” scheduled services away from the central corridor. The Lonsdale Road facility is said to be unpopular with such coach operators and its use is in decline. There has already been some relocation of year-round scheduled services to Talbot Road. Discussions with coach operators to formulate an alternative strategy for other services are continuing.

6. The parking areas at Sands Way / Rigby Road are used by some day trip


Blackpool Local Plan Review – Inspector’s Reportcoaches in the season but alternative parking could be provided elsewhere. The day trip operators are more concerned to have drop-off and pick-up facilities close to the main attractions and especially the Tower. Policy RR7.1 envisages such facilities at the redeveloped Central Station site.

7. The issue of providing convenient overnight parking for hotel parties will be addressed during the preparation of Resort Neighbourhood Action plans (that is on an area by area basis over a considerable period of time).

8. These matters are alluded to in Second Deposit paragraph 2.70a. The importance of local coach parks to nearby businesses is recognised but the current distribution is haphazard and is the result of the area’s history rather than any planned or systematic approach. Great importance is attached to providing convenient car parking to persuade visitors out of their cars whilst they are in the resort.

9. Several things strike me about the Council’s approach:

(a) it falls some way short of a fully thought-out plan that is ready for implementation;

(b) some aspects, in particular, remain to be finalised (for example, the facilities for seasonal scheduled services, drop-off and pick-up locations for day trippers and local parking for hotel coach parties);

(c) some priority appears to be given to cars rather than coaches;

(d) existing coach parks are at risk before replacement facilities have been identified.

10. I accept completely that, in theory at least, where coaches are parked is far less important than how easily they can set down and pick up their passengers. Even so, in the circumstances outlined above I have considerable sympathy with the objectors who are concerned about the future provision of coach parking facilities and/or the retention of existing coach parking areas. However, I would not go as far as to exclude areas of existing coach parking from the Key Tourism Investment Sites because this could compromise the successful comprehensive redevelopment of large areas.

11.Having noted that policy RR7.1 includes a requirement to provide coach drop-off and pick-up facilities, I conclude that policy RR7.2 (which now incorporates the area previously designated under RR17) should include coach parking, drop-off and pick-up facilities as supporting development. My purpose in making this recommendation is to ensure that this wider area is not left without such facilities after redevelopment, although the locations and numbers may change.

A Larger Area (Objector 002)

12.Since Blackpool Football Club (BFC) made their objection to the First Deposit, this area has been subsumed in the far larger RR7.2 Key Tourism Investment Site. In my view this meets the objection that the site was not large enough – it is now part of a much larger site. I note that BFC did not comment further on the matter either at the time of the Second Deposit or since.

13.The Council has also told me that since the time of the First Deposit, other changes have either taken place in the area or have the benefit of planning permission. These include improvements at the football ground itself, removal


Blackpool Local Plan Review – Inspector’s Reportof the Bloomfield Road Bridge, extensive environmental works in the Central Corridor and planning permission for other developments including a hotel, restaurant, a public house and housing.

14.Nevertheless, not all the land BFC wanted designated has been included in the RR7.2 designation. My understanding from what the Council has told me is that the major unresolved issue relates to the possible erection of an east stand at the football ground. This would raise the capacity of the ground from 12, 500 (now) and 16,500 (after completion of the south stand, which has planning permission and is likely to take place soon) to an even larger figure. Average gates are currently in the order of 6,000 so such an increase in capacity is dependent not only on finance being found but on the sustained success of the team on the field. I do not say that such conditions cannot be met or that they are undesirable but they must be regarded as uncertain and (probably) long-term.

15.To allow for the construction of the east stand would require existing housing to be taken into the site (as was suggested in the BFC First Deposit objection). In my view such an imposition on residents and individual property rights requires an especially strong justification, including proven feasibility and an ability to proceed. In all the circumstances, and from what I have been told, these are not present in this case at the moment.

16. I therefore conclude that the Local Plan should not be modified in response to the Football Club objection.

Mixed Development – Including Shopping (Objector 185)

17. In my view the intention behind policy RR17 (First Deposit) and policy RR7.2 (Second Deposit) is to pave the way for comprehensive redevelopment to provide major tourist attractions as part of resort regeneration. Whilst this may also provide attractions of some interest to the residents of the area, this is not its main aim. It may also provide for some ancillary catering facilities but this is also not its main aim. I consider it is unnecessary and could weaken the policy to highlight these possible secondary elements of the redevelopment.

18.As far as a mixed development including shopping is concerned, this would run counter to both the Local Plan’s shopping policies and to government guidance in PPG6.

19. I conclude that the Local Plan should not be modified in response to objection 185/01.

The Illuminations (Objector 277)

20. In my view a commitment to continue with the illuminations and the location of the site for the storage and manufacture of the lights and decorations are quite separate matters. My reading of the material I have been sent by the Council in support of the Local Plan is that there is a strong BBC commitment to keeping and enhancing the illuminations as a major attraction. In the Second Deposit Local Plan paragraph 7.39c indicates that the Illuminations and Transport Depots would need to be relocated before the area could be redeveloped as part of Key Tourism Investment Sites RR7.2.

21. I consider that this is as far as the as the Local Plan needs to (or should) go and I therefore conclude that the Local Plan should not be modified on account of this objection.


Blackpool Local Plan Review – Inspector’s ReportRecommendations

22. I recommend that coach parking, drop-off and pick-up facilities should be included as supporting development in policy RR7.2.


Officers Recommendations The Inspectors Recommendations are accepted and coach parking, drop-off and pick-

up facilities should accordingly be included as supporting development in policy RR7.2.

2.37 Reshaping the Resort Policy RR19The Objection43/1 Rev Stuart Westley

Summary of the ObjectionUnless the Council shows its willingness to co-operate by making the building presentable, no developer will ever come forward. The public open space surrounding the Harrowside Solarium should be coloured green. (043)

Inspector’s Reasoning and Conclusions 1. As far as the building itself is concerned, the Local Plan Inquiry was held in the

Solarium and a very convenient, pleasant and impressive venue it proved. Moreover the staff were consistently helpful and friendly. However, since the proposal has now been implemented, consideration could be given to deleting the policy from the Local Plan.

2. As to the open land behind the building, the Council wants to retain flexibility as to its future without indicating in what direction such flexibility might take it. However, the Council acknowledges that “currently, significantly more than half the site is provided as open space and this might continue to be the long term position.” If, as this suggests, the bulk of the land behind the building is de facto public open space, it seems to me that this should be reflected in the Local Plan and that its future should be resolved in the context of open space availability in the area and PPG17.

3. This leads me to conclude that the open area behind the Solarium should be designated as public open space under policy BH5 or, in the words of the Objector, coloured green.

4. The Objector wrote to say that the litter bins in the open area are not being emptied regularly and that no part of the Council’s organisation accepts responsibility for this task. Whilst this is clearly deplorable, and risks spoiling the ship for a ha’peth of tar, it is not a Local Plan matter.

Recommendations5. I recommend that consideration is given to deleting policy RR19.6. Whatever the outcome of such considerations, I recommend that the open

area at the site that is currently available as public open space should be designated as such under policy BH5.



Officers CommentsThis policy and the objection have been overtaken by events i.e. the completion of the Solaris development.

Officers Recommendations The Inspectors Recommendation to delete Policy RR19 is accepted

The Inspectors Recommendation to allocate the open area of the site as public open space is accepted.

2.38 Reshaping the Resort Policy RR20

The Objection145/42 Mrs F A Cunningham

Summary of the ObjectionThe comprehensive redevelopment of this site is supported but in view of the large scale proposals for hotel development elsewhere in the resort it is not reasonable to insist that the primary use of this site remains a hotel. What matters is the avoidance of piecemeal redevelopment. (145)

Proposed ChangesPC17 and PC 089 (affecting paragraph 2.84) relate to this objection but see immediately below where objections to paragraph 2.84 are considered.

Inspector’s Reasoning and Conclusions 1. The policy says that the primary use of this site should remain as a hotel. The

Council says it is the largest hotel in the resort and an important, but distinct, component of the Borough’s resort accommodation.

2. Neither the hotel owners nor the owners of the former petrol filling station site on the coastal side of the hotel appear to question the continuing primary role of the site as a hotel. I have no evidence or information to indicate that retaining the site primarily in this use is unjustified, unviable or unreasonable.

3. Whilst I agree with this Objector that piecemeal redevelopments are to be avoided, I have no basis for altering the policy to allow a residential (or any other) use to become predominant at this site.

4. In any event, the hotel has changed hands since this policy was first drafted (and the objection was made) and the new owners have apparently invested heavily in refurbishing the premises as a hotel. In my view events indicate that the policy may safely be left as it is.

5. Accordingly I conclude that no modification to the Local Plan is required in response to this objection.


objection (145/42).


Blackpool Local Plan Review – Inspector’s ReportOfficers Recommendation

The Inspectors Recommendation is accepted

2.39 Reshaping the Resort Paragraph 2.84The Objection364/1 Paul Harrison Ltd

Summary of the ObjectionReferences to the “wider role” of the hotel in this paragraph are unnecessary and too restrictive. Residential development may be appropriate in front of the hotel as well as behind it, as was accepted in principle in a 2003 appeal. The existing text should be replaced by a simpler framework that indicates that proposals will be permitted on land adjoining the hotel provided they would not be prejudicial to the hotel site. (364)

Also dealt with here are two objections to policy HN4:

050/1 Norbreck Castle Hotel

364/2 Paul Harrison Ltd

Land at the Norbreck Castle Hotel should be added to the list of sites in policy HN4. Also, add to paragraph 5.29 "However, where the existing use does not conflict with the surrounding area, proposals to extend or for improvements will be considered against the other relevant policies within the Local Plan and on the proposal's own merits". (050)

The site of the former petrol filling station in front of the Norbreck Castle Hotel should be included as a housing opportunity site in the same way as land behind the hotel. (364)

Proposed ChangesPC17 suggests an amended wording for paragraph 2.84.

PC89 suggests a further amendment.

Inspector’s Reasoning and Conclusions Policy HN4

1. Policy HN4 and the text that accompanies it are now, as proposed by the Council, recommended for deletion from the Local Plan. There is nothing about the land at the Norbreck Castle Hotel (in front of it or behind it) that leads me to doubt or revise that recommendation.

2. The policy was included in the First Deposit. Objection 50/1 suggested that land behind the hotel should be included in the list of the sites in the policy. This was done in the Second Deposit. Objection 364/2 sought similar treatment for a small area of land in front of the hotel. The Council says that the site in front of the hotel would have been too small to list in policy HN4 in any event. However, since the policy is now to be deleted (for reasons not connected with these objections) in my view the issue is resolved.

Paragraph 2.84

3. As recorded above, this paragraph has been the subject of considerable revision and reconsideration by the Council, largely in response to the objections from Objector 364 and no doubt taking account of the 2003 appeal decision (PC17 and PC89).

4. For the avoidance of doubt my understanding of how the paragraph would read


Blackpool Local Plan Review – Inspector’s Reportif both the Council’s Proposed Changes are made is as follows:

The Council’s Urban Potential Study identifies some potential for residential development within the Norbreck Castle site and there is also potential on some of the frontage lands for appropriate high quality residential development which relates well to the hotel and safeguards and enhances the amenities of holidaymakers. Any proposals for residential development will be considered in the context of the wider role and potential of the existing hotel site and proposals will not be permitted which would prejudice its future improvement and development.

5. It still contains the notion of the “wider role” of the hotel which is what the objection is about. Frankly, as explained at the Local Plan Inquiry, I do not know what “wider role” means and did not receive an explanation that persuaded me during the discussion. To retain this wording is in my view a hostage to fortune, opening the door for endless debate and argument.

6. The Objector takes the view that the principle of residential development on the site of the former petrol filling station in front of the hotel has been established at appeal and that any issues remaining to be resolved can be controlled by other (design) policies in the Local Plan. I have some sympathy for this view, without being persuaded to accept it completely. There is a difficult design issue to be resolved here and, in my view, the potential for residential development should be constrained by design considerations and the wish to protect the functioning and appearance of the hotel as well as the outlook for hotel guests.

7. I also have to say that I find the paragraph as it stands rather tortuous, inelegant and not very clear.

8. Having considered the arguments from both sides, I consider that the paragraph should be reworded as follows:

The Council’s Urban Potential Study identified some scope for residential development at the back of the Norbreck Castle Hotel. There may also be potential on some of the frontage land for appropriate high quality residential development. However, any development would need to relate well to the function and design of the hotel as well as safeguard the outlook and amenities of guests in the hotel. Proposals for residential development should take account of the needs and long term future of the hotel and its environment as well as the appearance of the sea front.

Recommendation9. I recommend that paragraph 8.24 in the Local Plan is modified to read:

The Council’s Urban Potential Study identified some scope for residential development at the back of the Norbreck Castle Hotel. There may also be potential on some of the frontage land for appropriate high quality residential development. However, any development would need to relate well to the function and design of the hotel as well as safeguard the outlook and amenities of guests in the hotel. Proposals for residential development should take account of the needs and long term future of the hotel and its environment as well as the appearance of the sea front.


Blackpool Local Plan Review – Inspector’s ReportOfficers Recommendation

The Inspectors Recommendation is accepted, with paragraph 2.84 (not 8.24 as stated above) modified to read as set out immediately above.

2.40 Reshaping the Resort Additional Policy AThe Objections089/2 Countryside Agency, N W Division (Conditionally Withdrawn)

Summary of the ObjectionsThe urban fringe should be included in the tourism policies. Urban fringe areas provide opportunities for tourism and more general recreation and leisure development. (089)

Inspector’s Reasoning and Conclusions 1. It is not clear to me why this objection has been conditionally withdrawn, as

opposed to withdrawn completely. By this I mean only that I do not know what the withdrawal is conditional upon.

2. The Objector acknowledges that most of the Borough is already built up and that inner area regeneration is a key issue for the Council. Nevertheless the Objector wants more attention paid to rural and urban fringe issues and to sustainable regeneration that would not harm the natural environment.

3. In my view the Council has clearly (and correctly) identified the main elements of its planning strategy. These include all aspects of environmental quality, although the urban and built environment is correctly identified as the main focus. This recognises the built-up character of the area and its tightly drawn boundary. In fact the Borough boundary is so tightly drawn that there is little land that can be described as urban fringe, let alone countryside. However, this fringe area does include Marton Moss for which the Local Plan includes policies to protect what remains of its undeveloped character. It also includes Marton Mere Nature Reserve.

4. In the absence of any specific proposals from the Objector to amend or improve these polices in the Local Plan, it is difficult to know what the Objector has in mind for a new policy.

5. I conclude that no modification to the Local Plan arises from this objection.


objection.


The Inspectors Recommendation is accepted


Blackpool Local Plan Review – Inspector’s Report3.1 Establishing a Thriving Sub-Regional Centre Policy SR1The Objections287/8 Tesco Stores Limited


331/11 Mr P Wright (Conditionally Withdrawn)


Summary of the ObjectionsThe policy is acceptable in principle. But it is suggested the policy is changed to allow for the benefits of a convenience retail outlet in a centralised location. Such benefits are identified in PPG6. (287)

Leisure Parks consider that the policy should recognise that it is important that development on the Hounds Hill site is compatible with the redevelopment and refurbishment of the Winter Gardens and that the Hounds Hill development contributes towards the overall regeneration of the town. (First Deposit) It is suggested that an additional sentence is added to the end of the second paragraph to read: Proposals on this site should also have regard to the special historic and architectural quality of the adjacent Grade II listed Winter Gardens. (Second Deposit) (306)

The proposal should specify that the car parking will be multi-storey rather than surface level. (331)

Policy SR1 and paragraph 3.8 should be amended to reflect changed circumstances and to include hotel accommodation as an alternative use for upper floors where appropriate. (Second Deposit) (365)

Proposed ChangesPC18 suggests the policy should be amended so that a hotel use could be accommodated at upper floor level.

PC19 suggests the policy should be amended to refer to the adjacent listed building (the Winter Gardens).

Inspector’s Reasoning and Conclusions Objector 287

1. The Council says that the reason for including this proposal (SR1 – Hounds Hill) in the Local Plan is to meet an identified need for non-food shopping floorspace in the town. It also says that planning permission has been granted for a retail development comprising a department store and eleven other shop units. It is the Council’s intention to pursue its aspiration for a centrally located supermarket on another site (adjacent to) the town centre. The Council also points to policy RR5, which allows for retailing (in general) to be located (anywhere) in the retail core. I accept that all this is factually correct and material to considering this policy in the Local Plan.

2. What neither the Local Plan nor the Council say is that convenience shopping can, or should, be restricted or discouraged either in the retail core or in the eleven (small) units in Hounds Hill. As such this part of the Local Plan is a statement of the distribution of shopping uses the Council would like to see. In my view, therefore, the Local Plan as it stands goes no further than it ought.

3. However, I see no need for the Local Plan to promote the attractions of an alternative approach and positively encourage convenience shopping in either Hounds Hill or the retail core.

4. I therefore conclude it is unnecessary to modify the Local Plan in response to this objection.



Objector 306

5. As far as Objector 306 is concerned, these matters (objections 306/9 and 306/22) were not pursued at the Local Plan Inquiry. I consider the matter has been dealt with adequately by PC19.

6. I conclude that PC19 should be advertised as a modification to the Local Plan but that no further modification is required.

Objector 331

7. Objection 331/11 was met by a change made in the Second Deposit and it has been conditionally withdrawn as a result. I conclude that no further modification arises.

Objector 365

8. Objection 365/1 would be met by PC18 and the objection has been conditionally withdrawn as a result. I conclude that PC18 should be advertised as a modification to the Local Plan.

Recommendations9. I recommend that PC18 is advertised as a modification to the Local Plan.10. I recommend that PC19 is advertised as a modification to the Local Plan.11. I recommend no modification to the Local Plan in response to objections

287/8 and 331/11.12. I note that in its evidence BBC/WS/22 the Council puts forward an

amended wording for paragraph 3.7. Whilst this appears sensible, I consider it is for the Council to decide whether to pursue this.

Officers Recommendations The Inspectors Recommendations are accepted and PC 18 and PC 19 should

accordingly be advertised as modifications to the Local Plan:

PC18 Amend third sentence of the policy to read:

‘Other supporting development could integrate appropriate leisure and hotel accommodation uses at upper floor level.’

PC19 Amend second paragraph of Policy SR1 as follows:

‘Rather than looking inward, any proposals for redevelopment should look outwards and create high street frontages that fully integrate with the surrounding shopping streets and the adjacent Grade II listed Winter Gardens.’

In addition PC 20 (which was not considered by the Inspector as this raised no objection, should also now be advertised as a proposed modification to the Local Plan.


PC020 Add the following sentence to the end of paragraph 3.8:

Blackpool Local Plan Review – Inspector’s ReportPC20 Add the following sentence to the end of paragraph 3.8:

‘Proposals for the remainder of the site which are of high quality and complement the permitted development will be supported in principle.’

In addition, in accordance with the Inspector’s comments amended wording to paragraph 3.7 is considered should also be advertised as a proposed modification to the Local Plan as follows:

3.7 The Town Centre must attract major development and investment to claw back some retail ex-penditure that is being lost to other destinations. Without new, higher quality stores to encour-age shoppers from the outlying, more affluent areas, additional expenditure will not be drawn in and shoppers will continue to go elsewhere. The Council commissioned Hillier Parker in 1999 to undertake the “Blackpool Shopping Study” and subsequently Savills in 2004 to provide an updated “Blackpool Shopping Study 2004 – 2016” and to consider the potential for retail growth in the Town Centre. Both studies This confirmed that Blackpool is under performing as a retail centre and is losing trade to out of centre stores and other centres particularly Preston. The “Blackpool Shopping Study 2004-16” concluded that Blackpool could support a further 43,000 24,000sqms of non-food shopping floorspace by 2006 and 35,000 sqms of non-food shopping floorspace by 2011 2016.

3.2Establishing a Thriving Sub-Regional Centre Policy SR2The Objections031/2 J M Rigg

186/2 Wyre Borough Council

255/5 Beverley Moy

306/10 / 23 Leisure Parcs Limited

Summary of the ObjectionsThe facilities at the Winter Gardens should be retained to provide choice and variety in the town. The building should be extended upwards. This would maintain the quality of the building towards the Albert Road entrance. It is important for the Winter Gardens to provide facilities for dancing. (031)

Clarification is sought as to what maximum floor space is to be attained through proposal SR2. (186)

The Winter Gardens should remain as an entertainment centre and vacant floorspace should not be converted to retail uses. (255)

Amend the policy to read as follows: "Future development/change of use proposals for the Winter Gardens to commercial uses including retailing and commercial leisure will be permitted subject to meeting all of the following criteria: (i) the site and buildings are dealt with comprehensively, based on a fully researched Conservation Plan which considers the historic and architectural quality of the Grade II Listed Building; (ii) improved and extended on site public car parking will be provided, in addition to improved coach and bus drop off points. (First Deposit) (306)

Policy SR2 should be amended as follows: Future development/change of use proposals for the Winter Gardens to commercial uses including retail and commercial leisure/casino/hotel and ancillary conference/exhibition development will be permitted subject to meeting all of the following criteria: (i) the sites/buildings are dealt with comprehensively based on a fully researched Conservation Plan which considers the historic and architectural quality of the Grade II Listed Building; (ii) there is a committed scheme to provide a replacement national conference venue and theatre facility elsewhere in Blackpool Town Centre or Resort Core; and (iii) improved and extended off-site public car parking will be provided, in addition to improved coach and bus drop-off points. (Second Deposit) (306)


Blackpool Local Plan Review – Inspector’s ReportProposed ChangesPC21 suggests amending the policy to allow for ancillary conference/exhibition development at the Winter Gardens.

Inspector’s Reasoning and ConclusionsObjector 31 (J M Rigg)

1. As far as retaining existing facilities at the Winter Gardens is concerned, the Council and the owners are agreed that the building is no longer fit for its traditional use as the major venue in the town (if not region) for conferences, exhibitions and events. Parts of the Winter Gardens are currently underused. The Council and owners are agreed that alternative uses need to be found and development undertaken that respects the character of this important listed building. New uses may include some retailing. Some of the existing facilities and uses may also be retained. PC21 refers to retaining an ancillary conference/exhibition function. It is my understanding from evidence at the Local Plan Inquiry that the present conference centre uses are secure until 2009 due to an agreement with the Council supported by Council funding.

2. Although I am not immune to the attractions of dancing, in my view the owners cannot be forced to provide facilities for this activity through the planning system, whatever the future of the building as a whole.

3. As to building upwards, this may be feasible but – given the importance of preserving the character of the listed building – it would be unwise to express a commitment to this in advance of an agreed and acceptable design.

4. I conclude that no modification to the Local Plan arises from objection 31/2.

Objector 186 (Wyre Borough Council)

5. As to the amount of shopping that may be provided, this is a town centre site where retailing is, in principle, acceptable (subject to preserving the character of the listed building). The Council has provided more information on its intentions in this regard and the results of its latest shopping study in its evidence BBC/WS/29. However, having read PPG6 and PPG15 I am bound to say that conservation issues are more likely to prove a constraint on the amount of retail floorspace that can be provided than any shopping policy considerations.


Objector 255 (Mrs Moy)

7. Mrs Moy’s objection is to the indication in policy SR2 and paragraphs 3.10 and 3.11 that vacant floor space in the Winter Gardens could be converted to retailing. She is of the view that this space should be retained as part of the entertainment sector which is important for the town as a whole.

8. PC21 refers to retaining some ancillary conference/exhibition facilities at the Winter Gardens even if the main conference centre facility is moved elsewhere in the town. The objection says it would be better if vacant shops elsewhere in the town were re-used, although the evidence I have is that vacancy rates are not especially high in the town centre.

9. At the Local Plan Inquiry the Objector said that, in her view, the prospect of converting any part of the Winter Gardens to a retail use has now receded and that “there is no point in debating this issue”. Although I do not necessarily share her view on this, she offered no evidence to support her view or her


Blackpool Local Plan Review – Inspector’s Reportobjection. This being the case, I have no reason to alter the Local Plan as a result of this objection.



11. I turn now to the objections from the owners of the site. At the Local Plan Inquiry four main issues were pursued, relating to:

(a) the sort of retailing that might be acceptable;

(b) the policy in relation to casinos and this site;

(c) the need for improved car and coach parking / access;

(d) and the timing of any changes.

Restricting the Sort of Retailing

12.As far as the sort of retailing that might be acceptable is concerned, the policy at the moment refers specifically to non-food retailing. The only reason the Council has given me for preferring non-food retailing is that it might be difficult to accommodate a large supermarket at the site without harming the character of the listed building. While this may, in practice, be true; the existing building is already protected by the first part of the policy. It therefore seems to me that the wish to restrict shopping floorspace on this site to non-food retailing lacks a coherent policy justification.

13. I have already said that this is a town centre site and, in my view, the guidance in PPG6 should apply unless there are compelling reasons for setting it to one side. In this context I can see no reason to stipulate either how much or what sort of shopping can be accommodated on this site.

14. I conclude that “non-food” should be deleted from SR2 B (i).

A Casino at the Winter Gardens?

15.The Council and the site owners agree there is scope for casino development at this site and that it is appropriate this should be the case given the site’s location in the town centre. What they disagree about is the priority that should be given to this site in any development of casinos in the town.

16.PC86 (and PC87) suggest that policy RR6 (and the text in the Local Plan that accompanies it) should be comprehensively re-written. Part of this redrafting introduced (for the first time) the idea that the four sites identified as suitable for casino development in policy RR6 should be prioritised, ranked or phased in two tiers. The Winter Gardens is placed in the second (later) of the two tiers that would only proceed if it were established that there is scope for further regional casino development in Blackpool after the first tier has been built and monitored.

17.The owners of the Winter Gardens object to this prioritisation / phasing and I deal fully with that objection in the context of policy RR6 and PC86.

18.My conclusions there are (briefly) that there is at most only likely to be scope for two regional (leisure destination) casinos in Blackpool for the foreseeable future and that the allocation of sites should reflect this. I consider that including the Central Station site in its first priority the Council has correctly identified the site (or sites since Central Station could accommodate two regional casinos) that should be developed first. In the case of the Winter Gardens there are


Blackpool Local Plan Review – Inspector’s Reportstrong practical reasons (see below) for supposing the site will not be available for a regional casino development in any first phase. In this context comparisons between the Winter Gardens and Rigby Road are superfluous.

19.Given all this, I consider there is little prospect of a regional casino at the Winter Gardens being feasible within the plan period. Moreover, the Development Plan context will have to be reviewed well before then.

20. I consider it would be unwise to blight the future of this important site for a prolonged period in the hope of such a development being possible in the very long term. In reaching this view I have had regard to the view expressed at the Local Plan Inquiry by the Objector’s planning witness that retailing was the most likely outcome at the Winter Gardens. I also note (see below) that Leisure Parcs object to the redevelopment of the Winter Gardens being held back by events that are outside their own control, which might well be the result of retaining the option of a regional casino development.

21.The Council says it is unwilling to pursue any lesser or smaller forms of new casino in Blackpool because they are unlikely to have wider regenerative benefits for the town. However, I consider that a strong case could be made for regarding the Winter Gardens as an exception to this approach in order to help find viable uses for this important building.

22. In these circumstances (and taking into account my conclusions on objections to policy RR6) I conclude that the word “casino” should be deleted from policy SR2 (B) (ii) unless the Council revises its view and decides to bid for a “non-regional casino” specifically with the Winter Gardens in mind. For further consideration of these matters see under policy RR6.

Cars, Coaches and Parking

23.The Objector wishes to secure commitments to additional parking in connection with this site and better access for cars and coaches.

24.As far as parking is concerned, it seems to me premature for the Local Plan to specify that more is needed before the future uses at the site are known. In my view, whether more parking is needed ought to be decided when a planning application for a change of use is under consideration. In addition, I am not aware that a suitable site has been identified for any off-site parking.

25.As far as government guidance is concerned, this acknowledges that there is often a difficult balance to be struck in town centres between providing access for car users and the capacity of the road network. The guidance also says that developers should not be required to provide more parking than they think is necessary, although the Objector in this case is looking for more rather than less. In any event there does not seem to me to be a sound basis for the Local Plan intervening as far as current government guidance is concerned.

26.The Council’s view is that parking and access to the Winter Gardens is problematic because the town centre road network could not easily accommodate large flows to this location. Similar considerations may also limit what can be done to improve access for coaches to the site, although the Council expressed a willingness to explore this in the context of its traffic management measures and Chapter 9 of the Local Plan.

27.All in all, I am not convinced there would be any merit in including a commitment to provide more parking for (or at) the Winter Gardens in the Local


Blackpool Local Plan Review – Inspector’s ReportPlan and I conclude that the plan should not be modified as a result of the part of this objection that relates to car and coach parking and access.

Timing

28.The issue arising in relation to timing is the inclusion in policy SR2 (A) (iv) of a requirement that there should be a committed scheme to provide a replacement national conference venue and theatre facility (elsewhere) before development and change of use proposals can be permitted at the Winter Gardens. Although the Objector had accepted (and indeed suggested) this at the Second Deposit stage, they pursued the matter at the Local Plan Inquiry. The Council accepted that they were in a position to do so because of their objection to the First Deposit. I shall therefore deal with the matter.

29.The cause of objection is that the Objector says this places them at the mercy of events beyond their control and that it is unreasonable for them to have to wait while other sites are sorted out before they can proceed towards resolving the future of the Winter Gardens. They also say it is not necessary and that the Council’s research by consultants did not identify it as a requirement.

30.The situation as it emerged at the Local Plan Inquiry is that the continued provision of conference/exhibition facilities at the Winter Gardens is secured until 2009 because of an agreement between the owners of the Winter Gardens and the Council. However, it is acknowledged on both sides that the suitability of the Winter Gardens for this purpose is now open to question and is declining as the years pass. I was not given details of the agreement, which is seen as commercially sensitive, but I was told that it involves payment of a “subvention” by the Council to Leisure Parcs. I was also told that such payments to the operators of major conference/exhibition facilities are commonplace and that no such facility could continue without such a subvention taking place.

31.The Council says the continued ability of Blackpool to offer accommodation capable of attracting large conferences and exhibitions is crucial to local hotels and the wider economy. The Council (and Local Plan) is taking steps to provide modern conference facilities (at Central Station) but in the meantime the economic health of the area rests on the Winter Gardens continuing to fulfil its traditional role. There is particular concern that a hiatus in the provision could cause very severe short-term harm to local hotels that depend on conferences and events to extend their season beyond holiday times. There is also concern about the long-term consequences of interrupting booking patterns, which often extend years in advance. It is feared that once long term arrangements are disrupted and organisers have been turned away, events may not return to Blackpool even if they have habitually done so in the past.

32.The Objector, however, does not accept this latter point and says that what matters is the availability of good facilities rather than continuity.

33. I am unsure about how serious for the long-term prospects of the resort a break in continuity would be because any new facilities would have a novelty attraction and thereafter would be assessed on their merits. I note in this respect that the provision of a new conference facility is not, in the Council’s view, dependent on casino investment and will occur whatever the outcome on casinos. However, I do not minimise or seek to deny the importance of these considerations and the magnitude of what is at stake for local hotels and the wider economy, especially in relation to a possible hiatus after 2009. Nevertheless, I am uneasy about the burden placed on the owners of the


Blackpool Local Plan Review – Inspector’s ReportWinter Gardens by the policy as it stands.

34. In my view the Objector is right to be concerned that they would be subject to events outside their control and that this could cause difficulties for them as an operating business, a would-be developer and the custodian of an important listed building. If I have understood what I was told correctly, what is at issue (in practice) is what will happen after 2009. By then the Objector could be finding themselves in a difficult situation in all three roles (as an operating business, a would-be developer and custodian of an important listed building). In my view it would not be reasonable to force them to endure further uncertainty into the indefinite future after 2009.

35.Moreover, the existence of the Council’s subvention indicates, to my mind, that the current use is not viable. I consider that seeking to secure the continuation of such a use through the Local Plan is questionable. (Whether similar facilities elsewhere in the country are in the same boat does not remove this consideration.) I recognise that the Council’s subvention may, by agreement, be extended beyond 2009. But such an arrangement would have to be negotiated. Retaining the contentious clause in the Local Plan would be akin to requiring the Objector to negotiate any future arrangements under duress.

36.The Council says all concerned have to take the wider view, that developments will involve partnerships between many stakeholders and that the Objector may be involved not only at this site but at others. I appreciate that this may turn out to be the case but at this stage nothing is certain and it seems to me that this Objector is being asked to accept a disproportionate share of the responsibility for the wider view and the attached risks.

37. I have looked for analogous situations to help me decide what to recommend as a result of this objection. I note that owners of sports pitches can be denied planning permission if their land is not surplus to local requirements. But, although a sports field may deteriorate if it is unused, the consequences are not in the same order of magnitude as they would be for a very large listed building. In any event, the long-term unsuitability of the Winter Gardens for this use is not contested. I am also conscious of the guidance in PPG15 on the importance of finding economically viable uses for listed buildings.

38.Taking all these things into account (and in spite of being mindful of the possibly serious consequences for local hotels and the local economy) I conclude, on balance, that SR2 (A) (iv) should be deleted from the Local Plan.

Recommendations39. I recommend that PC21 is advertised as a modification to the Local Plan.40. I recommend that the words “non-food” are deleted from SR2 B (i). 41. I recommend that the word “casino” is deleted from policy SR2 (B) (ii),

unless there is a realistic possibility that a small or large casino could be attracted to this site.

42. I recommend that SR2 (A) (iv) is deleted from the Local Plan. 43.Otherwise I recommend no modifications to policy SR2 in the Local Plan.44. I note that in its evidence BBC/WS/22 the Council puts forward an

amended wording for paragraph 3.10. Whilst this appears sensible, I consider it is a matter for the Council to decide.



Officers Comment

These are significant changes proposed to Policy SR2 as a result of the Inspector’s detailed considerations of various objections.

It is considered on balance that the deletion of the reference to non-food (although the preference remains) can be accepted, as in practical terms the listed building status and the need for convenient parking for a food superstore mean such a use could not realistically be accommodated on the site. It is otherwise accepted that a general policy restriction to exclude non-food is unnecessary.

Reference to potential casino use of the Winter Gardens is considered should continue. The Inspector’s emphasis on not unduly restricting the future use of the Winter Gardens is in order to ensure the future vitality and viability of an important listed building. Given this, and the reduction in potential casino sites being promoted both by the Inspector (and by the Government) it is considered important that a casino should be retained as part of a potential mix of uses to support regeneration of the Winter Gardens and the wider regeneration of the resort. The Inspector considers casino issues in more detail under Policy RR6, and concludes that a large or small casino could potentially be provided as part of the approach in order to help find viable uses for this important building.

The issue of the need for a committed replacement conference facility has been fully considered by the Inspector. The balance between hotelier/ conference and ownership interests is a difficult issue, and the continued use of the Winter Gardens is secured until 2009 by the current agreement with the Council. It is considered that the Inspector’s recommendation should be accepted.

Officers Recommendations

The Inspector’s recommendation that PC21 is advertised as a modification to the Local Plan is accepted:

PC21 Amend policy SR2 B(ii) to state:

‘appropriate leisure/casino/hotel development and ancillary conference/exhibition development.’

The Inspector’s recommendation (40) that that the words ‘non-food’ are deleted from SR2B (i) is accepted.

With reference to the Inspector’s recommendation (41), reference to ‘casino’ development should be retained in Policy SR2B (ii)

The Inspector’s recommendation that SR2A (iv) (that there is a committed scheme to provide a replacement national conference venue and theatre facility) is deleted from the Plan is accepted.

In addition, in accordance with the Inspector’s comments in recommendation (44), the amended wording for paragraph 3.10 should be advertised as a proposed modification to the Plan, as follows:

3.10 Implementation of the Hounds Hill scheme would still leave identified potential for further non-food retailing of about 10,000 sq ms to 2006 or 21,000 sqms to 2011 24,000 sqms to 2016. The Winter Gardens complex has significant levels of underused floorspace, which could incor-porate retail uses. It benefits from being immediately adjacent to the Marks and Spencer store and its main entrance faces Victoria Street, one of the Town Centre’s busiest pedestrian routes.


Blackpool Local Plan Review – Inspector’s Report In addition, reflecting the Inspector’s conclusions and recommendations under Policy RR6,

there is a need to mend the supporting text to paragraph 3.11A to refer to the appropriate potential use of the site for a large or small casino, as follows:.

3.11a The Former Central Station site has been identified as the only site for Regional Casino development. In addition the Resort Masterplan identifies potential for the Winter Gardens to be developed as a casino and for related adjoining hotel development. It is considered that large/small casino development at the Winter Gardens as part of a mixed-use development may enable the architectural value of the building to be retained. It also provides a one-off opportunity for a large/small casino to be located in a building of outstanding historic and architectural merit. It is therefore considered appropriate that, in these exceptional circumstances, casino and hotel development should be permitted even though such development would be outside the areas generally identified as appropriate for such development (the Resort Core and Resort Neighbourhoods/Promenade respectively).

3.3 Establishing a Thriving Sub-Regional Centre Policy SR3The Objections176/1 Lidl UK GmbH



206/1 C J Blackwell (Conditionally Withdrawn)

239/4 Sainsburys Supermarkets Ltd



294/2 Mr and Mrs V W & P Hughes



329/3 Sport England

331/12 Mr P Wright

334/1 A McInerney (Conditionally Withdrawn)

Summary of the ObjectionsThe policy should not identify a need for a "major food store" but should identify the approximate floor area of the convenience shopping deficiency. The location should not specifically refer to needs in the town centre but should also allow for proposals to provide additional convenience shopping floorspace close to existing facilities or within easy reach of residential areas that are not currently well served by supermarkets. (176)

Clarification is sought as to what maximum floor space is to be attained through proposal SR3. Consideration should be given to the possible impact of a major food store in the town centre on the wider area (including approved schemes in Wyre). (186)

For any businesses being purchased compulsorily, an independent committee should be assigned to advise, lease and oversee a fair return where the vendor feels it is necessary. (195)

Exclude holiday accommodation in Lord Street from the SR3 designation area and include it in the Resort Neighbourhood (policies RR9 and RR11). Businesses and livelihoods are at risk. (206) (294) (297) (307) (334)

Recommend modifying the policy to indicate that a range of uses may be accommodated within the redevelopment site. It is premature to be wedded to the inclusion of a major food store here, other


Blackpool Local Plan Review – Inspector’s Reportpreferable sites may emerge. (239)

How many new dwellings will be created by this policy at this site? Will there be an increase above the existing numbers? No specific modification to this part of the Local Plan is sought. At the Local Plan Inquiry a major food store was also objected to. (255)

The Second Deposit changes have made this policy too restrictive with regard to non-food shopping in this edge of centre location. Large food stores need to sell non-food items in any event. The site should be extended to include terraced housing on the edge of the site. (Second Deposit) (287)

The existing sports facility should be retained or, if redevelopment is unavoidable, an equivalent or better facility should be provided in a suitable location. (329)

A major food store is not needed, a smaller convenience supermarket closer to the town centre would be more appropriate. (331)

Inspector’s Reasoning and ConclusionsThe Need for a Town Centre Food Store (Objectors 176, 186, 239, 255, 331)

1. The 1999 Shopping Study identified potential for a major food store in the town centre. Such a store has still not been provided and the potential was confirmed by the update of the Shopping Study received during the Local Plan Inquiry. This also indicated that existing large supermarkets in the town (most of them out-of-any-centre) are “overtrading”.

2. I consider that the absence of a large supermarket in or close to the town centre is a deficiency in the local provision. To provide one could go some way to meeting the need that arises for convenience shopping in the town centre and the surrounding residential areas. It could also contribute to reinforcing the town centre’s role as the main shopping facility in the sub-regions shopping hierarchy. It would also go some way towards redressing the imbalance with out-of-centre locations and serve the needs of those without cars who have difficulty reaching out-of-centre stores.

3. As to wider impacts, I have no evidence that other town and district centres would be harmed, although the prospect that this proposal could lead to some trips “linking” convenience and comparison shopping in the town centre is, in my view, to be welcomed. I note that the need for additional shopping of this type in the town centre has been demonstrated by the two shopping studies undertaken for the Council. The prospect that the sub-regional role of the town centre could be reinforced is an entirely welcome one.

4. For these reasons I accept in principle that the Local Plan should allow for a new major food store in or adjacent to the town centre. I conclude, therefore, that Objection 176/3 should not succeed and that no modification arises from objections 186/3 and 331/12.

5. The Council says that this is the only available site for such a store. Any other spare capacity or sites in the centre are either unsuitable or should be reserved for “higher order” shopping provision. Although this has not been demonstrated by a careful examination of all possible sites, only one Objector (to another policy and not this one) has made a positive suggestion of an alternative – the Winter Gardens. Whether or not space in the Winter Gardens can accommodate a supermarket remains to be seen but the site is not available in the short term in any event. I therefore consider that no alternative site in the town centre has been identified.

6. The Council acknowledges that this can only be regarded as an edge-of-centre


Blackpool Local Plan Review – Inspector’s Reportsite but this is sequentially preferred to more remote locations. The Council also says that a proposed major food store here would not preclude the favourable consideration of proposals for smaller convenience stores in other sequentially appropriate locations if these arose. These arguments are persuasive.

7. At the Local Plan Inquiry, Objector 255 sought to extend her objection into the realms of shopping policy. In particular, she said that there is no need for a major food store here and that in any event it was unrealistic to differentiate between food and non-food retailing because major retailers no longer do so. Tesco made a similar point (see below). In any event, I see no need to limit the scope of a large supermarket here exclusively to food, although I accept that this is how the case is presented in the Local Plan.

8. Although these are issues that arise as a result of other objections to this policy, they are not directly related to objection 255/11. In any event, Mrs Moy offered no evidence in support of her views.

9. I conclude that policy SR3 should not be modified by the removal of the reference to a major food store.

Restrictions on Non-Food Shops (Objector 287)

10.The Objector complains that the changes made in the Second Deposit have made the policy too restrictive towards non-food shopping, which they regard as an essential part of the range offered by large modern supermarkets.

11.The Council accepts that non-food items are appropriate in large supermarkets and does not see this as a problem in relation to the policy as now worded. However, it is willing to see the text supporting this policy reworded to indicate that non-food stores would (only) be allowed on that part of the site that is within the town centre, thus making it clearer that the intended restriction would not apply to the hoped for supermarket.

12.This is nevertheless a restrictive approach. I am concerned that this is not in complete accordance with either the sequential approach in PPG6 or the Council’s case put to me in relation to objections seeking the extension to the Blackpool Retail Park, (in which BBC stated that there is enough scope for non-food retail floorspace in the town centre but, if not, there would be scope within this edge-of-centre and sequentially preferable site.)

13. I therefore consider that the sixth bullet point in the policy should be reworded as “non-food stores on that part of the site that is within the town centre” but that in addition the caveat that was in the First Deposit (but deleted in the Second Deposit) should be reworded and reinstated, as follows: “Any non-food stores on this site would be expected to locate within the part of the site that is included in the town centre. Non-food stores will only be allowed on the edge-of-centre part of the site if there is a need for such floorspace and there are no suitable sites available in the town centre.”

14. I conclude that the policy should be modified accordingly and the text amended to reflect this.

The TDA Area Should be Larger (Objector 287)

15.As far as enlarging the site is concerned, as suggested by Objector 287, this would extend the site, blight and the threat of compulsory purchase into an area of terraced housing. This could delay implementation and cause uncertainty


Blackpool Local Plan Review – Inspector’s Reportand hardship for those affected.

16. If I have understood the objection correctly, the Objector acknowledges that the additional land may not in fact be needed. But imposing blight in this way should only be contemplated if there is very compelling evidence that the original site is too small to achieve its objectives without the additional land. No such evidence has been presented to me. Indeed, such evidence as I have indicates that the present boundary has been determined after considerable investigation and in order to develop under-used land. The evidence indicates that the right boundary has been chosen.

17. I conclude that the site should not be enlarged.

Holiday Accommodation Affected by the Policy (Objectors 206, 294, 297, 307, 334)

18.There is an enclave of holiday accommodation within the SR3 designated area, centred on Lord Street. Essentially, the objectors who are concerned about these properties want to be left in peace and encouraged to flourish as part of the tourist trade for the resort. To assess whether this is reasonable, or even possible, it is first necessary to take a wider view.

19.The Council is committed to regenerating the town centre. The large area identified under policy SR3 is seen as being crucial to these wider aims. In general (leaving Lord Street aside for the moment) it is an underused and unattractive area that contains various transport related uses (bus station, rail station and parking as well as roads). It is in, or on the edge of, the town centre and has potential for comprehensive redevelopment to provide a variety of uses including retail, employment, housing and rationalised (and therefore more convenient) transport facilities. Although only part of the designated area is regarded as being within the defined town centre, the redevelopment and revival of this part of the town is seen as making a major contribution to town centre renewal.

20. In general terms I accept this view of, and these aspirations for, the SR3 area. The evidence I have is that this is in accord with regional guidance and current government guidance and has been supported by the allocation of public funds. Indeed, the objectors do not seek to question or undermine this approach in general terms. They simply ask to be left out of it. The issue before me is whether it would make sense to do this.

21.The Council’s evidence is that inclusion in the SR3 area does not necessarily imply that all the properties affected will be taken for redevelopment, this will depend on the design of the overall scheme for the area that is yet to be devised. However, in my view, the possibility of parts of the area not being needed for redevelopment is unlikely to have a direct bearing on the future of the buildings in Lord Street. I say this for several reasons:

(a) the Resort Masterplan clearly envisages a major rebuilding of the wider area to a unified plan to create imposing spaces as well as a composed and integrated collection of buildings;

(b) in this context buildings of the scale, design and character under discussion here are likely to be difficult to integrate with the overall scheme;

(c) moreover, this site is close to the train station in a position that may


Blackpool Local Plan Review – Inspector’s Reportdemand an open and expansive treatment. In civic design terms the area that is now Lord Street is likely to be in or close to one of several focal points in the overall design.

22.Accordingly I take the view that it would not be sensible to exclude this part of the SR3 area, at least at this stage in the evolution of the overall scheme.

23.None of this is to deny the effort and investment the objectors have put into making their hotels a success. Neither is to deny that hotels are an appropriate use in the town centre in general or close to the railway station in particular.

24.Should matters come to such a point, the code that governs the amount of compensation to be paid for a business being compulsorily purchased would ensure that a fair market value is paid for business properties. However, this is not a matter that I can deal with as part of the Local Plan Inquiry.

25.Thus, although I have great sympathy for those unwittingly caught up in the wider scheme of things, I consider that in this case logic and planning considerations (which coincide here) point to the Lord Street properties remaining in the SR3 designated area.

26. I therefore conclude that the Local Plan should not be modified in response to these objections.

Sports Provision (Objector 329)

27.My initial reaction to this objection was to wonder whether the existing facility at this site fell within the scope of PPG17. A close re-reading of that guidance indicates to me that indoor bowling facilities are not excluded from the guidance and that, therefore, they fall fairly and squarely within its remit. The guidance is clear that such a facility should not be lost unless either it is shown to be surplus to requirements or it is being replaced elsewhere.

28. In response to the objection the Council says only that they are in the process of deciding on the future of this facility and that Sport England will be consulted before a decision is taken. It does not seem to me that this comes close to complying with the guidance in PPG17. In the absence of further evidence of need, one way or the other, I consider that the Local Plan should not deal with this issue by ignoring it (which is the present situation).

29. I conclude that the Local Plan should be modified by including a replacement sport and recreation facility in the list of itemised uses to be accommodated at this site. A paragraph should be added to the text explaining that the existing indoor bowling facility will be replaced on the site unless it is either shown to be surplus to requirements, relocated elsewhere or replaced by another comparable facility within the redevelopment area.

The Number of Dwellings (Objector 255)

30.This is one of several similar objections in which the Objector seeks further information about the number of new dwellings that could be created as a result of a (non-housing or mixed use) policy in the Local Plan. My understanding is that in general she is less concerned to achieve an alteration to this part of the Local Plan than to reduce the number of dwellings that have to be provided for in the housing allocations.

31.The answer given at the Local Plan Inquiry was that it is estimated that there are likely to be 263 dwellings provided as part of the mixed-use SR3 and SR4 redevelopment (taking the two together) of which 173 would be a net increase.


Blackpool Local Plan Review – Inspector’s Report32.However, in this case the Objector thought the Council’s estimate is too high in

view of the other uses it is intended to accommodate on these sites. (I note, in passing, that this runs counter to her general argument and that, if she is right about this, it would offset her other similar objections.)

33.The Council bases its estimate on the New Horizons Masterplan. No alternative basis for calculating a revised figure was suggested. In any event, it would appear that the Objector had good reason to doubt the Council’s figures because in the Proposed Changes to the housing policies the allowance for this source of housing was deleted and subsumed in the overall windfall figure. My understanding is that this is largely because the Council has accepted that only the net additional houses should be counted towards the Structure Plan housing requirement rather the gross number of dwelling to be built.

34.Be that as it may, the Objector does not suggest or seek any specific modification to policy SR3 and its supporting text in the Local Plan, even though the objection relates to them.

35.For these reasons I conclude that no modification to the Local Plan arises from objection 255/11.

The Rules and Procedures for Determining CPO Compensation (Objector 195)

36.These are matters that are determined by statute. The Local Plan cannot and should not depart from what the law provides. I conclude that the Local Plan should not be modified in response to this objection.

Recommendations37. I recommend that the sixth bullet point in the policy should be reworded

as “non-food stores on that part of the site that is within the town centre”. 38. In addition I recommend that the caveat that was in the First Deposit (but

deleted in the Second Deposit) should be reworded and reinstated, as follows: “Any non-food stores on this site would be expected to locate within the part of the site that is included in the town centre. Non-food stores will only be allowed in the edge-of-centre part of the site if there is a need for such floorspace and there are no suitable sites available in the town centre.”

39. I recommend that the accompanying text is modified to reflect the above changes to the policy.

40.Otherwise, I recommend no modification to the Local Plan with regard to the shopping aspects of policy SR3.

41. I recommend no modification of the boundary to enlarge this site. 42. I recommend that the holiday accommodation in (and around) Lord Street

should not be removed from the SR3 designated area.43. I recommend that the Local Plan is modified by including a replacement

sport and recreation facility in the list of itemised uses to be accommodated at this site. A paragraph should be added to the text explaining that the existing indoor bowling facility will be replaced on the site unless it is either shown to be surplus to requirements, is to be relocated elsewhere or replaced by a comparable facility in this redevelopment area.


Blackpool Local Plan Review – Inspector’s Report44. I recommend no modification to the Local Plan in response to objections

255/11 and 195/3. 45. I note that in its evidence BBC/WS/22 the Council puts forward an

amended wording for paragraph 3.13. Whilst this appears sensible, I consider it is a matter for the Council to decide.

Officers Comment

The Inspector’s recommendations are basically in support of Policy SR3. His suggested minor rewording (37) is in support and clarification of the Council’s desired focus for non- food provision to be located in the defined town centre. The Inspector’s recommendation 43 is accepted. It is recognised that the redevelopment of the indoor bowling facility needs to be justified – either as surplus to requirements or to be replaced by a new facility elsewhere.


The Inspector’s recommendation 37 that the sixth bullet point of the Policy should be reworded to “non-food stores on that part of the site that is within the town centre” is accepted.

The Inspector’s recommendation 38 that the following wording that was in the First Deposit (but deleted in the Second Deposit) should be reworded and reinstated, as follows: “Any non-food stores on this site would be expected to locate within the part of the site that is included in the town centre. Non-food stores will only be allowed in the edge-of-centre part of the site if there is a need for such floorspace and there are no suitable sites available in the town centre.”

The Inspector’s recommendation that the accompanying text is modified to reflect the above change is accepted. The recommended amended text (paragraph 3.14, last sentence0 is as follows:“in order to ensure that the viability and vitality of the existing town centre is not adversely affected any non-food stores will be expected to locate within that part of the site within the town centre”.

The Inspector’s recommendations 40, 41, 1and 42 are accepted. The Inspector’s recommendation (43) is accepted. Accordingly “replacement sport and

recreation facility” to be added to the list of itemised uses in the policy that may be accommodated on the site.

In accordance with recommendation (43) the following sentence to be added to the end of paragraph 3.14:“The existing indoor bowls facility will need to be replaced unless it is either shown to be surplus to requirements, is relocated elsewhere or is replaced by a comparable facility in the redevelopment area”.

The Inspector’s recommendation 44 is accepted. In addition, in accordance with the Inspector’s comments (recommendation 45) amended

wording for paragraph 3.13 should also be advertised as a proposed modification to the Local Plan as follows:

“The “Blackpool Shopping Study” Blackpool Shopping Studies in both 1999 and 2004 high-lighted quantitative and qualitative deficiencies in Town Centre food shopping facilities and identified a potential for major foodstore development”


Blackpool Local Plan Review – Inspector’s Report3.4 Establishing a Thriving Sub-Regional Centre

Paragraphs 3.12, 3.14, 315The Objections297/ 7 / 8 / 9 Mr Geoff Brankston

307/ 7 / 8 / 9 Mr Brian McAllister

Summary of the ObjectionsLord Street is a convenient location for visitors to the town. Move the hotel out of the SR3 area and include it in the Resort Neighbourhood areas as covered by policies RR9 - RR12, as all the properties on Springfield Road opposite have been. (307/7), (297/7)

Office development should be restricted to the SR4 area. Move 15-17 Lord Street from the SR3 area into the Resort Neighbourhood areas as covered by policies RR9 - RR12. (297/8), (307/8)

Remove 15-17 Lord Street from the SR3 area and put them into the Resort Neighbourhood areas as covered by policies RR9 - RR12. This would remove the threat of any compulsory purchase and allow the property to be freely marketed if required. (307/9), (297/9)

Inspector’s Reasoning and Conclusions 1. I have already concluded that the objection site should remain in the SR3 area.

It would be inconsistent to take a different view here.

2. The present suitability of this area for hotels is not disputed but the overall need for redevelopment and regeneration is very compelling and overrides the benefits of keeping these particular hotels. There is no good planning reason why the redevelopment should not include offices but the need for redevelopment is not dependent upon doing so.


Recommendation4. I recommend no modification to the Local Plan in response to these

objections. Officers Recommendation


3.5 Establishing a Thriving Sub-Regional Centre Policy SR4The Objections255/12 Beverley Moy

331/10 Mr P Wright

Summary of the ObjectionsHow many new dwellings will be created by this policy at this site? Will there be an increase above the existing numbers? No specific modification to this part of the Local Plan is sought. (255)

Redevelopment here is supported. The site should allow for expansion to include the land enclosed by George Street, Grosvenor Street, Church Street and Cookson Street or at the very least Caunce Street, Grosvenor Street, Church Street and Cookson Street. Public sector jobs should be relocated to the town centre. (331)

Inspector’s Explanatory NoteThe land that was designated for new car parking in the First Deposit (under policy SR13) was included in an expanded SR4 designation in the Second Deposit. I deal with all the objections made to SR13 at the time of the First Deposit under that heading (see below) even though technically they should now be


Blackpool Local Plan Review – Inspector’s Reportseen as objections to Policy SR4.

Inspector’s Reasoning and Conclusions 1. As far as Objector 255 is concerned, her objection is identical to that relating to

policy SR3. Because the Council’s estimates of dwellings for SR3 and SR4 are combined, I have already dealt with this objection (see SR3, above).

2. My conclusion is therefore the same; that no modifications to the Local Plan arise from objection 255/12.

3. As far as Objector 332 is concerned, he suggests that the area for redevelopment should be enlarged to take in a considerable area of housing (and other uses) currently not inside the defined town centre. The Council says only that this is over-ambitious at this stage.

4. Even if such a large area of redevelopment were desirable, the effects of designating an area for demolition can have very profound and unwelcome effects on those living in the area. It is not a matter to be decided lightly. As things stand there is no evidence that the area in question is so intrinsically unsatisfactory that demolition is appropriate, that the land is needed for other uses or that any action is likely within the plan period. In my view in these circumstances it would be irresponsible to designate the larger area for redevelopment.

5. As to the relocation of public sector employment, whilst this may be desirable, the Local Plan is not the right way of achieving it. However, the Local Plan is attempting to provide more town centre offices, which is as far as the Local Plan can and should go.



objections. Officers Recommendation

The Inspector’s recommendation is accepted.

3.6 Establishing a Thriving Sub-Regional Centre Policy SR5The Objections236/2 Academy Land (Blackpool) Limited

255/13 Beverley Moy


Summary of the ObjectionsThe principle of consolidating the primary retail core is supported but a wider range of uses should be permitted, especially on upper floors. (236)

How many new dwellings will be created by this policy at this site? Will there be an increase above the existing numbers? No specific modification to this part of the Local Plan is sought. (255)

Hotels should be added as appropriate uses on upper floors. (365) (Second Deposit) (Conditionally Withdrawn)



Proposed ChangesPC22 suggests including hotels as an appropriate use in upper floors.

Inspector’s Reasoning and Conclusions A Wider Range of Uses? (Objector 236)

1. Although not using the precise form of words suggested in the objection, I consider that the changes made in the Second Deposit and Proposed Changes effectively and reasonably meet this objection. I conclude that no (further) modifications arise.

Hotels (Objector 365)

2. PC22 meets this objection as far as the policy is concerned and there would be no need to amend the text to reflect this. The objection has been conditionally withdrawn as a result. I conclude that PC22 should be advertised as a modification to the Local Plan.

How Many Dwellings? (Objector 255)

3. As far as objection 255/13 is concerned, this objection is the same as 255/6 (see below), which because of its objection number was dealt with first at the Local Plan Inquiry. However, it was agreed at the Inquiry that the issues raised are the same in relation to the two objections and that there is no merit in arguing the same case twice.

4. My conclusion is therefore the same; that no modifications to the Local Plan arise from objection 255/13.

Recommendations5. I recommend that PC22 is advertised as a modification to the Local Plan. 6. Otherwise I recommend no modification to the Local Plan in response to

objections 236/2 and 255/13.


The Inspector’s recommendation (5) that PC22 is advertised as a modification to the Local Plan is accepted:PC22 Amend criterion (b) to:

(b) appropriate leisure, residential, hotel or office uses at upper floor level.

The Inspector’s recommendation (6) is accepted..

3.7 Establishing a Thriving Sub-Regional Centre Policy SR7The Objections243/1 BT plc



Amend Criterion (b) to:

Blackpool Local Plan Review – Inspector’s Report307/10 Mr Brian McAllister

Summary of the ObjectionsProposals for public houses, bars and night clubs should not be ruled out in principle but only if they would harm the character of this area or the amenities of nearby residents. (243)

Extend the SR7 boundary from Dickson Road to High Street to remove properties in Lord Street from the SR3 area and into the SR7 area. (307) (297)

Inspector’s Reasoning and Conclusions Pubs, Bars and Night Clubs (Objector 243)

1. The Council argues, plausibly in my view, that over-concentrations of these uses cause problems for shoppers, residents and other businesses in an area. It therefore proposes that they should be concentrated in a specific leisure zone in the town centre.

2. It further says that the mixed use zone does not have, and should not have, a predominant use but should provide an environment suitable for a range and mix of uses. However, in view of the number of pubs, bars and night clubs already in this area there is a danger that the character of the area and its suitability for other uses would be harmed if more of these uses were to be allowed here. Whilst the Objector is right to say that not all such uses will necessarily cause disruption, in my view this is a correct analysis of the area and its needs.


The Boundary (Objectors 297, 307)

4. I have already concluded that the objection site should remain in the SR3 area. It would be inconsistent to take a different view here.


Recommendations6. I recommend the Local Plan should not be modified in response to

objection 243/1.7. I recommend no modification to the Local Plan in response to objections

297/10 and 307/10.


The Inspector’s recommendations are accepted.

3.8 Establishing a Thriving Sub-Regional Centre Policy SR8The Objection195/4 Blackpool Combined Association

Summary of the ObjectionAny new pub, bar or club use should not be allowed if the premises seek to attract only single-sex groups i.e. strip clubs or lap dancing bars. (195)


Blackpool Local Plan Review – Inspector’s ReportInspector’s Reasoning and Conclusions

1. The sort of control that the Objector is seeking is outside the scope of planning legislation. I conclude that the Local Plan cannot be changed to reflect this objection.


objection.



3.9 Establishing a Thriving Sub-Regional Centre Policy SR9The Objections255/6 Beverley Moy


Summary of the ObjectionsWhat is the estimate of new dwellings that will be created? Will there be an increase above the existing numbers? No specific modification to this part of the Local Plan is sought. (255)

Amend Policy SR9 to say 'The use of upper floors for hotels and appropriate leisure ..' Also amend penultimate line of paragraph 3.29 to say 'only those hotels and leisure uses ..' (365) (Second Deposit) (Conditionally Withdrawn)

Proposed ChangesPC23 suggests including hotels as an appropriate use in upper floors.

Inspector’s Reasoning and Conclusions Mrs Moy (Objector 255)

1. This objection is to policy SR9 and paragraph 3.29. It is one of several similar objections in which the Objector seeks further information about the number of dwellings that could be created as a result of a (non-housing or mixed use) policy in the Local Plan. My understanding is that she is less concerned to achieve some alteration to this part of the Local Plan than to reduce the number of dwellings that have to be provided in the Local Plan’s housing allocations.

2. The answer given at the Local Plan Inquiry was that it is estimated that there will be 18 dwellings provided as a result of using upper floors in the town centre.

3. The difficulties involved in arriving at this sort of estimate were discussed at the Inquiry, including the difficulty of identifying vacant floor space. However, no alternative basis for calculating a revised figure was suggested. The Objector thought that – in view of the amount of vacant space she believes exists – the Council’s estimate is too low. The Council said this is not the case, especially because it wishes to achieve larger dwelling units in conversions than have usually been provided in the past and because detailed investigations of



particular premises revealed practical difficulties.

4. Having considered the matter, and on the basis of the evidence before me, I have no reason to suppose that a different estimate than the Council’s would be more reliable. In any event, the Council’s figures are such that the Local Plan does not need to include the release of any greenfield land to meet the Borough’s Structure Plan requirement. So, increasing the allowance for new dwellings from this source and reducing the numbers to be found in housing allocations would have very little effect in practice on the housing policies in the Local Plan. Even if the historic rate of conversions increased dramatically the total numbers of dwellings to be derived from this source would still be small.

5. Moreover, the Objector does not suggest or seek any specific modification to policy SR9 or paragraph 3.29 in the Local Plan, even though the objection relates to these.

6. For these reasons I conclude that no modification to the Local Plan arises from objection 255/6.

Threadneedle Property (Objector 365)

7. PC23 meets this objection as far as the policy is concerned and there would be no need to amend the text to reflect this. The objection has been conditionally withdrawn as a result. I conclude that PC23 should be advertised as a modification to the Local Plan.

Recommendations8. I recommend that PC23 is advertised as a modification to the Local Plan. 9. I recommend no modification in response to objection 255/6.


The Inspector’s recommendation that PC23 is advertised as a modification to the Local Plan is accepted.

PC23 Amend Policy SR9 as follows:

‘The use of upper floors for appropriate leisure and hotel uses will be permitted in all of the town centre.’

In addition it is recommended that PC 24 is advertised as a modification to the Local Plan which makes similar amendments to the supporting text:

PC24 Amend second sentence of paragraph 3.29 to include the following:

‘Where not required for retail/storage uses, the conversion of upper floors to offices, flats, hotels or appropriate leisure uses makes use of vacant accommodation and assists in the repair and maintenance of buildings. The Council will therefore encourage the use of vacant upper floors for appropriate leisure, hotel, office or residential use.’

The Inspector’s recommendation (9) is accepted.


Amend policy as follows:


3.10 Establishing a Thriving Sub-Regional Centre Policy SR10The Objections078/1 Peter McGreevy

291/2 M G Allen

Summary of the ObjectionsPlanners should think as if they were disabled when planning the town centre to ensure the disabled are not disadvantaged by any proposals. Particular fears are expressed about the possible loss of disabled parking spaces in the town centre and at Cedar Square. (078)

Concern is expressed about traffic in Albert Road and the impact of traffic displaced by trams in Talbot Road and the Hounds Hill development. Loading and unloading areas in Albert Road should be kept. Would it not be possible for developers to widen Albert Road having one lane from McDonalds to the car park entrance for their traffic? (291)

Proposed ChangesPC25 suggests clarifying the Town Centre Distribution Route on the (amended) Proposals Map.

Inspector’s Reasoning and Conclusions Objector 78

1. Objector 78 is concerned about the loss of disabled parking facilities in convenient town centre locations. The Council says this is not the intention or effect of this policy and that it recognises the importance of providing such parking in convenient locations. In response paragraph 3.31 was amended in the Second Deposit to refer to meeting the needs of those with mobility problems by providing convenient parking facilities.

2. I also recognise the needs of disabled motorists for convenient parking although, if traffic circulation systems in the town are being changed, this cannot amount to a commitment to leave all the existing spaces for disabled parking exactly where they are now. The location of on-street parking has to be decided within the context of wider traffic management and pedestrianisation objectives.

3. Be that as it may, such detailed matters as the siting of each parking space, cannot be sorted out in the Local Plan; which should deal only with the broad issues of traffic management and parking provision.


Objector 291

5. The Council says that under current traffic management proposals Albert Road is to be for local access only, which means that traffic should not be displaced onto it from Talbot Road. The Council also says that the Hounds Hill development now has planning permission and is not a matter that needs to be addressed in this Local Plan.

6. All of that may, or may not, satisfy the Objector. However, my view is that detailed traffic management matters such as reserved lanes for car park and service access on Albert Road and the retention of particular loading and unloading areas is not a matter for the Local Plan.

7. I conclude that the Local Plan should not be modified in response to this


Blackpool Local Plan Review – Inspector’s Reportobjection.


objections.



3.11 Establishing a Thriving Sub-Regional Centre Policy SR11The Objections026/5 J Dewhurst

073/ 1/ 2 Miss Jennifer Jones

078/2 Peter McGreevy

161/1 Mrs Lynda Eastham

168/1 Joy Bosworth (Conditionally Withdrawn)

183/1 Peter Whitehead

190/1 Marks and Spencer

236/3 Academy Land (Blackpool) Limited

292/1 Mr Adrian Gleadhill


310/ 1 / 2 Royal Mail Group plc

Summary of the ObjectionsThe needs of disabled drivers are being ignored. There are not enough spaces for wheel chair users. To improve availability parking bays for blue badge holders should be painted blue and chevron markings should be used. The time limit should be extended from 2 hours to 3 hours. (026)

Many people only want to visit the town centre for a short period. They need cheap and convenient short stay parking. Make the first hour at all car parks free. Do not pedestrianise any more of the town; especially not the streets listed which are convenient for quick business trips. Make more on street parking for one hour only. Do not remove traffic from Talbot road, trams and traffic can co-exist. (073)

Planners should think as if they were disabled when planning the town centre to ensure the disabled are not disadvantaged by any proposals. Particular fears are expressed about the possible loss of disabled parking spaces in the town centre and Cedar Square. (078)

Car access to Marks & Spencer should be maintained to allow customers to collect shopping. For this reason Church Street and Abingdon Street should remain as through roads. Disabled parking should be allowed in Coronation Street. There should be free parking for disabled drivers in any new car parks. There should be more disabled on-street parking. (161)

As a person with a disability the Objector welcomes pedestrian only areas but public transport access should be maintained. Park and ride or mini bus services should be introduced to the town centre. (168)

Car owners are the majority and should be catered for. Access is essential for shopping, especially Marks & Spencer. Cars should not be removed from the streets listed in this policy. To accommodate the car on these streets, ban stopping and parking and apply a 20mph speed limit. The introduction of no-car access cycle lanes would assist the parking/stopping ban. (183)


Blackpool Local Plan Review – Inspector’s ReportAlthough an improved ambiance for pedestrians is welcomed, this must be achieved without restricting the servicing or Collect by Car operations of Marks & Spencer. (190)

Any traffic calming and pedestrian priority works will need to take account of the need to safeguard access to shoppers’ car parking and servicing areas, both for existing premises within the retail area and for the redevelopment proposals in Policy SR1. Any proposals under policy SR11 should only be progressed after full consultation with existing users and town centre stakeholders. (236)

The extension of pedestrianisation in the town centre is opposed. The areas created so far have created rat-runs, on-street trading and parking areas for the disabled and coaches. The local bylaws and traffic regulations in the existing pedestrianised areas should be enforced. (292)

Pedestrianisation in the town centre is supported but more attention needs to be given to the Promenade in this respect. Add a paragraph on the importance of the Promenade. Include proposals to increase pedestrian priority on the Promenade and reduce all but essential traffic and evening visitors during the illuminations. (295)

Royal Mail objects to the interference with its service by impeding access to the (former) main Post Office and sorting office. The wording of SR11 should be amended to ensure that when formulating the pedestrian priority and related measures the Council will take full account of the interests of the occupiers of affected premises and ensure that any works are not to their detriment. The Local Plan’s wording needs to reflect the status of the proposals and say that consultation will occur and the views of occupiers of properties affected will be fully considered prior to works being undertaken. (310)

Inspector’s Reasoning and Conclusions First Principles

1. I suppose that every driver would like there to be a parking space available for them in front of the building they want to visit when they want to visit it. Whilst this may be a realistic hope in small shopping centres, it is just not possible in large town centres. And it would not be safe or pleasant for pedestrians (including drivers once they have got out of their cars) to try and achieve this. In planning town centres one is dealing with competing demands on limited space.

2. Government guidance is clear that in resolving these competing demands, in general priority should be given to pedestrians, cyclists and public transport. Safety and improving the overall shopping environment are important considerations. These, then, are my priorities in assessing these objections. This means that I do not sympathise with those (such as objectors 183 and 292) who oppose pedestrianisation in principle or see it as an attack on motorists.

Parking for the Disabled

3. An exception to this general order of priorities is making provision for disabled parkers and I accept that this needs special and careful consideration.

4. Several objectors (including 26, 78, 161) are concerned about the loss of disabled parking facilities in streets identified in this policy. The Council says this is not the intention or effect of this policy and that pedestrianisation can and will allow for “blue badge” parking in appropriate locations. However, in my view if traffic circulation systems in the town are being changed, this cannot amount to a commitment to leave all the existing spaces for disabled parking exactly where they are now. The location of on-street parking has to be decided within the context of wider traffic management and pedestrianisation objectives.

5. Be that as it may, such detailed matters as the siting of each parking space, cannot be sorted out in the Local Plan; which should deal only with the broad issues of traffic management and parking provision.

6. As to the suggestion that “blue badge” spaces should be marked in a distinctive


Blackpool Local Plan Review – Inspector’s Reportway, such matters are (the Council says) subject to national regulations and Blackpool cannot introduce its own system.

7. I conclude that no modification to the Local Plan arise from the objections to this policy that are concerned with disabled parking.

Short Stay / Convenience / Car Priority

8. Objector 73 wants increased priority given to (very) short stay parking in the town centre. The Council says it is their policy to give increasing emphasis to short stay parking in the centre, although it makes no commitment on the charging regime that will result from this.

9. I also accept the principle of giving priority to short stay parking in the town centre and my only criticism would be that more progress has not already been made in this direction. Government guidance indicates that such steps should be taken early in the process of reviewing parking policies and I would regard it as premature to seek to provide more parking until this has been done. In any event, this Objector appears to be knocking on an open door and I conclude there is no need to modify the Local Plan to achieve what she wants.

10.Objector 161 advocates free parking in car parks for disabled motorists. The Council says that parking charges will be subject to decisions and variations in the future and declines to give any guarantees in this respect. In my view the Local Plan is not the right place to decide on the detailed parking charges that will apply throughout the plan period to 2016.

11. I conclude that no modification to the Local Plan is needed.

Public Transport Penetration

12. In response to objection 168/1 (seeking greater penetration of buses into pedestrianised areas) the Council says that “essential vehicles” are not ruled out in pedestrianised areas. Essential vehicles include “rideability” buses, other buses, taxis and dial-a-ride vehicles. The Objector appears to be satisfied with this answer and has conditionally withdrawn the objection.

13. I conclude that no further action is needed from me.

The Promenade

14.Objector 295 wants more priority given to pedestrians on the Promenade, which they say is currently unsafe. The Council does not dispute that there is a problem and says the issue will be taken up elsewhere.

15.Since it is agreed there is a problem and that action will be required, I consider that it is appropriate for the Local Plan to address the issue. However, I am less convinced that this policy is the appropriate place in the Local Plan to consider the matter – the Reshaping the Resort chapter might be more appropriate.

16. I conclude that consideration should be given to including in the Local Plan a reference to the need to improve pedestrian safety on the Promenade.

Businesses and Servicing

17.Three objectors (190, 236 and 310) raise the issue of servicing existing businesses in the town centre. The Council accepts that this is a general requirement for new development but does not indicate that it accepts the need for any change to the Local Plan to reflect the need to access existing businesses.


Blackpool Local Plan Review – Inspector’s Report18. I consider this to be an omission, although I anticipate that these issues would

have to be addressed at the detailed planning stage when traffic regulation orders are being made and confirmed. Nevertheless I take the view that the Local Plan should refer to this as an important consideration.

19. I conclude that a sentence should be added to paragraph 3.32 to the effect that in designing pedestrianisation schemes the Council will have regard to the servicing needs of existing businesses in the area.

Marks & Spencer

20.M & S and some of its customers are concerned about vehicular access to its store. These objections were to the First Deposit version of the Local Plan. The Council’s evidence is that, since that time, these matters have been addressed and resolved in the detailed preparation of a pedestrian priority scheme for Church Street, Coronation Street and Abingdon Street.

21. I have no evidence that contradicts what the Council says and accordingly conclude that the matter has been resolved so that no modification to the Local Plan is required.

Consultation Arrangements

22.At least one Objector (310) advocates the inclusion in the Local Plan of extended references to the consultation procedures that will be followed when pedestrianisation schemes are being implemented.

23. In general I do not regard it as appropriate for this to be done because the Local Plan is not, in my view, the right place for such material. It could also make for a very long Local Plan if every opportunity for consultation is to be highlighted. In any event, there are statutory requirements in this particular instance that would apply whether or not they are referred to in the Local Plan. The Local Plan should not be seen as a mechanism for either diluting or reinforcing statutory requirements.

24. I conclude that the Local Plan should not be modified in this respect.

Recommendations25. I recommend that consideration is given to including in the Local Plan a

reference to the need to improve pedestrian safety on the Promenade.26. I recommend that a sentence is added to paragraph 3.32 to the effect that

in designing pedestrianisation schemes the Council will have regard to the servicing needs of existing businesses in the area.


Officers Comments

Recommendation 25 is that consideration is given to including in the Local Plan a reference to the need to improve pedestrian safety on the Promenade. Mention is made that the Reshaping the Resort chapter is the more appropriate place to consider this matter. This is accepted and your officers view is that the penultimate bullet point of Policy RR13 (which refers to “traffic calming


Blackpool Local Plan Review – Inspector’s Reportmeasures and improved pedestrian crossing arrangements”) already adequately addresses this particular point on the central promenade and seafront.

Reference to improved pedestrian crossing arrangements could additionally also be added to Policy RR14 covering other promenade areas to take account of the Inspector’s recommendation.


The Inspector’s recommendation (25) is accepted and accordingly an additional bullet point should be added to Policy RR14 (Other Promenade Areas) to state that developments will include:

o “Improved pedestrian crossing arrangements”.

The Inspector’s recommendation (26) that a sentence is added to the end of paragraph 3.32 is accepted to state as follows:

“In designing pedestrian schemes the Council will have regard to the servicing needs of existing businesses in the area”.


3.12 Establishing a Thriving Sub-Regional Centre Paragraph 3.33The Objection182/2 Sebert Gwillym

Summary of the ObjectionRemove reference to a tram route in pedestrian areas as these are unsafe. The is no objection to buses in such areas. (Second Deposit) (182)

Inspector’s Reasoning and Conclusions 1. The Council says that this paragraph is not meant to rule out buses in the town

centre pedestrian areas. However, it maintains that a tram link between the resort areas and the station would be a great asset and considers that the removal of other traffic would reduce obstructions and make matters safer for pedestrians as well.

2. It seems to me that the advantages of the proposed tram link are self evident, as are the dangers. Whether the funds can be found is another matter entirely. However, trams do now run in busy British streets without having achieved a notorious safety record. Although much will depend on the detailed plans made to control tram and pedestrian movements where they share the same space, I am not persuaded that there is enough evidence to rule them out completely for safety reasons.

3. I conclude that the Local Plan should not be modified as a result of this objection.


objection. Officers Recommendation




3.13 Establishing a Thriving Sub-Regional Centre Policy SR12The Objections014/1 Mr A F Hall

026/3 J R Dewhurst

073/1 Miss Jennifer Jones

145/44 Mrs F A Cunningham

182/1 Sebert Gwillym




Summary of the ObjectionsThe idea of running trams along Talbot Road is opposed. There will be too much conflict with other traffic. It would be better to relocate the Town Hall out of the town centre. (014)

Public transport priority on Talbot Road should not overlook the needs of the disabled, including the blind, deaf and wheelchair users. (026)

Although the proposed tram link to the station is supported, other traffic should not be removed from Talbot Road. General traffic used to share the road with trams and could do so again. (073)

Re-instate policy SR12 (145) (Second Deposit)

Instead of the tram link, have a cable car connection from Queen's Square to North Station. (182)

The importance of the rail service into Blackpool North is much reduced and will not expand again. The transport interchange at Blackpool North Station should concentrate on car and taxi connections. Abandon the proposed tram connection and retain the road space for cars. The tram connection is not cost-effective and would be intrusive. This is a covert attack on the motorist. (183)

Although a tram link is supported in principle, the exact line of the proposed tramline should be flexible and should be determined in conjunction with the development brief for the TDA. (287)

Strengthen the role of rail traffic in contributing to the economic success of Blackpool and consider developing a tramway system serving a wider area. (295)

Inspector’s Reasoning and Conclusions 1. In the Second Deposit this policy and the accompanying text was deleted and

policy SR 11 and text were expanded somewhat. Be that as it may, the substance of most of these objections remains relevant.

Opposition to the Proposal (Objectors 14, 73, 182, 183)

2. All of these objectors oppose some aspect of the proposals.

3. Much of this opposition is based on a wish to keep general traffic in Talbot Road and some objectors say that in the past trams and traffic used this street. However, one objector says that this was not safe.

4. My overall approach follows government guidance and is that, if there are competing claims for scarce road space, public transport should be given priority over cars.

5. Objector 73 does not oppose the tram link but thinks that general traffic should remain on Talbot Road. The Council points out that the public transport priority on Talbot Road is for the benefit of buses as well as any trams. Talbot Road already has too much traffic for the efficiency of the bus services that use it. This appears to me to be the case in peak times and, as I have already said,


Blackpool Local Plan Review – Inspector’s Reportgovernment guidance would give priority to public transport where there is competition for scarce road space. I therefore consider that this objection should not succeed.

6. Objector 183 sees the proposed tram link and the associated reduction in road space as an attack on the motorist. I must say I find this a little fanciful. There are reasons for wanting to extend the tram network without seeing the proposal as an attack on the car.

7. He may be on stronger ground when he says that the tram link will be too expensive to be cost-effective but I have no data on this. On the basis of the evidence I have the proposed tram link would be a useful extension of public transport services in the town and on this basis I consider it is worthy of inclusion in the Local Plan.

8. If it turns out that the tram project is not pursued for other reasons, little harm will have been done and the future role of Talbot Road can be decided upon by weighing the competing demands of buses and general traffic.

9. In all the circumstances I consider the arguments advanced by this Objector are not sufficiently strong or sufficiently alert to government guidance to delete the tram extension from the Local Plan.

10. I conclude that no modification arises from these objections.

Alternative Proposals (Objectors 14, 182, 183, 295)

11.As far as a possible cable car connection on the suggested route is concerned (Objector 182), the Council says that this is not feasible for a combination of engineering, environmental and cost reasons. Although it may be an imaginative idea, I conclude that it is impractical. Possible safety concerns for cyclists could be overcome by providing alternative cycle routes.

12.Objector 295 wants to enhance the role of rail connections in Blackpool. The Council agrees and is pursuing this by other means. Although a laudable objective, it does not seem to me to be appropriate for inclusion in the Local Plan because it depends on decisions outside Blackpool. The Objector also wants a more extensive tram network. Again this may have merits but the Council regards it as unrealistic because of the cost. I have no evidence to the contrary and consider that it would not be sound to include it in the Local Plan.

13.Objector 183 suggests that the priority at the railway station should be for cars and taxis not for public transport and sees the current approach as hostile to the motorist. The approach he advocates would not be in accord with government guidance which is to improve public transport connections and integration.

14.Objector 14 advances the idea that the Town Hall should be relocated as an alternative. I do not see this as an alternative mainly because the site of the Town Hall would attract an alternative use that would also generate trips.




Flexibility (Objector 287)

16.Tesco, although not opposing the proposal, do not want the line of any tram link fixed in advance of the Development Brief for the redevelopment of the TDA site. Although the notion of a flexible tram track is an amusing one, I think I know what they mean. So, apparently, does the Council, which agrees to some extent but says there are constraints on where the link can go if possible long term extensions are not to be prejudiced.

17. In the event, policy SR12 in the First Deposit was deleted in the Second Deposit and references to a tramway in the town centre moved to policy SR11 and its text. The right time to revisit this matter will be, as Tesco suggests, when the Development Brief for the TDA scheme is being finalised. In the meanwhile, I consider that the policy, text and Proposals Map are all flexible enough to accommodate reasonable adjustments to the alignment.


The Needs of the Disabled

19.Since Objector 26 refers to the needs of the deaf and blind as well as wheel chair users, I do not regard this objection as being primarily about parking spaces. However, it is not entirely clear what the Objector wants. I consider that I have already dealt with the needs of the disabled in a general sense under policies SR10 and SR11 and do not know what I could usefully add here.

20. I conclude that no modification arises from this objection.

Reinstate Policy SR12 (Objector 145)

21.This objection is against the deletion of policy SR12 in the Second Deposit. The Council says it has deleted the policy because the tram extension is dependent on government approval and funding and is therefore less than certain. However, public transport priority on Talbot Road (for bus or ultimately tram as well) is now included in policy SR11. The possibility of the tram extension is now referred to in paragraph 3.33. All in all I consider this to be a more realistic approach that reflects the uncertainties surrounding the proposed tram line.


Recommendations23. I recommend no modifications to the Local Plan in response to these

objections.





3.14 Establishing a Thriving Sub-Regional Centre Paragraph 3.34The Objection26/3 J R Dewhurst

Summary of the ObjectionBus/tram priority on Talbot Road should consider the needs of disabled people, the old and infirm. This should be made clear in the supporting text. (026)

Inspector’s Reasoning and Conclusions 1. It is not entirely clear what addition to the text in the Local Plan this Objector

wants. It is clear they support public transport improvements because they say they look forward to a tram ride. It is also the case that many of the people the Objector is concerned about (the blind, old and mobility impaired) necessarily depend on public transport and measures to improve public transport services to the town centre and railway station will help them. It may also make public transport more attractive to some disabled people who now travel by car.

2. I do not consider that the Local Plan is the right place to determine the detailed location and design of stopping facilities.

3. All in all, I consider there is no need to modify the Local Plan in response to this objection.


objection.



3.15 Establishing a Thriving Sub-Regional Centre Policy SR13The Objections035/1 Veronica Lees

039/1 Blackpool Royal British Legion

078/3 Peter McGreevy

160/1 Dr F J Hughes

180/1 Mr Kenneth Hyman


298/1 Steven Heald

299/1 Christine Jennings

331/9 Mr P Wright

Summary of the ObjectionsAs a long-term resident of the area the Objector does not wish to be moved from what is a convenient location. There is already enough parking in the area. This policy should be deleted. (35)


Blackpool Local Plan Review – Inspector’s ReportThe established British Legion premises should not be disturbed; they are important to the social life and welfare of the members and the town and are an important tourist attraction. If relocation is absolutely necessary, a site very close to the present one is needed. (39)

Disabled people need parking at ground-level. The proposed multi-storey car park would not be of use to the disabled and would involve the loss of existing ground-level spaces. (78)

The large (NHS) dental surgery needs a central location. Either leave the practice where it is or provide suitable alternative premises and facilitate the relocation. (160)

A multi-storey car park would block light in nearby properties. Keep existing ground-level parking. (180)

The creation of a car park on this important site would detract from the vitality of the centre and the prosperity of existing businesses. If town centre retailing is to continue to move south with the expansion of Hounds Hill, new car parking should be sited there (preferably above the new shops). If a car park is required on the northern edge of the centre, it should be sited on the SR3 land. Assistance with site assembly where required is not an element of land use planning policy. (295)

The proposed car park would destroy a thriving business. There is no need for more parking. Park and ride would be preferable. (298) (299)

The proposal should make it clear that the proposed car park would be multi-storey. (331)

Explanatory NoteIn the First Deposit of the Local Plan Policy SR13 proposed a new car park on a site at King Street / East Topping Street. All these objections were made to that proposal in the First Deposit. In the Second Deposit the site was included with a larger area to the north (under Policy SR4) as an area primarily for office use and new public car parking. Although these are designated as the primary uses, the Local Plan says that other supporting development (including residential) could be included as part of a mixed-use scheme.

At the Local Plan Inquiry the Council explained that what had previously been the proposed SR13 parking site was still intended for that use under (the revised and extended) policy SR4. What is proposed is a multi-storey car park on the land that currently has ground level parking on it but incorporating the properties on the west side of King Street. This would provide a rectangular site that would be suitable for a multi-storey car park. It could, however, include ground level shops or other uses on the King Street frontage to enhance the street scene.

In the circumstances it is clear that all these objections to policy SR13 in the First Deposit are still relevant to SR4 in the Second Deposit and I intend to proceed accordingly.

The text accompanying policy SR4 in the Second Deposit makes it clear that the car park proposal is for a multi-storey facility, so I consider that objection 331/9 has been met in full by the Second Deposit (albeit at the expense of reinforcing objections 180/1 and 78/3).

Inspector’s Reasoning and Conclusions The Main Issue

1. In view of the objections I consider the main issue is whether the proposal for a multi-storey car park on this site has been substantiated by the Council. In view of the fact that the Local Plan proposal would have to be implemented in spite of there being unwilling landowners and residents (possibly using compulsory purchase powers), I consider a robust justification is needed for this proposal.

The Case for a New Multi-Storey Car Park on This Site

2. In general terms the case is that the Council wishes to maintain the number of parking spaces in the town centre to support its vitality and regeneration. This is to be achieved by providing new spaces to replace those that will be lost during redevelopment. At the same time, changes in the management of car parks will secure a shift from long-stay spaces to short-stay.

3. The location of car parks is important both in relation to the position of the town centre bypass and the origin of traffic. This proposed car park would be well related to the nearby bypass (without circuitous entry or exit routes) and would


Blackpool Local Plan Review – Inspector’s Reportserve traffic coming from the east. The parking situation in the town is complicated by the need to cater for tourists as well as shoppers.

4. Whilst at a general level this reasoning is persuasive, in my view far more detailed information is needed to provide a convincing case and to demonstrate that the overall approach is consistent with current government guidance on parking. At the Local Plan Inquiry I asked the Council to produce more evidence to support this proposal.

5. Even so, it does not seem to me that the Council has demonstrated it has an overall approach to car parking that is consistent with current government guidance. I say this for the following reasons:

(a) the current pricing policy, in the Council’s own words, “creates little differentiation in use” (between short, intermediate and long stay);

(b) there are a considerable number of long stay parking spaces (and intermediate ones, which it is acknowledged amounts to much the same thing in practice) in and close to the town centre;

(c) the Council says “over time a more sophisticated strategy is to be developed to relocate and differentiate parking provision”;

(d) neither the current provision (and charging regime) nor the proposals appear to be justified by a survey of usage or any reliable projections of demand for the future;

(e) there has been no examination of the potential for park and ride.

6. In all these circumstances I consider the Council’s approach is deficient. In as far as the overall amount, location and charges they are planning are known; these appear to be very different from the current situation. But there is no clear indication of what the overall demand and usage either is or would be.

7. It is therefore far from clear that a multi-storey car park on the objection site is needed or justified. (I do not go as far as to say that a car park here could not be justified but only that the Council has failed to justify it by the information given to me.) The Council readily admits that a “sophisticated strategy” (for car park location and charging) has yet to be devised but in the absence of this the proposal for a new car park is at least premature. In my view this is not a sufficiently robust case for including the proposal in the Local Plan with all the implications for landowners and objectors this would have.

8. I conclude that the proposal for a multi-storey car park on this site has not been substantiated by the Council. In view of the fact that the Local Plan proposal would need to be implemented in spite of there being unwilling landowners and residents (possibly using compulsory purchase powers), I conclude that this site should be removed from the SR4 / SR13 designation in the Local Plan.

The Nature of the Area

9. At present this area is rather marginal in terms of its location on the edge of the town centre and in terms of its uses and the condition of buildings. It is rather run down and not very attractive. However, I consider there is a marked and significant difference between the west side of King Street and the area to the east (that is between the SR13 and the SR4 designations in the First Deposit). The west side of King Street is better maintained and has more substantial and established uses. In contrast to the east the condition of the buildings appears to be worse and the uses are, in general, less evidently well-established. I also


Blackpool Local Plan Review – Inspector’s Reportnote that this is reflected in the pattern of objections to the Local Plan; there were several objections in principle to the SR13 designation in the First Deposit but none to SR4 even though it is a bigger area with more properties in it.

10.For these reasons I consider the case for redeveloping the properties on the west side of King Street as a contribution to town centre regeneration has not been substantiated. Neither the appearance of this frontage nor the uses within it suggest to me that redevelopment is necessary to secure visual improvement in the wider area, although such a claim could be made with greater force to the area east of King Street and the rest of the SR4 designation.

Design Considerations

11.To exclude all or some of the existing properties on the west side of King Street from the intended car park site would create an irregularly shaped site. The Council says this would be difficult to use efficiently for a multi-storey car park. Whilst I am sure that an ingenious design to make the best use of such a site could be devised, I am inclined to accept what the Council says in this respect because so much of the space would be needed for the circulation of vehicles in an irregularly shaped building.

12. I also accept that retaining the existing buildings, which are not very tall, in the context of the much taller club at the end of the street (which is to remain) and a tall multi-storey car park would create a discordant street scene. It could also give rise to amenity and neighbourliness issues.

13.For these reasons I do not consider it would be sensible to attempt to resolve these objections by the apparently simple step of removing the existing properties west of King Street from the designated site of the proposed car park. In my view it is a case of all or nothing.

14.As far as the impact on neighbours outside the car park site itself (Objector 180) is concerned, it seems to me that the design of any proposed building would have to take this into account. At this stage I do not regard this as a matter of principle that indicates that the whole proposal should be stopped.

Relocation and Disruption

15.Several of the objectors start from the position of not wanting to be moved or disrupted. This is an entirely understandable stance, although in planning terms not a completely decisive one by itself. Two of the objectors express the view that if they are to be moved they need new premises close to their present locations and help with relocation. The location and terms of any relocation might go some way to overcoming their objections. Whilst such considerations are clearly important to those affected, it does not seem to me that they should affect the decision in principle in the Local Plan.

16.One of the affected objectors is the Royal British Legion. They emphasised their importance to the town and the Council accepted this. They also emphasised the importance of this location to their continued success. During discussion it emerged that ground floor premises might be created during redevelopment on the King Street frontage that could be suitable for their purposes, even if the upper floors were to be for parking. Both sides in the debate showed flexibility and reasonableness to an extent that led me to think that an accommodation might be made. Even so, to protect their position the Legion had to maintain their objection. In the event, given my conclusions above there is no need to pursue this matter further in this report.


Blackpool Local Plan Review – Inspector’s Report17. I note that the use of Compulsory Purchase Powers is no longer referred to in

the policy, although they are retained in the accompanying text in the Second Deposit. I consider that this is an adequate response to the comment from the firm of solicitors that have objected that such considerations are not properly part of the Local Plan.

Other Matters

18.As far as disabled people are concerned, I am not inclined to generalise. Some may find multi-storey parking impossible to use but others may simply find it less convenient than ground level parking. Also, some multi-storey car parks reserve especially convenient spaces for disabled drivers. Either way, the answer may be to explore the availability of designated on-street spaces for disabled drivers. I do not take the view that this is an adequate reason to stop this proposal.

Overall Conclusion

19. I therefore conclude that the designation of the land west of King Street as either SR13 (First Deposit) or SR4 (Second Deposit) in order to provide additional car parking is not justified and that the whole of this area should be removed from what is now the SR4 area.

20. I have considered whether the land should be left unallocated or included within the adjacent mixed use zone (policy SR7) but make no recommendation.

Recommendation21. I recommend that the SR4 designation west of King Street should be

deleted from the Local Plan.

Officer Comments

In line with the Inspectors findings, further detailed work is being undertaken to review and update the case for car park development on this site and to assess such parking development directly against national, regional and sub-regional car parking policy and guidance. In particular, detailed discussions are taking place with ReBlackpool as the requirement for replacement car parking relates directly to proposals for the Blackpool North site (SR3), one of three priority projects for the URC and a key element of Masterplan and Local Plan proposals for town centre regeneration.

As soon as this work has been completed and a conclusion reached an appropriate proposed modification to the plan will be brought before Executive for its consideration and for subsequent formal advertisement.



3.16 Establishing a Thriving Sub-Regional Centre Policy SR13 – TargetsThe Objection361/2 Grosvenor

Summary of the ObjectionClarify the targets, which are currently unclear. (361)

Proposed ChangesPC26 suggests clarification of target number 4, to say that 20,000 sq m (gross) of new retail floorspace development should be completed by 2007.

Inspector’s Reasoning and Conclusions 1. The Council accepts this objection and has attempted to meet it through PC26.

I have no evidence to the contrary so conclude that PC26 should be advertised as a modification to the Local Plan.



The Inspector’s recommendation that PC26 is advertised as a modification to the Local Plan is accepted:PC26 Amend fourth target to state:

‘Completion of 20,000 sq metres (gross) of new retail floorspace development by 2007.


Amend fourth target to state:

Blackpool Local Plan Review – Inspector’s Report4.1 Lifting Quality in the Built Environment Policy LQ1The Objections089/3 Countryside Agency, N W Division (Conditionally Withdrawn)

188/1 Wildlife Trust (Lancs, Manchester & N Merseyside) (Conditionally Withdrawn)


Summary of the Objections(a) Include a broader concept of quality in the policy; (b) the requirements should apply throughout the Borough. (First Deposit) (089)

Insert a specific reference to wildlife and biodiversity (First Deposit) (188)

Delete the requirement to submit a formal “urban design statement” for all developments over 500 sq m. Whilst good design is supported; this requirement goes beyond government guidance and is unduly onerous. (287)

Inspector’s Reasoning and Conclusions 1. I am told that, as a result of changes made to the Local Plan in the Second

Deposit, the objections from the Countryside Agency and Wildlife Trust have been conditionally withdrawn. I see no reason to consider these objections further and conclude that no (further) modifications arise.

2. As far as the Tesco objection is concerned, my time in Blackpool has convinced me that a major impetus to good design is needed in the town.

3. The Council says the submission of an urban design statement represents the formalisation of a design process that should be followed in every case in any event.

4. I sympathise with this view. I am also aware of the importance that the government attaches to good design as part of its policy of making urban areas attractive places in which to live. Given the scale of threshold that is included in the policy (500 sq m), which is not inconsiderable, I take the view that this is a legitimate requirement in Blackpool.

5. I conclude that the Local Plan should not be modified.

Recommendation6. I recommend no modifications to the Local Plan in response to these

objections.




4.2 Lifting Quality in the Built Environment Policy LQ2The Objection287/12 Tesco Stores Limited

Summary of the ObjectionOnly proposals in Conservation Areas or affecting the setting of a Listed Building should have to reflect and enhance the existing local character of an area. Design is a matter of taste. (287)

Inspector’s Reasoning and Conclusions 1. I note the wording of the policy was changed in the Second Deposit. Some of

the wording objected to was changed. In the absence of further views from the Objector I do not know whether the changes meet the objection.

2. In my view good design is more than a matter if individual taste and the wish protect and enhance local character is neither irrational nor unduly onerous. I am also aware of the importance that the government attaches to good design as part of its policy of making urban areas attractive places in which to live.

3. I conclude there is no need or reason to modify this part of the Local Plan.


objection.



4.3 Lifting Quality in the Built Environment Policy LQ3The Objections194/67 Government Office for the North West (Conditionally Withdrawn)

253/4 Kensington Developments Ltd


Summary of the ObjectionsDelete “urban” from “sustainable urban drainage systems” (194) (Conditionally Withdrawn after PC28)

The policy should be less prescriptive and leave scope for more variety in layout design. (253)

Move the detail in the policy to the supporting text or Supplementary Planning Guidance. A policy as detailed as this will be difficult to implement. (287)

Proposed ChangesPC28 changes “sustainable urban drainage” to “sustainable drainage”

Inspector’s Reasoning and Conclusions 1. I conclude that PC28 should be advertised as a modification to the Local Plan

and this will take care of objection 194/67.

2. As far as Objector 253 is concerned, the Council says that the criteria are not prescriptive but merely represent principles that can be used and applied during the design process. This appears to me to be the case. In any event it is not

154Lifting Quality in the Built Environment Chapter 4

clear what specific parts of the policy are objected to or how more variety in layouts could be achieved by changing the policy.

3. I conclude that the policy should not be modified as a result of objection 253/4.

4. As far as Tesco is concerned, it is not clear which aspects of the policy they take exception to because they have not suggested any specific changes. In any event the policy was changed in the Second Deposit, although it was not shortened as a result. Tesco has not commented on the changes. The Council says it intends to produce Supplementary Planning Guidance in addition to the policy (but not instead of it).

5. In the circumstances I conclude no modification arises from objection 287/13.

Recommendations6. I recommend that PC28 is advertised as a modification to the Local Plan.7. Otherwise I recommend no modification to policy LQ3.


The Inspector’s recommendation that PC 28 is advertised as a modification to the Local Plan is accepted:

PC28 Amend point (viii) as follows:‘(viii) where possible, incorporates drainage requirements as features within the design in conjunction with sustainable urban drainage (SUDS) technology.’


4.4 Lifting Quality in the Built Environment Policy LQ4The Objections253/5 Kensington Developments Ltd


Summary of the ObjectionsThe policy should be less prescriptive in its approach and leave scope for more innovation. The policy should be deleted and replaced by a general aim. (253)

Move the detail in the policy to the supporting text or Supplementary Planning Guidance. A policy as detailed as this will be difficult to implement. (287)

Inspector’s Reasoning and Conclusions 1. As far as Objector 253 is concerned, the Council says that the criteria are not

prescriptive but merely represent principles that can be used and applied during the design process. This appears to me to be the case. In any event it is not clear what parts of the policy are objected to or how more innovation could be achieved by deleting the policy and replacing it with a general aim.

2. I conclude that the policy should not be modified as a result of objection 253/5.

3. As far as Tesco is concerned, it is not clear which aspects of the policy they take exception to because they have not suggested any specific changes. In any event the policy was changed in the Second Deposit, although it was not


shortened as a result. Tesco has not commented on the changes. The Council says it intends to produce Supplementary Planning Guidance in addition to the policy (but not instead of it).

4. In the circumstances I conclude no modification arises from objection 287/14.


253/5 and 287/14.



4.5 Lifting Quality in the Built Environment Policy LQ6The Objections109/ 1 / 2 English Nature (Cheshire to Lancashire Team)


305/3 United Utilities

326/7 CPRE (Lancashire Branch)

327/5 Miss A J Gray

Summary of the ObjectionsSuggest the following changes to policy LQ6: (i) the title should be Landscape and Biodiversity in Design; (ii) new development will be required to incorporate appropriate landscaping "and benefits to biodiversity" wherever possible, which (b) retains existing mature trees, shrubs, hedgerows and other landscape features and species or habitats of ecological importance within the site where possible and incorporates them into the overall design (c) makes provision for appropriate replacement planting or creation of features where the removal of existing mature landscaping or important ecological species or habitats is unavoidable. (109)

The policy should make reference to the use of nature species of local prevalence in planting schemes and the positive contribution landscaping can make to local biodiversity. (188)

The wording should include "planting of trees and deep-rooted shrubs should be avoided near to electricity cables, water distribution pipelines and public sewers". (305)

The policy should include the targets 20.1 and 20.2 of the deposit Joint Lancashire Structure Plan, referring to retaining woodland, hedgerows and ponds. (326) (327) (First Deposit)

Proposed ChangesPC29 suggests changing the title of the policy to “Landscape Design and Biodiversity”.

PC30 suggests a grammatical change to criterion (b).

Inspector’s Reasoning and Conclusions Objector 109 (English Nature), 188 (Wildlife Trust)

1. In my view, subject to the grammatical tidying up in the Proposed Changes, the Council has accepted these objections to the First Deposit and made the necessary changes in the Second Deposit. The Objectors have conditionally withdrawn on this basis.

2. I conclude that PC29 and PC30 should be advertised as modifications to the Local Plan but that no further changes arise from these objections.


Objector 305 (United Utilities)

3. The Council says that to rule out all tree planting near cables, pipes and sewers would mean that a large part of the Borough could not be planted. It also says that damage can be avoided by employing available technology to prevent root damage to such infrastructure.

4. In view of the importance that government guidance attaches to good design and improving the townscape – to which trees make such a valuable contribution – I agree that a blanket prohibition would not be appropriate.

5. I conclude that this objection should not succeed.

Objector 326 (CPRE) and Objector 327 (Miss Gray)

6. The Council agreed with these objections to the First Deposit and made the necessary changes in the Second Deposit (although not all in this part of the Local Plan). The objectors have not commented further.

7. I conclude that no further modifications are needed.

Recommendations8. I recommend that PC29 and PC30 are advertised as modifications to the

Local Plan.9. Otherwise I recommend no modification to the Local Plan in response to

these objections.


The Inspector’s recommendation that PC29 and PC30 are advertised as modifications to the Local Plan is accepted:PC29 Revise title of Policy as follows:

‘Landscape Design and Biodiversity Design’

PC30 Revise point (b) in the policy to read:

‘(b) retains existing mature trees, shrubs, hedgerows and other landscape features and species, including species or habitats of ecological importance, within the site where possible and incorporates them into the overall design.’


4.6 Lifting Quality in the Built Environment Paragraphs 4.22 – 4.23The Objection109/2 English Nature (Cheshire to Lancashire Team)

Summary of the ObjectionReference should be made in the text to the beneficial use of Sustainable Drainage Systems. (109)

Inspector’s Reasoning and Conclusions


Revise policy title as follows:PC30 Revise point (b) in the policy to read:

1. I consider that this matter is already dealt with elsewhere in the Local Plan (see especially policy NE13) and that there is no merit in repetition. I conclude that no modification to the Local Plan arises from this aspect of this objection.

Recommendation2. I recommend no modification to the Local Plan in respect of this

objection.



4.7 Lifting Quality in the Built Environment Paragraph 4.23The Objection285/1 Nature Watch Group BEAT

Summary of the ObjectionA modification of paragraph 4.23 or an addition of a paragraph 4.24 should say “The potential for including areas of natural habitat such as unmown species-rich grassland, ponds and marsh areas should be assessed at an early stage". (285)

Inspector’s Reasoning and Conclusions 1. The Council accepts that it is right and proper for ecological issues to be dealt

with at this point in the Local Plan and introduced changes in the Second Deposit in response to this objection. However, the Council preferred to deal with such matters in general terms rather than specifying grassland, ponds and marshes. In any event existing features of this kind would be protected by the Natural Environment policies.

2. In my view the changes introduced in the Second Deposit are a reasonable and adequate response to this objection. The Objector has not made further representations since the First Deposit, so I do not know their view but I have no evidence that they are dissatisfied.


285/1.



4.8 Lifting Quality in the Built Environment Policy LQ7The Objection329/4 Sport England

Summary of the ObjectionThe word 'school' should be deleted from the final category of locations which will be priorities for public


realm improvements. (329)

Inspector’s Reasoning and Conclusions 1. This policy and the accompanying text were deleted from the Local Plan in the

Second Deposit. With no objections to the contrary, this is no longer a matter for me. I conclude that no modifications to the Local Plan arise from this objection.


329/4.



4.9 Lifting Quality in the Built Environment Policy LQ9The Objection296/2 Susan R. Garlick (Conditionally Withdrawn)

Summary of the ObjectionThe policy should place a greater emphasis on the incorporation of energy efficiency and renewable energy measures and make reference to the re-use and recycling of construction materials and the siting of community recycling facilities. (296)

Proposed ChangesPC31 would add a reference to using recycled aggregates to criterion (b) in the policy.

PC32 suggests adding a new criterion to the policy referring to the provision of storage facilities to enable recycling to take place.

Inspector’s Reasoning and Conclusions 1. I am told that this objection has been conditionally withdrawn as a result of the

changes proposed by the Council. I conclude that PC31 and PC32 should be advertised as modifications to the Local Plan but no other changes are needed.


Local Plan.3. Otherwise I recommend no modification to the Local Plan in response to

this objection.


The Inspector’s recommendation that PC31 and PC32 are advertised as proposed modifications to the Local Plan is accepted:PC31 Revise point (b) of the policy to read:

‘(b) the use of environmentally-friendly materials, including the reuse of


PC31 Revise point (b) of the policy:

construction materials and recycled aggregates, where appropriate.’

PC32 Add point (f) to the policy:

‘(f) the provision of storage facilities for materials to be recycled.’


4.10 Lifting Quality in the Built Environment Paragraph 4.29The Objection109/3 English Nature (Cheshire to Lancashire Team) (Conditionally Withdrawn)

Summary of the ObjectionSuggest the following changes to the wording of paragraph 4.29: Good design "and the use of secondary and recycled materials from well-managed sources", can help to promote sustainable development by minimising the overall demand for resources generated by new development. (109)

Inspector’s Reasoning and Conclusions 1. This objection to the First Deposit was met by changes in the Second Deposit

and the objection has been conditionally withdrawn as a result. I conclude that no further modifications are needed.


objection.



4.11 Lifting Quality in the Built Environment Paragraph 4.30The Objection326/8 CPRE (Lancashire Branch)

Summary of the ObjectionThe sentence starting 'Blackpool has relatively few brownfield sites” should be amended to 'Brownfield sites must meet a minimum of the 79% of housing needs forecast in the JLSP deposit edition in the plan period, and development potential on these sites should be maximized with schemes proposing a minimum of 40 dwellings per hectare being considered preferentially'. (326)

Inspector’s Reasoning and Conclusions 1. The Council accepted this objection to the First Deposit and made changes in

the Second Deposit. The offending words (“Blackpool has relatively few brownfield sites”) have been removed and, although the full text suggested by the Objector was not used, the matters referred to are now included elsewhere in the Local Plan.

2. I conclude that this objection has been reasonably and appropriately met.

Recommendation


3. I recommend no modification to the Local Plan in response to objection 326/8



4.12 Lifting Quality in the Built Environment Paragraph 4.32The Objection311/1 Future Energy Solutions

Summary of the ObjectionDelete the statement in paragraph 4.32 of the Local Plan “Blackpool has limited potential for large scale renewable energy due to the urbanised nature of the Borough” and alter the Local Plan to cater for the possibility that wind or wave technology, for example, will develop to the extent that planning applications for such technologies will be made within the Borough during the plan period. (311)

Inspector’s Reasoning and Conclusions 1. I deal with this objection to paragraph 4.32 at the end of this section in

conjunction with the objection seeking a separate policy on this topic. (see below)

Recommendation2. For my recommendation on this objection see below.

4.15 Lifting Quality in the Built Environment Policy LQ13The Objection194/68 Government Office for the North West (Conditionally Withdrawn after PC35)

Summary of the ObjectionThe term “external solutions” is not clear. (194)

Proposed ChangesPC35 would change the word “solutions” to “shutters” in part (A) of the policy.

Inspector’s Reasoning and Conclusions 1. This objection is conditionally withdrawn as a result of PC35. I conclude that is

the end of the matter.





PC35 Amend section (A) of policy as follows:

‘(A) Applications for external solutions shutters will not be permitted, other than in exceptional circumstances:’

4.16 Lifting Quality in the Built Environment Policy LQ16The Objections139/1 Vodafone Ltd


Summary of the ObjectionsInsert additional criterion (d) to read: applicants provide certification that the proposed development meets the ICNIRP guidelines for public exposure or any subsequent government guidelines. (139)

Telecommunications cables should be placed underground so that telegraph poles and overhead wires can be phased out. (195)

Inspector’s Reasoning and Conclusions 1. The change sought by Objector 139 was made in the Second Deposit. I

conclude that no further modifications arise from this objection

2. As far as removing telegraph poles and associated wires are concerned, the Council says this is not a matter for the Local Plan because such work could be carried out without express planning permission. Whilst the idea is undoubtedly attractive, such a programme would be expensive. Without some indication as to how this would be financed I see little point in pursuing the matter here.


Recommendation4. I recommend no modifications to the Local Plan in response to objections

139/1 and 195/6.



4.17 Lifting Quality in the Built Environment Paragraphs 4.51 – 4.53The Objections034/1 Orange Personal Communications Services Ltd


Summary of the ObjectionsThe Objector generally approves of this policy but has some suggestions to rectify omissions. Consideration should be given to mentioning PPG8 and the General Permitted Development (Amendment) (England) Order 2001 and the scope of the policy could be clarified. Paragraph 4.51 should be amended to take account of the technical constraints on the location of development (or deleted). Exception is taken to the 15 metre height restriction. Paragraph 4.53 should quote directly from PPG8 paragraph 94 and 98 to provide a more balanced account highlighting operators’ obligations to


comply with ICNIRP guidelines. (034)

Areas which require special justification should include Marton Mere SSSI (NE7) and other Sites of Nature Conservation Value (NE8), as well as those already described in 4.51. (326)

Inspector’s Reasoning and Conclusions 1. Both these objections were to the First Deposit. In the Second Deposit the

Council made changes that, in my view, reasonably reflect and respond to these objections. In any event neither objector has made further representations so that I have no evidence to the contrary.

2. I conclude that no (further) modifications are needed.

Recommendation3. I recommend no modifications in response to objections 34/1 and 326/10.



4.18 Lifting Quality in the Built Environment Policy Omission New Policy Suggested on Renewable Energy Sources

The Objections296/3 Susan R. Garlick (Conditionally Withdrawn)

311/2 Future Energy Solutions

Summary of the ObjectionSustainable development should be an over-arching theme of the plan. Developers should be required to incorporate energy efficiency measures in all developments as should the re-use and recycling of construction waste. Developers should be encouraged to incorporate community recycling facilities within certain developments. (296)

The Plan should contain a specific section entitled renewable energy, which includes: (a) text outlining government policy on renewable energy, as expressed in paragraph 8 of PPG22; (b) a reference to the government's target for 10% of UK electricity requirements to be met from renewable energy generation by 2010; (c) a reference to the findings of the most recent regional renewable resource assessment and any conclusions regarding Blackpool; (d) an appropriate policy which provides clear guidance about the circumstances in which proposals for all forms of renewable energy developments will be permitted; (e) if appropriate, specific policies dealing with particular renewable energy technologies, such as wind turbines or photovoltaic cells. (311/2)

ALSO DEALT WITH HERE IS OBJECTION 311/1 TO PARAGRAPH 4.32 IN THE LOCAL PLAN

311/1 Future Energy Solutions

Summary of the ObjectionDelete the statement in paragraph 4.32 of the Local Plan “Blackpool has limited potential for large scale renewable energy due to the urbanised nature of the Borough” and alter the Local Plan to cater for the possibility that wind or wave technology, for example, will develop to the extent that planning applications for such technologies will be made within the Borough during the plan period. (311/1)

Inspector’s Reasoning and Conclusions Objector 296 (Ms Garlick)


1. This objection has been conditionally withdrawn as a result of changes made to policy LQ9 in the Second Deposit. I conclude there is no need for me to consider this matter further.

Objector 311 (Future Energy Solutions for the DTI)

2. In response to the first of these two objections to the First Deposit the Council altered and expanded paragraph 4.32 in the Second Deposit to take on board some of the issues raised by the Objector. The Objector has not responded to the changes but I think it is fair to say that the objections have not been met in full because the Local Plan still does not contain a separate section or specific policies on this topic. However, paragraph 4.32 is a far more positive statement than it was in the First Deposit, even though it anticipates that developments in this field are likely to be on a small scale and incorporated in buildings or groups of buildings.

3. Otherwise, the Council’s view is that Blackpool is a tightly constrained built up area with little scope for large-scale wind turbine development. The Council also says the prospects for wave energy development are as yet unknown but, given the importance of the Blackpool beaches for tourism, I find it hard to envisage any acceptable development within the Borough boundary of this kind.

4. The Council intends to treat any proposals for renewable power generation that do arise on their individual merits and, presumably, in the light of its general development control policies.

5. I find this approach entirely reasonable in the context of Blackpool and have no evidence that there is scope for renewable energy development on any scale within the Borough. Rather, the Objector talks in general terms about advances in technology being possible before the end of the plan period. In my view, and in accordance with general government guidance, such a speculative and uncertain approach is a poor basis for including anything in the Local Plan.


Recommendations7. I recommend no modification in response to objection 296/3.8. I recommend no modifications in response to objections 311/1 and 311/2.




5.1 Homes for Every Need Paragraph 5.2The Objection255/16 Beverley Moy

Summary of the ObjectionAmend paragraph 5.2 to reflect: the falling population, the exodus of young people from the town, vacant housing, declining economic prospects and the reluctance of builders to take up allocated land. With conversions of upper floors in the town centre and former holiday accommodation there is a case for not providing for any additional housing. (255)

Inspector’s Reasoning and Conclusions 1. This is a convenient point at which to draw together several related objections

from Mrs Moy. She seeks to minimise the amount of land to be allocated for housing, believing that no new (or additional) dwellings are needed. In particular she opposes the release of (some) greenfield sites for development.

2. The first strand in her argument is that the Council has under-estimated the number of dwellings that are likely to be provided as a result of other policies in the Local Plan, in particular:

RR11 (Loss of Holiday Accommodation);

SR3 (Blackpool North Transport Development Area);

SR4 (Redevelopment at Cookson Street / East Topping Street);

SR5 (Principal retail Core);

SR9 (Use of Upper Floors).

3. I have considered each of the objections to these parts of the plan and have not found reliable alternatives to the Council’s figures. Moreover, in the one case where the Council effectively accepts what the Objector says (policies SR3 and SR4) it transpires that the Council’s figure was too high. This could offset, in part or completely, any shortfall in the other cases. So taking the objections together and in the round I consider that her concerns about the Local Plan relying on under-estimates of conversions and the like are not substantiated.

4. Another strand in the Objector’s case is that the First Deposit failed to recognise that Blackpool’s population has fallen recently. But the Second Deposit altered paragraph 5.2 which now refers to more recent population estimates showing a decline in the 1990s. But it also records that this fall in the number of people was accompanied by an increase in the number of dwellings. Be that as it may, I consider that her objection on this matter has been met in the Second Deposit.

5. A related issue is the extent to which existing vacant properties will contribute to any requirement for new housing. The Council supplied further evidence on this matter. In short, the Council says that vacancy rates in Blackpool are lower than comparable national or regional figures so that the expected contribution from this source is not large and has already been allowed for in arriving at the Structure Plan requirement. In addition the majority of any such contribution is beyond the scope of planning legislation and would be difficult to monitor. Having taken into account the additional information supplied by the Council and the advice on this subject in the government’s guidance Tapping the Potential (cited by the Council in their supplementary proof), I consider that the Local Plan deals with this issue in a reasonable and satisfactory way.


6. Another criticism is to denigrate the Structure Plan as the source of the housing requirement in the Local Plan. She does this on the basis that the Structure Plan is imposed by an outside and alien authority that is ignorant of the detailed situation in Blackpool. The Borough Council points out that it has been party to the preparation of the Structure Plan and does not seek to question or undermine it as far as the housing requirement is concerned. More importantly, from my point of view, the Structure Plan and Regional Guidance are part of the Development Plan for the area and by law should be adhered to in general terms unless there are compelling planning reasons for doing otherwise. No such compelling planning reasons have been advanced.

7. The Objector also points to several demographic and migration characteristics of Blackpool she believes undermine any need for additional housing in the Borough. For example young people are leaving the town and there is an ageing population that will die and vacate their housing within the plan period.

8. Population projections are a complex and expert field. Reliable results are most likely to be obtained if migration movements are taken into account over a wide area together with the demographic composition of the existing population. This is why the results of the work that went into the Structure Plan and Regional Guidance are, in my view, to be preferred to Mrs Moy’s home-spun analysis (if she will accept this description) that focuses narrowly on Blackpool in isolation.

9. It is undeniable that even though Blackpool has a large number of old residents the national trend is for an increase in this segment of the population. Perhaps sadly, an ageing population leads to more old people living alone which means that the same, or even a declining, population requires more dwellings. Younger people are also living in smaller households with the same result. There is no evidence that Blackpool is exempt from these long-established and continuing trends. In short, I have no reason to depart from the Council’s view that even a smaller population will need more dwellings.

10. In any event the Structure Plan housing requirement can be met in the Local Plan without having to develop greenfield sites. And some of the sites that are to be developed have other advantages such as contributing to the town’s regeneration, improving the environment, providing affordable housing or providing other housing types that are in short supply locally. In short, I see no particular need to prevent much of the residential development that is proposed in the Local Plan. I also note that Mrs Moy does not, in fact, object to most of the individual housing allocations in the Local Plan but only to a few greenfield sites. We can, I feel, “crack” these few remaining “nuts” in the Local Plan without taking her “sledgehammer” to the plan as a whole.

11.Therefore, having noted the changes to paragraph 5.2 introduced in the Second Deposit, I conclude that no modifications to the Local Plan arise from this and Mrs Moy’s related objections.

Recommendations12. I recommend no modifications to the Local Plan in response to objection

255/16.




5.2 Homes for Every Need Policy HN1 – Housing RequirementParagraphs 5.12, 5.12a

The Objections194/69 Government Office for the North West

(Objection in part Conditionally Withdrawn subject to PC36 and PC38)

(Objection in part Conditionally Withdrawn subject to PC49 - see policy HN3)

242/ 1 / 11 House Builders Federation

251/1 Owen Baguley

253/ 8 / 9 / 18 Kensington Developments Ltd

255/17 Beverley Moy

256/1 E Sloane

279/1 C.A. Banks


289/1 Karl & Wendy Smith

303/ 1 / 9 / 20 Morris Homes

328/1 Persimmon Homes

330/1 Phil Shevloff

331/8 Mr P Wright

332/1 Dorothy Standerwick

333/1 John Terence Maddock

343/1 Yardena Shevloff

345/2 Hazel Cragg

Summary of the Objections(All GONW objections to the First Deposit are withdrawn, what follows relates to the Second Deposit.) Paragraph 5.12A should refer to the end of the plan period as 2016 and all reference to 2015 removed. The housing requirement to 2016 should be 3225 (or 2712 for the period 2003-2016, allowing for recent completions). This figure should not include replacements of any cleared dwellings as the requirement is for additional dwellings. When these revisions are taken into account there is an over-supply of 216 dwellings. PPG3 says the Local Plan should only provide for the required figures and the allocations should be adjusted downwards to reflect this. The Local Plan needs to indicate how plan, monitor and manage will be implemented to avoid the Structure Plan figure being exceeded. (194)

Low density development on greenfield sites is needed to arrest the loss of population. Poor quality conversions in the urban area are no substitute for wider housing choice. An assessment of possible property demolition over the plan period is needed. Cleared high density properties cannot be replaced on a one for one basis and 33% of the replacements should be on new allocations. (First Deposit) A Structure Plan requirement of 3200 new dwellings to 2016 is accepted. But completions in 2001 should be discounted and the figure should be provided in the period 2002-2016. (Second Deposit) (242)

The regeneration of Blackpool requires new housing. Windfalls and conversions will not supply enough housing; more land and larger sites are needed to secure growth. (251) (256) (279) (289) (330) (331) (332) (333) (343) (345)

The Local Plan should be delayed until the Structure Plan and Regional Guidance are finalised. (253)

Paragraph 5.12a: a flexibility allowance of 15% should be applied to account for potential non-implementation of conversions, windfalls and allocated sites. (253) (303)

Paragraph 5.12: the Local Plan should allocate additional housing sites which can be identified on the


Proposals Map, as advised by national planning guidance. (253)

The policy should reflect the falling population, the exodus of young people from the town, vacant housing, declining economic prospects and the reluctance of builders to take up allocated land. With conversions of upper floors in the town centre and former holiday accommodation there is a case for not providing for any additional housing. (255)

The existing requirements should be met and larger ones sought. (287)

A 2001-2016 requirement of 2600 is too low to secure regeneration. The windfall expectation of 800 is unrealistic. (First Deposit) More housing land should be released. (Second Deposit) (303)

The requirement derived from the Draft Structure Plan may change. The Local Plan should use an annualised figure for 2001-2016. Too much reliance is placed on conversions and windfalls. The assumed densities are too high. More land should be released for development. (First Deposit) (328)

Proposed ChangesPC36 would change “3200” to “3230” for the dwelling requirement 2001-2016 in policy HN1 to reflect the latest Structure Plan position.

PC37 would delete paragraph 5.11B from the Local Plan.

PC38 would update paragraph 5.12A to include figures for dwellings under construction to 1 April 2004. The plan period in the table is extended to 2016 and demolished dwellings are, in effect, added to the requirement, giving an overall requirement of 2624 dwellings 2004-2016.

PC39 would amend paragraph 5.14 to change the windfalls estimate from 750 to 600 for the period 2004-2016. (600 is the also figure included for windfalls in PC38)

PC40 would amend paragraph 5.16 also to refer to 2004-2016.

PC91 would amend paragraph 5.10 so that it also referred to a Structure Plan requirement of 3230 2001-2016 and say that the annualised requirements also run to 2016.

PC92 would add text to paragraph 5.11 to refer to the Council’s Urban Potential Study 2004 and the publication Tapping the Potential.

PC93 would further amend paragraph 5.12A (beyond the changes in PC38), principally to alter the way some replacement dwellings are dealt with in the calculations. As a result new figures are presented for: dwellings completed (725, 2001-2016), the remaining requirement (3230 - 725 = 2505 dwellings, 2004-2016), dwellings under construction (290 at 1 April 2004) and other sites with planning permission (778 at 1 April 2004). The figure for “Future Resort Masterplan Sites" is deleted. The total dwellings amount to 2816 (2004-2016), which exceeds the requirement of 2505 by 311.

PC94 would amend paragraph 5.13 to explain the figures in PC93. PC94 refers, in particular, to the additional greenfield sites now suggested for allocation in PC41, PC42 and PC43.

PC95 would amend paragraph 5.14 to refer to the Urban Potential Study as a justification for the 600 windfall allowance.

PC96 would amend paragraph 5.15 to provide a justification for the increased allowance of 800 dwellings for conversions in the plan period.

PC97 would add a new paragraph 5.15A to explain the approach to clearance / demolitions.

PC98 would delete paragraphs 5.16 to 5.19 (because the information has been included in PC94).

Objections to the Proposed Changes194/ 80 / 81 Government Office for the North West

249/ 31 / 32 / 33 / 34 / 35 Lancashire County Council

Summary of the Objections to Proposed ChangesAs Blackpool is in an “over-supply” situation the less sustainable greenfield sites should not be allocated in the Local Plan. The Objector also says there are two typing errors in PC38. (194)

The table should exclude “Sites Allocated” and “Masterplan Sites” and deal with the residual requirement to be found. The Masterplan figure has reduced markedly since the Second Deposit without explanation. (249/31) There are typing errors in the table. (249/32) (249/33) The first sentence of paragraph 5.12A should be reworded. (249/34) Demolitions will not necessarily be replaced one for one, follow the Structure Plan method. (249/35)


Inspector’s Reasoning and Conclusions 1. Objection 255/17 is identical to objection 255/16, which I have already dealt

with at length above. My reasoning here is the same and my conclusions are the same. I conclude that the Local Plan should not be modified as a result of objection 255/17.

2. Also considered here are several general objections that were made to policy H2 but are relevant to a consideration of the overall housing requirement.

3. The situation that arises from the Proposed Changes is somewhat confusing because they incorporate an updating of the figures to 2004 and some alterations to the ways the figures have been arrived at. It is not always easy to understand to which of these causes a particular change is attributable. The situation is further confused by there being two sets of Proposed Changes. Either way I consider that the (latest) Proposed Changes represent the latest and best information that has been widely publicised. I consider that I should base my recommendations on these.

4. I conclude that, subject to any modifications I recommend, the (latest) Proposed Changes should be advertised as modifications to the Local Plan.

Draft Strategic Plans / Clear Strategic Guidance

5. There were some objections to the First Deposit because it was based on (and reflected) housing requirements in an early draft of the Structure Plan and draft Regional Guidance. However, as the Local Plan has evolved and moved towards adoption, so too have the strategic plans. I note that changes in the emerging strategic plans have been reflected in the various versions of the Local Plan and now in the Proposed Changes.

6. In my view we have reached a position where the strategic context for this Local Plan is reasonably clear, fixed and reliable. The Council describe this as follows (CDH1, Housing Topic Paper): an annualised housing requirement of 5 x 175 (2001-6) and 10 x 235 (2006-16) = 3230 dwellings. This is reflected in PC36 (as far as the policy is concerned) and the other Proposed Changes (as far as the text is concerned).

7. Thus, whatever the uncertainties at the time of the First Deposit, I consider the Local Plan can safely continue on this basis. Earlier calls to delay the Local Plan until the strategic context was clearer may now be disregarded, even if they may have had more force at the time the objections were made.

8. I conclude that no further modifications are necessary to update the Local Plan to reflect the latest strategic guidance.

More Housing / Larger Requirements /Choice

9. Some objectors say that more dwellings – and especially large houses on large developments – are needed if the decline in the town’s population and economy are to be reversed and regeneration secured. In as far as these objections ignore the strategic context set by Regional Guidance and the Structure Plan; I consider they do not form an acceptable basis for the Local Plan.

10. It seems to me that if one departs from the strategic context set by the strategic plans, there would be no sound basis for deciding at what level development and land release in Blackpool should stop. This might suit some landowners and developers but it is not a sound basis for the Local Plan.


11.Even if, as some allege, the current regional guidance favours the Mersey Belt, this is the approved guidance for the region and should be followed in local plans. However, there is no evidence that reducing the rate of housing development in Blackpool is aimed at supporting the regeneration of the Mersey Belt or that it will have any harmful effects on Blackpool. My understanding of the regional situation is that there is too much housing, either built or allocated, and that an overall reduction is being pursued. If this is the case, I see no reason why Blackpool should be expected to receive special treatment.

12.The Structure Plan speaks in terms of additional new dwellings and does not specify what type of dwellings. PPG3 talks in terms of increasing the urban housing stock first, taking into account urban infilling, conversions of existing non-residential properties and other windfalls. Only after that should greenfield sites be considered. I consider there is no basis in existing policies or guidance for saying that an emphasis should be placed either on greenfield development or large sites.

13. It is argued that overall there is a need for larger detached dwellings in the Borough, although the Council points out that these housing types are “over-represented” in the adjoining authorities. More importantly, the Council argues, persuasively in my view, that the greatest need for variety and choice is in the town’s inner areas. A successful programme of improvements and conversions (to larger dwellings than in the past) in these areas will do more to meet the housing needs of the Borough than peripheral greenfield development.

14. I conclude no modifications arise from these objections.

Plan Period

15.For reasons that are not entirely clear to me, early versions of some of the text in the Local Plan described the plan period as extending until 2015. Some objectors have pointed out that the plan period should extend to 2016. As this is the plan period derived from the Structure Plan, I agree. However, the latest versions of the Proposed Changes make the necessary corrections (which for the avoidance of doubt I consider should be made throughout the Local Plan).

16.The HBF argues that the housing requirement should be spread over the years 2002-2016. I do not understand the logic of this either. The plan period is the plan period and this is 2001-2016. It starts in 2001, not 2002.

17. I conclude that no modifications to the Proposed Changes arise.

Clearance / Demolitions / Replacements

18.Some objections arose because of the way the calculations in the Local Plan took account of demolitions arising from clearance and redevelopment. My understanding is that what was at issue is whether the housing supply figures should measure net additions to the housing stock rather than the gross number of houses being built. Consistency with the way these matters are dealt with in the Structure Plan is also involved. In the main this issue arises in relation to development that has already taken place and the Council says it is less of an issue for the future because less clearance and fewer demolitions are envisaged during the rest of the plan period.

19.Be that as it may, my understanding is that the latest available figures now approach this in a way that is consistent with the Structure Plan and that net additional dwellings are being counted not the gross supply of new dwellings.


This being the case I consider this matter is resolved.


Completions

21.Having resolved the discrepancies concerning clearance and demolitions, there appears to be no dispute about the number of completions since 2001.

22. I note that the annual rate of completions since 2001 has been running at a level commensurate with the plans and needs of the 1990s rather than at the somewhat reduced rate now envisaged as being necessary. The scale of the “over-provision” (that is provision in excess of the annualised Structure Plan requirement) since 2001 is assessed as totalling 200 in three years.

23. I also note that the two large-scale and long-term housing commitments (at Marton Moss and North Blackpool) have largely been completed and there is an increasing contribution from small developments. The proportion of brownfield development has varied, the Council says depending on the level of windfalls in any one year. However, especially if conversions are taken into account, a higher proportion of brownfield development is expected in the future. I also note that higher densities, in line with PPG3, are also now being achieved.

24.On this basis the Council calculates that provision for 2505 new dwellings needs to be found between 2004 and 2016. I conclude that the Local Plan should provide for 2505 additional dwellings between 2004 and 2016.

Commitments

25.There is some argument about whether sites with lapsed planning permissions should be regarded as commitments or should be transferred to the windfall allowance (or identified as allocations if they are large enough). Three sites with a total capacity of 63 dwellings appear to be especially contentious in this respect. It is my understanding that the sites had planning permission at the time of the update, although the Council accepts that these have since lapsed. The Council says that because the sites had planning permission on 1 April 2004 they should be included in whatever category was correct on that date. Conversely, if these sites are removed from that category because their planning permissions have since lapsed, any other sites that have gained planning permission since that date should be included. The objectors point to constraints they say will prevent these lapsed sites coming forward again.

26. In my view too much can be made of the difficulties that arise because one is trying to obtain a snapshot picture of a moving target. For the purposes of carrying out any of these calculations cut-off dates have to be used. These then become somewhat arbitrary but one has to be consistent in their application. I therefore accept the Council’s argument that, if these sites are excluded, other sites that have since gained planning permission should be included (again, presumably, using another arbitrary cut-off to decide which sites should be included or excluded). I note that the April survey date, although arbitrary, is consistent with other calculations in the Local Plan and does not appear to have been selected with an eye to the results.

27. In any event, in these cases the numbers involved are not large enough to produce freak results or an unrepresentative picture. Furthermore, it does not seem to me that the alleged constraints at these sites are such as to rule out their development either in principle or for the whole of the plan period.


28. I conclude that no modifications to the Local Plan arise from a consideration of the sites with lapsed planning permissions at Warley Road, Ball Street / Ward Street and Brun Grove / Wood Park / Dover Road.

29.However, the Council acknowledges that one site (Kincraig Road) with a lapsed planning permission and a capacity of 84 dwellings should be removed from this category because its planning permission lapsed before 1 April 2004. But the Council says that on this basis it should now be reconsidered as a potential housing allocation. I return to this matter below but for the purposes of this immediate discussion it is enough to confirm that it is no longer a site with planning permission and a commitment.

30.Having considered detailed criticisms of the figures relating to sites with planning permission, I turn now to the broad brush approach of other objectors who say simply that all such figures should be discounted (by up to 15%) because some of these sites will not be developed. I have no evidence that would lead me to accept this or any other figure for discounting. In view of the long plan period remaining and the detailed assessments of the sites undertaken in the Council’s capacity studies, I consider it is unnecessary to discount these figures.

31. I conclude that the only change that needs to be made to the latest commitment figures in the Proposed Changes is to remove Kincraig Road (84 dwellings) from the figure for sites with planning permission.

Windfalls

32.The latest figure for windfalls in the Proposed Changes is 600 over the plan period. This now includes any net additional dwellings that arise from the large redevelopment proposals in the town centre (policies SR3 and SR4), which had previously been listed separately (300 (gross) in the Second Deposit, 83 (net) dwellings in PC38). The overall figure has been discounted down from a higher figure derived from the Urban Capacity Study and Resort Masterplan.

33.The rate of windfall development that is assumed is below that for recent years, although this is in some ways a less important statistic than the total number of dwelling sites identified because if the survey is reliable the pool of sites it has identified are a finite resource. Even so, there must be a possibility that some more windfall sites will become available during the plan period. (I say this partly because of the Masterplan contribution now included as a windfall.)

34.The Council claim their survey methods are in accordance with an agreed regional approach, which also complies with government guidance in Tapping the Potential. Some objectors dispute this without giving specific reasons for their criticisms. These objectors subject the sites identified in the Council’s Urban Capacity Study to further analysis and categorisation with the result that they say that some sites should be the subject of very heavy discounting (242 dwelling sites – a third of the total – are only given a one in four likelihood of completion). However, these two contrasting approaches were not tested against each other at the Local Plan Inquiry. On the balance of the evidence I have I consider there is no reason to accept the objectors approach or assessments in preference to the Council’s.

35.As already noted the Council’s assumptions on windfalls amount to a slowing in the recent historical rate at which such sites have been coming forward. It is also noteworthy that sites have actually been coming forward in the first three


years of the plan period at a higher rate than the Local Plan assumes.

36.Taking all these matters into account, I come to the view that the Council’s windfall estimates are soundly based and form a robust basis for calculating how much housing land needs to be allocated in the Local Plan.

37.There was an objection to the First Deposit to the effect that the Council’s windfall estimates should be reduced to provide an allowance for flexibility and/or non-implementation. Since the figures in PC93 have already been reduced as a result of detailed site surveys and assessments, I consider this is unnecessary and would inflate the amount of other land that needs to be found.

38. I conclude that the windfall allowance in PC93 is soundly based.

Conversions

39.Some objectors take issue with the Council’s assumptions concerning future conversions. It is agreed that the most important source of these is holiday accommodation being converted to residential use. The figure in PC93 is 800 over the plan period.

40. In my view two matters are of paramount importance when assessing the reliability of the Council’s estimate: recent past trends and the future prospects of (small) hotels in the Borough. In my view both these considerations confirm the Council’s assessment.

41.There is some argument as to whether conversions of hotels provide the accommodation that is most needed in the town but the Council says it is adopting policies that attempt to raise both the size and quality of the dwellings that are created. Either way, PPG3 and Tapping Potential indicate clearly that realistic estimates of conversions should be allowed for before greenfield land is released for housing.

42.Given the way the figures are derived (largely from past trends) an allowance for flexibility or non-implementation would not be appropriate. I note and attach significance to the fact that some objectors (for example 253) specifically say they accept the Council’s assessment of potential conversions, whilst others do not question it.

43. I conclude that the allowance of 800 conversions over the plan period is robust and a sound basis for deciding housing allocations.

The Resort Masterplan

44.Earlier versions of the Council’s calculations included an allowance (300 (gross) in the Second Deposit, 83 (net) in PC38) for an anticipated supply of dwellings on town centre redevelopment sites (policies SR3 and SR4). The ability of these sites to deliver this number of dwellings was the subject of some objection. The Council has now deleted this allowance in PC93. Because this meets the objections I consider it is unnecessary to go into more detail here. It is now acknowledged that some, perhaps the bulk, of these additional dwellings are dependent on complex redevelopment proposals that may not deliver additional housing until late in the plan period.

45.These figures are now subsumed in the windfall allowance, thus making it more robust. This is especially so towards the end of the plan period at which point the supply of windfall sites might otherwise be dropping if the sites currently


identified have not been augmented by new sites coming forward.

46. I conclude that this matter is resolved by PC93.

Densities

47.There are some objections that the densities being achieved and anticipated in Blackpool are too high. However, the Council’s approach in this respect is in accord with PPG3. Densities arise as an issue in relation to policy HN8 but for the purposes of policy HN1, I consider no modification is justified or needed.

48. I conclude that the density assumptions used in relation to policy HN1 are reasonable.

Allocated Sites: Brownfield

49.Some objectors attempt to cast doubt on the suitability of some or all of the brownfield allocations and sites in the Local Plan. These objections take two forms: generalised assertions that urban sites would be better used for recreational or other (unspecified) communal uses and particular criticisms of some of the allocated sites.

50.As far as the general criticisms are concerned, these have arisen primarily in relation to other policies in the Local Plan (in particular policy H2); although in my view they are also relevant here. Be that as it may, I deal with these objections in a little more detail under the other polices. It is enough to say here that PPG3 advocates searching for unused and underused land in urban areas that can be developed for housing. Generalised assertions that land is unsuitable are not a sufficient reason to set this guidance aside. I consider that such an approach would be in conflict with PPG3.

51.As to the specific cases, which include H16 (Coopers Way), H17 (Seymour Road) and H18 (Caunce Street), I also deal with these in more detail in relation to the site specific objections. Suffice it to say here that no modifications arise and that in every case the allocation is confirmed.

52.Site H16 is interesting for two reasons. First, the outcome suggests, to me at least, that these objectors may not have a complete understanding of every component of the housing land market and that this is relevant when considering their other objections to urban brownfield sites. Second, in view of PC44 and PC45, some upward adjustment of the housing capacity of this site may be needed.

53.This being the case, I see no reason why a flexibility or non-implementation allowance needs to be applied to these sites.

54. I conclude that none of the brownfield allocations should be deleted from the Local Plan and that the Council’s approach to this matter is soundly based. I also conclude that consideration should be given to whether, in view of PC44 and PC45, some further adjustment of the capacity of site H16 is needed.

Identifying Sites on the Proposals Map

55.At least one objector (253) drew attention to the guidance in PPG3 that a ten year supply of housing land should be identified at the time the Local Plan is adopted and that five years supply should be shown on the Proposals Map. The Council included some (previously deleted) greenfield sites for allocation in the Proposed Changes specifically to meet this line of objection.

56.As explained to me, the reason the Council has put forward these greenfield


sites for allocation is not because they are needed to meet the overall Structure Plan requirement to 2016. Rather, it is to comply with the guidance in PPG3. It is true that PPG3 says that a five year supply of housing land should be identified on the Proposals Map to guard against the possibility that windfall estimates used in preparing the Local Plan may prove to be unrealistically high.

57.However, there is no evidence the Local Plan windfall and conversion estimates are proving unrealistic. Indeed, recent rates of development are exceeding what would be needed to meet the Structure Plan requirement to such an extent that the Council now sees the need for a phasing policy to hold back development, even of brownfield land and conversions. In the Council’s view the phasing policy would prevent the release of any allocated greenfield sites now, for the foreseeable future and throughout the Local Plan period to 2016.

58.The Council says the reliance in the Local Plan on small sites and conversions arises because Blackpool is substantially built up so that a large proportion of new housing will inevitably be on sites that are too small to appear on the Proposals Map. In addition the local supply of holiday accommodation for conversions goes a long way, at least numerically, towards meeting local housing needs.

59. I find these arguments plausible and persuasive. I know that some objectors – especially those seeking the release of greenfield sites for housing – challenge the Council’s view but I consider that the balance of the available evidence and unfolding events (in terms of sites or dwellings coming forward) both support it.

60.There is potential tension between the emphasis in PPG3 on not allocating greenfield land for development if this can be avoided and the wish to identify a five year supply of sites large enough to appear on the Proposals Map. In Blackpool’s circumstances my inclination is towards giving greater priority to the preservation of greenfield land because this approach is more likely to stimulate much-needed inner urban regeneration. I am reinforced in this view by the ready and continuing availability of small sites and the rate of development that is being achieved. This means there are good reasons to accept the Council’s assessment that the development of the potential greenfield housing sites is, at best, a long-term prospect and may not happen at all.

61. It could be argued that if the proposed phasing policy works, no harm would result from allocating this land now. Whilst this may be true, there is equally no compelling housing need or planning reason to allocate the sites now and possibly pre-empt decisions that can safely and properly be left to future development plans. Moreover, because of the way the reforms to the planning system are being introduced this will, in effect, be a relatively short-term and short-lived Local Plan (albeit one prepared with a longer-term time horizon). In any event it seems perverse to allocate greenfield sites so that these can be shown on the Proposals Map and at the same time bring forward a phasing policy to ensure that the sites are not developed.

62. I conclude that there is no need or reason to allocate any greenfield sites for residential development in this Local Plan in order to comply with PPG3.

Allocated Sites: Greenfield

63.The Council has vacillated on this matter. It took greenfield sites out of the Local Plan in the Second Deposit, put them back in the Proposed Changes, said it was a matter it could leave to me in their Housing Topic Paper but then


suggested the sites’ reinstatement in their written statement BBC/WS/18.

64.The particular sites at issue are: H8 Cherry Tree Road Allotments (1.4 ha), H11 Leys Nursery (2.2 ha) and the amount of land at H4 Cornwall Place (an additional 0.6 ha or more). The total amount of land is therefore 4.2 ha or more, which at a density of 40 dwellings per ha (as indicated by policy HN8) would accommodate 168 or more dwellings.

65.At the moment PC93 indicates a housing supply of 2816 compared to a requirement for 2505. This amounts to a surplus of 311 dwellings. The Kincraig Road situation (see below) means that 84 dwellings are already in doubt, leaving a surplus of 227. Deleting the three greenfield sites listed above would reduce this further to 59. But it is still a surplus, although close enough for this not to be an issue in my view.

66.As I have indicated the Council has vacillated on these sites indicating at various times that they should not be included, should be included in order to show a five year supply on the Proposals Map and more recently included to achieve a margin of flexibility.

67.PPG3 indicates that only enough land to meet the assessed level of need should be released. I have already indicated that the “five year supply on the Proposals Map” argument is not in my view compelling in Blackpool’s situation. I have considered all the arguments relating to the assumptions and calculations that have gone into the housing requirement figures and found the figures to be reasonable. As to a margin of flexibility, in a situation in which supply is currently outstripping the annualised requirement, it could equally be argued that the best way of achieving real flexibility is to withhold these sites until the next review of the Local Plan.

68. I conclude that there is no need to allocate greenfield sites for residential development in this Local Plan and that none should be allocated.

Kincraig Road

69.The situation concerning this site has arisen late and for this reason it has not been subject to any general public scrutiny or the chance to object. Moreover the information I have is somewhat limited. (For example, I do not have a clear statement of whether the Council regards this as a greenfield or a brownfield site, although they do refer to a considerable amount of infrastructure that has been provided at the site.) According to my calculations (above) this site would not make a decisive contribution towards the overall housing requirement one way or the other.

70.The Council says they may seek to bring this site forward as an additional allocation in the Local Plan. An alternative might be to regard any development here as a windfall. In all the circumstances I consider I am not in a position to make a recommendation on the future of this site, except to say that the situation appears to be of the Council’s own making and that care should be taken not to embark on any course of action that could lead to the adoption of the Local Plan being delayed on account of it.

71. I conclude that it is for the Council to decide at the modifications stage what to do about the site at Kincraig Road.

The Need for New Allocations

72.Some argue that, whether or not enough land has been identified, the wrong


sites have been allocated. In particular sites at Marton Moss and the extended Cornwall Place are put forward as being the best that are available.

73.Whether or not these site are “better” than the greenfield sites the Council has at one time or another considered for inclusion as allocations in the Local Plan is no longer an issue in view of my conclusion that no greenfield sites should be allocated. Beyond that, PPG3 is clear that brownfield sites are to be preferred to greenfield ones. It is also possible that bringing forward new sites at this stage in the preparation of the Local Plan could give rise to new objections that would delay the adoption of the Local Plan. Be that as it may, on the merits of the sites and overall requirement I consider this to be unnecessary.

74. I conclude that no new greenfield sites should be brought forward as modifications to the Local Plan.

Typing Errors

75.Any typing errors in the Proposed Changes should be corrected.

Recommendations76. I recommend that no modification arises from objection 255/17.77. I recommend that, subject to my recommendations below and the

correction of any typing errors; PC36, PC37, PC39, PC40, PC91, PC92, PC93, PC94 (part only, delete greenfield sites), PC95, PC96, PC97 and PC98 are advertised as modifications to the Local Plan.

78. I recommend that the plan period is referred to as 2001 to 2016 throughout the Local Plan.

79. I recommend that in PC93, 84 dwellings are deducted from the total of 778 for sites with planning permission (to reflect the situation at Kincraig Road). Totals will need adjusting accordingly.

80. I recommend that no previously developed sites are deleted from the Local Plan, its tables or text.

81. I recommend that, in view of PC44 and PC45, consideration is given to whether some upward adjustment of the capacity of site H16 may be needed and that this should be carried forward into the overall housing supply figures.

82. I recommend that all three greenfield sites – H8 Cherry Tree Road Allotments (1.4 ha), H11 Leys Nursery (2.2 ha) and the additional land at H4 Cornwall Place (an additional 0.6 ha) – are deleted from the Local Plan and the tables and text adjusted accordingly.

83. I recommend that no new or additional sites are added to the housing allocations in the Local Plan.

84. I make no recommendation with regard to land at Kincraig Road.

Officers Comments

The Inspector’s Report concludes that the Council’s analysis of the sources of supply set out in the Plan to meet needs to 2016 is generally robust and soundly based.


Objections that sought the allocation of substantial additional lands (most particularly on Marton Moss) are not supported and no new sites are recommended for allocation in the Plan.

There were a number of objections that sites at Coopers Way, Seymour Road and Caunce Street Sawmills should be deleted from the Plan. In each instance the Inspector has supported the Council’s view that these are viable sites with realistic potential for residential development and has therefore upheld their allocation in the Plan.

A key conclusion where the Inspector has recommended change is the deletion of all greenfield sites. The Council’s evidence had already indicated that these sites are most unlikely to be needed to meet Blackpool’s identified housing requirement of 3,230 dwellings by 2016. Their inclusion was in response to objections and the need set out in Government Guidance to show a 5 year supply of housing land on the Proposals Map.

The deletion of the sites at Cherry Tree allotments, Leys Nursery and part of Site H4 Cornwall Place is therefore in accord with the Council’s own assessment in relation to Blackpool’s current housing requirement. Without these sites, and with planning permission subsequently already granted on a number of sites, it means few dwellings are now proposed on new sites allocated in the Local Plan. Blackpool’s housing requirement will largely continue to be provided through a mix of existing committed sites, conversions and other windfall developments.

On one other site, Kincraig Road, the Inspector concludes that this is a matter for the Council to decide at Modifications stage. The site comprises the remaining lands off Ryscar Way, north of the community hospital and the housing development currently under construction on the immediately adjoining lands to the south. This site does not have a current planning permission, but forms the last remaining parcel of land which has long been identified for development as part of comprehensive proposals set out in the existing adopted plan for north east Blackpool, and also set out in subsequent more detailed planning guidance.

Nearby residential developments, Kincraig Primary School, the Spar store, playground, and community hospital have all been completed. Major new road and drainage infrastructure has also been completed to cater for the demands of this site and the wider development lands.

The Inspector states the scale of the site (2.2 hectares, potentially providing 84 dwellings at 40 dwellings per hectare) is not such as to make a decisive contribution towards the overall housing requirement one way or the other. It is accordingly considered the site should be excluded from the Plan, to potentially be regarded as a windfall at some time in the future.


The Inspector’s recommendations 76 to 84 are accepted.

As a result of recommendation 77 it is accepted that PC36, PC37, PC39, PC40, PC91, PC92, PC93, PC94 (part only, delete greenfield sites), PC95, PC96, PC97 and PC98 are advertised as modifications to the Local Plan:

PC36 Amend policy as follows:‘Proposals for residential development will be permitted on allocated sites and through other identified opportunities to provide for the development of 3,200 3,230 new dwellings between 2001-2016.

PC37 Delete paragraph 5.11B:‘With forecast date for adoption of the Revised Deposit Draft Local Plan in 2005, the plan now needs to identify a 12 year supply of housing (2003-15), and identify a 7 year supply of sites on the Proposals Map (in 2003) to meet the 5 year requirement from 2005.’


PC39 Amend paragraph 5.14 as follows:‘The estimate of 750 600 dwellings from windfall sites …’

PC40 Amend paragraph 5.16 as follows:‘Taken together the above sources make provision to meet Blackpool’s Policy HN1 (2003-2015) (2004-2016).

PC91 Amend paragraph 5.10 to:The Revised Deposit Joint Lancashire Structure Plan proposes that Blackpool should provide for an additional 3,230 dwellings homes over the Plan period to 2016, with an annualised requirement of 175 dwellings in the period 2001-06 and 235 dwellings in the period 2006-16 dwellings per annum, compared to 280 dwellings per annum through the 1990’s. This reduced level of planned housing development provides no basis for any new greenfield housing development.

PC92 Amend paragraph 5.11 to:Over the last 3 years (1998-2001) before the start of the current plan period over half of the new housing development in Blackpool took place on greenfield sites. Up to 2006 further development will continue on longstanding greenfield sites on Marton Moss and in north east Blackpool, but increasingly new sites coming forward for development are located on brownfield land. The likelihood of this trend continuing over the plan period was assessed in the Council’s ‘Urban Potential Study 2004’, which evaluated the potential of sites and buildings within the Blackpool urban area to accommodate new housing development. The study utilised an approach consistent with the Government guide to better practice set out in ‘Tapping the Potential’ and followed the methodology set out in the NWRA guidance document: ‘Exploring Urban Potential for Housing’. The study concluded that the housing requirement could be met by focusing further new housing development will be on brownfield land.

PC93 Amend paragraph 5.12A (also taking account of Recommendations 79 & 82 below) to:

Blackpool’s Policy HN1 annualised housing requirement to 2016 comprises 5x175 (2001-6) and 10 x 235 (2006-16) = 3230 dwellings. A total of 764 817 additional dwellings, were completed in the period 2001-04 with 158 dwellings demolished. 92 of these represent off-site replacements for dwellings demolished in redevelopment schemes in which the full provision for replacement will not be made on-site. In accordance with draft Joint Lancashire Structure Plan policy these dwellings have not been counted towards meeting the housing requirement. The net contribution to meeting the housing requirement of 3,230 dwellings is therefore 725 dwellings, leaving a requirement of 2505 dwellings for the remaining period of the Plan (2004-16). The remaining requirement (2004-2016) is therefore 2,624 dwellings (3230 - 764 + 158 = 2624). Provision is accordingly made in the Plan to meet Blackpool’s needs to 2016 from the following sources of supply:

Dwelling requirement (2004-2016) 2,505Under construction (at 01.04.04) 290Other sites with planning permission 778 – 84 = 694

Future allowance for conversions 800Future allowance for windfall sites 600Sites allocated for residential development 348 – 180 = 168

Total Dwellings 2,816 – 84 – 180 = 2,552


PC94 Amend paragraph 5.13 to:Taken together the above sources make provision to meet Blackpool’s housing requirement for the period 2004-2016 on a range of types and size of site whilst giving priority to the development of previously-developed land and the conversion of existing buildings. The new housing sites allocated for development are set out in Policy HN2 of the Plan. The allocations include those sites identified in the ‘Urban Potential Study’ greater than 0.2 hectares in size, which are either available for development, or which form key components of regeneration initiatives proposed elsewhere in the Plan. The greenfield allocations are included to satisfy the requirement to show at least five years supply of housing on the proposals map. The release of all sites for development is subject to the phasing mechanism set out in Policy HN3. PC95 Amend paragraph 5.14 to:The estimate of 600 dwellings from windfall sites is in line with recent rates of provision and is supported by the results of the ‘Urban Potential Study’. The further allowance is made for includes new housing development opportunities potentially arising through the Resort Masterplan.

PC96 Amend paragraph 5.15 to:The estimate of 600 800 dwellings from conversions is similarly based on the results of the ‘Urban Potential Study’. an assessment of recent trends, and The allowance is below the average over the past 5 years reflecting the anticipated effect of the more restrictive approach to the development of one bedroom units set out in Policy HN7 and potential limitations on the available supply of buildings suitable for conversion.

PC97 Add new paragraph 5.15A as follows:During the plan period housing renewal and other regeneration programmes may involve the clearance of housing to assist the wider regeneration of an area. The loss of existing dwellings in housing clearance or redevelopment schemes and the dwellings built to replace those demolished, whether provided on-site or off-site, will not contribute towards meeting the overall housing requirement.

PC98 Delete paragraphs 5.16 – 5.19

As a result of recommendation 78 the plan period is to be referred to as 2001-2016 throughout the Local Plan

As a result of recommendation 79, 84 dwellings are deducted from the total of 778 for sites with planning permission (to reflect the situation at Kincraig Road). Totals will need adjusting accordingly.

As a result of recommendation 81, the Inspector states the Council should give consideration as to whether some adjustment is required of the capacity of site H16, Coopers Way (Abattoir) site. This has been considered and no increase is required, the enlarged site having already been accounted for.

As a result of Recommendation 82 all 3 greenfield sites - H8 Cherry Tree Road Allotments (1.4 ha), H11 Leys Nursery (2.2 ha) and the additional land at H4 Cornwall Place - are deleted from the Plan.

As a result of recommendations 77, 79, and 82, the revised recommended tables and text at paragraph 5.12A are set out above (see PC93).

As a result of consideration of recommendation 84, it is recommended the Kincraig Road site should be excluded from the Plan, to potentially be regarded as a windfall at some time in the future.


5.3 Homes for Every Need Paragraphs 5.10 – 5.11The Objection326/ 12 / 13 CPRE (Lancashire Branch)

Summary of the ObjectionAdd "Brownfield sites must meet a minimum of the 79% of housing needs forecast in the JLSP Deposit Edition and the development potential on these sites should be maximised with schemes proposing a minimum of 40 dwellings per hectare being considered preferentially". (326/13)

Paragraph 5.11 refers to longstanding commitments to the development of greenfield sites at Marton Moss. To accord with PPG3, all permissions and renewals should be reviewed against the availability of brownfield locations. (326/12)

Proposed ChangesPC37 suggests that paragraph 5.11B in the Second Deposit should be deleted.

PC91 suggests a rewording of paragraph 5.10 and alterations to some of the figures.

PC92 suggests an addition to paragraph 5.11 to indicate the results of the Council’s Urban Potential Study 2004 and the likelihood that the outstanding housing requirement can be met on brownfield land.

Inspector’s Reasoning and Conclusions 1. The Council says that density is dealt with in policy HN8. There does not seem

to be any disagreement between CPRE and the Council about what the appropriate density should be. I see no need to deal with this subject here as well as in policy HN8.

2. As to the proportion of development that should be on previously developed land, the Council added this as a Housing Chapter Target in the Second Deposit. In addition the revised (Second Deposit) wording of paragraphs 5.10 and 5.11 now indicates that the Structure Plan housing requirement can be met without using greenfield land. Thus there is now no disagreement about this with CPRE.

3. However, in this case I consider it would be appropriate to deal with the matter at the start of the Chapter as well as at the end of it because otherwise the origin of the target would not be recorded.

4. I conclude that the following should be added at the end of paragraph 5.10: “This means that the Structure Plan target that at least 80% of new housing should be on previously developed land will be met.”

5. As far as the commitments at Marton Moss are concerned, the Council says that these have planning permission and for this reason cannot be deleted. In accordance with PPG12, I accept that this is the case and conclude that no modification is required.

6. In addition, as a result of recommendations I have made elsewhere, I conclude that paragraph 5.11A should be deleted.

Recommendation7. I recommend that the following should be added at the end of paragraph

5.10: “This means that the Structure Plan target that at least 80% of new housing should be on previously developed land will be met.”

8. I recommend no modification in response to objection 326/12.9. I recommend that paragraph 5.11A of the Local Plan should be deleted.



The Inspector’s recommendation (7) that the following should be added at the end of paragraph 5.10 is accepted: “This means that the Structure Plan target that at least 80% of new housing should be on previously developed land will be met.”

The Inspector’s recommendations (8) and (9) are accepted.

5.4 Homes for Every Need Paragraph 5.12The Objections195/5 Blackpool Combined Association

Summary of the ObjectionParagraph 5.12: “Restrictions (should) be placed on Housing Association acquisitions to protect new developments and to encourage home ownership particularly property at the lower end of the market”. (Full Quote) (195)

Inspector’s Reasoning and Conclusions 1. The Council rightly points out that this sort of restriction on tenure (or property

ownership) is not a planning matter as the law currently stands.

2. In any event, it is not clear how such a restriction would “protect new developments” or, indeed, that there is a problem that new developments need to be protected from. In addition, shared equity schemes (operated by Housing Associations) are an effective way of extending home ownership at the lower end of the market.



195/5.



5.5 Homes for Every Need Paragraphs 5.16 – 5.19The Objection242/2 House Builders Federation

Summary of the ObjectionThe Local Plan process should be halted until such time as the development industry has been properly consulted. The ensuing market realism will promote adjustments to all numerical housing targets. (242)

Inspector’s Reasoning and Conclusions 1. This objection is similar to an objection from Objector 253 (Kensington


Developments) to policy HN1 that also said that Local Plan preparation should be put on hold (in their case until strategic guidance was clearer).

2. Although these objections have not been withdrawn, I consider they have been overtaken by events. As far as the HBF objection is concerned, there has now been considerable consultation on the Council’s proposals and the underlying assumptions and work behind them. I consider that no useful purpose would be served by halting the preparation of this Local Plan now.

3. I conclude the Local Plan should not be modified on account of this objection.


objection.



5.6 Homes for Every Need Policy HN2 – Housing AllocationsThe Objections028/1 L.A. Moss

177/1 Mr J B Clarke

230/3 S Clark

242/ 3 / 12 House Builders Federation

(Objection 12 Conditionally Withdrawn subject to PC40, PC41, PC42, PC43 and PC44)

251/2 Owen Baguley

253/ 7 / 14 Kensington Developments Ltd

256/2 E Sloane

279/2 C.A. Banks


303/ 2 / 21 Morris Homes

319/1 G J Moss


327/4 Miss A J Gray


330/2 Phil Shevloff

331/7 Mr P Wright




345/3 Hazel Cragg

Summary of the ObjectionsLand at Marton Moss is no longer suitable for horticulture and should be allocated for housing (or as


part of a mixed development. It is suitable for housing development, which would have advantages for the locality. (028) (230) (253) (303) (319) (328) (331) (These objections are dealt with in detail under Policy NE3, Site 3.2.)

10 ha of land west of Staining should be allocated for residential development to increase the supply of housing land. (177) (This objection is dealt with in conjunction with a matching objection - 177/2 - to policy NE3, Site 3.1.)

More land should be allocated for housing. (253)(331)(345)(Objections dealt with under policy H1)

The Council’s Urban Capacity Study has not been conducted in accordance with government guidance and is not a sound basis for decisions in the Local Plan. (First Deposit) Greenfield sites are needed to secure an adequate five year supply of housing land on the Proposals Map and a ten year supply overall. Greenfield sites should be reinstated with less reliance on windfalls and conversions. (Second Deposit) (242) (Conditionally Withdrawn after Proposed Changes) (But see under policy H1)

Many of the urban sites allocated for development in the Local Plan are small and should be retained for community use such as public open space. (251) (256) (279) (289) (330) (332) (333) (343) (345) (see also under policy H1)

There are doubts as to whether some of the allocated sites can or will be developed. Other land should be allocated instead. (253) (Second Deposit) (Objection dealt with under policy H1)

The sites brought forward in the Second Deposit are less in accord with PPG3 than development at Marton Moss. (303) (Second Deposit) (This objection is dealt with under Policy NE3, Site 3.2.)

Site H4 is greenfield land and need not be developed. (326) (327) (These objections are dealt with under Site H4.)

Site H11 is greenfield land and need not be developed. (326) (327) (These objections are dealt with under Site H11.)

Site H8 is greenfield land and need not be developed. (327) (This objection is dealt with under Site H8.)

Land between Bennets Lane and Progress Way should be developed. It is a small area that could be regarded as infilling. (331) (This objection is dealt with under Policy NE3, Site 3.2.)

Proposed ChangesPC41: Site H8 was allocated for residential development in the First Deposit but deleted in the Second Deposit. PC41 seeks to reintroduce it to the Local Plan.

PC42: Site H11 was allocated for residential development in the First Deposit but deleted in the Second Deposit. PC42 seeks to reintroduce it to the Local Plan.

PC43: increase the size of the H4 allocation from 0.5 ha to 0.9 ha (see map HN2PMC1).

Objections to Proposed Changes249/36 Lancashire County Council

253/19 Kensington Developments

255/19 Mrs Moy

303/9 / 10 Morris Homes

Summary of the ObjectionsThere is no need to allocate the greenfield sites proposed in the Proposed Changes which would be in danger of early development notwithstanding the Phasing Policy, H3. (249) (255) (These objections are dealt with under policy H1 and the individual sites.)

There are better greenfield sites than Cherry Tree allotments (H8). (253) (This objection is dealt with under site H8, below.)

The whole of the allocation in the First Deposit at Cornwall Place (H4) should be reinstated. (303) (This objection is dealt with under site H8, below.)

Inspector’s Reasoning and Conclusions 1. Most of these objections are dealt with elsewhere, either under policy H1 or in


relation to the individual sites that are referred to in the objections. Sites at Marton Moss and west of Staining are dealt with under policy NE3 in Chapter 8 of my report.

The Overall Need for Housing Land

2. However, at the risk of repetition, I have already concluded in relation to policy H1 that (if PC36 and PC93, as amended by my recommendations, are followed) enough housing development is being provided in the Local Plan. Admittedly much of the provision is in small urban sites and conversions. In my view this arises from the character of Blackpool and is in accordance with the guidance in PPG3. I consider the Local Plan is soundly based in this respect.

3. I have also concluded in my consideration of policy HN1 that there is no need to release any greenfield land to meet the housing requirement for this Local Plan.

4. This being the case, whether land at Marton Moss is (or is not) to be preferred to sites H4, H8, H11 or any other greenfield site is beside the point.

Comparing Sites

5. As to the merits of particular allocated sites, these are dealt with below.

6. Apart from the larger sites, many objectors with an interest in developing at Marton Moss say the small urban sites that have been identified at one time or another for housing development in the Local Plan would be better used for other purposes. However, the majority of these objections do not identify specific shortcomings in individual allocated sites (or sites previously identified in policy H4) and I have no evidence that would lead me to reject them.

7. Other objectors argue their preferred (greenfield) sites are more sustainable than the urban sites allocated in the Local Plan. Where comparisons between identified sites are made, I take the view that previously developed land is to be preferred to greenfield land and that sites that are within the urban area are to be preferred to sites that are not.

Infilling

8. Another argument sometimes advanced (for example by Objector 331) is that small parcels of greenfield land should be regarded as infilling. My own use of the term infilling is reserved for very small frontage sites that could accommodate at most one or two houses between existing properties. In most cases objectors are seeking to exceed this very tight definition, which I am not inclined to accept. Be that as it may, in a fragmented area such as Marton Moss, for example, even limited infilling could cumulatively amount to considerable development in total.

The HBF

9. At the First Deposit the HBF objected to the Council’s work on Urban Capacity but this criticism was not repeated later. I consider that, whatever the situation was at the time of the First Deposit, the results of the Council’s work have now been adequately publicised and tested. I note that some objectors still express doubts as to whether the sites identified by the Council can or will come forward but all the evidence is that the supply of land is being maintained at least at the rate required by the Structure Plan. I note that the HBF would withdraw its criticism if the greenfield land identified in the Proposed Changes is allocated


but for the reasons given above, I consider this is not necessary.

Individual Site Objections

10. I have already said that I have concluded there is no need to allocate greenfield land for residential development in this Local Plan. I will assess each of the sites identified in the Proposed Changes and all the other objection sites as I deal with site-specific objections below. However, although this may be anticipating what follows, for the avoidance of doubt this means that PC41, PC42 and PC43 should not be pursued.

Recommendations11. I recommend no modification to policy HN2 in response to these

objections. 12. I recommend that PC41, PC42 and PC43 should not be pursued.



5.7 Homes for Every Need Policy HN2 – Site H1The Objection110/1 James Alexander Williamson

Summary of the ObjectionThe site includes part of the Objector’s back garden. He would not like to see it developed. (110)

Inspector’s Reasoning and Conclusions 1. This site was deleted in the Second Deposit. I conclude there is no need for me

to consider the matter further.


objection.



5.8 Homes for Every Need Policy HN2 – Site H2The Objections133/1 Mr Mark Hayes

134/1 Barry Jones

138/1 Mrs Margaret Olive Hutchence

144/1 Ruth McArthur

149/1 Stephen Pattinson

150/1 Lesley Stephens


151/1 Victoria Scott

181/1 Mr Derek Wild (Conditionally Withdrawn)

193/1 Mrs Rose Marie Wild (Conditionally Withdrawn)

Summary of the ObjectionsThis site cannot be developed without impinging unduly on the amenity of existing adjacent dwellings. Delete the allocation. Security should be improved. (133) (134) (138) (144) (149) (150) (151) (181) (193)

Inspector’s Reasoning and Conclusions 1. The Council accepts that the area that can be developed here is below the

threshold for inclusion as a housing site in the Local Plan. The Council deleted the site in the Second Deposit. As far as I am concerned this is the end of the matter and I conclude that no (further) change to the Local Plan is required.

Recommendations2. I recommend no modification to the Local Plan in response to these

objections.



5.9 Homes for Every Need Policy HN2 – Site H3The Objections078/4 Peter McGreevy


329/5 Sport England

Summary of the ObjectionThis site should not be allocated for housing development. (078)

This site should be retained as open space for community use. Its development would cause problems. The allocation should be deleted from the Local Plan. (255)

The site should be protected under Policy BH7 of the Plan and the allocation for housing is inappropriate. (329)

Inspector’s Reasoning and Conclusions 1. Although this site was proposed for housing in the First Deposit, the Council

says that ground conditions make it unsuitable for housing. The housing allocation was deleted in the Second Deposit. It is not proposed to reintroduce it. In my view this meets the objections to the housing allocation.

2. That leaves the objections from Sport England and Mrs Moy that the site should be protected as open space, as far as Sport England are concerned under policy BH7.

3. The Second Deposit indicates that the objection site is to be added to the adjacent open area designated as Urban Greenspace under policy NE11. I note that this area is marked on the OS map as a playing field and it looks as if it could have been used for this purpose in the past, although I have no evidence one way or the other. In view of this and the changed scope of policy BH7 in the


Second Deposit (to deal with all playing fields and not just school playing fields) it seems to me that this could be the appropriate designation for (at least) the adjoining open land.

4. However, there is no objection to the NE11 (E11.2) designation. I therefore limit myself to concluding that, if this or the adjoining land was last used as a playing field, consideration should be given to designating site H3 and the adjoining open land under policy BH7. Otherwise both areas should retain their NE11 designations.

Recommendation5. I recommend that consideration is given to designating site H3 and the

adjoining open land under policy BH7. Otherwise both areas should retain their NE11 designations.

Officers Comments

The Inspector supports the Council’s allocation of the site as urban greenspace under Policy NE11, which recognises the particular attributes and potential of the wider adjoining land to create a ‘wild’ natural greenspace as against more formal recreational provision. He additionally recommends consideration is given to allocating the site under Policy BH7 (playing fields). As the H3 site and the wider adjoining land are no longer used as a playing field (and have not been for a number of years – with currently no formal access over the adjoining lands), it is considered the lands should not appropriately additionally be allocated as public open space.

Under Policy NE11 no development will be permissible and the lands fully safeguarded and enhanced as an important open landscape area.


Following consideration, the Inspector’s recommendation is accepted that the site should retain its NE11 designation, but should not be allocated under Policy BH7.


5.10 Homes for Every Need Policy HN2 – Site H4The Objection303/10 Morris Homes

Summary of the ObjectionThe allocation at Cornwall Place should be retained as 1.8 hectares as in the First Deposit. (Second Deposit) (303)

ALSO DEALT WITH HERE ARE OBJECTIONS TO POLICY HN2

(FOR MORE DETAILS OF OBJECTION NUMBERS, SEE UNDER POLICY HN2)

Site H4 is greenfield land and need not be developed. (326) (327)

Proposed ChangesPC43: increase the size of the H4 allocation from 0.5 ha to 0.9 ha (see map HN2PMC1).

Objections to Proposed Changes0145/59 Mrs F A Cunningham

249/36 Lancashire County Council

255/19 Beverley Moy

303/10 Morris Homes

Summary of the ObjectionsThis is greenfield land and valued as such. It should not be allocated for residential development while other sites are available. (145, 255)

Sufficient land is allocated to meet the strategic housing requirement and this land is unlikely to be needed for development until beyond 2010/2011. Allocating this site now will not help achieve brownfield development. The site should not be allocated. (249)

The increase in the site’s area is welcomed but does not go far enough, restore the full First Deposit site. (303)

Inspector’s Reasoning and Conclusions 1. At the time of the Local Plan Inquiry housing development was taking place at

Cornwall Place. It would appear that any development beyond what is already taking place would extend the housing onto greenfield land.

2. As indicated in my general discussion of the objections to H1 and H2, the policy context is clear. The allocation of (more) greenfield land is not required to meet Structure Plan targets and should not take place. This being the case I consider that the allocation here should be kept to the minimum that is already committed because of any extant planning permissions.

3. The Council and Objector now suggest that this extended site should be allocated and shown on the Proposals Map in order to comply with guidance in PPG3. I have dealt with this matter fully under policy H1 where I conclude that greenfield land should not be allocated only for this reason.

4. Objector 303 takes the view that the whole of the site allocated in the First Deposit should be reinstated. This is because the site is in the urban area so that this site is more sustainable than the greenfield sites the Council has from time to time put forward as residential allocations. Be that as it may, I am not recommending that any greenfield sites are allocated. For this reason I do not consider such comparisons to be decisive.

189Homes for Every Need Chapter 5

5. In my view, this site is not more sustainable than previously developed land within the urban area. In particular it is not more sustainable than the various urban previously developed sites to which Objector 303 has made specific objections. In line with PPG3 these are to be preferred to this site.

6. I do not dispute that this site would be suitable for development if it were needed to meet the Structure Plan housing requirement. I accept it has many merits and advantages, as detailed by the Objector. I also accept that the proposed development would complement the adjoining housing area allowed on appeal. This site may indeed be amongst the best greenfield sites in the Borough. But it is greenfield land and it is not needed to make up the Structure Plan housing requirement.

7. Whilst I note the evidence supplied by Objector 303 and BBC on the nature conservation importance of this site, in my view this is not the decisive consideration in determining whether to allocate the site for development.

8. I conclude that the area of land allocated for housing at Cornwall Place should not be extended beyond the area already with planning permission for housing development. Unless an area with planning permission is involved, PC43 should not be pursued.

Recommendations9. I recommend that the area of land allocated for housing at Cornwall Place

should not be extended beyond the area already with planning permission for housing.

10. I also recommend that PC43 is not pursued unless planning permission for residential development has already been granted on the land that would be affected.


The Inspector’s recommendations are accepted and Site H4 is deleted from Policy HN2, with the area with planning permission shown as a commitment on the Proposals Map. .

5.11 Homes for Every Need Policy HN2 – Site H8Objections to Proposed Changes0145/59 Mrs F A Cunningham


255/19 Beverley Moy


Summary of the ObjectionsThis is greenfield land and valued as such. It should not be allocated for residential development while other sites are available. (145, 255) The site is still needed for allotments. (255)


Whilst there is a need for some greenfield land to be allocated for housing, this site is poorly related to


services and is not in a sustainable location. (253)



Site H8 is greenfield land and need not be developed. (327)

Proposed ChangesPC41: Site H8 was allocated for residential development in the First Deposit but deleted in the Second Deposit. PC41 seeks to reintroduce it to the Local Plan.


253/19 Kensington Developments

255/19 Mrs Moy

303/9 Morris Homes

Summary of the ObjectionsThere is no need to allocate the greenfield sites proposed in the Proposed Changes which would be in danger of early development notwithstanding the Phasing Policy, H3. (249) (255)

There are better greenfield sites elsewhere in the Borough, more sustainable and accessible and better related to the urban area. (253) (303)

Inspector’s Reasoning and Conclusions 1. The Council’s position on this site has vacillated. However, I have concluded

(see policy H1) that this land is not needed in order to reach the overall Structure Plan housing requirement. Given the history of this site as the Local Plan has evolved (in – out – in); the Council clearly views H8 as a marginal housing site. However, there is no dispute that it is greenfield land. In terms of the PPG3 sequential approach to housing land release, it should therefore rank below all urban previously developed land.

2. The Council now suggests (in the Proposed Change) that this site should be allocated and shown on the Proposals Map in order to comply with guidance in PPG3. I have dealt with this matter fully under policy H1 where I conclude that land should not be allocated only for this reason.

3. Against this background, the need to preserve the land for allotments is not, in my view, a decisive consideration. The Council says that the land has not been used as allotments for some years and is not needed. Mrs Moy is suspicious that such matters can be manipulated to achieve a vacant site if this is desired. To be frank neither side in this particular argument has produced sufficiently strong evidence to entirely convince me one way or the other, although the longer the site remains unused without objections from would-be plot-holders, the stronger the Council’s position looks. In any event the demand for allotments fluctuates and this is perhaps another reason for not rushing to allocate the land for development now. Be all that as it may, I repeat that in my view this is not a decisive consideration in this particular decision.

4. Similarly, against the background that there is no need to allocate any greenfield land for development, the supposed superiority of other greenfield sites is not a decisive consideration either.

5. I conclude that site H8 should not be included as an allocation for residential development in the Local Plan. This means that I recommend no change to the (Second Deposit) Local Plan and that PC41 should not be pursued.


Recommendation6. I recommend that site H8 is not allocated for residential development in

the Local Plan and that PC41 is not pursued.


The Inspector’s recommendation is accepted that site H8 (Cherry Tree Road allotments) should not be allocated for residential development.

5.12 Homes for Every Need Policy HN2 – Site H11The Objections145/9 Mrs F A Cunningham (Conditionally Withdrawn after Second Deposit)

198/2 Tina Mulgrew

201/2 Gary Blamires

205/2 J Christie

Summary of the ObjectionsExclude site H11 from Policy HN2. (145, 198, 201, 205) (All First Deposit Objections)



Site H11 is greenfield land and need not be developed. (326) (327)

Proposed ChangePC42: Site H11 was allocated for residential development in the First Deposit but deleted in the Second Deposit. PC42 seeks to reintroduce it to the Local Plan.

Objections to the Proposed Change0145/59 Mrs F A Cunningham


255/19 Beverley Moy

373/1 Philip Megson

374/1 Hayley Wills

375/1 Linda Robinson

376/1 Robert Woods

377/1 Steven Mallalay

378/1 Hilary Woods

379/1 Mrs Reeves

380/1 Lyndsey Russell

381/1 Mary Baldwin

382/1 Karen Baldwin

383/1 J Fairclough

384/1 Mary Meadows

385/1 Mrs C Cunningham

Summary of the Objections


This is greenfield land and valued as such. It should not be allocated for residential development. (145, 255, 373, 375, 377, 378, 379, 380, 381, 382, 383, 384, 385)

The site is used informally for recreation and should be kept as public open space. (255, 373, 374, 375, 376, 380, 381, 382, 384)


Inspector’s Reasoning and Conclusions 1. The Council’s position is that this land is not needed in order to reach the

overall Structure Plan housing requirement. As I indicate in my consideration of objections to policy HN1, I accept that this is the case.

2. Given the history of site H11 as the Local Plan has evolved (in – out – in); the Council clearly views this as a marginal housing site. However, that it is greenfield land is not disputed. Therefore, in terms of the PPG3 sequential approach to housing land release, it should rank below all urban previously developed land.

3. The Council now suggests (in the Proposed Change) that this site should be allocated and shown on the Proposals Map in order to comply with guidance in PPG3. I have dealt with this matter fully under policy H1 where I conclude that land should not be allocated only for this reason.

4. Against this background, the wish of some objectors to designate the land as public open space is not a decisive consideration. The Council says that it has yet to review the amount and distribution of public open space and pitches in the Borough but that this site is not in an area with the most pressing needs. Mrs Moy and others do not accept this. Neither side in the argument has produced convincing evidence one way or the other, so perhaps it would be wise to maintain the present situation at this site pending the review of public open space that is promised. This is another reason for not rushing to allocate the land for development now. However at this stage, until a wider review has been undertaken, I do not recommend that the site is allocated as public open space.

5. I conclude that site H11 should not be included as an allocation for residential development in the Local Plan. This means that I recommend no change to the (Second Deposit) Local Plan and that the site should remain unallocated. In other words I conclude that PC42 should not be pursued.

Recommendation6. I recommend that site H11 is not allocated for residential development in

the Local Plan and that PC42 should not be pursued. 7. I further recommend that the site should remain unallocated pending the

Council’s review of its open space and playing field requirements.


The Inspector’s recommendations are accepted that the Leys Nursery site should not be allocated for residential development and remain unallocated in the Local Plan.


5.13 Homes for Every Need Policy HN2 – Site H14The Objections3/1 Mr R Tustin (Conditionally Withdrawn)

4/1 Mr D McGorrin (Conditionally Withdrawn)

5/1 Mrs E Tustin (Conditionally Withdrawn)

6/1 Mrs D McGorrin (Conditionally Withdrawn)

Summary of the ObjectionThe boundary of this allocation should be amended. (003) (004), (005), (006)

Inspector’s Reasoning and Conclusions 1. The boundary of the allocation was amended as suggested in the Second

Deposit. As a result these objections to the First Deposit were all conditionally withdrawn.

2. I conclude that no (further) modification to the Local Plan arises.


objections.



5.14 Homes for Every Need Policy HN2 – Site H16The Objections145/51 Mrs F A Cunningham


303/11 Morris Homes

Summary of the ObjectionsThe site should be retained as a housing opportunity site and deleted as a housing allocation. (303)

The land at Coopers Way should be a housing opportunity site and deleted as an allocation. (253)

The entire site should be allocated for residential development. (145)

Proposed ChangesPC44: increases the proposed allocation from 1.3 ha to 1.9 ha to reflect a planning application.

PC45: reallocates the whole of site H16 for housing for the same reason.

Objections to the Proposed Changes253/020 Kensington Developments Ltd


303/11 Morris Homes

Summary of Objections to Proposed ChangesThere are doubts as to whether the site will come forward; its poor surroundings, poor marketability and possible contamination make it doubtful. (253) (303)

Inspector’s Reasoning and Conclusions 1. I note that Objector 145 supports the Proposed Changes but she does not say

she withdraws her original objection because of them.

2. The Council says that planning permission has been granted and the site has been sold to a housing developer at an auction for £3.45 million. When I went to the site it was being cleared. In my view it looked to be a common-sense extension to the relatively recent adjoining housing development. To my mind these considerations are a complete answer to objectors 253 and 303.

3. It also suggests, to me at least, that these objectors may not have a complete understanding of every component of the housing land market and that this is relevant when considering their other objections to urban brownfield sites.

4. I conclude that PC44 and PC45 should be advertised as modifications to the Local Plan.

5. These Proposed Changes make me wonder whether the number of dwellings assumed for this site under policy HN1 is now correct.

Recommendation6. I recommend that PC44 and PC45 are advertised as modifications to the

Local Plan. 7. I have already recommended that the implications of these Proposed

Changes should be reflected in policy H1 and its accompanying text.


The Inspector’s recommendations are accepted and accordingly PC44 and PC45 are advertised as proposed modifications to the Local Plan:

PC44

Amend size of the following new housing allocation: Site H16 Coopers Way (Abattoir) 1.3ha 1.9 ha.

PC45

Reallocate H16 on proposals map wholly as a housing site (Policy HN2)

In addition, as a direct consequence reflecting the allocation of the whole of the site for housing, PC66 should be advertised as a proposed modification the Local Plan

PC66

Delete site E9 Coopers Way (Abattoir) 0.6H from Policy DE1

5.15 Homes for Every Need Policy HN2 – Site H17The Objections



303/12 Morris Homes

Summary of the ObjectionsThe land at Seymour Rd should be deleted as a housing allocation. (253), (303)

Proposed ChangesPC46: amend site boundary as in HN2PMC6

Objections to the Proposed Changes253/021 Kensington Developments Ltd

303/12 Morris Homes

Summary of Objections to Proposed ChangesThere are uncertainties about whether the site will come forward and its marketability. (253) (303)

Inspector’s Reasoning and Conclusions 1. These two “housing based” objections need to be viewed in the context of all

the objections from these objectors. They are seeking the allocation of greenfield land for housing development. To this end they seek to increase the overall amount of land allocated for housing in the Local Plan and to minimise the amount of land that can be found for this purpose within the urban area. In effect they wish to substitute greenfield land for this site.

2. I have no doubt that in terms of the sequential test in PPG3, site H17 is preferable to the alternatives they have in mind. All that remains to be explored is whether there is a realistic prospect of this site coming forward within the Local Plan period.

3. The objectors say there are doubts as to whether this site will come forward. They acknowledge that the site has planning permission but describe this as “premature” in advance of decisions on policy RR15. Premature or not, it is a fact and a material consideration.

4. Despite the objectors’ attempts to cast doubts on the site’s suitability and the likelihood of it being developed, it is my view that with a suitable design, a satisfactory environment can be created notwithstanding the other uses in the vicinity. It is brownfield land of the sort that PPG3 advocates being used for housing.

5. I conclude that there are no sound planning reasons not to allocate this site for housing or to suppose that it will not be delivered well within the plan period.


objections.



5.16 Homes for Every Need Policy HN2 – Site H18The Objections


145/ 50 / 56 Mrs F A Cunningham


303/13 Morris Homes

372/1 Mr M Kerry, Selbourne Road MOT Centre

Summary of the ObjectionsThe existing garage at the site should be retained or relocated to purpose-built premises on the site or nearby. Although not against redevelopment in principle, a garage is needed in the locality because of high car ownership. Businesses are being moved to less convenient locations further out of town, which is not suitable for car repairs / vehicle testing. Also, six jobs are unnecessarily put at risk. (372)

The site should be retained for employment uses as low cost starter units for local businesses. (145)

There is doubt whether this site will come forward for development. The site should be deleted as a housing allocation and reallocated for public open space or another community facility, which would support neighbourhood regeneration. (303, 253)

Inspector’s Reasoning and Conclusions Background

1. The site is near the centre of an inner area neighbourhood regeneration project. It is accepted by all concerned that the wider area is in need of regeneration and that the Council’s approach of improving it as a residential area suitable for families is correct. I also start from this position. On the basis of the evidence presented to me I am also persuaded that the Council is actively pursuing regeneration in the area, has secured funding to support the regeneration project and is involving local residents and others in the plans for the area.

2. The area is a mixed one containing many businesses as well as housing. The Council has come to the view (supported during consultations with residents) that some of the businesses and buildings in the locality harm the character and appearance of the area and detract from residential amenity. This has led them to want to move businesses from central positions in area to more peripheral locations in the neighbourhood (but not to out-of-town sites).

3. The site identified in the Local Plan as a housing allocation (Site H18) is said to be in three ownerships. Two of the owners apparently do not object to what is proposed and the Council said they have approached the Council to explore the possibility of residential redevelopment. The third ownership was represented at the Local Plan Inquiry in support of Objector 372 and retaining the existing garage on part of the site.

4. Against this background the following issues arise from these objections:

(a) should the H18 site be retained (in whole or in part) for employment purposes;

(b) would the site be better used for open space or community uses;

(c) is the prospect of residential redevelopment certain enough to be taken into account in determining the overall supply of housing land in the Local Plan.

Employment Retention

5. The Council does not dispute that local employment retention is important to the regeneration of the neighbourhood and I also recognise its importance. However, the Council – supported by local residents – is trying to move


businesses to the edge of the neighbourhood in order to protect and enhance residential amenity in most of the area. The Council presented uncontested evidence at the Local Plan Inquiry that it had already started on this process and saw no difficulty in continuing along these lines. It is not my role to become involved in the individual terms and conditions under which businesses are relocated. However, I accept that the close intermingling of homes and businesses can cause problems in a tightly knit area such as this.

6. The premises at the site (as a whole) are, generally speaking, not in good condition and are not well suited to modern business needs. Such evidence as I have, admittedly somewhat anecdotal, is that most of the premises are used rather unintensively, on short leases and with a turnover of occupants. The scale, appearance and condition of most of the buildings on the site mean that they do not make a positive contribution to regeneration, amenity or the character and appearance of the area. The site is surrounded by existing housing.

7. In all these circumstances I am firmly of the view that the site should not be allowed or encouraged to stay as it is throughout the plan period. I also consider that further deterioration is to be expected if this were to be attempted. This leads me to favour redevelopment in some form or other.

8. In choosing between redevelopment for employment and housing, the contribution that each use would make to regeneration should be the decisive consideration. Housing would clearly be compatible with the surrounding uses, could expand the stock of family accommodation in the area and would be favoured by many existing residents. Employment might not be compatible with the surrounding housing and could perpetuate traffic and noise in the area. In addition, whilst funding for housing is secured, the viability of – and funding for – an employment redevelopment is not certain. Although starter units for local businesses have been specifically advocated for this site, I have no evidence that these would be viable or that there is a local demand for them.

9. Thus, without in any way minimising the importance of employment protection, I conclude that – looking at the site as a whole – redevelopment for housing is to be preferred both to keeping the present buildings and uses in place or redevelopment for employment purposes.

10.This brings me to the existing garage / MOT testing centre on the corner of Caunce Street and Selbourne Road. Part of this business is in buildings on the H18 site but part is on an otherwise vacant house plot in Caunce Street. However, it was agreed at the Local Plan Inquiry that the Caunce Street plot is too small to support the business if the H18 land is redeveloped for another purpose. It was further agreed that if this were to occur the Caunce Street site would probably be redeveloped for housing.

11. In some ways this business is an exception to some of the things I have said about the H18 site as a whole. A garage has been established here for decades and, although the present business only goes back a few years, this is not a transient or low intensity activity. The present occupier has invested in the fabric of the buildings and the site is clean, tidy and presentable, although it also has to be said that this is not a modern or attractive building that adds to its surroundings. The occupier and landowner also told me that there is no history of complaints or conflicts with nearby residents in this case. The business employs six people and their futures are an important consideration.


12.The Council said, and I accept, that if the rest of the H18 site is to be redeveloped for housing there is no realistic prospect of excluding the garage from the redevelopment, even though only a small part of the total H18 site would be involved.

13. I have already reported the Council’s views on the prospects for relocation (paragraph 5 above). I have no evidence to set against what the Council said, which I found to be believable. I have already said it is not my role to oversee or become involved in the individual terms and conditions that might govern any possible relocation but, on the evidence I have, there is no reason to suppose that an affective and amicable way forward cannot be found.

14. I accept the need for businesses like this to be retained in the neighbourhood. I also attach great importance to protecting the six jobs involved. However, on the balance of the evidence I believe that these objectives can be secured by relocating this business locally and without impeding the overall redevelopment scheme in the Local Plan.

15. I conclude that the H18 allocation should be retained in the Local Plan in preference to seeking the continuation of employment uses at the site.

Open Space or Community Uses

16.The Council accepts that this neighbourhood lacks open space, greenery and community facilities. However, it says that the redevelopment of this site for these purposes would not be economically viable. Furthermore, land very close to this site is being redeveloped for community uses with some local open space. In all the circumstances I consider that redeveloping this site for such uses is not supportable.

17. I conclude that this site should not be reserved for community or open space uses in the Local Plan and that the housing allocation should be retained.

Uncertainty / Other Sites Preferred for Housing

18.The two “housing based” objections (253, 303) need to be viewed in the context of all the objections from these objectors. They are seeking the allocation of greenfield land for housing development. To this end they seek to increase the overall amount of land allocated for housing in the Local Plan and to minimise the amount of land that can be found for this purpose within the urban area. In effect they wish to substitute greenfield land for this site.

19. I have no doubt that in terms of the sequential test in PPG3, site H18 is preferable to the alternatives they have in mind. All that remains to be explored is whether there is a realistic prospect of this site coming forward within the Local Plan period.

20. I acknowledge there are several ownerships involved here and that there may not be unanimity amongst them at the moment about the desirability of housing. However, it does seem to me that housing redevelopment is likely to be more profitable (and more certain) for them than continuing the employment uses (either in the existing premises or redeveloped). Therefore, in the fullness of time I would expect them to come to the view that housing redevelopment is in their own best interests. Failing that, I note that the Council is committed to residential redevelopment and that funds are available to secure this. Thus I fully expect this site to come forward for residential redevelopment within the plan period.


21. I conclude that these objections should not succeed.

Overall Conclusions

22.Having considered the objections to the H18 allocation I conclude that it should be retained as it is in the Local Plan.


objections.



5.17 Homes for Every Need Paragraph 5.23The Objection109/4 English Nature (Cheshire to Lancashire Team) (Conditionally Withdrawn)

Summary of the ObjectionInsert a reference to the environmental value of sites in paragraph 5.23. (109)

Inspector’s Reasoning and Conclusions 1. The change that the Objector wanted was made in the Second Deposit and the

objection has been conditionally withdrawn as a result. I conclude there is no need for me to consider this matter further.


109/4.



5.18 Homes for Every Need Policy HN3 The Objections145/8 Mrs F A Cunningham (Conditionally Withdrawn)

242/4 House Builders Federation


(Objection Conditionally Withdrawn subject to PCs allocating greenfield sites.)

252/2 Arrowcroft Northwest Ltd



303/ 3 / 14 / 18 Morris Homes


327/3 Miss A J Gray

348/1 North West Regional Assembly (Conditionally Withdrawn)

Summary of the Objections“Phasing – object to Leys Nursery.” (Full Quote) (First Deposit) (Conditionally Withdrawn) (145)

Greenfield sites should not be held back because the Urban Capacity Study has not been market tested. Delete policy HN3 and include listed sites in overall allocations. (First Deposit) The greenfield sites listed in HN3 in the First Deposit are needed to ensure an adequate five and ten year supply. (Second Deposit) (Conditionally Withdrawn after PCs reinstated the greenfield sites.) (242)

The 2008 trigger for the release of greenfield sites is arbitrary and should be replaced by a plan, monitor and manage approach as in PPG3 (First Deposit) (252)

Policy HN3 should be retained in case of a short fall in the anticipated sources of supply. (Second Deposit) (253)

Phasing is in accord with PPG3 but the wording in HN3 should be changed to provide greater clarity as to when the release of sites will be allowed. More explanation is needed. (First Deposit) Policy HN3 should be retained in case of a short fall in the anticipated sources of supply. (Second Deposit) (303)

Delete sites H4 and H11 because of their nature conservation / environmental interest. If retained, the sites should be released one at a time, rather than partially using all the sites. CPRE suggest a sequence of release: H8, H11 then H4. (First Deposit) (326)

The sites should not be allocated for development. Remove the sites from Policy HN3 and redesignate as countryside areas or urban green space. (First Deposit) (327)

The loss of the phasing policy is regretted. The rate of windfall release may not be achieved as HN5 will not achieve this. Other authorities are looking to restrict supply to five or six years, subject to exceptions for particular types of development (such as affordable housing). (Second Deposit) (348)

Proposed ChangesPC49 suggests that a (completely different) phasing policy is introduced to the Local Plan. It does not relate to named sites but includes windfalls and conversions and says that a supply in excess of five years of the annualised requirement is not to be exceeded, although exceptions are allowed for.

PC99; suggests an amended wording (delete “significantly” from the second paragraph).

PC100; suggests an amended wording for the third criteria in the reinstated policy.

(Objection 194/69 to policy HN1 is also Conditionally Withdrawn in part subject to PC49)

Objections to Proposed Changes194/ 77 / 78 Government Office for the Northwest

249/ 37 / 38 / 39 Lancashire County Council

253/22 Kensington Developments Ltd (Part Support)

303/13 Morris Homes (Part Support)

Summary of Objections to Proposed ChangesThe word “significantly” in the second paragraph of the amended policy in PC49 is unclear and should be explained. (194/77) (but this is Conditionally Withdrawn because of PC99)

The policy and text should make it clear that no greenfield sites will be released unless there is no suitable previously developed land available. (194/78)

The policy is at odds with the Structure Plan, it is unclear how land release is to be managed and it could allow the early release of greenfield sites. (249/37) (249/38) (249/39)

The reintroduction of policy HN3 is supported in principle but it is too restrictive. Greenfield sites should be released now. There should be a ten year supply available. (253) (303)

Inspector’s Reasoning and Conclusions


The First and Second Deposits

1. The phasing policy that was in the First Deposit was deleted entirely in the Second Deposit. The Proposed Changes seek to reintroduce a phasing policy but it is completely different from the one in the First Deposit.

2. I consider that for all intents and purposes this means that the objections to the First Deposit can be set aside as having little relevance now. Moreover, several of the objections to the Second Deposit relate the issue of phasing to the reinstatement of the three greenfield sites that were originally identified in the First Deposit phasing policy. (These sites are H4 (part), H8 and H11.) I have already considered these sites collectively and individually and I am not recommending they are reintroduced as housing allocations.

3. However, for the avoidance of doubt, it is my view that they should not be identified as part of a phasing policy. This is mainly because they are greenfield sites and there is no need to identify such sites if there is no housing requirement to do so. This view is reinforced by events, which suggest that housing supply is running ahead of the Structure Plan annualised rate. This means that even if a shortage does materialise it will definitely not be early in the remaining plan period. The plan will necessarily have to be reviewed in time to deal with any shortfall that arises towards the end of the plan period.

4. However, I note that none of the objections to the First and Second Deposits could be described as objections to the principle of including a phasing policy in the Local Plan.

Objections to the Proposed Changes

5. I therefore turn to the objections to the Proposed Changes. Again, there are no objections to the principle of phasing.

6. The Government Office (194) objected to the word “significantly” in PC49. But PC99 would delete it so I consider this objection has now been met.

7. Several of the other objections (194/78, 249/39, 253/22 and 303/13) are concerned about the early release of greenfield sites – being anxious to prevent it or facilitate it. However, as things stand if my recommendations are followed; no greenfield sites would be allocated and none would be mentioned in the phasing policy. Thus the issue of the early release of greenfield sites (either way) does not arise. This means that some of the wording in the proposed policy is redundant because all the sites coming forward will be previously developed land.

8. Therefore the only issue left to be resolved is the mechanism to be employed in any phasing policy. Objectors 253 and 303 say that a ten year supply should be maintained. In the context of this Local Plan (with a plan period until 2016, only 11 years away now) this would effectively negate phasing. In the circumstances in which the annualised housing requirement towards the end of the plan period is higher than at the start of the period, the purpose of a phasing policy must be to hold back the rate of development in the early years. Providing a ten year supply would completely frustrate that intention.

9. That leaves the County Council objection about the mechanism, which alleges that the proposed policy is not in accord with the Structure Plan. What the County Council says seems to indicate that they want a very complex policy.


(However, it may be that their fears are allayed somewhat now that no greenfield sites are involved.) In as far as I understand what they are saying in their rather convoluted representation on this matter, it seems to me that what they want included in the policy is the notion that what is to be assessed is the cumulative supply of commitments.

10.Taking all this into account, I conclude that the following wording would be appropriate in the present situation:

Policy HN3

The release of housing sites, including windfalls and conversions, will be controlled in such a way as to deliver new housing at a rate that is consistent with the annualised housing requirements set out in paragraph 5.12A. (renumbering is needed but currently 5.12A in PC38) The intention will be to ensure that a five year supply of housing commitments is available that takes into account the cumulative effect of past decisions and rates of delivery in relation to the annualised housing requirements for earlier years as well as the annualised requirements for the next five years.

Where annual monitoring indicates that there is a need for planning permissions for new housing to be restricted to ensure that the housing requirement for the following five year period is not exceeded, planning permission will only be granted for development, including windfalls and conversions, that meets one or more of the following criteria:

continue policy as in PC49 and PC100.

11. In line with government guidance and to avoid worthwhile mixed-use developments being frustrated, I suggest that consideration should be given to including a criterion that gives priority to dwellings arising in mixed-use proposals.

12.Arising from my consideration of other polices in the Local Plan I also suggest that additional criteria giving priority to the conversion of houses in multiple occupation into dwellings and schemes involving the conversion of unviable shops or holiday accommodation are considered.

13.The accompanying text would also need revising.

Recommendations14. I recommend that the following wording is used for this policy:

Policy HN3The release of housing sites, including windfalls and conversions, will be controlled in such a way as to deliver new housing at a rate that is consistent with the annualised housing requirements set out in paragraph 5.12A. (renumbering is needed but currently 5.12A in PC38) The intention will be to ensure that a five year supply of housing commitments is available that takes into account the cumulative effect of past decisions and rates of delivery in relation to the annualised housing requirements for earlier years as well as the annualised requirements for the next five years. Where annual monitoring indicates that there is a need for


planning permissions for new housing to be restricted to ensure that the housing requirement for the following five year period is not exceeded, planning permission will only be granted for development, including windfalls and conversions, that meets one or more of the following criteria: continue policy as in PC49 and PC100.

15. I recommend that consideration is given to including a criterion that gives priority to dwellings arising in mixed-use proposals.

16. I recommend that additional criteria giving priority to the conversion of houses in multiple occupation into dwellings and schemes involving the conversion of unviable shops or holiday accommodation are considered.

17. I recommend that the accompanying text is revised to reflect the changes that are made.

Officers Comments

The Inspector supports the need for a Phasing policy to restrict the level of housing development to be permitted in line with the annualised housing requirements set out in the Plan to meet Blackpool’s need for 3,230 dwellings to 2016.

Amended wording is put forward, to reflect the deletion of the greenfield sites from the Plan. The Inspector agrees with the criteria previously set out in the Council’s Pre-Inquiry Modifications setting out those exceptional circumstances whereby planning permission might continue to be granted (eg supports regeneration, meets identified local need for affordable or specialist needs housing).

The Inspector also recommends that consideration should be given to the inclusion of additional criteria giving priority to:

- dwellings arising in mixed-use proposals- the conversion of dwellings in multiple occupation- schemes involving the conversion of unviable shops or holiday accommodation.

The Council’s housing release advice note approved in October 2004 sets out more detailed guidance on exceptions as part of the restrictive approach. This already includes reference to proposals with clear regeneration benefits - such as mixed use regeneration projects and the conversion of lower standard holiday accommodation. The conversion of HMOs through their conversion into high quality self-contained accommodation is similarly acceptable. It is accepted such criteria can therefore appropriately be included in Policy HN3.

It is not considered specific reference should be included in Policy HN3 to the conversion of unviable shops. Other detailed policies included in the Plan already provide the basis for considering applications for change of use of shops, which include the level of vacancies and an overall assessment of the retail function of shopping centres, rather than the viability of individual shops. The Policy HN3 criteria supported by the Inspector also already include bringing long term empty buildings into beneficial use as an exception. Taken together, it is not considered a further exception relating to viability is justified in the policy.


The Inspector’s recommendation 14 is accepted, with the Policy HN3 wording including the criteria previously set out by the Council in PC49 and PC100 to be amended as follows:


Policy HN3

The release of housing sites, including windfalls and conversions, will be controlled in such a way as to deliver new housing at a rate that is consistent with the annualised housing requirements set out in paragraph 5.12A. (renumbering is needed but currently 5.12A in PC38) The intention will be to ensure that a five year supply of housing commitments is available that takes into account the cumulative effect of past decisions and rates of delivery in relation to the annualised housing requirements for earlier years as well as the annualised requirements for the next five years.

Where annual monitoring indicates that there is a need for planning permissions for new housing to be restricted to ensure that the housing requirement for the following five year period is not exceeded, planning permission will only be granted for development, including windfalls and conversions, that meets one or more of the following criteria:

o Supports regeneration initiatives, particularly within identified priority areas;

o Has special townscape or conservation benefits;

o Brings derelict or contaminated land, or long term empty or neglected buildings into beneficial use;

o Meets a specifically identified local need such as for affordable or specialist housing

The Inspector’s recommendations (15) and (16) are accepted, with additional criteria relating to mixed use, HMOs and holiday accommodation to be included in the policy as set out below:

o Forms a key element of a mixed use regeneration projecto Would convert houses in multiple occupation or reduce the over-supply of lower

standard holiday accommodation, securing their replacement with high quality residential units.

No additional criterion involving the conversion of unviable shops is considered to be required.

The Inspector’s recommendation (17) is accepted, but it is considered no revisions are required as the changes made to the Policy are already adequately reflected in the supporting text which makes general reference to regeneration benefits.

5.19 Homes for Every Need Policy HN3 – Site H11The Objections198/3 Tina Mulgrew

201/3 Gary Blamires

205/3 J Christie

Summary of the ObjectionsDelete Leys Nursery from Policy HN3. (198) (201) (205)

Inspector’s Reasoning and Conclusions 1. I consider that these objections have already been dealt with earlier in my


report and conclude that no (further) modifications arise.


objections.



5.20 Homes for Every Need Policy HN4The Objections050/1 Norbreck Castle Hotel

232/1 Mrs B Kerr


251/3 Owen Baguley

253/2 / 12 Kensington Developments Ltd

256/3 E Sloane

279/3 C.A. Banks


303/4 / 15 / 19 Morris Homes

330/3 Phil Shevloff




345/4 Hazel Cragg

364/2 Paul Harrison Ltd

Summary of the ObjectionsMany of these small urban sites could be better used for community uses including public open space. Other land could be made available for housing (Marton Moss). The HN4 sites should be reviewed and deleted from the Local Plan in favour of other sites. (232, 251, 256, 279, 289, 330, 332, 333, 343, 345)

Market testing and a full Urban Capacity Study will be required before these sites can be accepted as making a contribution to the housing requirement for the Borough. (242)

All these sites have ownership or other constraints. The Policy should be deleted (253)

There is no need to identify opportunity sites which if not allocated would come forward as windfall sites. The policy should be deleted. The sites added to HN4 in the Second Deposit are constrained and should also be deleted. If the policy is retained, land at Marton Moss should be added to the list. (303)

Land at the Norbreck Castle Hotel should be added to the list of sites. Add to paragraph 5.29 "However, where the existing use does not conflict with the surrounding area, proposals to extend or for improvements will be considered against the other relevant policies within the Local Plan and on the proposal's own merits". (50)

The site of the former filling station in front of the Norbreck Hotel should be included as a housing opportunity site in the same way as land behind the hotel. (364)

Proposed ChangesPC50 proposes alterations in respect of three sites (one boundary change and two deletions).


PC101 proposes that the policy and accompanying text are deleted in their entirety.

Objections to the Proposed Change242/16 House Builders Federation

The opportunity sites should be retained to help meet higher than expected demands for housing.

Inspector’s Reasoning and Conclusions 1. In Proposed Change 101 the Council indicates that it wishes this policy and the

accompanying text to be deleted entirely. If this course of action is followed, most of these objections would either be met or would become redundant; so I shall start with this.

2. The Council’s reasons for wanting to delete policy HN4 and its list of opportunity sites is that it believes that enough land can be found in the Borough to meet the Structure Plan housing requirement. Indeed the Council takes the view that so much land has already come forward in the early years of the plan period that it now wishes to (re)introduce a phasing policy. The Council thinks it is inconsistent to be seeking to stimulate the supply of land for development in one policy (HN4) while restraining it in another (the reinstated HN3). This stance certainly has some logic to it.

3. Be that as it may, some of these sites are either too small or too uncertain (or both) to be housing allocations in their own right in policy HN2. I therefore agree with Objector 303 that they should be regarded as windfall sites and that it is unnecessary to list them in the Local Plan.

4. I am somewhat surprised the HBF (Objector 242) is making a Counter Objection that implies that the HN4 list could be seen as meeting the Structure Plan housing requirement. I would expect the HBF to be seeking certainty in respect of any sites making a contribution in this regard. Either way, removing the policy and the list of sites does not mean that the sites are unsuitable for residential development.

5. All in all I see no need or reason to retain this list of possible windfall sites in the Local Plan.

6. As far as Marton Moss is concerned, most of this is greenfield land where development would need to be justified in relation to the sequential test in PPG3 whether or not policy HN4 and its sites are retained in the Local Plan.

7. As to the Norbreck Castle Hotel and any housing capacity there, I address these issues in connection with objections to policy RR20 and paragraph 2.84. It is unnecessary for these matters to be dealt with twice in the Local Plan or my report.

8. I conclude that policy HN4 should be deleted from the Local Plan.

Recommendation9. I recommend that policy HN4 and all the text that accompanies it

(paragraphs 5.28 – 5.34) are deleted from the Local Plan.


The Inspector’s recommendation is accepted and Policy HN4 is accordingly deleted from the Plan.


5.21 Homes for Every Need Policy HN4 – Site 1The Objection192/3 Maurice Christian (Conditionally Withdrawn)

Summary of the ObjectionThe closeness of the ambulance station may cause a problem for housing on this site because of noise from sirens. (192)

Proposed ChangesPC101; delete policy HN4 and its supporting text.

Inspector’s Reasoning and Conclusions 1. In view of my recommendation that this policy and the supporting text should be

deleted (as suggested in PC101) I consider it is unnecessary to consider this objection further.


objection.



5.22 Homes for Every Need Paragraph 5.34The Objection109/5 (a and b) English Nature (Cheshire to Lancashire Team)

Summary of the ObjectionAdd at end of paragraph 5.34 "However, any future development of these sites must recognise that they may have existing environmental value, for example in the form of biodiversity". (109/5a) (First Deposit)

Objection 109/5a is maintained. In addition a cross-reference should be made policy NE10. (109/5b) (Second Deposit)

Proposed ChangesPC101; delete policy HN4 and its supporting text.

Inspector’s Reasoning and Conclusions 1. In view of my recommendation that this policy and the supporting text should be

deleted (as suggested in PC101) I consider it is unnecessary to consider these objections further.


objections.




5.23 Homes for Every Need Policy HN5 The Objections242/6 House Builders Federation




303/ 5 / 16 / 22 Morris Homes


Summary of the ObjectionsThe Urban Capacity Study needs to be market tested before the windfall contribution is relied on. (First Deposit) (242)

The policy is more restrictive than PPG3 which does not contain the test of whether land could contribute to the character and amenity of the area. (First Deposit) (252) (328)

The outcome for windfalls is uncertain. The policy should be reworded as follows: Planning permission for residential development will be granted on previously developed, vacant or under-used sites in the urban area provided: (a) if in the case it is allocated for another use it would not result in a shortfall for that use; (b) the development complies with the Council's standards for garden space, parking, access etc; (c) the layout, design, and materials are acceptable and (d) the development complements surrounding land uses in terms of character and appearance. (Second Deposit) (253) (303)

The test in part (a) of the policy relating to the character and amenity of the area is not derived from PPG3 and should not be included. The requirements for land safeguarded for other uses may change over time, so clause (b) of the policy is too inflexible. (First Deposit) (287)

The words “underused and other appropriate brownfield sites within the urban area” need clarification. It is not clear which sites are being referred to as “appropriate redundant land or buildings” in paragraph 5.35. Some land at Marton Moss has structures and redundant buildings on it and should be included within the terms of this policy. (First Deposit) (303) The policy should reflect the advice in PPG3. (Full quote) (Second Deposit) (303/22)

Proposed ChangesPC102 would alter paragraph 5.37 to reflect changes to policies HN1 and HN3 as amended in the Proposed Changes to those polices.

Inspector’s Reasoning and Conclusions 1. PC102 is not contentious and should be advertised as a modification.

2. As to the policy as a whole, there is no objection to the principle of including a policy dealing with windfalls. However, there is a general desire to see it more closely aligned to the guidance in PPG3 in one way or another. There is also a wish for greater clarity and certainty as to outcomes. I detect there is some tension between the wish to remove constraints on windfalls and a wish to “talk down” their contribution in order to increase the likelihood that greenfield sites will need to be released.

3. I note the HBF’s (First Deposit) reservation about testing the Urban Capacity Study but consider that events since have given ample opportunity for sites to be investigated and commented upon. The HBF have not pursued this point and this seems to indicate they are now content. In any event, I consider that no modification arises now.

4. It is true that PPG3 talks in terms of giving priority to the development of


previously developed land in urban areas but it also talks in terms of greening the residential environment through the protection and creation of open space. As long as the policy refers to vacant urban land (and not just previously developed land), I consider that the character and amenity of the area is justifiably included as a consideration. However, I note that the changes introduced in the Second Deposit restrict the application of clause (a) in the policy to identified priority neighbourhoods. In my view this concentrates on the most important areas and is a reasonable constraint within the policy. Notwithstanding the Council’s willingness to delete this part of the policy because they anticipate preparing new Action Area Plans, I consider that it should be retained to provide some protection in the meantime.

5. Objector 303 is concerned about a lack of clarity arising from the words “underused and other appropriate brownfield sites within the urban area” in the policy and “appropriate redundant land or buildings” in paragraph 5.35. I share these concerns because there is no accepted definition of the terms “appropriate” and “brownfield” and the issue of whether a site is “redundant” is a complication the Local Plan can do without. I therefore consider the following are clearer: “underused and previously developed sites within the urban area” and “previously developed urban land”.

6. The complete redrafting proposed by objectors 253 and 303 introduces other considerations (such as garden space, layout and materials) that are covered elsewhere in the Local Plan and do not need to be repeated here. I therefore consider that this suggestion should not be pursued.

7. Finally, some objectors take issue with clause (b) in the policy. I understand their concerns and consider that it should be qualified. Recent government guidance indicates that the allocation of land for industry/business/employment uses is sometimes unreasonably and unrealistically frustrating the need to bring forward previously developed urban land for housing and mixed uses schemes. The Local Plan should reflect this latest guidance.

8. As to the proposition that some land at Marton Moss has structures and redundant buildings on it and should be included in the policy, I do not accept that such a sweeping generalisation is of any help. Claims as to whether sites are previously developed land need to be assessed on a plot by plot basis using the definition and guidance in PPG3 Annex C. In any event this area is not within the urban area in my view.

9. I note the Council is willing to have a far shorter and simpler policy that in effect deletes criterion (a). However, I consider that the circumstances with which criterion (a) is intended to deal remain important. Moreover the suggested policy retains some of what I regard as the faults in the earlier versions.

10.Bearing all this in mind I conclude that the policy should be worded as follows:

Policy HN5

Housing development will be permitted on derelict, vacant, underused and previously developed land within the urban area, providing:

(a) the land is not needed to maintain amenity or correct deficiencies in the character or amenities of an identified priority neighbourhood; and

(b) the land is not identified as being safeguarded for another use in


the Local Plan and the need for that safeguarding still exists.

11. I conclude that paragraph 5.35 should read:

In addition to the housing sites already identified, other windfall sites may become available for housing development where the Council will grant planning permission for housing. Such sites will, in the main be previously developed urban land, although vacant urban sites with no known previous use may also arise. Development of such land for residential use will be considered having regard to the characteristics of the site, the contribution it can make to the character and amenity of the urban priority neighbourhoods and other development needs.

Recommendations12. I recommend that PC102 is advertised as a modification to the Local Plan. 13. I recommend that policy HN5 is worded as follows:

Policy HN5Housing development will be permitted on derelict, vacant, underused and previously developed land within the urban area, providing:

(a) the land is not needed to maintain amenity or correct deficiencies in the character or amenities of an identified priority neighbourhood; and(b) the land is not identified as being safeguarded for another use in the Local Plan and the need for that safeguarding still exists.

14. I recommend that paragraph 5.35 is worded as follows: In addition to the housing sites already identified, other windfall sites may become available for housing development where the Council will grant planning permission for housing. Such sites will, in the main be previously developed urban land, although vacant urban sites with no known previous use may also arise. Development of such land for residential use will be considered having regard to the characteristics of the site, the contribution it can make to the character and amenity of the urban priority neighbourhoods and other development needs.

15.Otherwise I recommend no modifications to HN5 and its accompanying text.

Officer CommentsThe Inspector’s recommendations for modification to Policy HN5 are accepted. The recommendations for amendments to the supporting text are also generally accepted, but it is considered unnecessary to include additional reference in paragraph 5.35 to the contribution housing development sites can make to “the character and amenity of the urban priority neighbourhoods”.

Paragraph 5.38 already sets out that residential development will not be permitted on windfall sites which could have wider benefits in addressing deficiencies in the character or amenities


of a neighbourhood.

The amended wording focuses on the contribution that “housing” development might make to the character and amenity of the area, rather than the wider assessment of potential uses already set out elsewhere within the policy. It is considered such additional reference should therefore be excluded from the amended paragraph 5.35.


The Inspector’s recommendation (12) is accepted and that PC102 is accordingly advertised as a proposed modification to paragraph 5.37 of the Local Plan as follows:

PC102 Amend paragraph 5.37 to state:Windfall sites provide an important contribution to Blackpool’s housing requirement with an allowance of an estimated 750 600 dwellings to be completed on such sites in the Plan period, and additional new including sites arising from the Resort Masterplan. If monitoring in the future shows that the amount of new housing development coming forward exceeds the housing requirement, consideration may need to be given later in the plan period to introducing restrictions on the development of new windfall housing sites (see Policy HN3).

The Inspector’s recommendation (13) is accepted and that Policy HN5 is accordingly reworded as follows:

Policy HN5

Housing development will be permitted on derelict, vacant, underused and previously developed land within the urban area, providing:

(a) the land is not needed to maintain amenity or correct deficiencies in the character or amenities of an identified priority neighbourhood; and

(b) the land is not identified as being safeguarded for another use in the Local Plan and the need for that safeguarding still exists.

The Inspector’s recommendation (14) is only partially accepted (in line with the comments above) and paragraph 5.35 is worded as follows:

“In addition to the housing sites already identified, other windfall sites may become available for housing development where the Council will grant planning permission for housing. Such sites will, in the main be previously developed urban land, although vacant urban sites with no known previous use may also arise. Development of such land for residential use will be considered having regard to the characteristics of the site, the contribution it can make to the character and amenity of the urban priority neighbourhoods and other development needs.

The Inspector’s recommendation 15 is accepted.

5.24 Homes for Every Need Policy HN6The Objection192/4 Maurice Christian

Summary of the ObjectionThe policy should restrict the activities of Housing Associations as well as preventing conversions into houses of multiple occupation. Whilst not averse to some Housing Associations others (like Bay House) are objectionable. (192)


Proposed ChangesPC51 proposes a wording change in the policy relating to inner areas.

PC103 proposes a further wording change to the same part of the policy.

Inspector’s Reasoning and Conclusions 1. This planning policy is neutral as to the tenure and ownership of properties and

proposals. This objector appears to want the policy to identify and control particular Housing Associations that he disapproves of, although it is not clear on what basis this could be done. In any event planning policies cannot do this.

2. I consider that the change sought by the Objector would be beyond the scope of planning law and would be unworkable.


Recommendation4. I recommend no modification to the Local Plan as a result of objection

192/4.5. I recommend that PC51 and PC103 are advertised as modifications to the

Local Plan.


The Inspector’s recommendations are accepted. The changes previously set out in PC51 are already incorporated in PC103, and PC103 is accordingly advertised as proposed modification to the Local Plan as follows:

PC103 Amend second part of Policy HN6 to:Inner Areas:

Within the defined Inner Areas proposals for conversion or sub-division for residential use involving extensions to the property or into the roofspace will not be permitted. Within Inner area Priority Neighbourhoods Proposals for conversion or sub-division for residential use will not be permitted which would further intensify existing over-concentrations of flat accommodation and conflict with wider efforts for the comprehensive improvement of the neighbourhood as a balanced and healthy community

Consistent with PC103, the earlier PC105 which proposed a similar change to paragraph 5.45 of the supporting text is also recommended is accordingly advertised as proposed modification to the Local Plan as follows:

PC105Within the defined Inner Areas Priority Neighbourhoods, conversions and sub-divisions may be subject to further separate policy advice. Detailed assessments will be made of the existing mix of properties and further supplementary Neighbourhood Planning Guidance will be prepared for the application of stricter controls and phasing of further conversions and sub-divisions where justified to create more balanced and healthy communities.


5.25 Homes for Every Need Policy HN7 The Objections145/47 Mrs F A Cunningham

189/6 McCarthy and Stone (Developments) Limited


243/3 BT plc



303/6 Morris Homes


Summary of the ObjectionsThe site size threshold for this policy should be 0.5 ha not 1.0 ha. (Second Deposit) (145)

Amend the last sentence of the policy to say that, in the case of sheltered or supported housing, exceptions to the above requirements "will" (not “may”) be made. (First Deposit) (189)

The policy is too prescriptive and is being applied to sites that are too small. Delete the policy. (First Deposit) (242) (253)

The policy could deter investment in flatted development and conversions. The restrictions on single bed units in flatted development should be altered to refer to “bedsits”. (First Deposit) (243)

More flexibility should be allowed in determining the appropriate housing mix to meet the demand for housing and the suitability of individual properties being converted. It is the standard of development as much as its size that matters. Inflexibility could deter investment in conversions. (First Deposit) (295)

PPG3 sanctions such a policy but housing mix should be achieved through discussions with developers taking into account site characteristics and surroundings. The imposition of arbitrary size thresholds could lead to proposals being formulated specifically to avoid the controls/thresholds. (First Deposit) (303) (328)

Proposed ChangesPC53: in effect replace restriction on the number of units with “single bedrooms” by a restriction on units with “one bedroom” (single or double).

Objections to Proposed Changes Whilst welcoming aspects of the proposed change, the policy is still too restrictive and should be amended further to give greater flexibility in relation to the provision of small flats. (243)

Inspector’s Reasoning and Conclusions The Need for a Policy

1. Most of the objectors accept that this is a legitimate topic for a Local Plan policy and several cite PPG3 in this respect.

2. The exception to this is Kensington Developments (Objector 253) who say this policy goes far beyond the aims of national guidance, ignores market forces and is contrary to the aims of the planning system. They advance no evidence in support of these claims but if market forces could be relied on to provide a satisfactory mix; there would be no need for a policy at all.

3. I consider that the inclusion of such a policy in the Local Plan is justified and is sanctioned by PPG3.

Thresholds

4. There is some concern that the use of thresholds, any thresholds, in the policy


is arbitrary and will have a distorting affect. It is suggested that the wish to keep below a particular threshold in order to escape from its consequences may lead developers to design proposals with an eye to avoiding the thresholds. However, unless the same policy and standards are to apply to every development, no matter how small or large, some thresholds have to be used. But I consider it is sensible and reasonable not to apply the same policy and standards to all developments.

5. It is easier to complain about the arbitrary nature of thresholds than to suggest a workable alternative. The only alternative that has been suggested is discussion on a site by site basis taking into account the particular circumstances of each site and its surroundings. This hardly amounts to a policy and is open to the criticism that it is imprecise and uncertain.

6. In any event even if such an approach produced a mix on each site, there is no guarantee that the overall result would meet the needs of the Borough or do anything to correct the lack of variety that exists in parts of Blackpool now. I consider it is significant in this context that none of the objectors contest what the Council says about there being a need for more variety, especially in certain parts of the Borough.

7. I consider that the use of thresholds in the policy is necessary, justified and better than any suggested alternative. It is preferable, in terms of precision, clarity and usability to not using thresholds.

8. Several objectors complain about the particular thresholds that have been used, saying they are too low/small (or in one case too large/high). Most of these objectors want the thresholds raised, as happened between the First and Second Deposit. This may have gone some way to meeting the objections to the First Deposit and I note that some of the objectors to the First Deposit have not reiterated their objections or submitted any new evidence since the Second Deposit was published.

9. Be that as it may, because of the nature of the area and the size of sites that are coming forward, if a policy such as this is to have any effect at all then it has to apply to fairly small sites. Whilst it can be argued that a large number of very small sites will guarantee some variety, it is nevertheless a valid planning objective to seek variety within medium and larger sites.

10.On the other hand, in response to Objector 145 who wants no thresholds and a mix on every site; very small sites will not accommodate enough units to allow for much variety. Also, design considerations will often mean that a mix on the smallest sites is not appropriate. For example a site with four houses can only achieve variety with a terrace of three and one detached house or a pair of semis and two detached houses. These will often not be the right design solutions, compared to a terrace of four or two semi-detached pairs.

11.On balance, therefore, I consider that the policy – having been changed in the Second Deposit – now represents a reasonable compromise as far as the thresholds it contains are concerned. It prevents monolithic developments containing only one type of housing on sites that are large enough for this to be either noticeable or a problem.

Flexibility

12.Again, with flexibility it is easier to say that a particular approach is not flexible enough than to suggest a workable alternative. By definition, if a policy is to be


worth including in the Local Plan, it has to have an effect and to have an effect it must impose some constraints on developers. It is then possible for developers to describe the policy as arbitrary and inflexible.

13. I note that the policy was relaxed in the Second Deposit by raising the amount of housing on each site that could be of any one type from 50% to 60%. However, Objector 303 still says that the 60% limit on any one house type on a site is arbitrary and provides no certainty that a range and mix of houses will be provided. They want this aspect of the policy deleted entirely and the policy replaced by a rather bland and imprecise exhortation to demonstrate that developments contribute to an overall mix of housing types and design in the locality. It does not seem to me that the policy would serve any real purpose if this were done.

14.Overall I consider that the Second Deposit strikes a reasonable compromise.

Flats

15.The two objections specifically directed at the parts of the policy dealing with flats are both concerned that new developments and (especially) conversions should be able to include a higher proportion of small flats. One welcomes the wording change in PC53 but it does not appear to meet either objection.

16. I note that PC53 suggests a change of wording. To my mind this proposed wording is clearer in its intent and meaning than the wording in the Second Deposit and is to be preferred for that reason if no other. However, I still find another aspect of the policy somewhat confusing. At the moment my reading of the policy is that it says that in inner areas:

in schemes involving three units, at most one unit can have only one bedroom;

in schemes of four units, at most 25% of the units can have only one bedroom – but 25% of four is still only one;

in schemes of five units, at most 25% of the units can have only one bedroom – but 25% of five is 1.25, which I would also interpret as meaning one in this context;

in schemes of six and seven units, at most 25% of the units can have only one bedroom, which in both cases produces a fraction above one and a half, which I would interpret as meaning two in this context;

in schemes of eight units, at most 25% of the units can have only one bedroom, which means two units.

17.This creates three problems for me. First I am at a loss to understand why a distinction is being made in the way the policy is expressed for schemes of three, four and five units because in all cases the answer seems to be the same; that is one! In other words the real threshold appears to me to come into play between five and six units and not between three and four units. This makes me doubt whether I have understood the policy. Second, I am uneasy with the fractions because they are open to interpretation and argument, which may not matter in large schemes but is proportionately more important in small schemes. Third, the situation is not entirely clear with regard to the “bedsits” mentioned by one of the objectors because these could be said to have no bedrooms. Would a scheme of one flat with one bedroom and two bedsits


comply with the policy as it is expressed now? (I know what is intended, what I am questioning is whether the policy achieves it.)

18.The same problems (for me at least) do not arise to the same extent for schemes outside the inner areas because of the way the policy is expressed for schemes in those areas.

19.Be that as it may, in essence both the objectors are saying that in some circumstances conversions including small flats are the most (or only) viable form of development and that an insistence on larger units may deter or prevent conversions and investment. However I imagine that this is an indication of the considerations involved rather than a universal or hard and fast rule.

20.The policy of seeking larger units is a response to a problem identified by the Council; namely a preponderance of small flats, especially in some inner parts of the Borough. Neither objector appears to acknowledge this as a problem or consider that it should be addressed. Yet, if what they say about the economics of conversions is true, without a policy such as this the imbalance in the supply will continue and get worse.

21.Without any evidence that the imbalance is not as pronounced or as much of a problem as the Council say it is, I am reluctant to relax the policy completely. And yet with the policy as it is, conversions creating five units could only be allowed one small flat. That seems very harsh to the extent that it would rule out any variety within that particular building and, in my view, could be a real disincentive to investment.

22.On balance therefore, I am inclined to the view that the policy should be clarified but in such a way as to give the benefit of any doubt (and some more flexibility) to the objectors. I therefore take the view that this part of the policy should be expressed as follows:

(D) Flat developments including conversions.

Inner Areas:

i. in developments creating up to 3 units not more than one of the units may have less than two bedrooms;

ii. in developments creating 4, 5 or 6 units not more than two of the units may have less than two bedrooms;

iii. in developments creating 7, 8 or 9 units not more than three of the units may have less than two bedrooms;

iv. in developments creating 10 or more units not more than one third of the units may have less than two bedrooms (with fractions of a unit counting a whole unit).

Elsewhere in the Borough – as now.

Sheltered Housing (Objector 189)

23.To my mind this is a curious objection coming from an objector who is generally concerned to secure flexibility for their specialised sector of the housing market. It is possible that to change the word “may” to “will” could create situations in which it became mandatory to depart from the generality of the policy and this could become an inflexible imposition. However, it is more likely that such a


change would make no difference to the implementation of the policy.

24.Be that as it may, I consider that the wording as it is creates a suitably flexible context in which to assess proposals of this specialised type on their individual merits. I consider that the policy should not be changed to meet this objection.

Conclusions

25. I conclude that a policy on housing mix should be included in the Local Plan. Such a policy necessarily has to have thresholds. In general I am satisfied that the thresholds in the Second Deposit policy are reasonable.

26.However, I conclude that the policy for flats and conversions in the inner areas should be more clearly expressed and less restricting.

Recommendations27. I recommend that policy HN7 is retained in the Local Plan.28. I recommend that part D of the policy is modified to read as follows:

(D) Flat developments including conversions.Inner Areas:





Elsewhere in the Borough – as in the Second Deposit.

29.Otherwise I recommend no modification to the policy.

Officers Comments

The Inspector supports the aims of the Policy and generally supports the policy thresholds set out in the Plan. However, he concludes that the policy for flats and conversions in the inner areas should be less restrictive on the number of one bedroom units than currently proposed by the Council.

The Inspector’s conclusion would not be as restrictive as some Members might wish, who have been anxious to achieve even stricter controls. However, Local Plan Policy HN6 (conversions) and HN7 (housing mix), both set out that within the defined inner areas further neighbourhood planning guidance will be prepared where justified for the application of stricter controls over new flat developments. The Inspector makes no recommended change to this aspect of the housing policies. The opportunity therefore remains for further detailed guidance to enable greater control if it can clearly be justified.

In addition to issues arising directly from the Inspector’s recommendations, clarification is required to ensure consistency in the precise wording in Policy HN7 (d) (iii) to refer to the defined inner areas


(rather than the inner area priority neighbourhoods), in line with Policy HN6 (see Appendix C, other recommended proposed changes).


The Inspector’s recommendations are accepted and part (D) of the Policy should accordingly be amended to state:

“(D) Flat developments including conversions.

Inner Areas:





Elsewhere in the Borough” – continue as in the Second Deposit.

5.26 Homes for Every Need Policy HN8 The Objections145/48 Mrs F A Cunningham



303/7 Morris Homes



Summary of the ObjectionsThe minimum density should apply on all sites. 40 dph is not a high density for an urban area. The threshold for this policy should remain at 0.2 ha. (Second Deposit) (145)

The density requirement is too high. Delete the policy and replace it with a policy that recognises the value of flexibility, including some development at less than 30 dph to provide choice. (First Deposit) (242)

A uniform density requirement is not in accord with PPG3. Account should also be taken of quality design and local character. The threshold of 0.2 ha is too low and is not derived from PPG3. Amend the policy to reflect PPG3. (First Deposit) (252)

The size threshold is arbitrary and should not be used. The density aspirations should be expressed as a range 30 – 50 dph as in PPG3. (First Deposit) (303)

The density requirement of 40 dph should apply to all sites not only those bigger than 0.2 ha. (First Deposit) (326)

PPG3 is expressed as a density range. The Council should seek densities appropriate to each site and its surroundings and to the sustainability of the location in accordance with PPG3. (First Deposit) (328)


Inspector’s Reasoning and Conclusions The Need for a Policy

1. Most of the objectors accept that this is a legitimate topic for a Local Plan policy and several cite PPG3 in this respect. I consider that the inclusion of such a policy in the Local Plan is justified and is sanctioned by PPG3.

Thresholds

2. As with policy H7, thresholds again come under attack from both sides. However, in this case – although there will always be some sites where density considerations are outweighed by other matters – there do not appear to be practical difficulties in achieving high densities on small sites. Indeed the Council’s latest evidence, derived from recent monitoring, suggests that higher densities are consistently being achieved on small sites. In any event there is no good reason to disregard the need not to waste land on small sites.

3. I therefore conclude that a threshold is both unnecessary and unhelpful in the context of this policy. Paradoxically this will satisfy objections from both sides in the debate – those who want higher densities and those who object to the arbitrary nature of thresholds.

Flexibility

4. There are also calls for greater flexibility in relation to densities and it is pointed out that PPG3 expresses the call for higher densities by indicating a range. However, this range is not so wide as to accommodate the objection from the HBF to allow densities lower than 30dph. Again, the Council has monitored the situation and is confident that expressing the policy as a range would not undermine the achievement of a satisfactory density overall.

5. Some objectors also point to the importance of site constraints and considering design and the surroundings that are of paramount importance in some cases.

Conclusions

6. Bearing all these things in mind and the guidance in PPG3, I consider that the appropriate form for this policy is as follows:

All new housing development should make efficient use of land, having regard to location, design and any constraints of the site. All housing developments should be built at a net density of 30 – 50 dwellings per hectare.

However, in order to promote more sustainable patterns of development, net densities of more than 50 dwellings per hectare will be permitted in the following locations:

i. along public transport corridors with a frequent service; and/or

ii. close to the town centre, district centres or local centres.

Recommendations7. I recommend that Policy HN8 is redrafted as:

All new housing development should make efficient use of land, having regard to location, design and any constraints of the site.


All housing developments should be built at a net density of 30 – 50 dwellings per hectare. However, in order to promote more sustainable patterns of development, net densities of more than 50 dwellings per hectare will be permitted in the following locations:

i. along public transport corridors with a frequent service; and/or

ii. close to the town centre, district centres or local centres.

Officers Comments

Reflecting the Inspector’s comments in paragraph 2, it is considered clarification should be included in the supporting text that ‘there will be some instances, particularly on very small sites, where location, design and site configuration constraints outweigh density considerations’.

In recognition that in such circumstances sometimes densities may still be below 30 dwellings per hectare and, at the other end of the scale there may be even higher densities than 50 dwellings per hectare in appropriate locations, it is considered it would be clearer and more accurate to delete “All” and amend the second sentence to state that ‘ Housing developments should “seek to achieve” a net site density of 30-50 dwellings per hectare’.


The Inspector’s recommendation that Policy HN8 is redrafted is accepted, subject to the minor rewording for further clarification as set out in the above commentary. Policy HN8 to accordingly be amended to state:

All new housing development should make efficient use of land, having regard to location, design and any constraints of the site. Housing developments should seek to achieve a net density of 30 – 50 dwellings per hectare.

However, in order to promote more sustainable patterns of development, net densities of more than 50 dwellings per hectare will be permitted in the following locations:

iii. along public transport corridors with a frequent service; and/or

iv. close to the town centre, district centres or local centres.

5.27 Homes for Every Need Policy HN9 The Objections089/5 Countryside Agency, N W Division (Conditionally Withdrawn)


189/4 McCarthy and Stone (Developments) Limited




242/14 House Builders Federation (Conditionally Withdrawn)

303/8 Morris Homes



358/1 Fordham Research LTD (Conditionally Withdrawn)

Summary of the ObjectionsWhilst Blackpool is predominantly urban, rural housing needs to be assessed to inform this policy. (First Deposit) (Conditionally Withdrawn) (089)

Off-site provision should not be allowed. Off-site provision could lead to social housing being concentrated in the inner areas thus exacerbating their social problems. (Second Deposit) (145)

The Council has not produced evidence to justify the threshold of 0.5 ha or the 20% requirement as indicated by Circular 6/98. In the admitted absence of a housing needs survey the policy is objected to. The policy should also refer to other matters to be taken into account when assessing each site, such as economics and the need to achieve successful housing developments. (First Deposit) (189)

The policy should be redrafted and supported by more justification in the light of identified need and Circular 6/98. In particular the policy should “seek” not “require” planning obligations, should define affordable housing, indicate how many affordable dwellings are needed, use this figure to set targets and justify the low thresholds currently in the policy. (First Deposit) (194)

The threshold in this policy should be 1.0 ha or 25 dwellings, not 0.5 ha. (First Deposit) (242) (303)

The changes to policy HN9 are welcome but affordable housing policy should be reviewed annually. (Second Deposit) (242) (Conditionally Withdrawn after PC54)

The 0.5 ha threshold should be removed so the policy applies to all housing sites. (First Deposit) (326)

The policy cannot be substantiated in its present form and should be revised on completion of a housing needs survey. (First Deposit) (328)

The policy is not rigorous and does not make clear the assumptions and definitions on which it is based. Since the housing needs survey on which policy HN9 is based is not robust, it is impossible to say what would be a valid affordable housing policy. (358) (Second Deposit)

Proposed ChangesPC54 suggest adding a sentence to the end of paragraph 5.64 to indicate there will be annual monitoring of affordable housing.

Inspector’s Reasoning and Conclusions Objections and Conditional Withdrawals

1. There are ten objections to this policy from nine objectors.

2. As far as objection 242/14 is concerned, this has been conditionally withdrawn after PC54.

3. I therefore conclude that PC54 should be advertised as a modification to the Local Plan.

4. As to objection 089/5, although this has also been conditionally withdrawn, it is not clear why the withdrawal is conditional or what it depends on. Be that as it may, as the Objector recognises Blackpool is an urban area. Indeed, I would go further and say that in my view no part of the Borough is sufficiently remote from the built up area to have what could be called (in terms of government guidance) specifically rural housing needs. Neither are there any areas for which “a rural exceptions policy” might be an appropriate policy response.

5. I conclude that the plan should not be modified in response to objection 089/5.

The Lack of a Housing Needs Survey (Objectors 189, 194, 328, 358)


6. Several objectors refer to the lack of an up-to-date Housing Needs Survey, without which the need for affordable housing contributions from housing developments has not been shown to exist. The Local Plan refers to a HNS that was being undertaken in 2002 and the results of this became available towards the end of the Local Plan Inquiry. Thus, although the complaints about a lack of data may have been justified at the time the objections were made, the situation has been remedied by the publication of the HNS. In my view the HNS demonstrates that there is a need for affordable housing in Blackpool. I consider that the text in the Local Plan should be updated to reflect all this.

7. Objector 358 apparently takes particular exception to the nature, form and procedures of the HNS that was undertaken. However, they declined to give me any evidence to substantiate these criticisms. I therefore consider that I have no reason to reject the HNS and its findings. This Objector also criticised the form and content of the policy presently in the Local Plan although they made no suggestions as to how it could be improved. I therefore consider I have no grounds for altering the policy in response to objection 358/1.

8. I conclude that the references in the text to the HNS should be up-dated.

The Threshold (Objectors 189, 194, 242, 303, 326)

9. The developers say the site size threshold is too low at 0.5 ha. CPRE says there should be no threshold so that all sites would be expected to make a contribution. GONW says that exceptional local constraints must be shown to exist if the threshold of 1.0 ha or 25 dwellings suggested in Circular 6/98 is to be departed from.

10.The Council’s 0.5 ha threshold was retained in the Second Deposit. The Council justifies this not by reference to the level of housing need but by reference to the small housing allocations and sites in Blackpool.

11. I note that very few of the housing allocations in the Local Plan are larger than 1.0 ha and to employ this as a size threshold would mean that very little affordable housing would be provided through this policy in Blackpool. In fact not many more of the housing allocations fall within the range 0.5 to 1.0 ha but some windfalls may occur in this range also.

12.As to CPRE’s objection, the Circular on affordable housing is quite clear that some level of threshold should be used and that expecting a contribution from all housing developments, no matter how small, is not envisaged.

13.However, in view of the number of conversions and high-density / small-site developments that are coming forward in Blackpool, I consider it is a surprising omission that the site size threshold is not expressed in terms of the number of dwellings as well as the area of sites. I consider that this should be rectified and that, if the ratio expressed in the Circular is followed, a threshold of 15 dwellings should be used.

14. I conclude that a level of need for affordable housing has now been demonstrated that, taken together with the small number of sites involved, justifies the 0.5 ha site size threshold in the Local Plan. However, this threshold should also be expressed in terms of a number of dwellings. I consider that this should be 15 dwellings.

The Level of Provision (Objectors 189)

15.Objector 189 takes issue with the 20% level of provision indicated in the policy,


especially in the absence of a robust HNS. However, the reference to a minimum of 20% affordable housing provision was removed from the Local Plan in the Second Deposit. To this extent this objection has been met.

16.However, in my view this leaves something of a void that the Council should consider addressing either by an addition to the text in the Local Plan, or by preparing supplementary planning guidance or by an early review of this part of the Local Plan.

17. I conclude that the Council should consider addressing the issue of the level of affordable housing contribution to be sought in developments either by an addition to the text in the Local Plan, or by preparing supplementary planning guidance or by an early review of this part of the Local Plan.

Site Characteristics (Objector 189)

18.The same Objector also wants the considerations mentioned in Circular 6/98 paragraph 10 (such as site size and suitability and the economics of provision) referred to in the Local Plan. The Council does not dispute that this is desirable. I consider that the text in the Local Plan should be expanded accordingly.

19. I conclude that the text of the Local Plan should be modified to refer to the matters identified in Circular 6/98 paragraph 10 that should be taken into account when assessing each site’s suitability for affordable housing.

Objector 194

20.Apart from the issues already dealt with, the Government Office (GONW) makes several more detailed objections. These include:

the policy should not “require” but should “seek” an affordable component in housing developments;

the Local Plan should define what the Council means by affordable housing in more detail, taking account of Circular 6/98 paragraphs 4 and 9a;

that the Local Plan should indicate how many affordable homes need to be provided in Blackpool overall;

the Local Plan should set indicative targets for each site.

21.As far as the first of these is concerned, it does not seem to me that this matter is entirely clear cut in the light of current practice. This is because affordable housing is now sometimes secured by planning conditions instead of by planning obligations. Planning conditions may be required even if planning obligations may only be sought. It is also the case that the policy as it stands does not require any particular level of contribution.

22.Be that as it may, no harm would be done to either the Local Plan or the Objector if the phrase in the policy “The Council will require new housing developments on sites greater than 0.5 ha to make” were reworded as “Housing developments larger than 0.5 ha (or 15 dwellings) will be expected to make”.

23. I conclude that this should be done.

24.As to the need to define what the Council means by affordable housing in more detail, I consider this was done by the changes to the policy made in the Second Deposit. I conclude that no further elaboration is necessary.

25. I agree that the Local Plan could and should now indicate how many affordable


homes need to be provided in Blackpool overall on the basis of the HNS results. This could be achieved by an addition to the up-dated text to take account of the results of the HNS. I conclude that this should be done.

26.As to setting indicative targets for each site, I have already concluded that the Council should consider addressing the issue of the level of affordable housing contribution to be sought in developments either by an addition to the text in the Local Plan, or by preparing supplementary planning guidance or by an early review of this part of the Local Plan. Unless it is known that the level being sought on any particular site would vary from the general level, I consider that no further action is needed in this direction.

27. I conclude that when the Council is addressing the issue of the level of affordable housing contribution to be sought in developments it also considers whether any individual sites should make a different contribution.

Off-Site Provision (Objector 145)

28.Mrs Cunningham is against allowing the off-site provision of affordable housing as this will not add to the general mix of development. She is also against directing social housing to the inner areas of the town because, she says, that is already where it is concentrated.

29.The Council disputes her view on both counts. The Council says it is not the intention to allow off-site provision in all cases. The Council also says that most of the existing social housing in the Borough is not in the inner areas but in the suburbs. Allowing more social housing in the inner areas would help redress this imbalance and help to solve housing problems in the private rented sector that are concentrated in the inner areas.

30.Whilst I note what the Council says, as the policy is currently worded it does seem to me that it contains no guidance on where off-site provision will be acceptable and this, in effect, leaves matters to the discretion of developers. This could lead to all the provision being off-site if that is what developers want.

31.However, the Council lays great emphasis on solving inner area housing problems which arise because of the present concentration of poor quality privately rented housing. In this situation, it does not seem to me that any great harm would be caused if much of the affordable housing was off-site if that led to the resources being directed to the inner areas. This is what the policy indicates should occur when off-site provision is being made.

32.On the balance of the evidence I conclude no modification is necessary.

The Council’s Evidence

33.As part of their evidence the Council produced a Housing Needs Survey (HNS). Where appropriate, I have taken this into account in the conclusions I have reached on each of the objections. At the end of their evidence the Council informally suggested a new policy HN9 they say is based on the HNS. Whilst I have considered the new policy, I have not based my recommendations on it. This is because the new policy came too late to be advertised as a Proposed Change and there has been no opportunity for objections to it.

34. If the Council wishes to pursue this new policy, it will be able to do so on the basis that the new policy arises from new information that was not available when either the Local Plan or the Proposed Changes were prepared. However, before deciding to embark on such a course of action the Council will no doubt


wish to consider whether this could lead to new objections that may necessitate another Local Plan Inquiry. A Local Plan Inquiry into the modifications could cause considerable delay to the process of adoption.

35.As an alternative the Council may wish to consider whether it can elaborate the affordable housing policy with supplementary planning guidance or whether an early review of this aspect of the Local Plan is preferable.

Overall Conclusions

36. I am not entirely satisfied that this is the affordable housing policy Blackpool needs. But modifying this Local Plan extensively may not be the best way forward. I have therefore couched my recommendations in terms that give the Council some flexibility to decide how to take matters forward. My overall conclusions are that:

PC54 should be advertised as a modification to the Local Plan;

the text in the Local Plan should be updated to refer to and describe the results of the Housing Needs Survey;

this updating should include an indication of the overall level of need for affordable homes in Blackpool during the plan period;

the size site threshold should remain at 0.5 ha but it should also be described as relating to a site capacity of 15 dwellings;

the Council should consider how best to indicate what level of contribution is expected from each eligible site either by expanding the text in the Local Plan or by preparing supplementary planning guidance. Alternatively the Council may decide that the best way forward is to move to an early review of this part of the Local Plan;

any sites that are expected to depart from the usual contribution for affordable homes should be identified in the policy or text;

the text in the Local Plan should refer to the matters identified in paragraph 10 of Circular 6/98 as being relevant to decisions about the suitability of each site for an affordable housing contribution;

the second paragraph in the policy should be reworded as: Housing developments larger than 0.5 ha (or 15 dwellings) will be expected to make”.

37.Otherwise, I conclude no modifications to the Local Plan arise from these objections.

Recommendations38. I recommend that PC54 is advertised as a modification to the Local Plan. 39. I recommend that the text in the Local Plan is updated to refer to and

describe the results of the Housing Needs Survey.40. I recommend that this updating should include an indication of the overall

level of need for affordable homes in Blackpool during the plan period.41. I recommend that the size site threshold in the policy remains at 0.5 ha

but that it is also described as relating to a site capacity of 15 dwellings.


42. I recommend that the Council considers how best to indicate what level of contribution is expected from each eligible site either by expanding the text in the Local Plan or by preparing supplementary guidance. Alternatively the Council may decide that the best way forward is to move to an early review of this part of the Local Plan.

43. I recommend that any individual sites that are expected to depart from the usual requirement for affordable homes are identified in the policy or text.

44. I recommend that the text in the Local Plan refers to the matters identified in paragraph 10 of Circular 6/98 as being relevant to decisions about the suitability of each site for affordable housing.

45. I recommend that the second paragraph in the policy is reworded as: Housing developments larger than 0.5 ha (or 15 dwellings) will be expected to make.

46.Otherwise I recommend no modifications to the Local Plan as a result of these objections.

Officers CommentsThe Local Plan affordable housing policy HN9 was written in advance of the results of the 2004 Blackpool Housing Needs Survey. The draft policy set out a strategic approach, broadly identifying the types of affordable housing provision appropriately provided in Blackpool. The 2004 Blackpool Housing Needs Survey was subsequently completed in advance of the close of the Inquiry in March 2005.

The Inspectors recommendations give flexibility to the Council how best to take on board the findings of the Survey and modify the policy, whilst advising caution about the extent of any modifications which could give rise to new objections that may necessitate another local plan inquiry. He puts forward 3 alternatives.

A fully modified policy including detailed new information arising from the results of the Survey. Elaborate Policy HN9 with supplementary planning guidance An early review of this aspect of the Local Plan.

Having regard to the early need for more detailed guidance to inform the delivery of affordable housing, and paying heed to the Inspector’s advice, it is considered the most appropriate action is to limit modification of Policy HN9 at this stage and to subsequently set out detailed guidance for implementation of the policy in supplementary guidance. The Inspector’s Report makes no specific modification to the strategic approach set out in the Policy.

Amendments to Policy HN9 are therefore limited to the Inspector’s specific recommendations which are all considered should be accepted, together with his recommendation to incorporate the main aspects of the findings of the Housing Needs Survey as a modification to the supporting text in the Local Plan.


Recommendation (38) is accepted and accordingly PC54 is advertised as a modification to the Local Plan.

PC54:

“Information on the annual delivery of affordable housing and the operation of affordable housing policy will be monitored on an annual basis”.


Recommendation (39) is accepted that the text in the Local Plan is updated to refer to and describe the results of the Housing Needs Survey (as set out below)

Recommendation (40) is accepted that this updating should include an indication of the overall level of need for affordable homes in Blackpool during the plan period. In line with the results of the Housing Needs Survey, all private sector housing developments over 0.5 hectares will therefore be required to provide 30% affordable housing.

Recommendation (41) is accepted that the size site threshold in the policy remains at 0.5 ha but that it is also described as relating to a site capacity of 15 dwellings.

Recommendation (42) is accepted that the Council provides further details on the scales and types of affordable housing required to be provided either by expanding the text in the Local Plan or by preparing supplementary guidance. Accordingly it is recommended that:

o the Policy should clarify in line with the results of the Housing Needs Survey that the overall affordable housing target should be 30% on new development sites.

o the supporting text is amended to clarify in line with the findings of the Survey that around half of this provision should be as discounted low cost market (intermediate) housing and half should be for social rented housing directly linked to housing renewal in Blackpool’s inner areas).

o Further details of the scale and types of affordable housing required and how it will be delivered will be provided in supplementary planning guidance and that appropriate reference is made to this in the Plan.

Recommendation (43) is accepted that any individual sites that are expected to depart from the usual requirement for affordable homes are identified in the policy or text. Each of the 4 sites identified in Policy HN2 over the identified size threshold are considered should comply with this aspect of the Policy, and no departure from this requirement is thus identified.

Recommendation (44) is accepted that the text in the Local Plan refers to the matters identified in paragraph 10 of Circular 6/98 as being relevant to decisions about the suitability of each site for affordable housing. Accordingly the following addition to the supporting text is therefore required:

“It is recognised that site configuration, location and the need to incorporate an appropriate

mix of dwellings might together undermine the ability of developers to provide a good quality

and mix of market and affordable housing on certain sites. In such circumstances in

accordance with the Policy any under provision on site can similarly be met by off-site

provision in partnership with Housing Associations as part of an agreed programme for

renewal action”.

Recommendation (45) is accepted that the second paragraph in the policy is reworded as: Housing developments larger than 0.5 ha (or 15 dwellings) will be expected to make.

Recommendation (46) is accepted.

In accordance with all the above recommendations it is therefore recommended that the full Revised Policy HN9 and supporting text is as follows:


HN9 - Affordable and Specialist Needs Housing

To make sufficient provision to meet the needs of Blackpool residents for affordable and specialist needs housing.

The Council will require new housing developments on sites greater than 0.5 hectares or of more than 15 dwellings to make provision of a minimum of 30% of the total number of dwellings as affordable housing comprising:

On-site provision of affordable housing, either as discounted low cost social housing, shared ownership social housing or replacement social housing to rent

or Off-site social housing provision to buy or rent directly linked to housing renewal action

in Blackpool’s housing priority neighbourhoods (to reduce the amount of poor quality rented accommodation)

Proposals for affordable and special needs housing including sheltered housing for the elderly should be located close to public transport, local shops and other community facilities, and provision should be mixed throughout the development site.

The Council will ensure that where discounted and affordable social housing is provided, it remains affordable to successive occupiers by:· developers entering into a legal agreement· imposing appropriate planning conditions on any consent granted· ensuring that initial rents or sale prices are subject to agreement by the council and

index linked thereafter.

5.53 It is a priority of the Council to ensure there is an adequate supply of good standard housing which people can afford to buy or rent.

5.54 North West Regional Planning Guidance suggests that the predominance of low cost housing provision in many parts of the Region means the greatest need will be in more scenic rural areas and affluent commuter belts around the major conurbations.

5.55 Blackpool does not have the same housing pressures, but house prices at the lower end of the market are substantially higher than in the region’s more industrial towns and cities. There are also problems caused by the poor standard of accommodation in much of the town’s large private rented sector, overwhelmingly concentrated in small multiple flatted premises.

5.56 The numbers on the Council’s housing waiting list for one bedroom accommodation reflects this shortage of better quality accommodation for younger persons, as well as a high demand for sheltered housing for Blackpool’s large elderly population. There are also needs for more family housing, particularly for larger families.

5.57 In the previous Plan period to 2001 there has been a mix of new house building across the Borough. The town’s large stock of terraced and semi-detached housing led to new build in the 1990’s including higher proportions of both smaller flats and detached dwellings.

5.58 In overall terms, however, much of the new private sector housing development recently built in Blackpool has been lower cost market housing, particularly in the inner areas. Additionally, most of the sites allocated in the currently adopted Local Plan were in Council ownership and around 500 new homes have been built by housing associations, much of it on land specifically released by the Council to meet affordable housing needs.

5.59 The Council has also continued to co-operate with housing associations to assist the acquisition


and refurbishment of existing premises for social rented housing, in good quality self-contained accommodation in accordance with the Council’s standards. Measures to increase low cost home ownership are also being encouraged by the Council.

5.60 The allocation and availability of sites 2001-2016 means future housing development will take place on a wider range of generally smaller sites, most of which will be privately owned rather than under the Council’s own estates control.

5.60A A comprehensive new survey of the housing needs of Blackpool residents was undertaken in 2004 and has further informed the Council’s understanding of the local housing market and the deed for affordable housing.

5.60B The results of the Survey showed that Blackpool’s social stock is only 11.2%, just over half the national average, with an annual need for around 300 more affordable homes than the existing annual supply. The survey indicated strongly that there is an affordability problem when assessing local incomes against the realistic supply of the cheapest stock available, with a key requirement to develop a more balanced housing stock.

5.60C The town’s large private rented stock particularly in the central area was found to provide an initial base for a large proportion of in-migrant households on low incomes, with a very close link between the private rented sector, in-migration and regeneration strategy. The report concluded there is a need to deliver radical change in the nature and quality of housing, focused on the inner areas and that large-scale resources will be required to achieve successful renewal.

5.60D The Council’s Housing Strategy, Neighbourhood Renewal Strategy and the Resort Masterplan provide a coordinated approach to the range of problems in the inner area. The findings of the Survey support an increased level of discounted low cost/ shared ownership housing, with future levels of provision of social rented housing linked to housing regeneration in the priority areas.

5.60E The Survey concluded the overall affordable housing target should be 30% on new development sites. It advised that:

o around half of provision should be as low cost market (intermediate) housing delivered at a cost below the cheapest entry level costs and available on a similar basis to subsequent purchasers.

o Around half of units should be for social rent to address problems of households within regeneration areas, with neighbourhood renewal strategies the primary driver in creating both better economic and social balance in the Borough.

5.61 Reflecting these circumstances Policy HN9 therefore seeks to secure a 30% ensure a continuing level of provision of affordable housing. on all substantial housing schemes over 0.5 hectares, including both low cost housing and social housing for sale or rent. The Council is focussed on delivering more balanced and healthy communities which best meet local residents needs, with any further on-site provision required either as discounted low cost or shared ownership social housing. Alternatively the Council will seek to encourage and actively promote Alternative provision in partnership with Housing Associations, as part of an agreed programme for renewal action to replace, improve and reduce the amount of poor quality rented accommodation and provide a more balanced mix of properties in Blackpool’s inner areas.

5.61B It is recognised that site configuration, location and the need to incorporate an appropriate mix of dwellings might together undermine the ability of developers to provide a good quality and mix of market and affordable housing on certain sites. In such circumstances in accordance with the Policy any under provision on site can similarly be met by off-site provision as part of an agreed programme for renewal action.

5.63 The Council will ensure affordable social housing will remain affordable to successive as well as initial occupiers, secured via legal agreements and planning conditions.


5.63A "The private sector can also make an important contribution to the provision of sheltered accommodation for the elderly/ specialist needs housing. Blackpool has by far the largest number of elderly people in Lancashire and in previous years the Council's own programme of house-building included making significant provision for Blackpool's elderly population. The Blackpool Housing Needs Survey states the retired will comprise 21% of the population by 2021, with the 80+ group growing by 14% having increased care and support needs. The findings suggest a substantial requirement for sheltered accommodation, both for older people living in the Borough and in-migrants.

5.63B It will be important to assess the convenience of potential affordable housing and sheltered/ specialist needs housing for public transport, local shops and other community facilities".

5.64 A comprehensive new survey of the housing needs of Blackpool residents is being undertaken during 2003 which will further enable the Council to develop its understanding of the local housing market and the need for affordable housing, informing the housing policies in the Plan. Supplementary planning guidance will be prepared utilising the results of the housing needs survey to provide more detailed guidance on the delivery of the types of affordable housing provision required in Blackpool. Information on the annual delivery of affordable housing and the operation of affordable housing policy will be monitored on an annual basis.

5.28 Homes for Every Need Additional PolicyThe Objection189/3 McCarthy and Stone (Developments) Limited

Summary of the ObjectionThere should be a policy in the Local Plan relating to the provision of special needs housing, especially sheltered housing for the elderly. Blackpool has an ageing population and the needs of the elderly should not be overlooked. (189)

Inspector’s Reasoning and Conclusions 1. This objection was to the First Deposit. In the Second Deposit the Council made

several changes to policy HN9 with the effect of broadening its area of concern to include special needs housing and sheltered housing for the elderly. Paragraph 5.63A also acknowledges the important contribution that the private sector can make to the provision of sheltered accommodation for the elderly and those with specialist housing needs. The Council also says that the most highly specialised residential uses are dealt with in policy BH24.

2. Although this objection has not been withdrawn, the Objector did not pursue it when they submitted written evidence to the Local Plan Inquiry on other aspects of the (altered) policy HN9.

3. In my view this matter is now adequately addressed in the Local Plan and I have no evidence to the contrary.



189/3.


Officers Recommendation The Inspector’s recommendation is accepted

5.29 Homes for Every Need Local Plan Page 125: Housing TargetsThe Objection326/21 CPRE (Lancashire Branch)

Summary of the ObjectionThe second housing target should be amended to a minimum of 79% housing on brownfield land over the whole period of the Local Plan. (326)

Inspector’s Reasoning and Conclusions 1. The Council accepted the substance of this objection and dealt with it by adding

an additional housing target in the Second Deposit: at least 80% of new dwellings in Blackpool to be on previously developed land, including conversions of buildings, 2001 – 2016.

2. I therefore consider that this objection has been met and conclude that no (further) modification is needed.

Recommendations3. I recommend that no modification to the Local Plan is made in response

to objection 326/21.



6.1 Balanced and Healthy Communities Paragraph 6.4The Objection277/5 Brian J Dougherty

Summary of the ObjectionDelete the word “or” and replace with "nor" (277)

Inspector’s Reasoning and Conclusions 1. The Council agreed with this objection and made the required correction in the

Second Deposit. I conclude that no (further) change is required.


objection.Officers Recommendation


6.2 Balanced and Healthy Communities Paragraph 6.7The Objection285/2 Nature Watch Group BEAT

Summary of the ObjectionBlackpool is a tightly constrained urban area in which maintaining contact with the natural environment should be a priority. Add to point 4: "including land of known wildlife conservation value and potential value." (285)

Inspector’s Reasoning and Conclusions 1. This paragraph in the Local Plan sets out the objectives for the Balanced and

Healthy Communities chapter. The Council says that the objectives relating to the Natural Environment are contained in Chapter 8 of the Local Plan. I see no reason to repeat the environmental objectives in every chapter and have no evidence as to why they should be included especially in Chapter 6.

2. I conclude that there is no need or reason to modify the Local Plan in response to this objection.


objection.


233Balanced and Healthy Communities Chapter 6

6.3 Balanced and Healthy Communities Policy BH1 The Objection287/17 Tesco Stores Limited

Summary of the ObjectionThe approach set out in the First Deposit is criticised but no specific change is suggested. (287)

Inspector’s Reasoning and Conclusions 1. I note that the material in the First Deposit that gave rise to this objection was

all deleted in the Second Deposit. I conclude there is no need to consider this objection further.


objection.


6.4 Balanced and Healthy Communities Policy BH2The Objections031/3 J M Rigg

194/32 Government Office for the North West (Conditionally Withdrawn)


287/18 / 30 Tesco Stores Limited

Summary of the ObjectionDickson Road should be included in the Local Plan’s regeneration proposals. It is generally agreed to be “tatty” and unattractive. Some properties should be demolished and bungalows built for the older generation, releasing houses which are well maintained for the younger generation. (031)

The status of Neighbourhood Action Plans needs to be clarified, in particular whether they are to be used as guidance for developers. If so, this policy needs to set out a clearer context for the preparation of the guidance. (194/32) (First Deposit)

The reference to planning guidance should be moved from the policy to the accompanying text because it cannot have the same status as the Development Plan. Paragraph 6.15 should make it clear that if the planning guidance leads to policies and proposals these will be progressed as part of the development Plan and not as supplementary guidance, so that the public have the opportunity to object within the statutory framework. (194/70) (Second Deposit)

When preparing Neighbourhood Action Plans the Council should bear in mind the potential for retail development to act as a catalyst for regeneration. No specific change to the Local Plan is suggested. (First Deposit) The changes in the Second Deposit go some way to meeting the Tesco objection to the First Deposit but more recognition for the positive role of retailing is needed. Specifically, deleting the word “community” from BH2 (A) (ii) and BH2 (B) (ii) would remove any suggestion that retailing is not included. (Second Deposit) (287)

Proposed ChangesPC55 suggests that the second sentence of policy BH2 (dealing with Neighbourhood Planning Guidance) should be deleted.


PC56 would add to paragraph 6.15 the clarification and distinction between policy and guidance sought by Objector 194.

On this basis the Government Office for the North West Conditionally Withdraws its objections to policy BH2 (194/32 and 194/70)

Inspector’s Reasoning and Conclusions Government Office (Objector 194)

1. It seems to me that the fine legal distinctions being made by the Government Office have been recognised in the PC55 and PC56. I also note that the Government Office conditionally withdraws its objections on this basis. I see no harm in what is now proposed. I conclude that PC55 and PC56 should be advertised as modifications to the Local Plan.

Tesco, Community Facilities and Retailing (Objector 287)

2. As to the Tesco objections, the changes in the Second Deposit seem to have gone some way towards meeting the original objection to the First Deposit. However, the word “community” in both the clauses numbered (ii) in the policy is objected to on the grounds that this could be seen as (unreasonably) excluding new or improved shopping facilities.

3. However, the Council says that “community facilities” are intended to cover a wide range of facilities that may include shops. This being the case, I see no reason to retain the word community in this context. Larger scale shopping provision is the subject of other policies in the Local Plan.

4. I conclude that the word “community” should be deleted from the two parts of policy BH2 numbered (ii).

Dickson Road (Objector 031)

5. The Council says that between its junctions with Springfield Road and Pleasant Street, Dickson Road is located within the Dickson Road / North Promenade Resort Action Plan area. Between Pleasant Street and Warley Road it forms the boundary between the Resort Neighbourhood Action Plan area and the Claremont Neighbourhood Action Plan area. Proposals to improve the Dickson Road frontage will be a high priority for these Neighbourhood Action Plans.

6. Although the terminology may change as a result of the changes already discussed above, my understanding is that the intention remains the same. In other words the Council also regards the improvement of this area as a high priority and will be directing planning and other resources to achieve this. To this extent there is no disagreement between the Council and the Objector.

7. I note that the Council does not comment on the detailed proposal suggested by the Objector (partial redevelopment for old persons’ housing). However, it would not be appropriate for the Local Plan to go into this sort of detail, certainly not before the necessary survey work and public consultation take place.

8. I conclude there is no need to modify the Local Plan in response to this objection.


Local Plan.10. I recommend that the word “community” is deleted from the two parts of


policy BH2 numbered (ii). 11. I recommend no modification to the Local Plan in response to objection

31/3.

Officers Recommendation The Inspector’s recommendation that PC55 and PC56 are advertised as modifications

to the Local Plan is accepted:

PC55 Delete the second sentence of the Policy:

Neighbourhood Planning Guidance will be prepared, as part of Neighbourhood Action Plans, to secure the comprehensive improvement of the following priority neighbourhoods:

PC56 Amend first and second sentences of paragraph 6.15 to read;

Neighbourhood Planning Guidance (NPG) will be a key component of NAPs bringing forward detailed policies and proposals to secure the comprehensive improvement of the defined inner area and outer estate priority neighbourhoods. shaping the physical development of neighbourhoods in accordance with Local Plan policies but reflecting the specific needs of the area and its local community. The NPG will reflect the specific needs of the area and its local community. This guidance will be adopted, either as Supplementary Planning Guidance or, where it brings forward detailed new policies and proposals, as a formal amendment to the Local Plan.

The Inspector’s recommendation that the word “community” is deleted from the two parts of Policy BH2 numbered (ii) is accepted.

The Inspector’s recommendation (11) is accepted

6.5 Balanced and Healthy Communities Policy BH3The Objection145/53 Mrs F A Cunningham

Summary of the ObjectionNo development should be allowed without private amenity space, especially in or near the town centre because amenity space is in such short supply there. (145)

Proposed ChangePC57 would add to part B (iv) provision for storing materials to facilitate recycling.

Inspector’s Reasoning and Conclusions 1. The Council is anxious not to be over-prescriptive in this matter for fear of

preventing some schemes with worthwhile regeneration effects or making mixed-use schemes impossible.

2. As the policy stands, the provision of private amenity space in residential development will be the norm unless the criteria in the second part of the policy are all met. In my view this is a reasonable approach; at least more reasonable than a blanket requirement to provide private amenity space and gardens for all flats would be. This could prevent some otherwise desirable developments.

3. I conclude that the policy should not be modified.

Recommendation


4. I recommend no modification to the Local Plan in response to this objection.


6.6 Balanced and Healthy Communities Paragraph 6.26The Objection329/17 Sport England

Summary of the ObjectionThe title of this sub-section of the Local Plan should include the word “sport” to reflect PPG17. (329)

Proposed ChangePC58: change heading of subsection to “Open Space, Sports and Recreational Facilities”.

Inspector’s Reasoning and Conclusions 1. The Council’s Pre-Inquiry Change would meet this objection. I conclude that it

should be progressed.


Officers Recommendation The Inspector’s recommendation that PC58 is advertised as a modification to the Local

Plan is accepted:

PC58 Amend the title of the sub-section as follows:

Open Space, and Sports and Recreational Facilities’

6.7 Balanced and Healthy Communities Policy BH5The Objections109/18 English Nature (Cheshire to Lancashire Team) (Conditionally Withdrawn)


188/4 Wildlife Trust (Lancashire, Manchester & North Merseyside)


255/8 Beverley Moy

329/ 7 / 14 / 15 Sport England

Summary of the ObjectionsParagraph 6.32 (where it refers to small scale structures in open space) should qualify what is said by the addition of: 'providing they are incorporated sensitively within the open space, and do not impact (adversely) on existing nature conservation interest.' (109) (Second Deposit) (Conditionally Withdrawn


after PC62)

Objection is made to the change of the designation at Leys Nursery (south of Rock Garden at Warbreck). The site is derelict, why has it been removed from the designation? (The objection relates to the amendment of the Proposals Map in BH5PM1. (Second Deposit) (145)

Policy BH5 should make reference to the importance of contact with nature and the text should have cross-references to the relevant Natural Environment Policies (NE8, NE9, NE10 and NE11). (188)

The designated land to the south of the Rock Garden (Warbreck) is United Utilities operational land. It should not be designated under this policy but should be shown as unallocated "white land" within the urban area. (252)

Geldof Drive should be allocated and protected as public open space under this policy. (255)

The policy should reflect paragraphs 16 and 17 of PPG17 and should read as follows: "No development will be permitted of Public Open Space, unless it would support existing recreational uses (for example, interpretation centres, toilets, and refreshment facilities), or would provide facilities for new recreational uses. The Council will seek to ensure that all proposed development takes account of, and is sensitive to, the local context. The Council will seek to: (i) avoid any erosion of recreational function and maintain or enhance the character of open spaces; (ii) ensure that open spaces do not suffer from increased overloading, traffic flows, or other encroachment; (iii) protect and enhance those parts of the rights of way network that might benefit from open space; and (iv) consider the impact of any development on biodiversity and nature conservation. (329/7) (First Deposit)

BH5 (a) fails to mention and protect existing sports facilities. (329/14) (Second Deposit)

Policy BH5 is not fully in accord with PPG17 paragraph 10, which indicates that open space should not be built on unless an assessment shows it to be surplus to requirements. (329/15) (Second Deposit)

Proposed ChangesPC59 proposed amending the boundary at Claremont Park / Claremont Primary School (but this was withdrawn by the Council during the Local Plan Inquiry to meet the objection from Mrs Moy).

PC60 proposes a minor amendment to the boundary of the area designated as future open space at Strathdale. (It therefore seems to me to relate to policy BH6, not BH5 as stated in the PC document because this land is shown on the Proposals Map as being New Open Space protected by policy BH6.)

PC62 would add to paragraph 6.32 in relation to small structures “and do not impact on existing nature conservation interest”.

Objections to the Proposed Changes255/20 Beverley Moy

PC59 is objected to because of the loss of public open space.

Inspector’s Reasoning and Conclusions The Policy in General (Objector 329)

1. Given the respective dates of publication of the First Deposit Local Plan and the latest version of PPG17, it is not surprising that the Local Plan did not reflect the guidance in the PPG. However, largely in response to the first Sport England objection, the policy was completely re-written in the Second Deposit. In my view it is now much closer to the guidance in PPG17.

2. Furthermore, in view of the fact that the Objector has re-visited the matter in their objections to the Second Deposit and now only has two specific and detailed criticisms, it seems to me that Sport England are now largely satisfied. I shall therefore limit myself to considering the two outstanding Sport England objections to the Second Deposit.

3. As far as the first of these is concerned it is true that clause (a) of the policy


refers to sport in relation to new uses but not in relation to existing uses. It seems to me this is an oversight. It could be remedied by rewording the clause as: “(a) the proposal would support existing sport or recreational uses or would provide facilities for new sport or recreational uses.”

4. I conclude that this should be done.

5. As to referring to the test inherent in PPG17 that before open space is removed from sport and recreation uses it should be demonstrated by an independent audit to be surplus to requirements, it is also true that this is missing from the policy as it stands. The Council says that in advance of an up-to-date open space assessment in line with PPG17, the Council is taking a generally protective stance towards the development of all types of public open space. Any development of public open space would be contrary to policy BH5 unless it satisfied criteria (a) and (b), or unless provision was made for replacement open space in a suitable location. This is a precautionary approach which reflects the low level of open space provision across the Borough when assessed against the NPFA standards. If other material considerations indicated that a development may be acceptable, contrary to this policy, the applicants would need to demonstrate they have met the requirements of PPG17 paragraph 10. The Council therefore feel there is no need for the policy to repeat the guidance in PPG17 in this respect.

6. I also note that playing fields and sports grounds (public and private) are dealt with in policy BH7, which should further protect the Sport England interest in the matter. I therefore find the Council’s stance on policy BH5 plausible and convincing. In my view, in the circumstances that Blackpool finds itself in, the policy protecting public open space is adequate.

7. I conclude that the policy need not be modified to refer explicitly to the need for a needs assessment to demonstrate that public open space is surplus to requirements before such land could be developed.

Small Scale Structures (Objector 109)

8. I note that this objection has been conditionally withdrawn in the light of PC62. I conclude that PC62 should be advertised as a modification to the Local Plan and that no further consideration of the matter is required of me.

Importance of Open Space / Cross References to Other Policies (Objector 188)

9. This objection was to the First Deposit. In response the Council amended paragraph 6.32 in the Second Deposit so that it now refers to the opportunities provided by open space for enhancing nature conservation. I consider that this part of the objection is therefore met.

10.As to cross-referencing to the Natural Environment Policies, the Council says it accepts that there is a link but that, as a general rule, it has not made such cross-references in the plan in order to comply with government guidance on keeping plans short and simple. In any event, every policy in the plan is subject to the provisions of all the other policies in the plan. I accept that this general rule is a sensible one and that there is no particular reason to depart from it in this instance.

11. I conclude that no (further) modification arises from this objection (beyond the changes made in the Second Deposit).


South of Rock Garden (Warbreck) (Objectors 252 and 145)

12.The Council agreed with objection 252/1 to the First Deposit and made the necessary change in the Second Deposit (see map BH5PM1). This was done because the land was said to be operational land.

13.Although Objector 145 questions this decision, I have no evidence that it is not correct or that it does not reflect the true situation and condition of this land.

14. I conclude that no (further) modifications arise from these objections (beyond the change made in the Second Deposit).

Geldof Drive (Objector 255)

15.At the Local Plan Inquiry the Objector said that this objection could be completely withdrawn, although I have no record of this being confirmed in writing. Be that as it may, the land is no longer allocated for housing. I therefore conclude that no further change is needed in response to this objection.

Claremont Park / Claremont Primary School (Objector 255)

16.At the Local Plan Inquiry the Council withdrew the Proposed Change affecting this site in response to Mrs Moy’s objection. I have no reason to disagree.

17. I therefore conclude that PC59 should not proceed and that in this respect matters should be left as they were in the Second Deposit.

Recommendations18. I recommend that PC62 is advertised as a modification to the Local Plan.19. I recommend that PC60 is advertised as a modification to the Local Plan.20. I recommend that PC59 is not pursued.21. I recommend that clause (a) in the policy is modified to: (a) the proposal

would support existing sport or recreational uses or would provide facilities for new sport or recreational uses.

22.Otherwise I recommend no modifications to policy BH5 in the Local Plan.


Plan is accepted:

PC62 Amend the final sentence of paragraph 6.32 to read:

Small-scale structures, such as interpretation centres, toilets, refreshment facilities and changing rooms, which would support existing recreational uses or would provide facilities for new recreational uses will be acceptable development, providing they are incorporated sensitively within the open space, and do not impact on existing nature conservation interest


PC60 Amend Boundary on proposals map – (as per map BH5PMC2) The Inspector’s recommendation that PC59 (to change the boundary of Claremont

Park and Claremont Primary sites) is not pursued is accepted:


23. The Inspector’s recommendation that Clause (a) in the policy is modified as set out below is accepted:

(a) the proposal would support existing sport or recreational uses or would provide facilities for new sport or recreational uses.


Summary of the ObjectionThe use of NPFA standards is a guide but does not relate to PPG17 standards and this should be acknowledged. (329) (Second Deposit)

Inspector’s Reasoning and Conclusions 1. Paragraph 6.29 says “the use of this national (NPFA) standard provides a

useful guide but in practice the appropriate level of provision must reflect the specific demand for different types of open space and facilities, site opportunities and the accessibility of facilities to residents.” It goes onto to say that the Council will be carrying out a more detailed examination of the quantity, quality and accessibility of specific types of open space and sports and recreation facilities and will develop local standards of provision for Blackpool. In my view this does acknowledge the inadequacies of the NPFA standards. However, for the avoidance of doubt I consider that the last sentence in paragraph 6.29 could start with the words “In accordance with the guidance in PPG17, a more detailed assessment . . . .”.

2. I conclude that the last sentence in paragraph 6.29 should start with the words “In accordance with PPG17, a more detailed assessment . . . .”.

Recommendations3. I recommend that the last sentence in paragraph 6.29 should start with the

words “In accordance with the guidance in PPG17, a more detailed assessment . . . .”.


4. The Inspector’s recommendation that the last sentence in paragraph 6.29 should start with the words “In accordance with the guidance in PPG17, a more detailed assessment . . . .” is accepted.


Summary of the ObjectionThe benefits of open space for sports should also be mentioned. (329)

Proposed ChangesPC61 would add “sports” to the first sentence of paragraph 6.32.


PC62 would add to paragraph 6.32 in relation to small structures “and do not impact on existing nature conservation interest”.

Inspector’s Reasoning and Conclusions 1. It appears to me that this objection would be met by PC61 and I conclude that it

should be advertised as a modification to the Local Plan.



Plan is accepted:PC61 Amend first sentence of paragraph 6.32 to read:

‘Open space within the urban area has important recreational, sports and visual amenity benefits and is highly valued by local communities.’

6.10 Balanced and Healthy Communities Policy BH6The Objections145/4 Mrs F A Cunningham

244/1 Fylde Bird Club

329/8 Sport England

Summary of the ObjectionsHousing allocation H11 (Leys Nursery) should be designated as public open space. (145)

Include Rough Heys County Biological Heritage Site within BH6 to afford it protection. Restore the area by bulldozing the top soil back across the site. (The top soil is still on site in a pile and should contain important biological material such as seeds.) This site is not designated for building in this Plan but building work has begun. This should be stopped urgently and the site afforded protection. (244)

Whilst Sport England supports the objective of this policy, BH6 should be amended to reflect fully the contents of PPG17 paragraph 20. (329)

Proposed ChangesPC60 proposes a minor amendment to the boundary of the area designated as future open space at Strathdale. (It therefore seems to me to relate to policy BH6, not BH5 as stated in the PC document.)

Inspector’s Reasoning and Conclusions Sport England

1. Sport England’s objection was to the First Deposit, since when the Second Deposit changed this policy and the accompanying text. The policy now says that new public open space and sports facilities should be in areas of existing under-provision. Paragraph 6.32b indicates that opportunities will be sought to improve provision where there is potential and especially in areas of need such as the inner areas of the town. I have also noted elsewhere that a full study of open space, sport and recreation facilities is to be undertaken.

2. Paragraph 20 of PPG17 includes a list of eleven criteria to be used in the


selection of locations for new open space and sports and recreation facilities. Blackpool is an area that is already built up in which it will be difficult to find new sites. The Local Plan now places priority on finding new open space and sports and recreation facilities in areas where there is an identified shortfall. Pending the promised further work on identifying the areas of greatest need, I consider this is as far as it is sensible for the Local Plan to go.


Rough Heys

4. As I understand matters, this site was granted planning permission (in 1997) for development before it was notified to BBC as a County Biological Heritage Site (in 1999). Development had commenced even at the time of the First Deposit. It therefore seems to me that the future of this site is not in my hands – things have gone too far.

5. In any event, it does not seem to me that designating the land as public open space would be the right way to go about protecting its wildlife value – the need for new public open space and nature conservation are different considerations.


Leys Nursery

7. I deal with this site (H11) in the Housing section of my report where I recommend it is allocated neither for housing development nor as new public open space. There is no need to repeat the arguments here.


Recommendations9. I recommend that the Local Plan is not modified in response to objection

329/8.10. I recommend that the Local Plan is not modified in response to objection

244/1.11. I recommend that the Local Plan is not modified in response to objection

145/4.

Officers Recommendation The Inspector’s recommendations are accepted.

6.11 Balanced and Healthy Communities Paragraph 6.39The Objection188/6 Wildlife Trust (Lancashire, Manchester & North Merseyside)

Summary of the ObjectionParagraph 6.39 should cross-reference to Policy NE8 (Other Sites of Nature Conservation Value). This


is because in some instances the BH8 and NE8 designations coincide. Land at Kincraig Road is cited as an example. (188)

Inspector’s Reasoning and Conclusions 1. The Council says that the land at Kincraig Road is to be reclassified as BH5

and this took place in the Second Deposit (see map BH6PM1). Although in one sense this deals with the objection (because this site would no longer be BH8), in my view it does not deal with the general point that is being made.

2. However, I have already dealt with the issue of cross-referencing policy BH5 to the Natural Environment policies. In that context I noted that the Council says it accepts that there is a link but that, as a general rule, it has not made such cross-references in the plan in order to comply with government guidance on keeping plans short and simple. In any event, every policy in the plan is subject to the provisions of all the other policies in the plan.

3. I accept this general rule is a sensible one in relation to policy BH5 and there is no particular reason to depart from it in relation to policy BH8 either.

4. I therefore conclude that the Local Plan should not be modified in response to objection 188/6.

Recommendation5. I recommend that the Local Plan is not modified in response to objection

188/6. Officers Recommendation


6.12 Balanced and Healthy Communities Policy BH7and paragraph 6.37a

The Objections329/ 9 / 11 / 12 Sport England

Summary of the ObjectionsThe policy does not adequately protect all playing fields or reflect PPG17. A complete re-drafting of the policy is suggested. Also, the following definitions should be included in the supporting text: "playing field" – the whole of a site which encompasses at least one playing pitch; "playing pitch" – a delineated area which, together with any run off area, is of 0.4 hectares or more, and which is used for association football, American football, rugby, cricket, hockey, lacrosse, rounders, baseball, softball, Australian football, Gaelic football, shinty, hurling, polo, or cycle polo. (First Deposit) (329/9)

In criterion (e) the issue is not one of retaining a sufficient area to meet school needs but of wider community needs. (Second Deposit) (329/11)

The redrafted policy is not fully in accord with Sport England policy, nor with PPG17. In particular section (e) of the policy is not adequate because it ignores wider community needs. (Second Deposit) (329/12)

Proposed ChangesPC63 would add to the wording of paragraph 6.36a dealing with the loss of school playing fields to differentiate between those with a secured agreement for wider community use and those without.

Objections to the Proposed Changes329/ 18 / 19 Sport England


Summary of the ObjectionsThe existence of secured agreements is not a sufficient protection for school playing fields. (329/18) Before school playing fields are given up the English Sports Council‘s requirements should be met. (329/10)

Inspector’s Reasoning and Conclusions 1. The Objector made a comprehensive critique of the First Deposit policy. Since

then the policy has been substantially re-written, the suggested definitions have been included as paragraph 6.38a and the scope of the policy has been widened to cover all playing fields and sports grounds not just protected school playing fields.

2. The Second Deposit policy follows PPG17 closely (except for section (e) that relates to school playing fields). In view of the Sport England Second Deposit objection it would appear that the Objector is far more content than was the case at the First Deposit. Be that as it may, the Local Plan – as I must assess it – is now the Second Deposit version.

3. In my view there was a fundamental flaw in the alternative policy suggested by the Objector at the First Deposit – in that it referred to “the judgement of Sport England” being the determining consideration. This is unacceptable because the responsibility for planning decisions is with, and must remain with, the Local Planning Authority. Also the wish to achieve a completely watertight policy has led to a rather detailed, long and fussy wording. Therefore the general form of the Council’s Second Deposit policy is to be preferred. It has the added advantage (for me at least) of following PPG17 more closely.

4. However, one remaining difference is that the Sport England suggested policy referred to land that was last used as a playing field as well as land currently used as such. In my view this is a weakness in the Local Plan policy that should be rectified either in the policy or the text.

5. That leaves criterion (e) in the Second Deposit policy as the major contentious matter to be resolved. As it stands this part of the Local Plan policy is a significant departure from the guidance in PPG17.

6. In defending this part of the policy the Council seeks to distinguish between school playing fields that are subject to a secured agreement to be used by the wider community and those that are not. PC63 would write this into the Local Plan. However, the existence of such agreements may be haphazard and, even where they exist, such agreements may be more easily revoked than is desirable.

7. On balance therefore – and on the evidence I have – I consider that clause (e) of the policy should be deleted.

8. I conclude that:

(a) it should be made clear in the policy or the text that the policy applies to land last used as a playing field as well as land now used as such;

(b) criterion (e) of the policy should be deleted;

(c) PC63 should not be progressed.

Recommendations9. I recommend that policy BH7 is modified as follows:


(a) it should be made clear in the policy or the text that the policy applies to land last used as a playing field;

(b) criterion (e) of the policy should be deleted. 10. I recommend that PC63 is not progressed

Officers CommentsThe Inspector recommends the deletion of criterion (e) of Policy BH7 in response to objection from Sport England that it is inadequate because it ignores wider community needs. The Council’s additional wording in its pre-Inquiry amendment (PC63) including further safeguards in instances where a playing field ‘has a secured agreement for use by the wider community’ was still considered insufficient by Sport England to protect wider community needs.

Your officers remain concerned about the recommended deletion of criterion (e). In Blackpool there are quite regularly instances when extensions to existing school facilities are required, with a substantial rebuilding modernisation and extension programme having been undertaken by the Council since it became a unitary authority to improve facilities for children in its schools.

In such instances in Blackpool’s highly developed urban area new classroom provision may lead to loss of playing fields, with no potential for nearby suitable replacement provision. Criterion (e) is therefore needed to ensure such developments can be permitted providing there is still a sufficient area of playing fields/ playground to meet existing/ future school needs.

Whereas the existing policy does not satisfy Sport England, its deletion effectively avoids addressing a specific issue that continues to occur in Blackpool schools. In addition, as stated in the supporting text to the policy, the Council is in any case required to consult Sport England about all proposed developments that affect land used as playing fields. It is therefore considered that criterion (e) should be retained subject to further amendment to address the objection from Sports England, whilst ensuring that school building on playing fields is dealt with in the policy, as set out below:

Officers Recommendation That the Inspector’s Recommendation 9 (a) is accepted and paragraph 6.38a of the supporting

text should therefore be amended to state in the fist sentence “For the purposes of this policy a playing field, including land last used as a playing field, is defined as the whole of the site which accompanies at least one playing pitch”.

That the Inspector’s Recommendation 9(b) is not accepted

Amend criterion (e) and PC63 is amended to state:

(e) “ In the case of school playing fields or playgrounds:

o The land is needed for the expansion of school facilities, and,

o A sufficient area of playing fields/ playgrounds is retained to meet existing and future school needs, and,

o The land is not required to meet other existing or potential future community needs and its development is supported by the wider community.

As a consequence to amend paragraph 6.37(a) of the supporting text to state:

6.37(a) Development adversely affecting the quantity or quality of playing field or sports ground provision will only be permitted where there are wider community benefits and the development is supported by the wider community. This may


include the development of a playing field or sports ground for an alternative outdoor or indoor sport facility or, in the case of school playing fields or playgrounds, for expanded school facilities, - providing a sufficient area is retained to meet the school’s existing and future needs and that land is not required to meet other existing or potential future community needs. The Council will consult Sport England about all proposed developments that affect land used as playing fields. Where development would result in the loss of a school playing field that has a secured agreement for use by the wider community, replacement provision will need to be made in a suitable location.

6.13 Balanced and Healthy Communities Policy BH8The Objections188/7 Wildlife Trust (Lancs, Manchester & N Merseyside) (Conditionally Withdrawn)

329/10 Sport England

Summary of the ObjectionsPolicy BH8 should make reference to the importance of contact with nature and the text should have cross-references to the relevant Natural Environment Policies (NE8, NE9, NE10 and NE11). (188)

Land meeting community and recreational needs should be protected by policy BH5.(329)(First Deposit)

Inspector’s Reasoning and Conclusions Sport England

1. The Sport England objection was to the First Deposit, since when there were several changes to the Local Plan. In particular, policy BH7 has been changed in the Second Deposit so that it now refers to all playing fields and sports grounds and not only to (some) school playing fields. I consider that the Local Plan is right to differentiate between playing fields / sports pitches and other land of community and recreational value. The two sorts of land are different in function and character. I also consider that the Sport England interest is now adequately safeguarded by policy BH7 (if my recommendations are followed).

2. I conclude no modification to the plan is needed in response to this objection.

Wildlife Trust

3. As a result of this objection to the First Deposit, in the Second Deposit paragraph 6.39 was amended to refer to the nature conservation value of these sites and policy BH8. As a result the objection was conditionally withdrawn. I conclude that no further modifications arise.

Recommendation4. I recommend that the Local Plan is not modified in response to objections

329/10 and 188/7.


That the Inspector’s Recommendation is accepted


6.14 Balanced and Healthy Communities Policy BH9The Objection326/22 CPRE (Lancashire Branch)

Summary of the ObjectionThe wording of this policy should be changed to “Alternative uses of allotment sites will not be permitted unless: . . . (326) (First Deposit)

Inspector’s Reasoning and Conclusions 1. The wording change sought in this objection was made in the Second Deposit. I

conclude that no further change is needed.


326/22.



______________________________________________________________

6.15 Balanced and Healthy Communities Policy BH10and paragraph 6.44

The Objections189/2 McCarthy and Stone (Developments) Limited



Summary of the ObjectionsThe text supporting policy BH10 should be amended to include a sentence along the following lines: "In respect of new development providing specialised accommodation for the elderly such as sheltered housing, the Council will only require the provision of amenity space as part of the scheme." (189)

Open space provision is only necessary on sites greater than 1 ha in area. Commuted sums should only be payable on sites greater than 1 ha. (242)

The threshold should be increased from 3 to 10 dwellings. (253)

Inspector’s Reasoning and Conclusions The Threshold (Objectors 242, 253)

1. As far as the threshold is concerned, the Council says that this is carried forward from the previous adopted Local Plan, is contained in their current supplementary planning guidance and has worked well for several years.

2. They also point to recent government guidance (Companion Guide to PPG17, paragraph 9.13) that appears to argue against any threshold at all (and that all development should be treated in the same way).

3. One of the objectors says that a higher threshold would be consistent with current practice in neighbouring authorities but supplied no information to substantiate this. In any event, the situation in the neighbouring (more rural) authorities may not be comparable to the situation in Blackpool. In the absence


of any (persuasive) evidence to the contrary, I conclude that things should be left as they are.

Specialised Housing for the Elderly (Objector 189)

4. In response to this objection to the First Deposit the Council included a sentence very like the one suggested in the Second Deposit. The Objector has not withdrawn their objection but neither have they made any further representations in support of their original wording.

5. The difference is that the Council’s wording allows for the possibility that the amenity space provided in association with sheltered housing could be close to the development as well as within it. It seems to me that this provides some flexibility and is therefore both desirable and may be in the Objector’s interest.

6. I conclude that no (further) modification to the Local Plan is needed in response to objection 189/2.


189/2, 242/10 and 253/1. Officers Recommendation


6.16 Balanced and Healthy Communities Paragraphs 6.42 – 6.45The Objection109/8 English Nature (Cheshire to Lancashire Team)

Summary of the ObjectionWhilst in general support of this policy, the following should be added to the text, as paragraph 6.46: "The provision of public open space also provides opportunities for enhancing nature conservation, which is beneficial to biodiversity and the well-being and quality of life of residents.” (109)

Inspector’s Reasoning and Conclusions 1. In considering this objection to the First Deposit, the Council accepted the

importance of open space for nature conservation and decided to amend paragraph 6.32 to reflect this. The point is thus made in relation to the policy concerned with retaining existing open space rather than (as the Objector wished) in relation to the policy concerned with providing open space in new development. However, it seems to me to be a relevant consideration in both contexts and see no harm in the issue being raised in both parts of the Local Plan.

2. I therefore conclude that the suggested wording is added to the text accompanying policy BH10. In my view the most logical place for the new paragraph is between 6.42 and 6.44 to replace (the now deleted) paragraph 6.43.

Recommendation3. I recommend that the following is added to the Local Plan as paragraph

6.43: The provision of public open space also provides opportunities for enhancing nature conservation, which is beneficial to biodiversity and the


well-being and quality of life of residents.


That the Inspector’s Recommendation is accepted that the following is added to the Local Plan as paragraph 6.43:

“The provision of public open space also provides opportunities for enhancing nature conservation, which is beneficial to biodiversity and the well-being and quality of life of residents”.

6.17 Balanced and Healthy Communities Policy BH11The Objections023/2 Ravenside Investments Ltd




Summary of the ObjectionsBlackpool Retail Park (and land adjacent to it) should be identified as a preferred location for retail warehouses and/or a district centre. (023)

Reword the second sentence of the policy as: "New retail, cultural and community development and key town centre uses will normally be permitted within the defined boundaries of Blackpool town centre, the district centres and local centres, appropriate to the scale, role and character of each centre". (236)

The Tesco store and Clifton Retail Park should be identified as a district centre. (287)

The maintenance and enhancement of the hierarchy of centres is supported. But some uses (eg saunas, massage parlours, escort agencies, health/suntan clubs) have a harmful effect on neighbouring properties and harm the image of the resort. A paragraph should be added to indicate that the Council will work towards curtailing these activities based on location, the likely impact on neighbours and the vicinity and the unsuitability of such uses as a group or part of a retail frontage. (295)

Inspector’s Reasoning and Conclusions Policy Wording (Objector 236)

1. This objection was to the First Deposit. It appears to the Council (and to me) that the specific wording changes were largely made in the Second Deposit. (The exception to this was the suggested inclusion of the word “normally” in the policy. I do not normally recommend the inclusion of this word in policies because its meaning is unclear and because reasonable exceptions to policies can be made in any event.)

2. I conclude that no (further) modifications arise from this objection.

Unacceptable Uses (Objector 295)

3. The Council takes the view that the purpose of this policy is to set out the overall approach to shopping and that it would not be appropriate to deal with specific uses in detail here. Whilst the Council may also not approve of some of these uses, they are best located in secondary shopping frontages. Whether some of these uses are entirely within the law is not a planning matter that should be addressed in the Local Plan.

4. In general terms I agree with what the Council is saying here. If a use is legal,


then the role of planning is to guide it to the best locations. If a use is against the law then it should be dealt with under the legislation which it offends. It does seem to me that the best location for the sort of uses referred to is in secondary shopping areas – after all they would be less welcome in prime shopping or residential areas. In planning terms the location of such uses has to be dealt with on their planning merits and not according whatever other views we have about their desirability. It might also be difficult to define what constitutes an undesirable use other than by example.

5. For all these reasons I conclude that the Local Plan should not be modified in response to this objection.

Blackpool Retail Park (Objector 023)

6. At the Local Plan Inquiry Objector 023 withdrew their objection seeking the designation of the Blackpool Retail Park as a district (shopping) centre. I therefore consider that matter no further.

7. All the other (retail) aspects of the objections from Objector 023 are considered below under policy BH12. The industry / business aspects of their objections are considered under policy DE2.

Tesco and Clifton Retail Park (Objector 287)

8. There are three shops, including the very large Tesco store at the Clifton Retail Park. Although these may, to some extent, serve nearby residents; the facilities are clearly designed as, and function as, an out-of-centre retail facility. There are no other services and facilities at the site such as one might expect to find in a district centre. I consider that the decision not to designate this area as a district centre is consistent with government guidance and the definitions set out therein. That there are no district centres in the vicinity does not alter the facts of the case.

9. I conclude that the Clifton Retail Park is not a district centre and should not be designated as one.

Recommendations10.For my recommendations on objection 023/2 see under policy BH12.11. I recommend no modification to the Local Plan in response to objections

236/04, 295/9 and 287/19.


That the Inspector’s Recommendations are accepted.

________________________________________________________________6.18 Balanced and Healthy Communities Policy BH12The Objections023/ 5 /7 Ravenside Investments Ltd


203/1 B & Q plc




287/ 20 / 31 Tesco Stores Limited

369/1 Nathaniel Lichfield & Partners

Summary of the Objections(Land adjacent to) Blackpool Retail Park should be identified in policy BH12 as the preferred location for retail warehouses. (023/5) (First Deposit)

Leave paragraph BH12 (b) as originally in the First Deposit. (023/7) (Second Deposit)

It is not clear to which areas the policy applies. The policy starts by referring to Blackpool Town Centre, although later in the policy and the text Blackpool’s district and local centres are referred to. Criteria (a) to (f) are worded as if they are intended to apply to centres other than the Town Centre. It is suggested the start of the policy is reworded to make it clear that the uses being described will be focussed on the different centres (the Town Centre and the district and local centres) commensurate with their scale, catchment and function. The criteria would then be applied to edge-of-centre and out-of-centre sites and locations. Although the wording in criterion (d) is derived from PPG6 paragraph 1.11, deleting the words “district and local centres” would be consistent with PPS6 paragraph 2.36. (194) (Other Government Office objections to this policy in the First Deposit have been met by changes made in the Second Deposit and are withdrawn.) (194)

The policy is confused and confusing. The need for new shops only has to be demonstrated in relation to proposals in edge-of-centre and out-of-centre locations and not in centres. This is not apparent in criterion (a) as worded. Criterion (c) is unnecessary. Flexibility in format, design and scale should not be expected to an extent that would prevent an identified need being met. The policy should be reworded: “Proposals for the development of retail uses, and other key town centre uses which attract a lot of people, will be considered in accordance with a sequential approach. Development will be permitted where the local planning authority is satisfied that: (a) There is a need for the proposal. (b) The proposal is located in accordance with the sequential approach where first preference is for town centre sites, followed by edge of centre sites, district and local centres and only then out of centre sites. (c) Either by itself or cumulatively with other committed development it would not adversely affect the vitality and viability of local centres. (d) access and car parking requirements are satisfactory and that the local roads can accommodate anticipated traffic generation. (e) the site is readily accessible or can be made accessible by foot, cycle and public transport. (First Deposit) (203)

The need for new shops and the sequential test only have to be demonstrated in relation to proposals in edge-of-centre and out-of-centre locations and not in centres. The wording should be changed to relate only to proposals for major new retail development including extensions and changes of use outside existing defined centres. There should be a separate policy for other key town centre uses as there is no requirement to demonstrate need in relation to these. The criteria should be amended, deleted or added to in order to reflect this approach and national guidance. (236, 239)

Only retail and leisure developments are required to demonstrate need and not the other cultural, community and key town centre uses referred to. (First Deposit) In any event the policy should not apply to extensions to stores to which the sequential test does not apply. (Second Deposit) (287)

BH12 (b) should be reworded by the deletion of “the proposal either by itself, or cumulatively with other recent and committed developments, would not adversely affect the vitality and viability” to be replaced by “the proposal either by itself, or cumulatively with other recent and committed developments, would cause no material adverse impact on the vitality and viability” (369)

Proposed ChangesPC64 suggests that BH12 (b) should be reworded as: “The proposal either by itself, or cumulatively with other recent and committed developments, would cause no material adverse impact on the vitality and viability of Blackpool Town Centre, district and local centres, or any other nearby town centres.” (Inspector’s comment: this appears to reflect exactly the change sought by objection 369/1)

Inspector’s Reasoning and Conclusions 1. The Local Plan Inquiry closed before PPS6 was issued. What follows therefore

relies on PPG6 (and subsequent ministerial statements) as current expressions of government policy and guidance. It is true that a draft of PPS6 had been issued for consultation before the Inquiry closed and some objectors referred to this. However, as a draft statement of policy this carries far less weight than the


version of PPG6 that was current at the time. The Council (and others) will need to bear this in mind when reading what follows and when determining what to do about my recommendations and possible modifications.

The General Form and Application of the Policy (Objectors 194, 203, 236, 239, 287)

2. Objector 194 finds the policy confusing because it starts by focussing on Blackpool town centre and goes on to deal with district and local centres. In response the Council offers some additional wording that could be added to the first part of the policy, although it considers this to be unnecessary.

3. My own view is also that this may be unnecessary, but I accept that it makes matters absolutely clear and harder to misinterpret. On this basis I am inclined to accept what is offered. I consider it is also helpful in relation to one of the matters raised by Objector 203.

4. I conclude that the words “and in other existing centres appropriate to their scale and catchment” should be added to the end of the opening paragraph in policy BH12.

5. The other unresolved issue for Objector 194 relates to the inclusion of a reference to district and local centres in section (d) of the policy. The Objector acknowledges that this is in complete accord with PPG6 but less so with draft PPS6. For the reasons explained at the outset of my consideration of this policy I attach much more weight here to PPG6 than to the draft PPS6. I therefore conclude that I should not recommend deleting these words, although it is a matter that the Council may need to return to when it has studied the issued version of PPS6.

6. As for Objector 203, there have been changes in the Second Deposit since this objection was made but I do not have the further views of the Objector on these. It seems to me that in some respects the detailed points made by the Objector were incorporated in the Second Deposit (although the resultant policy lacks the simplicity of the Objector’s suggested alternative wording). In particular it is now clear (especially with the added words recommended above) that considerations of need only apply outside centres. Otherwise the matters raised are concerned with wording and interpretation that do not appear to me to affect the overall meaning of the policy.

7. I conclude that no (further) modifications arise from objection 203/1.

8. Objectors 236 and 239 also make the point about the requirement to assess the need for new retailing only outside centres, which I say has been met. In other respects their comments on the First Deposit were also accepted in the Second Deposit; for example, by adding accessibility as a consideration at the end of the policy.

9. These Objectors (and 287) also say that a separate policy is needed for non-retailing (and possibly also leisure) uses. However, this is not my view because PPG6 specifically refers to “all key town centre uses which attract a lot of people” (which are the words used in the policy). In any event I consider there is no necessity to separate out other uses into a separate policy if the Council wishes to deal with them together.

10.Apart from this, in my view the comments made are matters of detail that do not relate to material departures from government guidance and do not, therefore, necessitate changes to the Local Plan. It is clear that the policy is couched in


terms that refer to and acknowledge the government’s sequential approach and it is not necessary to (selectively) include details of how this guidance will be applied (for example by specifying that town centre sites should be suitable, available and viable).

11. I conclude that no (further) modifications to policy BH12 are needed as a result of the objections from objectors 236 and 239.

12.As well as the question of how non-retailing uses should be dealt with, Objector 287 takes issue with the inclusion of (retail) extensions in the policy, although in my view this is in line with ministerial statements. However, this matter may need to be re-examined in the light of PPS6.

13. I conclude that no modification arises from the objections from Objector 287.

The Wording of Criterion (b) (Objectors 023, 369)

14.This particular criterion has attracted a lot of attention and fine tuning. To cut a long story short, the Council’s current version – as in PIC64 – meets the wishes of Objector 369 but not of Objector 023.

15.For my part, the cumulative changes represent an improvement in clarity and appear to accurately reflect current government guidance. I consider that the original wording (“unacceptable impact”) favoured by Objector 023 is open to wider interpretation, which is perhaps why that Objector favours it. I therefore consider that the PC64 wording is better.

16.Having said that, it is now a rather inelegant mouthful and I wonder whether the following would not be better English: “The proposal either by itself, or cumulatively with other recent and committed developments, would not cause material harm to the vitality and viability of Blackpool Town Centre, district and local centres, or any other nearby town centre.” However, this is not a matter upon which I feel it is necessary to make a firm recommendation.

17. I conclude that PC64 should be advertised as a modification to the Local Plan but that consideration is given to my wording as an alternative.

Extending Blackpool Retail Park (Objector 023)

18.Objector 023 is concerned with a site that adjoins the Blackpool Retail Park (hereafter BRP). As things stand the site is designated under policy DE1 as (part of) the Squires Gate Estate, which is to be retained under that policy for industrial/business uses. It is also designated under policy DE2 as an Industrial Improvement Zone. Both these designations are objected to and the Objector wishes the site to be allocated for retailing as part of the adjacent BRP.

19.For convenience both the DE policy objections are dealt with under policy DE2. All aspects of the shopping objection(s) relating to this site are dealt with here.

20. It is accepted that the objection site could be redeveloped for retailing purposes using its (rather narrow) frontage facing into the BRP. The narrow frontage available dictates that the redeveloped site could contain one (relatively large) unit or (at most) one small and one large unit. Although no prospective occupier was referred to, it was said that the type of shopping at the site would be retail warehousing for bulky goods, akin to the sort of activity in the adjoining units.

21. In presenting their case to the Local Plan Inquiry the Objector relied, in part, on calculations that treated “bulky goods retail warehousing” as a distinct sector of


total retail demand. Although this approach may have proved useful in particular appeal cases in the past, in my view it does not adequately reflect current government guidance on retail planning in the wider context that is relevant during Local Plan preparation. To adopt such an approach in Blackpool could have the result that a demand for out-of-centre facilities could be shown to exist only because such facilities are already in the catchment area.

22. In sequential terms the objection site is a long way down the pecking order. Above it are Blackpool town centre, sites adjacent to the town centre, other district centres in Blackpool and other existing centres within what is acknowledged to be the wider Fylde catchment area served by BRP. In my view it has not been demonstrated that there are no sites (or insufficient sites) in sequentially preferential locations within the catchment area. In particular the Local Plan contains proposals that will bring forward sites in and adjacent to Blackpool town centre for retailing, some of which will be able to accommodate units selling bulky goods.

23.The Objector says this site should be recognised as sequentially preferable to other out-of-centre sites by virtue of its location next to BRP which means that it can be integrated with that existing retail park. In my view, there is no basis for this claim in government guidance and I am not persuaded that the claim has much logic or force. In any event, it would only become a consideration when there was a proven need to provide additional out-of-centre retailing and I see no merit in taking this decision before such a need is proved.

24.As to whether there is a need, the Objector and Council used somewhat different survey data with different results (although they are within 5% of each other). Be that as it may, it is agreed there will be scope for further retail development in the catchment area over the plan period. But there are reasons to believe that the survey data is not entirely reliable as far as shopping patterns at BRP are concerned. Be that as it may, it is agreed that the scope for more retail floorspace in the wider catchment will build up over time and become more significant towards the end of the Local Plan period.

25. In the meantime there is a major shopping development already afoot in the town centre (Hounds Hill) and less well defined prospects for more in the medium term (at Blackpool North and the Winter Gardens). This evolving and phased approach in the town centre (which provides some now but with more to come in the later part of the plan period) reflects the gradual build up of demand for more floorspace in the area. It is not, in my view, a convincing argument for providing for more floorspace in a sequentially less suitable location now.

26.There is also a difference of view about how robust Blackpool Town Centre is as a shopping centre. It is agreed that its market share has declined, although the Objector says that in other respects it continues to thrive. For my part, I do not consider the Council is wrong to want to bolster its role as the pre-eminent shopping destination in the Fylde. However, whatever view one takes on this issue does not alter the outcome as far as assessing the objection site is concerned, especially as it is not argued that any decline of the town centre is directly attributable to BRP.

27.The Objector placed some reliance on (their interpretation of) particular wording in draft PPS6. As explained above, I have attached less weight to this than to PPG6 and ministerial statements.

28.For these reasons I conclude that the Objection site should not be allocated for


shopping development now and should not be identified in the Local Plan as a suitable location for retail development in the future.

Recommendations29. I recommend that the words “and in other existing centres appropriate to

their scale and catchment” are added to the end of the opening paragraph in policy BH12.

30. I recommend that PIC64 should be advertised as a modification to the Local Plan but that consideration is also given to my preferred wording as an alternative.

31. I recommend that the objection site at (or next to) the Blackpool Retail Park should not be allocated for shopping development now and should not be identified in the Local Plan as a suitable location for retail development in the future.

32. In other respects I recommend no modifications to policy BH12 in response to these objections.


The Inspector’s Recommendation (29) is accepted that the words “and in other existing centres appropriate to their scale and catchment” are added to the end of the opening paragraph in policy BH12.

The Inspector’s recommendation (30) is accepted that PC64 is advertised as a modification to the Local Plan, but with amended wording (in line with paragraph 16 of the Inspector’s Report) to improve its clarity as set out below:

“The proposal either by itself, or cumulatively with other recent and committed developments, would not cause material harm to the vitality and viability of Blackpool Town Centre, district and local centres, or any other nearby town centre.”



6.18 Balanced and Healthy Communities Policy BH12 and PPS6

Officers CommentsWhile the Inspector makes no other specific recommendations on Policy BH12, he makes reference (in paragraphs 5 and 12) to two issues that may require further reconsideration to take account of the Government’s Revised Planning Policy Statement (PPS6) on Planning for Town Centres which was not published until after the close of the Local Plan Inquiry. These are:

The inclusion of retail extensions in the policy.


The inclusion of reference to district and local centres in section (d) of the policy.

Extensions: PPS6 clarifies that the requirement to take into account the impact of extensions should continue to be given particular weight, including establishing need and the application of the sequential approach (the latter relating to extensions over 200 sq.m.). There is therefore no further change required on this issue and reference to extensions is correctly retained in the Policy.

Criterion (d) referring to district and local centres:

PPS6 clarifies that local planning authorities should continue to set out their strategy for a hierarchy of centres in development plans, including local centres. It therefore remains relevant to include local centres within the area of search for developments appropriate to their scale and function. PPS6 suggests LPAs should consider setting an indicative limit for the scale of developments likely to be permissible in different types of centres, with developments above these limits directed to higher order centres.

The sequential approach set out in PPS6 requires that locations are considered in the following order:1 locations in appropriate existing centres2 edge of centre locations3 out of centre sites

In Blackpool’s terms ‘appropriate existing centres’ thus includes all existing town, district and local centres, taking account of an appropriate scale of development in relation to the role and function of the various centres. It is therefore considered Policy BH12 should be amended to reflect the approach as set out in PPS6.

PPS6 also suggests consideration should be given to setting indicative limits for the scale of developments likely to be permissible in different types of centre – but this is not a requirement. Given Policies BH11 and BH12 already set out the need for new developments to be considered having regard to the scale, role, character and catchment of each centre, and the substantial variation in the size of Blackpool’s various centres, it is not considered appropriate to set arbitrary size thresholds.

For example, if there was a sequential choice of sites for a sizeable 1,000 sq.m. foodstore, this could be larger than what might generally be thought an appropriate scale of development for most local centres. However, it remains better that such a store is integrated within a local centre containing two dozen existing shops, rather than being a new stand alone destination. On the other hand relating such a store to a small local shopping parade of 4 or 5 shops is of very little relevance. The indicative thresholds for different local centres in Blackpool could thus vary substantially and while amending the Policy B12 criterion (d) to generically refer to all existing centres, it is therefore considered unnecessary to go further and identify size thresholds for lower order centres.


Policy BH12 (d) should be amended to reflect PPS6 to state:

(d) The proposal is located in accordance with the sequential test, having regard to the need for flexibility of format, design and scale. First preference is for town centre sites locations in appropriate existing centres, followed by edge of centre sites, district and local centres and only then out of centre sites.


6.19 Balanced and Healthy Communities Paragraph 6.51The Objections023/6 Ravenside Investments Ltd

203/2 B & Q plc

Summary of the ObjectionsThe Council’s Retail Study is out of date. A proper assessment of the need for further retail warehouse development is an essential requirement of the Plan (023)

The Council’s Retail Capacity Study is not accepted – it should consider specific sectors such as DIY. In any event the text should clarify that the Blackpool Shopping Study was undertaken in 1999 (203)

Inspector’s Reasoning and Conclusions 1. To the extent that the Second Deposit altered paragraph 6.51 to make it clear

that the Blackpool Shopping Study referred to dates from 1999, objection 203/2 has been met. However, both objections go deeper than that in my view.

2. At the Local Plan Inquiry a much more recent Blackpool Shopping study was produced and used by the Council. To my mind it would be useful if the adopted Local Plan were to refer to that and give some indication of its contents. This should include such generalisations and sector breakdowns as are possible, bearing in mind the nature of the data involved and the need to keep the Local Plan reasonably brief. However, I recognise that this will not necessarily satisfy these objectors who may have particular outcomes in mind.

3. Be that as it may, I conclude that paragraph 6.51 in the Local Plan should be revised in the light of the latest available study.

4. As to the B & Q suggestion that DIY should be identified and treated as a separate sector of retail demand, such forms of analysis may be produced as a result of shopping studies. However, they would only be essential in a Local Plan context if the Local Plan were making specific allocations of land for that retail sector. This is not the case here, the Objector has not suggested that it should be the case and I would be unlikely to agree even if they did.

5. I therefore conclude that no modification to the Local Plan arises.

Recommendations6. I recommend paragraph 6.51 is updated to refer to the latest retail study

and to give a broad indication of the study’s contents and conclusions. 7. Otherwise I recommend no modification to the Local Plan in response to

these objections.


The Inspector’s recommendations are accepted, with paragraph 6.51accordingly updated to refer to the latest retail study and to give a broad indication of the study’s contents and conclusions as set out below:

6.51 ‘In terms of major retail development, the Blackpool Shopping Study in 1999 and the 2004

Blackpool Shopping Study both identified a clear and specific need to improve provision in Blackpool

town centre and no quantitative or qualitative need for new floorspace outside the centre. The 2004

Study found that since 1999 Blackpool’s market share has fallen, with continuing leakage to other


major competing centres outside the sub-region and a substantial loss of trade to out of centre facilities

within the town’s immediate urban area. The Study identifies substantial capacity for 43,000 sq.m. of

additional non-food retail floorspace by 2016 and also confirms a need to bolster Blackpool town

centre’s poor market share in food shopping. The Study concluded retail growth should therefore be

directed to the existing town centre, with sufficient sites already identified in the Local Plan to meet

most of the identified need, and no need for the allocation of any further sites elsewhere in the urban

area.”

6.20 Balanced and Healthy Communities Policy BH13The Objections023/1 Ravenside Investments Ltd

26/2 J R Dewhurst (Conditionally Withdrawn)



Summary of the ObjectionsDesignate Blackpool Retail Park as district centre. (023)

There should be a reference to improving car parking in the District Centres, especially for those with impaired mobility and especially in Bispham. (026)

Modify the final sentence of the policy which indicates that the expansion of these centres will not normally be allowed. The policy should allow development of an appropriate scale and function having regard to amenity and environmental considerations. (239)

The Tesco store and the Clifton Retail Park should be identified as a district centre. (287)

Inspector’s Reasoning and Conclusions The Expansion of District Centres (Objector 239)

1. Sainsburys point to the advantages that the expansion of district centres can bring and say that the policy as worded is too restrictive in this respect.

2. However, my reading of the policy is that it does not prevent or restrict expansion as a matter of principle or in all cases. Indeed, it specifically says that proposals for retail and other active frontage uses that are appropriate to the scale and function of the centres will be permitted. However, it is true that the policy explicitly says that the expansion of shopping and commercial uses into adjoining residential streets will not be permitted.

3. The Council says that the prohibition of expansions into residential streets is a long-standing policy in Blackpool’s Local Plans and is necessary to protect residential amenity. On the face of it, this seems to be a justifiable stance.

4. Although this Objector does not indicate any location where this policy should not apply, an analogous situation does arise as a result of an objection to policy BH14. In that case I conclude that part (b) of that policy should be reworded as follows: “The expansion of shopping and commercial uses into adjoining residential streets by the piecemeal conversion of individual properties will not be permitted. Proposals to extend the shopping frontages of these centres will


only be allowed if they involve frontages that are contiguous with an existing shopping frontage, are in scale with the existing centre and can be achieved without harming residential amenity.” In my view the same considerations arise here and consistency is important.

5. I conclude that the policy should be modified accordingly.

Tesco and the Adjoining Retailers (Objector 287)

6. There are three shops, including the very large Tesco store at the Clifton Retail Park. Although these may, to some extent, serve nearby residents; the facilities are clearly designed as, and function as, an out-of-centre retail facility. There are no other services and facilities at the site such as one might expect to find in a district centre. I consider that the decision not to designate this area as a district centre is consistent with government guidance and the definitions set out therein. That there are no district centres in the vicinity does not alter the facts of the case.


Blackpool Retail Park (Objector 023)

8. This objection was withdrawn at the Local Plan Inquiry. Therefore no modification arises. I deal with the other objections from this Objector to the shopping policies in the Local Plan above.

Car Parking (Objector 026)

1. The suggested change to paragraph 6.61 was made in the Second Deposit. As a result this objection to the First Deposit was conditionally withdrawn. (There are two paragraphs 6.61 in my copy of the Local Plan; this relates to the first of them.)

2. I conclude that no (further) modification to the Local Plan arises.

Recommendations9. I recommend that the last paragraph of policy BH13 is modified to read as

follows: “The expansion of shopping and commercial uses into adjoining residential streets by the piecemeal conversion of individual properties will not be permitted. Proposals to extend the shopping frontages of these centres will only be allowed if they involve frontages that are contiguous with an existing shopping frontage, are in scale with the existing centre and can be achieved without harming residential amenity.”


Officers Recommendation The Inspector’s recommendation (9) is accepted that the last paragraph of policy

BH13 is modified to read as follows:

“The expansion of shopping and commercial uses into adjoining residential streets by the piecemeal conversion of individual properties will not be permitted. Proposals to extend the shopping frontages of these centres will only be allowed if they involve frontages that are contiguous with an existing shopping frontage, are in scale with the existing centre and can be achieved without harming residential amenity.”



6.21 Balanced and Healthy Communities Policy BH14The Objections176/ 2 / 3 Lidl UK GmbH


255/14 Beverley Moy


362/1 Mrs J E Forsyth

363/1 Mrs P A Kitching

Summary of the ObjectionsThe boundary of the Ansdell Road local centre should be extended to include 39-43 Queen Victoria Road and 49 Palmer Avenue. Lidl wish to extend their existing store into this area and it would strengthen the local centre to do so. Policy BH14 should be amended to permit such a development provided the amenity impacts on local residents are acceptable. There is a conflict between policies BH14 and BH16 in this respect. (176)

Parts of the supporting text should be included in the policy. (194)

Supermarkets make smaller shops unviable. How will local centres be protected? (No specific modification to the Local Plan is suggested.) (255)

The Tesco store and the Clifton Retail Park should be identified as a district centre. (287)

A local shopping centre at Caunce Street is not viable. Most of the existing shops no longer serve local needs. The restriction on converting shops to residential accommodation should be removed. (362, 363)

Inspector’s Reasoning and Conclusions Lidl (Objector 176)

1. Although the Local Plan is not the right place to deal with individual planning proposals, this objection arises from a wish on the part of the Objector to extend one of their existing stores. This would involve the demolition and redevelopment of a block of a few houses on the corner of Queen Victoria Road and Palmer Avenue.

2. The Council says that because this block is currently still in residential use it would not be appropriate to extend the boundary of the local centre to include it. I see the logic of this position and accept it.

3. However, the Council goes on to say that because the whole of a (small) block of houses would be involved and because the Lidl shop already has a frontage with the main road; the proposal would comply with part (b) of the policy. Part (b) of the policy says that the expansion of shopping and other commercial uses into adjoining residential streets will not be permitted.

4. Although the Council’s approach to this matter is ingenious, in my view it flies in the face of what part (b) of the policy actually says. In my view the part of Queen Victoria Road that would be affected is an adjoining residential street not only because of the residential block it is hoped to redevelop but because of the houses opposite the objection site. In other words, even if the Council find the proposed extension acceptable in principle, it is my view that what is proposed would be in conflict with this part of the policy as it stands.


5. This leads me to the view that the policy does not correctly state what the Council intend. I consider that a more precise formulation of the policy would be as follows: “The expansion of shopping and commercial uses into adjoining residential streets by the piecemeal conversion of individual properties will not be permitted. Proposals to extend the shopping frontages of these centres will only be allowed if they involve frontages that are contiguous with an existing shopping frontage, are in scale with the existing centre and can be achieved without harming residential amenity.”

6. I conclude that policy BH14 (b) should be modified accordingly.

The Government Office (Objector 194)

7. The Objector is not specific about which part of the text should be moved into the policy but the Council surmises that it is “where there is over-supply, high vacancy rates and other clear supporting evidence that shops are no longer viable, the conversion of local shops to residential and other appropriate uses will be considered. In such circumstances it would need to be demonstrated that the proposal would not undermine the remaining retail function, role and character of the centre having regard to the criteria set out in the policy and proposals for ground floor residential use will not be permitted in the main shopping core.” In as far as this introduces new considerations to the operation of the policy it seems to me that it should be included in the policy and not placed in the text.

8. I therefore consider that the last part of the policy should be modified as follows:

(c) Proposals for new development and changes of use from shopping to other uses (including residential) will be permitted where they would not undermine the retail function, role and character of the centre.

The impact of a proposal on the retail function of a centre will be determined having regard to:

a. the type of use proposed and its compatibility with nearby uses;

b. the site’s location and prominence within the centre;

c. the number and proximity of nearby units not occupied by retail or allied uses;

d. the level of vacancies in the centre and whether there is an over-supply of shop premises in the area;

e. the need to maintain a retail core within the centre;

f. the suitability of the premises for use as a viable shop.

9. I conclude that the policy should be modified accordingly. The text need not be modified, other than to improve its readability.

Mrs Moy (Objector 255)

10.This Objector makes a general and fundamental criticism of this policy for several reasons. First she considers that supermarkets undercut local centres and threaten their viability. This is made worse because supermarkets do not limit themselves to selling food (and nor could they be made to do so). She considers that all parts of Blackpool are now served by supermarkets and that no more are needed. But even as things are, the decline of local centres cannot be reversed and this policy is no more than a pious hope that should not be


included in the plan unless clear, specific and effective steps can be identified.

11.The Council argues that its local shopping policies are part of a wider package that includes preventing any more large out-of-centre shopping developments. This is in accord with the approach set out in PPG6. I accept that in general terms this is true.

12. In addition, in my experience there are a number and variety of measures (for example traffic management and environmental improvements) that can be taken to enhance local and district centres. It would be inappropriate for the Local Plan to attempt to specify all the measures that are intended or could arise in every centre at this stage. Moreover, the simple act of defining the centres where shopping will be encouraged (and thereby making it easier for shops in other locations to change to other uses) can enhance the viability of the designated shopping areas.

13.As to the strength and influence of supermarkets, this cannot be denied but it does not mean that the need for all local shops will necessarily fade away. Defining the areas in which attempts are to be made to retain shops is a valuable first step. In general terms, therefore, I do not accept that the policy is bound to fail and should be deleted from the Local Plan.

14.At the Local Plan Inquiry this objection led to a general examination of the extent of the local and district shopping centres in the Local Plan. The Objector argued that these are too widely drawn and that this causes blight when vacant shops cannot be changed to other uses such as residential. However, with one exception (at Caunce Street) there are no specific objections to the effect that the areas covered by local and district centres should be reduced. I consider that specific case below.

15.As to the others, it is my general impression that some do have a large number of vacancies but I have no evidence that this is because local shopping is no longer viable in a particular area or that changes of use are being refused because of this policy. Having considered the matter I take the view that a general review of all these designations is beyond my remit and cannot be justified on the basis of one unspecific objection that does not identify a single site or area that needs to be taken out of a centre.


Tesco (Objector 287)

17.There are three shops, including the very large Tesco store at the Clifton Retail Park. Although these may, to some extent, serve nearby residents, the facilities are clearly designed as, and function as, an out-of-centre retail facility. There are no other services and facilities at the site such as one might expect to find in a district centre. I consider that the decision not to designate this area as a district centre is consistent with government guidance and the definitions set out therein. That there are no district centres in the vicinity does not alter the facts of the case.


Mrs Forsyth and Mrs Kitching (Objectors 362, 363)

19. It will be noted that I am recommending modifications to the policy that may


help these objectors.

20.These objections arise from the identification (in the Second Deposit) of a local shopping centre at Caunce Street. The Objectors are fearful that when they come to dispose of their properties (which is likely to be within the Local Plan period) they will be unable to find buyers who want to use them as businesses. They consider they would have a better prospect of selling their properties if they were allowed to convert them completely to dwellings (which was their original use).

21.The Council says that the identification and protection of the shopping facilities at Caunce Street are part of the proposals to regenerate the wider area. Even so, although the policy seeks to retain the existing shops in this location, the Council would be willing to consider proposals to convert premises to dwellings if no buyer for a business is forthcoming. The policy contains criteria to assist in determining individual cases as and when they arise. In this context the Council is more likely to favour a proposed change of use to residential at number 96 than at number 90. This is because number 96 retains much of its residential character and is a corner property with dwellings on each side. In contrast number 90 is in a row of similar shop units.

22. I accept that this is an area in need of regeneration and that, in general terms, the Council’s strategy for the area is well-founded. I therefore accept that the creation and/or preservation of a small shopping centre at its heart could make a valuable contribution to uplifting the residential attractiveness of the area. Even so, the present state of this centre and its location relatively close to the main shopping area in the town must make its viability somewhat questionable. But for the reasons stated, I am not persuaded that I should recommend the deletion of this local centre in its entirety.

23.However, I am also completely sympathetic to anyone who finds themselves in the situation in which they cannot dispose of their business and/or property when they wish to retire. But in fact I have no evidence that this is likely to occur here. Although the local shop units may not all be serving local needs, the vacancy rate is not especially high. It may also be that the Council’s regeneration policy and the removal of isolated shops in the surrounding area will make these business premises more attractive over the next few years. In particular I have no evidence that these premises would be made more saleable if they were converted to residential accommodation.

24. In all the circumstances (and in particular noting the Council’s assurances that they would look at individual cases afresh if and when the need arises) I consider that the best way forward is to leave the Local Plan as it is. Policy BH14 allows for some flexibility if circumstances require it. Although this may mean that time has to be spent trying to sell a shop unit and proving that there is no demand for it before it can be converted to residential accommodation, I consider that this would not cause undue hardship.

25.Anyway, the possibility of a vacant and boarded-up shop would not assist in the regeneration of the area and I cannot imagine the Council would persist in rigidly applying this policy if it would lead to such an outcome.

26. I conclude that the Local Plan should not be modified as a result of these objections.


Recommendations27. I recommend that BH14 (b) is modified to read as follows: “The expansion

of shopping and commercial uses into adjoining residential streets by the piecemeal conversion of individual properties will not be permitted. Proposals to extend the shopping frontages of these centres will only be allowed if they involve frontages that are contiguous with an existing shopping frontage, are in scale with the existing centre and can be achieved without harming residential amenity.”

28. I recommend that the last part of the policy should be modified as follows:(c) Proposals for new development and changes of use from shopping to other uses (including residential) will be permitted where they would not undermine the retail function, role and character of the centre. The impact of a proposal on the retail function of a centre will be determined having regard to:a. the type of use proposed and its compatibility with nearby uses;b. the site’s location and prominence within the centre;c. the number and proximity of nearby units not occupied by retail

or allied uses;d. the level of vacancies in the centre and whether there is an over-

supply of shop premises in the area;e. the need to maintain a retail core within the centre;f. the suitability of the premises for use as a viable shop.

29. I recommend that paragraph 6.65 need not be modified.30.Otherwise I recommend no modifications to policy BH14.

Officers Recommendations The Inspector’s recommendation (27) that BH14 (b) is modified to read as follows is

accepted:

“The expansion of shopping and commercial uses into adjoining residential streets by the piecemeal conversion of individual properties will not be permitted. Proposals to extend the shopping frontages of these centres will only be allowed if they involve frontages that are contiguous with an existing shopping frontage, are in scale with the existing centre and can be achieved without harming residential amenity.”

The Inspector’s recommendation (28) that the last part of the policy should be modified to read as follows is accepted:

(c) Proposals for new development and changes of use from shopping to other uses (including residential) will be permitted where they would not undermine the retail function, role and character of the centre.

The impact of a proposal on the retail function of a centre will be determined having regard to:

a. the type of use proposed and its compatibility with nearby uses;

b. the site’s location and prominence within the centre;


c. the number and proximity of nearby units not occupied by retail or allied uses;

d. the level of vacancies in the centre and whether there is an over-supply of shop premises in the area;

e. the need to maintain a retail core within the centre;

f. the suitability of the premises for use as a viable shop.

The Inspectors recommendations (29) and (30) are accepted.

6.22 Balanced and Healthy Communities Policy BH15The Objection89/6 Countryside Agency, N W Division (Conditionally Withdrawn)

Summary of the ObjectionThere is a need to protect small settlements from the loss of shops, pubs and community facilities. (First Deposit) (Conditionally Withdrawn) (089)

Inspector’s Reasoning and Conclusions 1. I note this objection has been conditionally withdrawn, although it is unclear to

me what this is conditional upon. Be that as it may, the Council says there are no small settlements in Blackpool to which this comment might apply. I am also somewhat at a loss to know to which areas the objection relates.



objection. Officers Recommendations


6.23 Balanced and Healthy Communities Policy BH20 The Objections189/1 McCarthy and Stone (Developments) Limited

320/1 Blackpool Young People's Council

Summary of the ObjectionsRedraft the policy to ensure that the policy complies with current Government Guidance on developer contributions and will be applied flexibly. (189)

The term “community facilities” is not specific enough. The needs of young people go beyond play areas and more mature young people need to be catered for as well. (320)

Inspector’s Reasoning and Conclusions 1. As far as Objector 189 is concerned, I note that the full details of the Council’s

approach to planning obligations are set out in policy PO1 and that there is a cross-reference to that policy in paragraph 6.81. This seems as much as is necessary as far as this policy is concerned. To say more at this point would involve unnecessary duplication in the Local Plan.


2. I note in passing that this Objector does not object in principle to policy BH20. However, as part of their objection they say “Notwithstanding the above, the majority of residents of sheltered housing schemes originate from within the local area and, as such, do not generate a need for additional facilities for recreation.” I am bound to say that I find this a particularly unconvincing line of argument. Are we to vary the facilities to be provided in association with each new development according to where the future residents may come from? Would the Objector want the origins of their clients to become a matter for planning control?

3. Be that as it may, I conclude that no modification arises from objection 189/1.

4. As far as Objector 320 is concerned, their objection to the First Deposit led the Council to expand paragraph 6.79 in the Second Deposit to include “appropriate facilities should be provided for children, young people, adults and the elderly”. In my view this meets the point made by the Objector and goes as far as could reasonably be expected in the Local Plan.

5. I conclude that no modification arises from objection 320/1.

Recommendations6. I recommend that policy BH20 is not modified.Officers Recommendation

The Inspector’s recommendation is accepted:

6.24 Balanced and Healthy Communities Policy BH22The Objection331/6 Mr P Wright

Summary of the ObjectionAn addition should be made to the effect that future developments should have a minimum number of floors so that the best use is made of the land available. (331)

Inspector’s Reasoning and Conclusions 1. I am told that this objection has been conditionally withdrawn, although the

Local Plan has not been changed in the way the Objector suggested. Be that as it may, I consider it would be inappropriate to specify a minimum number of storeys that should be built either in general or on any particular site in the Local Plan.



331/6.

Officers Recommendation The Inspector’s recommendation is accepted:


6.25 Balanced and Healthy Communities Policy BH23The Objection331/5 Mr P Wright

Summary of the ObjectionThe Council should pro-actively encourage the expansion of the college, to increase the number of degree courses and ultimately to aim for university status. (0331)

Inspector’s Reasoning and Conclusions 1. I am told that this objection has been conditionally withdrawn, although the

Local Plan has not been changed in the way the Objector suggested. Be that as it may, I consider it would be inappropriate for the Local Plan to trespass into matters of education policy.



331/5.


6.26 Balanced and Healthy Communities Policy BH24The Objection081/1 Coliseum Trade Association

Summary of the ObjectionNo C2 uses should be allowed in the Resort Core. They should only be allowed in areas where the market cannot support holiday accommodation and in neighbourhoods that are well suited to such uses. Housing Associations should have restrictions placed on them to prevent them buying properties on the edge of the main holiday area. Other communal residences, especially those involved with “problem” clients should be located only in detached properties. (081)

Inspector’s Reasoning and Conclusions 1. This is the only objection to this policy. The Objector starts by saying that they

“fully support BH24” but they go on to make comments that suggest that, in fact, what they want is a far more restrictive policy. I am somewhat at a loss to know exactly what they do want.

2. Be that as it may, the Council points out that some of the restrictions they appear to want would go beyond existing planning powers (for example in restricting the ability of Housing Associations to buy properties in some areas).

3. The policy as it stands sets out criteria for assessing individual planning proposals as and when they arise. It does not seem to me that the Local Plan could go further. I also consider that the policy cannot be amended to take on board the Objector’s specific comments without going beyond the confines of planning law as currently enacted.



Recommendations5. I recommend that policy BH24 is not modified in response to this

objection.



7.1 Diversifying the Local Economy Paragraph 7.0 The Objection287/23 Tesco Stores Limited

Summary of the ObjectionTesco comment that retailing provides considerable employment in the town and that Tesco are a major employer. No change to the Local Plan is suggested. (287)

Proposed ChangesPC65 would add “to increase employment quality and opportunities” to the main aim of the chapter.

Inspector’s Reasoning and Conclusions 1. What Tesco say may be true but there is no need for the Local Plan to include

it. In particular the Local Plan is not the place to list every major employer. In any event Tesco suggest no change to this part of the Local Plan.

2. I conclude that no modification arises from this representation.


representation.


7.2 Diversifying the Local Economy Policy DE1 The Objections023/3 Ravenside Investments Ltd

145/ 17 / 56 Mrs F A Cunningham


187/2 Asda Stores Limited

203/3 B & Q plc

243/2 BT plc

309/1 / 3 Lionbrook Property Partnership


331/4 Mr P Wright

Summary of the ObjectionsLand at Squires Gate Industrial/Business Area should be reallocated as part of the Blackpool Retail Park. (023) (This objection is dealt with under policy DE2, below.)

All office development should be located in the town centre. (145/17 – First Deposit)

The Caunce Street sawmills (Site H18) should be retained for employment. (145/56 – Second Deposit) (This objection is dealt with under policy HN2, site H18.)

Traffic from the Technology Park could impact on the A585 which is near capacity. Development at all these sites should be subject to full Traffic Impact Assessments. (186)

270Diversifying the Local economy Chapter 7

Land at Warren Drive should be allocated for employment development to reflect the allocation in the existing Local Plan and the extant planning permission. (187)

The policy should be redrafted to allow flexibility beyond Classes B1, B2 and B8. If one of the preferred uses is not forthcoming and there is enough employment land available, alternative uses – such as retail – should be considered. (203)

Amend the policy to ensure proposals for telecommunications purposes are accepted in employment areas. The objection relates to BT’s existing radio station at site E5. The use is an acceptable one at this location and future additional development should not be prevented by a narrow definition in the policy. Category D in the policy should be extended to include telecommunications. (243)

Clause (a) of the policy should be deleted. It is unreasonable to prevent offices on DE1 sites until all the town centre sites have been developed. If clause (a) is to be retained, guidance should be included in the Plan on how the policy would be operated. (309/1) (First Deposit) Paragraph 7.11a should be deleted and Policy DE1(a) be amended to read "B1a office developments which would be significant trip generators will only be permitted if no suitable site is available within or adjoining the town centre". The meaning of paragraph 7.11a is unclear when it says the policy will be “applied realistically”. (309/3) (Second Deposit)

Land at Marton Moss (north of Chapel Road and at Runnell Farm) should be allocated for mixed use development to include high quality employment land, in addition to the housing allocation sought under policy HN2. (328)

The policy should say that Blackpool, Wyre and Fylde Councils will work together to attract new employment. It would not matter in which of the Council areas the employment was located. (331)

Proposed ChangesPC67 suggests amending the last two sentences of paragraph 7.11a.

PC106 seeks to amend clause (a) of the policy so that it refers to major office developments not being permitted outside the town centre unless there are no sites in or adjacent to the town centre.

PC 107 would amend paragraph 7.11(a) partly to reflect PC 106, to define “major” and to make other changes to the text.

Objections to the Proposed Changes309/4 Lionbrook Property

Summary of the ObjectionsThe Proposed Changes do not address our original objection which is maintained. Whilst large offices may be appropriately sited in town centres, there should be no restriction on small office developments on DE1 sites (see also Lancashire Structure Plan EIP Panel Report and RPG13 policy EC8). (309)

Inspector’s Reasoning and Conclusions DE1 Sites and Retailing (Objectors 023, 203)

1. Objector 023 is concerned with a site that adjoins the Blackpool Retail Park. As things stand the site is designated under policy DE1 as (part of) the Squires Gate Estate, which is to be retained under that policy for industrial/business uses. It is also designated under policy DE2 as an Industrial Improvement Zone. Both these designations are objected to and the Objector wishes the site to be allocated for retailing as part of the adjacent Blackpool Retail Park.

2. For convenience both the DE policy objections from Objector 023 are dealt with under policy DE2 (see below). Their shopping objections are dealt with in chapter 6 of my report.

3. As far as Objector 203 is concerned, the purpose of this policy is to reserve land for the uses specified. It would undermine the policy to allow for the possibility of retailing uses on this land. Furthermore, there are separate policies in the Local Plan to control the location of retailing and the guidance in PPG6 would also apply.


4. I conclude the policy should not be modified in response to objection 203/3.

DE1 Sites and Offices (Objectors 145, 309)

5. Although Objector 309 supports Proposed Changes 106 and 107, this has not led them to conditionally withdraw their original objections. However, in my view the proposed changes go as far as can reasonably be expected (within the constraints of current government guidance) to meet their objections.

6. I conclude that PC106 and PC107 should be advertised as modifications to the Local Plan. (However it seems to me that the words “office sites” are repeated unnecessarily in the first line of the proposed paragraph 7.11b.) I consider that PC67 is no longer needed and should not be pursued.

7. As far as Objector 145 is concerned, she wishes all offices to be located in the town centre. However, the policy already says that major office developments will only be permitted on the DE1 sites if there are no available sites in the town centre. This represents a significant shift (since the last Local Plan) in policy towards locating offices in the town centre and is, in my view, a reasonable stance that is in accord with current government guidance.

8. I conclude that no modification arises from objection 145/17.

DE1 Sites and Telecommunications (Objector 243)

9. Objection 243/2 arises because BT already has a sui generis use established on one of the designated sites. The Council says this existing use would not be affected by the policy and, presumably, proposals to alter or extend the existing premises would be treated on their merits.

10.However, not all possible telecommunications development would necessarily be appropriate on all the DE1 sites. So to allow for this possibility would not be the right thing to do. In my view Local Plan policies cannot be constructed around particular individual circumstances and a Local Plan cannot cover every possible eventuality. In any event policy LQ16 deals with telecommunications in general and need not be repeated here.


DE1 Sites and Traffic Impact Assessments

12.As far as Objector 186 is concerned, the Council says it is aware of the situation at the Technology Park and on the A585. There is a general requirement in policy AS2 that deals with the impact of traffic from development.

13. I consider it is unnecessary for this requirement to be repeated here. It would also be inappropriate for all development at these sites, including small alterations and extensions, to be subject to this requirement.


Co-operation with Neighbouring Councils (Objector 331)

15.The Council accepts the merits of this objection and in the Second Deposit amended paragraph 7.10 so that it now refers to sites near the Borough boundary and cross-boundary co-operation. I conclude that no further changes to the Local Plan are needed.


Marton Moss (Objector 328)

16.On the evidence supplied to me, the Structure Plan requirements for both residential land and employment land can be met without allocating land for development at Marton Moss. There is thus no need for either component of a mixed-use development there. Better sites for both types of development are already included in the Local Plan. Although government guidance advocates mixed use development, two wrongs would not make a right.


Warren Drive (Objector 187)

18.At the Local Plan Inquiry the extent of the land to which this objection relates was clarified. It is the area owned by the Objector but excluding a strip of land fronting Warren Drive that is to be kept open in any event. The Council-owned land to the south is not included in the objection. I shall consider the objection on this basis.

19.Put simply, the Objector wishes to see the designation of their land in the adopted Local Plan (policy IB3.2, large office uses within a landscape setting) retained. This would also reflect an extant planning permission for office development on the site which the Objector intends to implement.

20.The Council wishes to take the opportunity of the Local Plan review to remove the allocation at Warren Drive to reflect the increased emphasis on the town centre as an office location. It also doubts whether there is currently a demand for speculative out-of-centre office development in the Borough and questions whether the planning permission will be implemented.

21. In my experience of local plans the existence of a valid planning permission for development is usually a decisive consideration in determining the appropriate designation of land. It is usually the Local Planning Authority that takes this view in the face of objectors who oppose a permitted development proposal. Indeed this is the stance BBC adopts elsewhere in response to objections to the effect that land with planning permission should not be allocated for development. Be that as it may, I note that PPG12 paragraph 2.22 says that a Local Plan review is the opportunity to re-assess existing site allocations where development has not yet been given planning permission. This implies that where planning permission has been granted no such opportunity arises.

22. I have no reason to doubt the Objector when they say that they intend to implement the extant planning permission that they have. It could be seen as short sighted of them if they did not, especially in view of the Council’s current stance. Indeed, removing the inherited designation from their land could provide the greatest possible incentive to them (at least) starting to implement it. I therefore take what they say on this matter at face value and regard it as a weighty consideration.

23.However, the Council’s wish to redirect office development towards the town centre is not unimportant and, in my view, reflects the current government guidance on the location of office development. However, in the face of an extant and implementable planning permission there may be little they can do about it as far as this site is concerned. Even so, policy DE1 makes it clear that the town centre is the preferred location for offices and that DE1 sites should be


used, in effect, only after the sequentially preferable town centre has been examined. I consider that this is as far as the Local Plan can go in this case.

24. I conclude, therefore, that this objection should succeed and that the objection site (as described above) should be allocated under policy DE1 and identified as suitable for office uses (Class A in terms of the policy).

25.The related objection concerning policy NE11 is considered elsewhere.


Local Plan. (However it seems to me that the words “office sites” are repeated unnecessarily in the first line of the proposed paragraph 7.11b.)

27. I recommend that PC67 is not pursued.28. I recommend that the objection site at Warren Drive (as described in

paragraph 18 above) should be allocated as a DE1 site and identified as suitable for office development (class A in the policy).


Officers CommentThe Inspector recommends that the Asda owned part of the Warren Drive lands is allocated as a Policy DE1 site suitable for office development, reflecting the existing extant planning permission. He states in his report that in his experience the existence of a valid planning permission is usually a decisive consideration in determining the appropriate designation of land.

The Inspector also very relevantly recommends no change to the Council’s Policy NE11 urban greenspace allocation of the whole of the Warren Drive lands, including the Asda owned land. He accepts – as established in the adopted local plan, and confirmed by a recent appeal decision – that retaining the open character of this site and the views across it are important planning considerations. He considers these objectives are best secured by retaining the Policy NE11 designation as urban greenspace, as well as a designated DE1 allocation, both of which would then need to be taken into account in determining any future development proposals.

While there is no disagreement between the Inspector, objector, and the Council that the approved development will be commenced, and the extant planning permission safeguarded, the LPA’s view is that there is no direct parallel of the Warren Drive site with other Policy DE1 sites. All the other Policy DE1 sites are already long established existing employment locations. Policy DE1 identifies and safeguards available sites for IB development within these established estates. Policy DE1 in Blackpool’s current circumstances and level of employment need does not allocate new areas of land.

Therefore given:

The Inspector and LPA’s view on the NE11 designation of the land

The Objector, Inspector, and LPA’s shared view that the development will be commenced

The Council’s treatment of other existing committed sites with planning permission on the Proposals Map’

…. it is recommended that the appropriate way forward could accordingly be most appropriately be met by showing it as a committed site outlined in purple with a ‘p’ on


the Proposals Map, similar to other existing housing commitments.

Officers Recommendations The Inspector’s recommendation (26) is accepted that PC106 and PC107 are

advertised as modifications to the Local Plan (minus the words “office sites” in the first line of the proposed paragraph 7.11b.):

PC106 Add the word “major “ to criterion A:

a) Major B1a office development will only be permitted if there is no suitable available site within or adjacent to Blackpool Town Centre

PC 107 Amend paragraph 7.11a and add new paragraph 7.11b:7.11a Proposals for major B1(a) office developments in excess of 2,500 sq metres gross floor area, will first be directed towards the town centre and edge of centre locations in accordance with the established application of national planning policy for key town centre uses and local plan objectives ( To promote the Town Centre as a location for offices and administrative use” - paragraph 3.6 and to make Blackpool Town Centre a stronger focus as a main employment location – paragraph 7.6 ).. Further Other policies in the Plan specifically promote the redevelopment of town centre sites for office use. It is a priority of the Council to attract new office uses and such development will continue to be promoted and will not be resisted on other Policy DE1 sites unless there is a suitable available site for the use in or adjacent the town centre.

Add new paragraph:

7.11b Office sites promoted in Policy DE1 office sites will generally be suitable for office development of a lesser scale or for major office development where there is no suitable site for such use in or adjacent to the town centre. Small scale office development of purely local significance may be appropriate in other locations (see Policy DE4).

The Inspector’s recommendations (27) and (29) are accepted.

The Inspector’s recommendation (28) that the Warren Drive site should be allocated as a Policy DE1 site is not accepted.

The northern part of the Warren Drive site (in the ownership of Asda) to be shown as a committed site with existing planning permission for office development, identified on the Proposals Map.

7.3 Diversifying the Local Economy Policy DE1 – Site E2The Objection244/2 Fylde Bird Club

Summary of the ObjectionThis development will isolate the Bispham Marsh and Kincraig ponds from the countryside to the east, severely reducing their value as habitats. Abandon the development of site E2 and use a brownfield site elsewhere. Ensure the full protection of natural heritage sites during the development of site E2 and provide wildlife corridors through this area at all possible locations. (244)


Inspector’s Reasoning and Conclusions 1. The Objector seems in two minds as to whether they oppose this development

in principle or whether they want to ensure adequate mitigation measures.

2. Be that as it may, the Council says that this site was brought forward in the previous Local Plan and that much of the development has been completed. They also say that considerable care has been taken to mitigate the impact of the development on wildlife and that a swathe of open land has been retained in northeast Blackpool. They say that English Nature and the Lancashire Wildlife Trust did not object to the original designation for development.

3. I also note that in the Second Deposit a paragraph was added to the Local Plan referring to the importance of wildlife in this area.

4. I consider that matters have progressed beyond the point at which I could influence them and conclude that the Local Plan should not be modified.


objection.


________________________________________________________________

7.4 Diversifying the Local Economy Policy DE1 – Site E6 The Objection244/3 Fylde Bird Club (Conditionally Withdrawn)

Summary of the ObjectionReduce the area of E6 by a small amount at the northern boundary to protect the County Biological Heritage Site at Kincraig Road. (First Deposit) (244)

Inspector’s Reasoning and Conclusions 1. The Council amended the boundaries of the industrial/business land and the

adjoining public open space to reflect the extent of the Heritage Site in the Second Deposit (Map DE1PM1). I conclude this meets the objection and that no further change is needed. .


objection.


7.5 Diversifying the Local Economy Paragraph 7.13


The Objection326/23 CPRE (Lancashire Branch)

Summary of the ObjectionAdd a paragraph after 7.13 to say the presence of protected species will be a material consideration in relation to applications for development on sites E2 and E6. Add a cross-reference to policy NE9. (326)

Inspector’s Reasoning and Conclusions1. This objection has largely been met by the addition of paragraph 7.13B in the

Second Deposit version of the Local Plan. However, the new paragraph cross-references to policy NE8, which is not the one dealing with protected species.

2. I conclude that the only modification that is needed is to change the cross-reference in paragraph 7.13B from NE8 to NE 9 (or both).

Recommendation3. I recommend that the Local Plan is modified by changing the cross-

reference in paragraph 7.13B from NE8 to NE 9 (or both).

Officers Recommendation The Inspector’s recommendation is accepted that the Local Plan is modified by

changing the cross-reference in paragraph 7.13B to “see Policies NE8 and NE9”.

7.6 Diversifying the Local Economy Policy DE2The Objections023/ 3 / 4 Ravenside Investments Ltd

309/2 Lionbrook Property Partnership

Summary of the ObjectionsLand at Squires Gate Industrial/Business Area should be reallocated as part of the Blackpool Retail Park. (023)

Amend policy DE2 by adding: 'Redevelopment should achieve no net loss of employment floorspace whilst improving the appearance of the site. It may include small scale commercial and business support services which are related to and compatible with the employment use of the site.' (309)

Inspector’s Reasoning and Conclusions Objector 309 (Lionbrook Property)

1. This Objector (who owns most of the designated area) welcomes the Industrial Improvement Zone and expresses a willingness to work with the Council in its implementation. However, there is one very large building on the site that may need to be redeveloped during the plan period. In the event of redevelopment the Objector seeks greater flexibility in relation to the uses that will be allowed, subject to there being no net loss of employment floorspace.

2. As examples the Objector puts forward a list of possible uses, including: offices, small scale leisure uses, restaurant / food and drink uses and hotel accommodation for business travellers. I have identified here the suggested uses that cause me concern, none of which, in my view, would appropriately be located at this site except (possibly) in a very minor, ancillary and supporting


role in relation to the main industrial and business uses. In any event it is difficult to see how (for example) a restaurant or hotel could be ancillary uses in a business/employment park.

3. Although I consider that the form of words put forward by the Objector for inclusion in the policy is less contentious, this “wish list” alerts me to the possible dangers of diluting the main thrust and purpose of the policy. Accordingly I am inclined to agree with the Council that the policy should not be altered. The Council says that proposals for other uses than those already allowed for in the policy could be treated as departures if they assisted the wider regeneration of the estate as a whole. It is also the case, surely, that truly ancillary and supporting services could be integrated into any redevelopment proposals without the need to treat them as departures.

4. I therefore conclude that the policy should not be modified in response to this objection.

5. In answering this objection the Council put forward a revision to paragraph 7.16 that it says updates the text and to make it clear that it is not necessary for BBC to prepare an Improvement Zone Plan for this area. Although I do not have the Objector’s view on this suggested alteration, it does not seem to me that it arises from this objection. Be that as it may, I have no objection to the deletion of the words “by the Council” from the text if this is seen as advantageous. I conclude that the Council should be left to decide whether or not to proceed with a modification along these lines.

Objector 023 (Ravenside Investments)

6. Objector 023 is concerned with a site that adjoins the Blackpool Retail Park. As things stand the site is designated under policy DE1 as (part of) the Squires Gate Estate, which is to be retained under that policy for industrial/business uses. It is also designated under policy DE2 as an Industrial Improvement Zone. Both these designations are objected to and the Objector wishes the site to be allocated for retailing as part of the adjacent Blackpool Retail Park.

7. For convenience both the DE1 and DE2 policy objections are dealt with here. The shopping objections are dealt with in chapter 6 of my report.

8. The objection site is oblong with an industrial building on it that is currently divided into three units, partly occupied and partly vacant. It has a shallow forecourt but lacks the deeper unloading area that exists in front of the larger buildings on the opposite side of the access road. However, in my view the area available for accessing and servicing the buildings is commensurate with their size and not a barrier to their use or re-use.

9. The site could be redeveloped to face into the adjoining retail park, although – in my view – it can equally be retained as part of the industrial and business area because it is not accessed through the retail area. In short, the site could be redeveloped and/or used to face in either direction and the physical disposition of the site is not a decisive consideration.

10.The buildings on the site are not attractive and do not appear to have been maintained with great care or at great expense. On the other hand they do not appear to be so dilapidated as to be incapable of renovation and I have no evidence to suggest otherwise. In my view the buildings could be renovated or


redeveloped so that the physical condition and appearance of the buildings is not a decisive consideration either.

11.However, the buildings are partly in use on what I was told is a relatively long lease. Although neither side at the Local Plan Inquiry made anything of this fact, to my mind it indicates there is a demand for the buildings as industrial or business premises (even) in their present condition. I consider this also shows the existing buildings are not inherently unsuitable for a modern business use.

12.Although the situation in Blackpool as a whole may not exhibit a great need and demand for industrial / business premises, the situation in this part of the town is, on the evidence at the Local Plan Inquiry, far more buoyant. The area has good access to the motorway, is close to the airport (which is seen as a potential growth stimulator) and is showing considerable signs of regeneration and renewal. The investment taking place to improve the business environment is especially noticeable in the rest of the Squires Gate Estate and the nearby Sycamore Estate. Furthermore this is part of a large block of industrial and business land and uses that do not impinge adversely on residential neighbours and for which (retailing apart) no alternative use is likely.

13.For these reasons I attach more importance to the location of this site than to the apparent abundance of land and premises in the Borough as a whole. Whilst there may be many previously used business premises in the Borough, I consider that the prospects for this site are better than most, either for continuing occupation of the existing buildings or for the redevelopment of the site for employment purposes. In my view the assessment that redevelopment would not be viable has not been demonstrated and supported by detailed evidence. The objection site may be only a small fraction of what is available but it is in an important locality.

14. I consider the retailing arguments in chapter 6 but it is enough to say here that the case for retailing on the objection site is not strong enough to override the need for employment land in this part of the Borough.

15.For all these reasons I conclude that the objection site is correctly designated for industrial / business uses and as an improvement zone. I therefore conclude that these objections should not succeed.

Recommendations16. I conclude that the Local Plan should not be modified in response to

objection 309/2. 17. I recommend no modifications to the Local Plan in response to objections

023/3 and 023/4.18. I leave it to the Council to decide whether to bring forward a revised

wording for paragraph 7.16 as a modification to the Local Plan.

Officers Recommendations The Inspector’s recommendations (16) and (17) are accepted.

In accordance with the Inspector’s recommendation (18) paragraph 7.16 is amended and should be advertised as a proposed modification to the Local Plan as follows:

7.16 “An Improvement Zone plan will be prepared by the Council for the two


estates and adjoining lands in consultation with existing owners/ occupiers and set out a strategy for their enhancement and retention as a prime business location”.

7.7 Diversifying the Local Economy Policy DE4The Objection203/4 B & Q plc

Summary of the ObjectionRetailing is an important source of employment and should be recognised as such. Policy DE4 should be made more flexible to reflect this. It should allow for alternative uses if a preferred employment use is not forthcoming or if employment allocations are not taken up. Redraft the last part of policy DE4 as follows: Development of existing industrial business premises for other uses will only be permitted where: (a) resulting environmental and wider community benefits outweigh the loss of employment capacity; or (b) It can be demonstrated that no demand exists for either industrial/ business uses; or (c) It can be demonstrated that there is sufficient quantity and range of alternative supply of employment sites and premises available. (203)

Proposed ChangesPC68 suggests that the policy should be properly numbered as DE4.

Inspector’s Reasoning and Conclusions 1. The Proposed Change is clearly sensible and is not contentious, but it has no

bearing on this objection.

2. The policy is in two parts. The first part deals with employment uses outside allocated employment areas and this is not objected to.

3. The objection, on the face of it, adds two possible reasons for allowing existing premises to be developed for other purposes. These are: if it can be shown that no demand exists for industrial or business uses or if there is a sufficient quantity and range of alternative employment sites and premises available.

4. The control of retail uses and locations is a separate and distinct policy area both as far as government guidance and this Local Plan are concerned. Suffice it to say that, for this reason, I do not accept the underlying argument in this objection that retailing should be regarded in the same way as any other employment or business use.

5. Having said that, I acknowledge government guidance expresses considerable concern that land and premises may be underused and blighted because of the unrealistic policies and aspirations of Local Planning Authorities to attract employment uses to their areas. Admittedly, this concern arises from a wish to recycle underused employment land for residential purposes in order to reduce the pressure on greenfield land for housing and this does not appear to be a pressing issue in Blackpool. Even so, it does not seem to me to be consistent with the thrust of current government guidance for a Local Plan to be over-restrictive in this respect.

6. The policy already allows for alternative redevelopment proposals where “resulting environmental and wider community benefits outweigh the loss of employment capacity”. This is cast in very broad terms. It would, in my view, already encompass a situation in which there is no demand for a site for employment purposes with the result that land or premises are standing idle


and declining into dereliction. Moreover, whether or not there were at the time sufficient employment land and premises elsewhere in the town would be a legitimate secondary consideration that could be raised by either the Council or a would-be developer. In other words I think that these matters are already covered by the policy, even though not explicitly stated.

7. I therefore take the view that the modification sought by this Objector is unnecessary and would add nothing to the Local Plan.

8. I conclude that no modification is needed or justified.


203/4. 10. I recommend that PC68 is advertised as a modification to the Local Plan.

Officers Recommendation The Inspector’s recommendations are accepted and that PC68 is accordingly

advertised as a proposed modification to the Local Plan:

PC68 Add number to Policy heading:

DE4 Outside the Defined Industrial/Business Estates

7.8 Diversifying the Local Economy Policy OmissionThe Objection089/8 Countryside Agency (N W Division) (Conditionally Withdrawn)

Summary of the ObjectionThe majority of the proposed employment sites are in or close to the urban fringe. We encourage the adoption of a positive criteria-based approach to the provision of employment land and premises, derived from sustainable development principles and taking into account local characteristics and needs. (089)

Inspector’s Reasoning and Conclusions1. I note that this objection has been conditionally withdrawn but what this is

conditional upon is not clear. In any event it is not clear what changes to the Local Plan the Objector is seeking. Enough employment sites are allocated in the Local Plan so there is no need for a criteria based policy.





8.1 Conserving the Natural Environment Paragraph 8.5


The Objection255/7 Beverley Moy (Conditionally Withdrawn)

Summary of the ObjectionRemove the reference to enhancing open space or say that it should not apply in all cases. Landscaping can inhibit children’s enjoyment of open spaces. (255)

Inspector’s Reasoning and Conclusions 1. At the Local Plan Inquiry Mrs Moy decided not to press this objection and

advanced no evidence or arguments in support of it.

2. Anyway, it seems to me that the objection is based on the assumption that maintaining and improving open land will always involve creating formal and unnatural landscaping schemes. I see no reason to make this assumption because in some cases improvement may amount to the return to the wild state that Mrs Moy wants. Each case has to be assessed and decided on its own merits. As a general statement of intent in favour of maintaining and improving open land I consider that paragraph 8.5 cannot be faulted.



255/7.Officers Recommendation


8.2 Conserving the Natural Environment Paragraph 8.9The Objection194/71 Government Office for the North West

Summary of the ObjectionIn the Second Deposit paragraph 8.9 was amended to refer to a minor change to the Green Belt (as shown on map NE1PM1) to accommodate what is described as an appropriate development at the Sixth Form College.

The objection says that PPG2 indicates that, once the general extent of the Green Belt has been approved, it should be altered only in exceptional circumstances. Where such an alteration is proposed, the Secretary of State will wish to be satisfied that the Local Planning Authority has considered opportunities for development within the urban area. In view of the fact that an essential characteristic of the Green Belt is its permanence, any exceptional circumstances to justify releasing land from the Green Belt should be set out more fully in the Local Plan. (194)

Proposed ChangesPC69 expands the reason given for the proposed alteration to the Green Belt boundary.

Inspector’s Reasoning and Conclusions 1. I note that this objection to the Second Deposit has not been conditionally

withdrawn as a result of the expanded explanation in PC69. I take this as an indication that the Objector still regards the explanation as inadequate.

2. I also have the benefit of an even fuller explanation given to me by the Council as evidence. This says that the proposed alteration to the Green Belt boundary arose from consideration of a planning application for a college extension in 2003. The decision was taken in “full awareness of the importance of the Green


Belt” and following an assessment of the educational need for the development, the justification for the development in the Green Belt (including an assessment of alternatives elsewhere in the college but outside the Green Belt) and consideration / assurances regarding longer term aspirations.

3. In the light of the assessment the Council was satisfied that in this instance there was an exceptional justification for the proposed development within, but on the edge of, the Green Belt. The planning application was referred to the Secretary of State as a departure from the Development Plan (with particular reference to the Green Belt).

4. The Council also refers to educational policy and the need to encourage more people to enter higher and further education.

5. I have not been told the outcome of referring the 2003 planning application to the Secretary of State. But there are two possibilities: either the proposal received planning permission or it didn’t. If it did not, it is clear in my mind that the Green Belt boundary should not be altered in order to accommodate the proposal. Even if it did, it is questionable – even from the College’s and Council’s points of view – whether it is necessary to amend the Green Belt.

6. Two particular aspects of what the Council have told me cause me concern. The first is that the Council refers to the development as being “appropriate”. If it is indeed appropriate development in the Green Belt, it is far from clear why the boundary should be changed to recognise it. The other is that the Council says it is relying on “assurances” concerning future developments at the College. The best form of assurance would, in my view, be one that was backed up by the full rigour of Green Belt policy.

7. Another consideration to which I attach some importance is that there are other objectors who wish to alter the Green Belt boundary. It seems to me that a consistent approach is best.

8. So, all in all and on the balance of the evidence I have, I am far from convinced that it is either wise or necessary to alter the Green Belt boundary. More importantly, it does not seem to me that exceptional circumstances have been demonstrated in this instance. If a development has been granted planning permission either as a departure from Green Belt policy or because the proposal was appropriate development in the Green Belt, it does not follow that the Green Belt boundary should be changed to reflect what has happened. Neither departures nor appropriate developments are wholly exceptional.

9. I therefore consider this objection has not been met or answered by PC69. In these circumstances I conclude that the Green Belt boundary should not be changed and that paragraph 8.9 should revert to the wording in the First Deposit.

Recommendations10. I recommend that the wording of paragraph 8.9 should revert to that used

in the First Deposit of the Local Plan.11. I further recommend that the Green Belt boundary is not altered in this

Local Plan.



The Inspector’s recommendation (10) is accepted and the wording of paragraph 8.9 is accordingly amended to that set out in the First Deposit Plan:

8.9 “The essential permanence of the Green Belt should be secured as far as can be seen ahead. North West Regional Planning Guidance states that development needs in Lancashire as a whole can be accommodated without any changes in Green Belt. The boundaries in Blackpool remain unchanged from those designated in the previous Local Plan (1991-2001)”.


8.3 Conserving the Natural Environment Policy NE3The Objections285/3 Nature Watch Group BEAT

303/17 Morris Homes


349/2 Mr D E Warder Summary of the ObjectionsAdd the following to paragraphs 8.11 – 8.17: "Enhancement of the wildlife features of these sites will be encouraged as will developments leading to their enjoyment by the public." (285)

Marton Moss site should be deleted as a NE3 site and re-allocated as a housing site or as an area of search. (303)

The areas currently proposed for designation as Countryside Areas (NE3-NE5) should be included in the Green Belt. (326)

The vulnerability of Marton Moss to flooding is the main reason why it cannot be developed. It is one of several parts of the Borough that are at risk. These problems warrant more attention and investment. If more work and additional measures were undertaken to prevent future flooding there would be no objection to development in this area. (349)

Inspector’s Reasoning and Conclusions Objector 285 (Nature Watch)

1. The Council’s response to this objection says it accepts the point. Paragraph 8.15 already says that enhancement of the wildlife features of the countryside areas will be encouraged. To complete the response to the objection the words “as will developments leading to their enjoyment by the public” should also be added. I conclude that this should be done.

Objector 303 (Morris Homes)

2. The substance of this objection is dealt with elsewhere in this report and I see no need to go over the same ground again. I conclude that no modification arises from this objection.

Objector 326 (CPRE)

3. As this Objector will know and recognise, an essential characteristic of Green Belts is their permanence. PPG2 (paragraph 2.12) says that Green Belt boundaries should be related to a timescale which is longer than that normally adopted for other aspects of the plan. Land between urban areas and the Green Belt may be required to meet longer-term development needs and should be safeguarded for this reason. Regional and strategic guidance should provide a strategic framework for considering this issue and, as the Objector acknowledges, there is no strategic imperative to alter the Green Belt boundary


in this case. PPG2 also says (paragraph 2.6) that detailed Green Belt boundaries defined in adopted Local Plans (as is the case here) should (only) be altered in exceptional circumstances.

4. The Objector may like to believe that these considerations relate primarily to the possibility of taking land out of the Green Belt but, in my view, there is no evidence to support this contention.

5. I conclude that the Green Belt boundary should not be altered to include the Countryside Areas.

Objector 349 (Mr Warder)

6. As to Mr Warder’s objections, these are dealt in greater detail in relation to his objection to policy NE13 (see below). He is anxious that more attention is paid – especially by United Utilities – to existing flooding problems in the parts of the Borough that are affected, one of which is Marton Moss. However, he acknowledges there is no specific modification to policy NE3 that would achieve what he wants.

7. It also has to be said that, in planning terms, poor drainage is not the main reason for preventing development at Marton Moss in this review of the Local Plan. The main planning reason for not building on Marton Moss for the foreseeable future is that there is no proven need to develop greenfield land in Blackpool at the moment. Government guidance clearly discourages the unnecessary development of greenfield land.


Recommendations9. I recommend that the words “as will developments leading to their

enjoyment by the public” are added to the end of paragraph 8.15. 10. I recommend no modification to the Local Plan in response to objection

303/17.11. I recommend no modification to the Local Plan in response to objection

326/24.12. I recommend no modification to the Local Plan in response to objection

349/2.

Officers Recommendation The Inspector’s recommendation (9) is accepted that the words “as will

developments leading to their enjoyment by the public” are added to the end of paragraph 8.15.

The Inspector’s recommendations (10) to (12) are accepted.


8.4 Conserving the Natural Environment Policy NE3 – Site 3.1(renumbered 3.2 in the Second Deposit)

The Objection177/2 Mr J B Clarke

Summary of the Objection10 ha of land west of Staining should be allocated for residential development to increase the supply of housing land. (177) (Also considered here is a matching objection – 177/1 – to policy HN2.) (Also dealt with here is a matching objection – 177/3 – to policy NE5.)

Inspector’s Reasoning and Conclusions 1. Government guidance in PPG3 is very clear; greenfield land should not be

released for residential development unless all the needs for housing land cannot be met on previously developed land.

2. The objection site is greenfield land. The Council says there is no need to release any greenfield sites for housing in order to meet the foreseeable need for new housing because enough previously developed land is available. Although this Objector does not question this assessment; others have and I have found the Council’s stance to be soundly based. There is thus no need or reason to release this land for residential development.

3. Furthermore, this is (in the Blackpool context) a relatively large site in an isolated rural location. Development here would distort the form of Staining village and erode the important gap between the village and Blackpool’s urban area. Even if there were a need to release greenfield sites for development, there are other better placed sites closer to (and better related to) the urban area that would be preferred.

4. I conclude that the objection site should not be allocated for residential development and should remain as a designated Countryside Area in the Local Plan.

Recommendation5. I recommend no modification(s) to the Local Plan as a result of objections

177/1, 177/2 and 177/3.


8.5 Conserving the Natural Environment Policy NE3 – Site 3.2(renumbered 3.1 in the Second Deposit)

The Objections028/2 L.A. Moss

052/1 Mrs M Shiers

069/1 Thomas Cardwell

286Conserving the Natural Environment Chapter 8

093/2 Mr Leslie Kenyon

107/2 Mrs Jean Parkinson

132/1 Mr S Bentley (Conditionally Withdrawn)

169/1 David Ringrose

204/1 Michael Cottam

221/1 Frederick Dilnorth

230/2 S Clark

232/2 Mrs B Kerr

237/1 Anita Cottam

251/4 Owen Baguley

256/4 E Sloane

279/4 C.A. Banks

281/1 Mrs D Taylor

282/1 Mr N Taylor

283/1 Mr Pasquale Pascucci


301/2 Mrs Eirian Toth

304/1 Antonio Pascucci

319/2 G J Moss


330/4 Phil Shevloff



341/1 Linda Dilnorth


345/1 Hazel Cragg

Summary of the ObjectionsMarton Moss should not be designated as a Countryside Area so that controlled (lower density) housing development can take place. The town is over-developed and low density development here, incorporating amenities, would be an asset. There is no agricultural or recreational benefit in keeping the area as it is, horticulture is no longer viable. Some of the area is no longer agricultural or greenfield land and some is unused or despoiled and derelict. Well planned development could assist in solving the area’s drainage and traffic problems – the existing roads and drains are inadequate. Housing would be conveniently located for jobs and shops. Fylde Council allow some development in their area and so should Blackpool BC. (28, 52, 69, 93, 107, 132, 169, 204, 221, 230, 232, 237, 251, 256, 279, 281, 282, 283, 289, 301, 304, 319, 330, 332, 333, 341, 343, 345)

The area is becoming attractive for gypsy encampments (132) (Conditionally Withdrawn)

The area suffers from traffic noise on the new road. (169, 281)

More housing land needs to be released by the Local Plan. The NE3 designation should be deleted to allow housing or mixed development. (328)

ALSO DEALT WITH HERE ARE OBJECTIONS TO POLICY HN2 RELATING TO MARTON MOSS (FOR MORE DETAILS OF OBJECTION NUMBERS SEE UNDER POLICY HN2)

Land at Marton Moss is no longer suitable for horticulture and should be allocated for housing (or as part of a mixed development. It is suitable for housing development, which would have advantages for the locality. (028) (230) (253) (303) (319) (328) (331)


Many of the urban sites allocated for development in the Local Plan are small and should be retained for community uses such as public open space. (251) (256) (279) (289) (330) (332) (333) (343) (345)

The sites brought forward in the Second Deposit are less in accord with PPG3 than development at Marton Moss. (303) (Second Deposit)

Inspector’s Reasoning and Conclusions Background

1. The background to the future of Marton Moss in this Local Plan is to be found in the government’s guidance in PPG3. This says that greenfield land should only be released for housing development if vacant or underused land cannot be found within the urban area. All the land with development potential within the urban area should be used before peripheral greenfield land is considered. Many of the objectors may not like or agree with this guidance but it is absolutely clear and the Council is right to have had regard to it.

2. The guidance in PPG3 provides definitions of greenfield land and previously developed land. In my view these can best be applied to individual plots or parcels of land and not to larger tracts such as Marton Moss as a whole. Be that as it may, land that is used (or was last used) for agriculture or horticulture and land where the remains of any structure or activity have blended into the landscape in the process of time are to be treated as greenfield land. Without specific and compelling evidence to the contrary relating to individual fields or parcels of land, I am inclined to view much of Marton Moss as greenfield land with some sporadic housing and other uses within it. For the same reasons I take the view that it is a rural area, albeit one in which there has been intensive horticulture and in which there are sporadic dwellings and some other non-agricultural uses. In any event the area is not urban or within of the urban area.

3. The Council has decided in the Local Plan that it can find all the land it needs for housing development within the urban area. It even takes the view that it can find all the land it needs without using greenfield land that is within the urban area. I explore these matters in detail in connection with policies HN1 and HN2. On the basis of the evidence presented to me I accept that the Council’s view of housing land availability is well-founded.

4. This means that there is no need or reason to allocate greenfield land outside the urban area for development. To do so would be contrary to government policy and guidance. This means that there is no general case for residential development at Marton Moss.

5. I will now look at some of the other arguments for developing Marton Moss that have been put to me.

Agriculture and Horticulture

6. I am told that horticulture and agriculture are no longer viable on this land. It is also said that, although the land was originally of a high quality, it is now degraded by broken glass and the foundations of greenhouses. I doubt whether such arguments apply to the whole area, but even if they do, these would not be compelling reasons to release greenfield land for development if there is no need to do so. Just because the land is no longer needed for agriculture or horticulture is not a sufficient reason to identify it for development if there is no need to do so. As indicated above, government guidance is clear that greenfield land should only be developed if there is a need to do so after land in the urban area has been brought into use.


Drainage and Traffic

7. It is also said that the area suffers from poor drainage and inadequate roads and that these could be improved with the investment that would be needed for development. Again, this may be true but in my view it is not a sufficient reason to allow greenfield development if there is no need for it.

Planning History and Future Prospects

8. Some objectors point to past development on moss land and say that the process should now be extended into the remaining parts of the Moss. Other objectors say that in the past they were led to expect that there would be good prospects for development in the area, although the Council says that the remaining moss land has been protected from development for decades. Be that as it may, I have to assess the need for development in the light of current circumstances and as I have indicated there is no reason for such development within the current plan period.

9. Some objectors say that the adjoining Fylde Council adopts a more relaxed and permissive attitude to development on their part of the Moss. I have no way of assessing whether this is the case or not because my remit extends only to land and policies in Blackpool Borough. However even if it is true and there is a need for development in Fylde, this does not change the situation in Blackpool where there is no such need.

10.The Council acknowledges that there may be a need for development on the Moss in the longer term beyond this plan period or if circumstances change. In this sense, Marton Moss may be regarded as a reservoir of land with potential for long-term development. However, this does not mean that the land should be made available now or that development can be expected before 2016.

Urban Fringe, Character and Appearance

11.Some objectors point to the unique qualities of the Moss and stress that it is no longer open countryside or rural. Although the Moss (and its character and problems) may be distinctive in the Blackpool context it is not unlike other urban fringe areas elsewhere in the country. The land uses, fragmentation of holdings, appearance and the condition of the land at Marton Moss are not unique and are not a sufficient reason for the development of greenfield land. Neither does land being neglected, underused or unused mean that it is derelict and needs remedial action.

12. It is said that the area is now unsightly and unattractive, although in my view this is not true of the whole area. It is said that housing development would “tidy it up”. However, to accept this as a reason for allowing residential development might only encourage landowners to neglect their land in the hope of achieving development on land that would otherwise not be considered suitable.

13.One particular complaint is that the noise from the new road now intrudes into the area, destroying its rural tranquillity. However, this is hardly a strong recommendation that it is suitable for housing.

Density, Phasing and Fringe Benefits

14.Many objectors stress that they envisage low density development and/or the controlled and programmed release of land for development.

15.Low densities are not encouraged by current government guidance because this leads to the wasteful use of land and, ultimately, to a need to release more


greenfield land. I therefore do not see the proposed low densities favoured by some objectors as a benefit of development at Marton Moss. If the area is suitable for development, it should be developed in accord with the densities indicated in current government guidance.

16.As to the gradual release of land for development, the Local Plan assessment of need extends over many years. If there is no need for land to be released in this reasonably long-term context, gradual release is beside the point.

17.Sporadic housing spread through the area to meet the individual needs and aspirations of particular landowners would have no wider benefits in my view, except for the individuals concerned.

18. It is also argued by some that further development would complete a process of urbanisation that has been taking place for decades. However, the need for housing in the Borough has changed in recent years and the amount of land that is released for development should reflect this.

19.Others suggest that residential development could incorporate various leisure attractions such as footpaths, cycleways and fishing lakes. Whilst this may be true (especially if low densities were involved) these considerations are not in my view a sufficient reason to allow development that is not needed.

Infilling

20.Some objectors suggest that the development of their particular site could be regarded as “infilling”. My definition of infilling is that it is development of a small site within an otherwise built up frontage, capable of accommodating no more than one or two dwellings. Some of the sites referred to in this context are much too large to be regarded as infill. And any sites that are small enough to be properly regarded as infilling are too small to be identified in the Local Plan.

21.But even where small sites are referred to, the Local Plan policy specifically says that infilling is not to be regarded as an exception to the policy. In my view the gradual and piecemeal erosion of what remains of the open and rural character of Marton Moss would be an even worse outcome than comprehensive and planned development.

22. I therefore take the view that the objections relying on the infilling argument have no merit.

Personal Considerations

23. I recognise that many objectors may have personal reasons for finding the development of their land particularly attractive at the present time. They may be finding the burden of caring for the land is becoming onerous, they may wish to realise their assets, perhaps to retire or move away from the area. Whilst I sympathise with such personal aspirations, they are not matters that can or should influence the contents of the Local Plan.

Other Matters

24. I accept that at least some of the area is conveniently located for shops and employment. However, this is far from true for the whole area. In any event this land should be compared to land within the urban area. In general Marton Moss is a rather peripheral and unsustainable location. Be that as it may (and parts of the Moss are relatively close to existing services), such considerations would only come into play if there was a need to allocate greenfield land for development and one were choosing between potential sites. This is not the


situation in Blackpool and this Local Plan.

25.The suggestion that any housing should be part of a mixed development does not, in my view, overcome the difficulty that there is no need for additional housing on this greenfield land. In addition there is no evidence that there is a need for any other (non-residential) development with which to “mix” housing. It would be a case of two inappropriate and unnecessary uses being combined, each to justify the other. Two wrongs would not make a right!

26. I note one objector considers the area may become attractive for occupation by gypsies. However, any developments of this sort will be subject to planning control, so that this does not alter my assessment of the overall situation.

27.Morris Homes say that in the part of the Moss in which they have an interest, a scheme could be devised “which configured the site in such a way that the majority of it equates to an area which is previously developed land with the remainder as open space or land for future development.” However, they have not produced evidence to show that this is so. In any event, to be acceptable at this time, such a scheme would need to use only previously developed land within the urban area and would need to achieve acceptable densities.

The Form of the Policy

28.Although none of the objectors have suggested an alternative form of words for the policy, it is clear that many would favour a “less strict” or “more flexible” approach. However, having considered the matter I cannot conceive of a fair or acceptable way to achieve the sort of relaxation that the objectors appear to want. I therefore take the view that the policy should remain as it is.

Conclusions

29. In view of all the above. I conclude that a case has not been made for modifying the Local Plan to include the release of land at Marton Moss for residential development. I conclude that the NE3 designation of the land should be retained in the Local Plan.

Recommendation30. I recommend no modification to policy NE3 (site 3.1 – Marton Moss) in the

Local Plan.


_____________________________________________________________________

8.6 Conserving the Natural Environment Policy NE4(subsumed in policy NE3 in the Second Deposit)

The Objections028/3 L.A. Moss

052/2 Mrs M Shiers

069/2 Thomas Cardwell

093/1 Mr Leslie Kenyon


107/1 Mrs Jean Parkinson

117/1 G & R Pascucci

127/1 Mr Michael Bardsley

132/2 Mr S Bentley (Conditionally Withdrawn)

169/2 David Ringrose

204/2 Michael Cottam

221/2 Frederick Dilnorth

230/1 S Clark

232/3 Mrs B Kerr

237/2 Anita Cottam

251/5 Owen Baguley

256/5 E Sloane

279/5 C.A. Banks

281/2 Mrs D Taylor

282/2 Mr N Taylor

283/2 Mr Pasquale Pascucci


301/1 Mrs Eirian Toth

304/2 Antonio Pascucci

319/3 G J Moss


330/5 Phil Shevloff



341/2 Linda Dilnorth


345/5 Hazel Cragg

Summary of the ObjectionsMarton Moss should not be designated as a Countryside Area so that controlled (lower density) housing development can take place. The town is over-developed and low density development here, incorporating amenities, would be an asset. There is no agricultural or recreational benefit in keeping the area as it is, horticulture is no longer viable. Some of the area is no longer agricultural or greenfield land and some is unused or despoiled and derelict. Well planned development could assist in solving the area’s drainage and traffic problems – the existing roads and drains are inadequate. Housing would be conveniently located for jobs and shops. Fylde Council allow some development in their area and so should Blackpool BC. (28, 52, 69, 93, 107, 117, 127, 132, 169, 204, 221, 230, 232, 237, 251, 256, 279, 281, 282, 283, 289, 301, 304, 319, 330, 332, 333, 341, 343, 345)

The area is becoming attractive for gypsy encampments (132) (Conditionally Withdrawn)

The area suffers from traffic noise on the new road. (169, 281)

More housing land needs to be released by the Local Plan. The NE3 designation should be deleted to allow housing or mixed development. (328)

Inspector’s Reasoning and Conclusions 1. Since these objections were made to the First Deposit, policies NE3 and NE4 in

the Local Plan have been combined in the Second Deposit version of the plan.


2. With two additions (117 and 127) the objectors to policy NE4 are the same as objected to NE3, Site 3.2 immediately above. The objections are linked and raise essentially the same issues.

3. I consider that I have already dealt with all the matters of substance raised here under policy NE3 and that there is no need to go over the same ground again.


Recommendations5. I recommend no modifications to the Local Plan in response to these

objections.Officers Recommendation


8.7 Conserving the Natural Environment Paragraphs 8.12 – 8.14The Objections204/3 Michael Cottam

237/3 Anita Cottam

Summary of the ObjectionsThe accuracy of paragraphs 8.12 – 8.14 is disputed. The area is now residential not agricultural. Most of the land is in residential use or unused; the glass houses are derelict. There is no active horticulture or agriculture left. (204) (237)

Inspector’s Reasoning and Conclusions 1. These identical objections dispute the accuracy of these paragraphs in the

Local Plan. It appears to me that the objectors are wrong in as far as the majority of the land is concerned; it does not appear to me to be in residential use. They may be on stronger ground when they say that most of the glass houses and a lot of the land are no longer in use; although even if the horticultural and agricultural uses have ceased it does not follow that new (residential or other) uses have been established.

2. It is clear that this is a distinctive area outside the current urban area. It may offend these objectors to see it described as countryside or rural but in planning terms this is what it is because of the historic legacy of the present and last known uses. This is the basis on which policy formulation should start.



objections.



8.8 Conserving the Natural Environment Policy NE5The Objection177/3 Mr J B Clarke

Summary of the Objection10 ha of land west of Staining should be allocated for residential development to increase the supply of housing land. (177) (This objection is dealt with in conjunction with a matching objection – 177/2 – to policy NE3)

Inspector’s Reasoning and Conclusions 1. In the Second Deposit policy NE5 was subsumed in policy NE3. This objection

is considered under that heading (please see above).

Recommendations2. For my recommendation on this objection please see under policy NE3.

8.9 Conserving the Natural Environment Policy NE6The Objections204/4 Michael Cottam

237/4 Anita Cottam

Summary of the ObjectionsThe figure limiting the scale of extensions to dwellings in the countryside (including the Green Belt) should be 50%. New houses are much larger now compared to 40 years ago so this figure would be reasonable. Also, because the figure relates to the footprint of the building it discriminates in favour of bungalows. The meaning of “conflict with the open character of the countryside and Green Belt” is subjective and unclear. (204) (237)

Inspector’s Reasoning and Conclusions 1. I accept that a policy dealing with this subject is needed and the objectors do

not question this either.

2. I understand why the objectors may feel that the concept of “open character” is a subjective or nebulous one but it is the basic reason for the policy that needs to be interpreted and applied in the circumstances of each site and proposal. Therefore, it should be retained.

3. However, I do share some of the objectors concerns about the mechanics of this policy, principally for the following reasons:

(a) in my experience elsewhere (admittedly often outside Lancashire) a limit of 50% is not uncommon, although I have also encountered lower figures;

(b) however, any such figure is usually related to the whole floor area of the original building and not to its footprint. It is also applied to the (cumulative) increase in the floor area of the whole building;

(c) it is not clear how the mechanism proposed here would work; (is the 35% limit to apply only to proposals that extend the footprint of the building or to upward extensions as well? Indeed, is any limit on upper-storey extensions implied by this policy?)


(d) the confusion is made worse because in my view the words “the original footprint building” seem to me to be grammatically incorrect, is “the original footprint of the building” what is meant?

4. Depending on the view taken on the above matters the policy could very well have very different implications for bungalows and houses.

5. The Council has not gone into the reasons why it has adopted this form of policy or why the local circumstances lead them to regard 35% as an appropriate figure. However, in my view the difficulties inherent in the current policy go beyond the 35% issue raised by these objectors.

6. I therefore conclude that the Council should review the general form of this policy as well as the 35% limit it contains. Clearly the appropriateness of a 35% figure will depend, in part, on how it is to be applied. It may also depend on local circumstances and experience about which I have not been told.

Recommendation7. I recommend that the Council reviews the form and content of policy NE6

with a view to clarifying its meaning and how it is to be applied. Part of this review should involve an examination of whether a limit of 35% is justified by local circumstances.

Officers Comments

The Inspector’s recommendation of a need for further clarification and review of the form and content of Policy NE6 is accepted. This he recommends should involve an examination of whether a limit of 35% is justified in local circumstances. He raises a number of issues:

- His view (d) that the policy wording should for clarification be amended to refer to the ‘original footprint of the building’ is accepted.

- His views (b) and (c) primarily relate to a need for review and clarification whether the 35% limit on extensions/ replacements should be applied to the ‘ground floor original footprint of the building’ or the ‘total floorspace’ (including upper floor extensions).

The current policy wording means that the 35% limit does only apply to the ground floor footprint of the building.

Control over upper floor extensions is instead exercised via the outset statement in the Policy that “extensions and replacements for existing dwellings in the countryside will only be permitted if in keeping with the scale and open character of the designated Countryside Area or Green Belt”. Policy BH3 (residential amenity) and Policy LQ4 (building design) both provide further control of upper floor extensions out of scale and character with the area.

Together this is considered provides the necessary level of control of upper floor extensions. The principle concern is to ensure that any extensions do not have an adverse impact on the remaining open character of countryside areas – with the focus of the policy on the Marton Moss countryside area. Given the large number of houses already developed on the Moss, the main concern is to prevent the ground floor footprint extensions which would further erode any open aspects across the lands. A whole floorspace limit would potentially allow a much higher level of expansion of the ground floor footprint of two storey buildings.

In these terms the figure of 35% relating to the original ground floor footprint rather than the total floorspace is considered fully justified and more directly addresses the Council’s concerns


about over-intensive development.

Similarly the 35% limit rather than a 50% limit is considered fully justified given the particular characteristics of the Moss, comprising a large number of small independent existing and former agricultural holdings and dwellings in a very concentrated form of development, different from typical countryside areas. The lower limit is necessary to avoid the adverse impact of the further intensification of development on the remaining rural environment.

Officers RecommendationIn accordance with the Inspector’s recommendation to review its form and content, Policy NE6 to be amended for clarification to state:

“Extensions and replacements for existing dwellings in the countryside will only be permitted if in keeping with the scale and open character of the designated Countryside Area or Green Belt”. and not Extensions and replacements for existing dwellings in excess of 35% of the original ground floor footprint of the building will not be permitted”.

8.10 Conserving the Natural Environment Policy NE7The Objection109/ 9 / 19 English Nature (Cheshire to Lancashire Team) (Conditionally Withdrawn)

Summary of the ObjectionPolicy NE7 should apply to all SSSIs. (First Deposit) (Conditionally Withdrawn) (109)

"SSSIs" needs no apostrophe. (109) (Second Deposit)

Inspector’s Reasoning and Conclusions 1. Apart from the spelling correction, the changes sought by these objections were

made in the Second Deposit. As a result the objections were conditionally withdrawn. I conclude there is no need for me to consider this matter further.

Recommendation2. I recommend no modification to the Local Plan as a result of these

objections, other than the spelling correction.


8.11 Conserving the Natural Environment Paragraph 8.21The Objections244/4 Fylde Bird Club (Conditionally Withdrawn)


Summary of the ObjectionsThe policy should consider protecting potential alternative routes for the Fylde Coast Easterly Bypass, which may pose less of a threat to the integrity of the Marton Moss SSSI. (326)

Remove any suggestion in paragraph 8.21 that the SSSI could be protected from adverse effects of the


new road. (244)

Inspector’s Reasoning and Conclusions 1. The Council says that the Fylde Coast Easterly Bypass has been removed from

policy AS6. The reference to it in paragraph 8.21 was deleted in the Second Deposit. In my view this meets these objections.


244/4 and 326/25.


8.12 Conserving the Natural Environment Paragraph 8.22The Objection244/4 Fylde Bird Club (Conditionally Withdrawn)

285/4 Nature Watch Group BEAT

Summary of the ObjectionParagraph 8.22: “Remove reference to the Management Plan or admit to the current status.” (Full quote) (244)

Add to the paragraph: "The Plan is annually updated and is subject to review by the interested parties at intervals." (285)

Inspector’s Reasoning and Conclusions 1. Since these objections were made, paragraph 8.22 has been deleted but its

contents have been moved to a later position in the Local Plan (paragraph 8.23a).

2. The Council’s response to Objector 285 says that it accepts the point that is being made, although I cannot find where this is reflected in the version of the plan that I have.

3. It is not clear to me what Objector 244 wants but I see no need to remove all reference to the Management Plan from the Local Plan.

4. Be that as it may, it is my view that whether the Management Plan for Marton Mere is reviewed on an annual (or some other) basis is not a matter for the Local Plan.

5. I therefore conclude that no modification arises from these objections.


244/4 and 285/4.Officers Recommendation



8.13 Conserving the Natural Environment Policy NE 8The Objections244/7 Fylde Bird Club

255/10 Beverley Moy

285/6 Nature Watch Group BEAT

327/2 Miss A J Gray

Summary of the ObjectionsA thorough review of all existing biological sites is needed to update the list of Biological heritage Sites. Also, a survey of the whole Borough is needed to identify all important wildlife sites for designation. Local groups (such as Fylde Bird Club) should be consulted to supplement professional surveys. (244)

Paragraphs 8.24, 8.25 and 8.27 should be reworded to accurately describe current policy or they should be withdrawn. It is misleading to give the impression that affected sites can be safeguarded from the adverse affects of development adjacent to them. (244)

There is a need for discussion regarding how to restore countrified places to their former glory before conservation is contemplated. Objection is made to the Council paying lip service to an aim with no plan in place to ensure the protection of these places. Two neglected sites (8.1 and 8.12) in particular are referred to. (255)

(a) Delete Site 8.13 from the list, it has been destroyed. (b) Add the following phrase to the text of the policy: "Designated Biological Heritage Sites identified for protection were at the last revision ..." (c) Add to paragraph 8.24: "The list is reviewed annually at the BHS Annual Review Meeting (Lancashire Wildlife Trust/ Lancashire County Council) (285)

Policy NE8 should be brought into line with the deposit Structure Plan Policy 20. (327)

Proposed ChangesPC70; amend boundary of Marton Mere Local Nature Reserve as in map NE8PMC1.

Inspector’s Reasoning and Conclusions Objector 244 (Fylde Bird Club)

1. Since this objection was made to the First Deposit, substantial changes to the policy and text have been made in the Second Deposit. One effect of this has been to move the list of sites from the policy to the text and to indicate how the list is kept under review. There are further suggested amendments to the text in the Proposed Changes.

2. The Council says that there was a review of the sites and their boundaries in April 2003 (the objection is dated February 2003), although the Council was not able to undertake a full survey of the whole Borough. However, the Council would welcome the advice of local groups, such as this Objector.

3. In other respects, some of the text that was objected to has been changed, including the paragraph on ponds which was particularly contentious.

4. All in all, the changes made in the Second Deposit and suggested since appear to me to have gone at least some of the way to meeting this objection. Whether the Objector is now satisfied is not for me to say but I note that there has been no subsequent objection. In the absence of specific comments on the revised policy and text, it is difficult for me to know what more the Objector wants.

5. I conclude that no (further) changes to the Local Plan arise from this objection.


Mrs Moy

6. Mrs Moy is concerned that some of the identified sites are not being properly cared for or maintained. She cites two examples. Although she argues that designation is an empty gesture unless sites are maintained in a satisfactory way, she did not suggest that any sites should be removed from the list. I am sure this is not the outcome she would favour, even though she does want something positive done.

7. At the Local Plan Inquiry the Council did not dispute the poor state of the sites referred to but emphasised that the main point of including a site in this policy is to prevent it being developed, or at least to ensure that the nature conservation value of the site can be taken into account when planning decisions are being made. The Borough planners said that the care and maintenance of the sites is for other Council departments and is not a Local Plan matter.

8. Whilst this answer is understandable to me as a planner, I suspect that it cuts little ice with a member of the public who wants to see the sites she is concerned about maintained in a better condition. And even a planner must surely recognise that it does not indicate a very comprehensive corporate approach. However, I am bound to accept the limits of what can properly be included in a Local Plan. Moreover the Objector did not suggest or seek any changes to the policy (or text) that would improve matters.

9. I therefore conclude, more in sorrow than with enthusiasm, that the Local Plan should not be modified in response to objection 255/10.

Nature Watch Group

10.The Council disagrees that site 8.13 has been completely destroyed but added a reference to a planning permission affecting the site in the Second Deposit. Otherwise the wording changes suggested by the Objector were included in the revised text in the Second Deposit.

11. I consider that the objection has been reasonably and adequately met and conclude that no (further) changes are needed.

Miss Gray

12.The Council accepted the point made in this objection and introduced the clause about pond replacement to paragraph 8.31. I conclude that this objection has been met. (But see subsequent discussion of this issue.)

Recommendations13. I recommend that PC70 is advertised as a modification to the Local Plan.14.Otherwise, I recommend no modification to the Local Plan in response to

these objections.

Officers Recommendation The Inspector’s recommendation that PC70 is advertised as a proposed

modification to the Local Plan is accepted:

PC70 Amend boundary of Marton Mere Local Nature Reserve (as per map NE8PMC1)



8.14 Conserving the Natural Environment Paragraph 8.32The Objection188/13 Wildlife Trust (Lancs, Manchester & N Merseyside) (Conditionally Withdrawn)

Summary of the ObjectionAdd wording to the text to support the creation of new ponds in association with new development, especially where this would also contribute to Sustainable Drainage Systems. (First Deposit) (188) (Conditionally Withdrawn)

Inspector’s Reasoning and Conclusions 1. The changes sought by this objection were made in the Second Deposit. As a

result the objection was conditionally withdrawn. I conclude there is no need for me to consider this matter further.


objection.


8.15 Conserving the Natural Environment Paragraphs 8.26 – 8.31The Objection326/26 CPRE (Lancashire Branch)

Summary of the ObjectionAdd an additional paragraph (8.32) which reflects Target 20.2 of the deposit Structure Plan, stating that two ponds will be created for every one lost through development. The policy should require that the new ponds are comparable to the ones lost in terms of physical, chemical and biological properties and in their siting in relation to other ponds. (326)

Inspector’s Reasoning and Conclusions 1. The requirement to replace each pond lost with two new ones was added to

paragraph 8.32 in the Second Deposit. However, the Council has not specified that the new ponds should be comparable to the lost ones in terms of their physical, chemical and biological properties because it regards this as unduly onerous.

2. In my view it is difficult to see how newly created ponds could be entirely comparable with lost mature ones, although if the replacement were clearly inadequate in some important respect it could be argued that it was not a proper replacement in the true sense of that word. On balance I consider that the changes made by the Council in the Second Deposit go as far as it is reasonable to go.

3. I conclude that this objection has been reasonably met in the Second Deposit.



326/26.


8.16 Conserving the Natural Environment Paragraph 8.27The Objections326/27 CPRE (Lancashire Branch)

327/1 Miss A J Gray

Summary of the ObjectionDelete this paragraph or simply state that "The largest concentration of ponds is on the edge of the Borough in north east Blackpool." (326) (327)

Inspector’s Reasoning and Conclusions 1. I consider that these objections were fully met by a change introduced in the

Second Deposit. I conclude that no (further) change is needed.


objections.


8.17 Conserving the Natural Environment Paragraph 8.28The Objection285/7 Nature Watch Group BEAT

Summary of the ObjectionAdd to paragraph 8.28: "as adding to the wildlife and amenity value of the BHS network." (285)

Inspector’s Reasoning and Conclusions 1. The suggested change was made in the Second Deposit. I conclude that no

(further) modification to the Local Plan is required. Personally, I think the Local Plan would be easier to read if “BHS network” were to be replaced by “the network of Biological Heritage Sites”.


285/7


Officers Recommendation The Inspector’s recommendation is accepted. In addition in response to the

comments of the Inspector the words “BHS network” are deleted from the end of paragraph 8.28 and replaced by “the network of Biological Heritage Sites”.

8.18 Conserving the Natural Environment Paragraph 8.31The Objection194/72 Government Office for the North West (Conditionally Withdrawn)

Summary of the ObjectionSustainable Urban Drainage Systems should be described as Sustainable Drainage Systems. (Conditionally Withdrawn after PC72) (194)

Proposed ChangesPC71; an amendment to the wording of paragraph 8.31 is suggested to indicate that the replacement of each pond lost by two new ponds will be required.

PC72; deletes the word “urban” from Sustainable Drainage Systems.

PC111 suggests a further change to the wording of paragraph 8.31 to indicate that any ponds provided as part of SUDS would be in addition to replacement ponds.


Summary of the Objection to the Proposed ChangesPonds that are part of SUDS should not be regarded as replacements for ponds lost to development. The two sorts of ponds have different characteristics and implications for nature conservation. (249)

Inspector’s Reasoning and Conclusions 1. In my view these objections are met by the latest versions of the Proposed

Changes. I find no fault with the Proposed Changes and conclude that they should be advertised as modifications to the Local Plan.

Recommendations2. I recommend that PC71 (as amended by PC111) and PC72 should be

advertised as modifications to the Local Plan.

Officers Recommendation The Inspector’s recommendation is accepted and accordingly that PC71 (as

amended by PC111) and PC72 are advertised as modifications to the Local Plan:

PC71/72 & PC111

Amend last two sentences of paragraph 8.31 as follows:

‘…the Council will seek to negotiate require the creation of two ponds for every pond lost through development.’ In addition the creation of other new ponds in association with any new development will be supported, especially where this would also contribute to Sustainable Urban Drainage Systems.


Amend penultimate sentence of paragraph 8.31 as follows:

8.19 Conserving the Natural Environment Policy NE9The Objection109/11 English Nature (Cheshire to Lancashire Team) (Conditionally Withdrawn)

Summary of the ObjectionChange the wording of Policy NE9 to: "Development will not be permitted if it would have an adverse impact on animal or plant species protected under national or international legislation. Development proposals should ensure that species and habitats set out in the UK and local biodiversity action plans will be protected and where possible enhanced." The supporting text should make reference to the Lancashire Local Biodiversity Action Plan. (First Deposit) (Conditionally Withdrawn) (109)




objection.


8.20 Conserving the Natural Environment Paragraph 8.23The Objection188/14 Wildlife Trust (Lancs, Manchester & N Merseyside) (Conditionally Withdrawn)

Summary of the ObjectionSubstitute "national" in place of "the Wildlife and Countryside Act" in the text and refer to a list of all the relevant national European and International legislation and regulations and PPG9 in a new Appendix or in a new Nature Conservation SPG. (First Deposit) (Conditionally Withdrawn) (188)




objection.

Officers Recommendation The Inspector’s recommendation is accepted (Note this paragraph reference in

the Inspector’s Report should be to paragraph 8.32 not 8.23).


8.21 Conserving the Natural Environment Policy NE10The Objections089/9 Countryside Agency, N W Division (Conditionally Withdrawn)

109/13 English Nature (Cheshire to Lancashire Team) (Conditionally Withdrawn)


Summary of the ObjectionsThe policy should reflect landscape character assessment. (First Deposit) (Conditionally Withdrawn) (089)

Reword policy NE10: Sites and Features of Landscape, Nature Conservation and Environmental Value. The Council will protect and retain sites and features of landscape, nature conservation and environmental value. Particular... groups of trees and hedgerows that contribute to public amenity and/or are of nature conservation importance; other habitats listed in the Lancashire Biodiversity Action Plan (BAP) or supporting species listed in the BAP. Development proposals should ensure that these sites and features are protected and where possible enhanced. The Council will identify suitable sites for landscape enhancement and use its powers to promote and encourage their renewal, including maximising benefits for nature conservation using available grant resources. The supporting text could also refer more strongly to the potential of such sites for enhancing nature conservation value and provide reference to encouraging habitats and species as listed in Lancashire BAP. (First Deposit) (Conditionally Withdrawn) (109)

Although the Second Deposit changes to this policy are supported, the text does not reflect these changes and should be amended accordingly. References should be added referring to nature conservation and biodiversity. (Second Deposit) (109)

The policy should make explicit reference to biodiversity and the delivery of the Lancashire Biodiversity Action Plan through site retention and appropriate management. It should also refer to PPG9 - Nature Conservation outside Designated Sites - paragraphs 14, 15 and 16 in particular, with their reference to stepping stones. (188)

Inspector’s Reasoning and Conclusions 1. This policy was extensively altered at the Second Deposit stage. As a result

these objections were conditionally withdrawn. I consider that the objections have been substantially met. The only objection (109/13) made to the Second Deposit says that, although the policy was changed, the text was not altered to fully reflect the changes made to the policy. I conclude that the text should be reviewed to ensure it does fully reflect the current wording of the policy.

Recommendation2. I recommend that the text accompanying policy NE10 is reviewed and

modified to ensure that it accurately reflects the current wording of the policy.

3. Otherwise I recommend no modifications in response to these objections.

Officers Recommendation The Inspector’s recommendation (2) that the accompanying text to Policy NE10 is reviewed and

modified to ensure that it accurately reflects the current wording of the Policy is accepted.

It is therefore further recommended that the following amendments are made to the supporting text to Policy NE10 as proposed modifications to the Plan:

o Paragraph 8.35, second line, amend to state “has important landscape, nature conservation, and environmental value”

o Paragraph 8.36, second line, amend to state “including public open space, sites of nature conservation value, and environmental benefits”


o Paragraph 8.37, fifth line, amend to state “wooded areas and hedgerows”


8.22 Conserving the Natural Environment Paragraph 8.40The Objection305/5 United Utilities

Summary of the ObjectionThe wording of this paragraph should include "planting of trees or deep rooted shrubs should be avoided near to electricity cables, water distribution pipelines and public sewers" (305)

Inspector’s Reasoning and Conclusions1. In response to an earlier similar objection (305/3 to policy LQ6), the Council

said that to rule out all tree planting near cables, pipes and sewers would mean that a large part of the Borough could not be planted. The Council also said that problems can be avoided by employing available technology to prevent root damage to such infrastructure. In response to this objection the Council says it accepts the point made but considers it unnecessary to include it at this point in the Local Plan. Be that as it may, in view of the importance that government guidance attaches to good design and improving the townscape – to which trees make a valuable contribution – I agree that a blanket prohibition would not be appropriate.

2. I conclude that this objection should not succeed.


305/5.


8.23 Conserving the Natural Environment Policy NE11The Objection89/10 Countryside Agency, N W Division (Conditionally Withdrawn)

Summary of the ObjectionWith the lack of open space in the inner areas, the Plan should look at providing green links from the inner areas out into the urban fringe as a means of giving access, in addition to local provision, to open space. (089)

Inspector’s Reasoning and Conclusions 1. I note this objection has been conditionally withdrawn, although it is not clear

what this is conditional upon. The Council responds by saying that there are proposals in the Local Plan to protect existing green linear spaces and increase open space in the inner areas.


2. In the absence of any clear suggestions or proposals to change or improve the Local Plan, I consider that I cannot take this matter further. I conclude that no modification arises for this objection.




8.24 Conserving the Natural Environment Policy NE11 – Site E11.1The Objection187/1 Asda Stores Limited

Summary of the ObjectionThe site at Warren Drive should be removed from this policy. If retaining the adopted Local Plan employment allocation is thought to be inappropriate for the site, it should be allocated for residential development or mixed use including housing, commercial uses and employment. (187)

Inspector’s Reasoning and Conclusions1. At the Local Plan Inquiry the extent of the land to which this objection relates

was clarified as being the land owned by the Objector. The Council owned land to the south is not included in the objection. The Objector also limited themselves to pursuing office development rather than housing or any other use. I shall consider the matter on this basis.

2. I have already considered whether this site should be allocated as a DE1 site suitable for office development. I have recommended that it should be, largely to reflect and recognize the extant planning permission on the site. This goes some way towards retaining the designation of the site in the adopted Local Plan (policy IB3.2, large office uses within a landscape setting).

3. However, the allocation in the adopted Local Plan was for a large office development in a landscaped setting and the landscape and design aspects of the adopted policy are not reflected in review policy DE1. As established in the adopted Local Plan, and confirmed at appeal since, retaining the open character of this site and the views across it are important planning considerations. I share this approach to this site and, in fact, the Objector did not dispute it at the Local Plan Inquiry. I consider this objective is best secured by retaining the NE11 policy and designation as in the draft review Local Plan.

4. I conclude that the Local Plan should not be modified in respect of the NE11 designation at Warren Drive.

5. This would leave the site with two designations, both of which would need to be taken into account in any development proposals.


objection (187/1).


Officers Recommendation The Inspector’s recommendation is accepted (see also recommendation on

Policy DE1).

8.25 Conserving the Natural Environment Paragraph 8.41The Objection188/17 Wildlife Trust (Lancashire, Manchester & North Merseyside)

Summary of the ObjectionA reference to the fact that the retention and management of urban greenspace can contribute to the delivery of BAP targets should be included. (188)

Inspector’s Reasoning and Conclusions 1. The Council agreed with this objection to the First Deposit and made the

requested change in the Second Deposit. I conclude that no further modification arises.


188/17.


8.26 Conserving the Natural Environment Paragraph 8.49The Objection33/2 Fylde Borough Council

Summary of the ObjectionParagraph 8.49 relates to sand extraction, which is a matter for the Minerals and Waste Local Plan. It also relates to an area outside Blackpool Borough. (033)

Inspector’s Reasoning and Conclusions 1. It cannot be denied that what the Objector says is right: this is not a matter for

this Local Plan on two counts. I note BBC’s position and acknowledge the importance of the issue for Blackpool Council. However, it can pursue a policy towards minerals proposals outside its own boundary whether or not this is included in the Local Plan. It can also monitor the situation on its beaches.

2. I note that BBC has discussed this matter and an alternative wording with the Objector but on balance I conclude that the contentious paragraph should be deleted from the Local Plan.

Recommendation3. I recommend that paragraph 8.49 is deleted from the Local Plan.


Officers CommentsThere is no disagreement between the Inspector, Objector, and the Council that the Local Plan should be amended to exclude any reference to mineral proposals outside its own boundary.

The wording accordingly agreed with Fylde Council relates only to Blackpool ‘s direct concerns about its own beaches. Despite the Inspector’s recommendation that paragraph 8.49 is entirely deleted from Policy NE12, the issue of the safeguarding of Blackpool’s own coast and foreshore is considered relevant and appropriate to be retained as supporting text in the Plan.

Officers Recommendation The Inspector’s recommendation is not accepted and it is recommended that amended

supporting text to paragraph 8.49 (as previously agreed between Blackpool and Fylde Councils) is included as a proposed modification to the Plan.

Reference in the last sentence is amended to “resist” rather than “oppose” – to make clearer it relates directly to Blackpool development issues.

“Sand is currently extracted for commercial purposes from the foreshore adjacent to St Annes

and Lytham in Fylde Borough. This Council is committed to maintaining and protecting the large

expanse of beaches. and is concerned that continued extraction further along the coast will

have an adverse effect on them. The Council will continue to monitor beach levels and will

oppose any proposed development that would be likely to further extraction that might threaten

the Blackpool sands.

8.27 Conserving the Natural Environment Policy NE13The Objections120/2 K Thornton



349/1 Mr D E Warder

Summary of the ObjectionsThe Objector seeks re-instatement of wording in paragraph 8.52 in the First Deposit that was deleted in the Second Deposit or the amendment of Policy NE13 to read: "Development in areas at risk ... will only be permitted where adequate drainage capacity already exists or is provided by the developer". (120)

The policy and text should be strengthened by including a commitment to promote sustainable drainage systems along the lines set out in PPG25 paragraphs 40 to 42 and 56. (194) (Conditionally Withdrawn after PC73)

The policy and text should be strengthened by including a commitment to promote sustainable drainage systems as indicated in the Structure Plan. (326)

Unless investigations and measures are undertaken to alleviate existing flooding problems, no more houses should be built in the parts of the Borough that are at risk. (349)

Proposed Changes


PC73 suggests that the last sentence in the policy should be: “Sustainable drainage systems will be used in new developments unless it can be demonstrated to the Council’s satisfaction that such a scheme is impractical.”

PC74 would add to paragraph 8.50 a requirement for flood risk assessments in areas at risk.

PC75 suggests adding the following as the second sentence in paragraph 8.52: “New developments will only be permitted where there is adequate drainage capacity and should seek to minimise surface water run off.”

PC76 would delete “urban” from the term “sustainable urban drainage systems” in paragraph 8.52 to accord with current usage

PC77 suggests a wording change to paragraph 8.52 (add “the rate of” surface water run off).

PC78 would amend the wording of paragraph 8.53A.

Inspector’s Reasoning and Conclusions Objector 120 (K Thornton)

1. This objection would be met by Proposed Change 75. I see no harm in this and conclude that it should be advertised as a modification to the Local Plan.

Objector 194 (GONW)

2. Objection 194/73 has been conditionally withdrawn as a result of PC73. I conclude that this should be advertised as a modification to the Local Plan.

Objector 326 (CPRE)

3. The Council agreed with this objection to the First Deposit and made appropriate changes in the Second Deposit. I consider this objection has been adequately and reasonably met and I conclude that no (further) modification is required.

Objector 349 (Mr Warder)

4. As far as Mr Warder is concerned, he attended the Local Plan Inquiry to draw attention to the flooding problems that exist in parts of the Borough, especially in the Anchorsholme area in the north of the Borough. He is anxious that more attention is paid – especially by United Utilities – to existing flooding problems because these may give rise to severe health hazards.

5. During the debate it emerged that problems in the Anchorsholme area have been caused on a number of occasions by faults in the computer controlling the pumping station serving the area. It was agreed that old sewers, the combined drainage system and the generally low-lying nature of the area are contributory factors. The system is under the control of United Utilities, not the Council.

6. In Mr Warder’s view what is needed is more investigation, investment and urgency on the part of the sewerage authority (United Utilities). The Council did not dispute this and said they are already lobbying to this effect. The Council offered to facilitate a meeting between Mr Warder and United Utilities.

7. However, the Council says the purpose of the Local Plan, and in particular policy NE13, is to ensure the risk of flooding is not made any worse because of new development. This is to be achieved by ensuring that appropriate measures are undertaken to avert any increased risk of flooding before new development is built. The Council says it would not be proper, or possible, for the Local Plan to load the responsibility and cost of solving existing problems onto new development proposals. The Objector accepts there is no specific modification to policy NE13 that would achieve what he wants.


8. Sympathetic though I am to anyone who has suffered from flooding and being aware of the health and other risks, I nevertheless consider that the Local Plan is right to focus on the requirements that new development can be expected to meet. In the light of information supplied to me, I note that whilst a relatively large area is involved, the affected area is almost all built up already.

9. I therefore consider there is no scope or reason to modify the Local Plan in relation to the, admittedly unsatisfactory, situation at Anchorsholme. After the Local Plan Inquiry Mr Warder wrote again to emphasise the unsatisfactory situation and the need for measures to prevent future flooding and the discharge of sewage into the sea. However, as I have indicated above, it does not seem to me that I or the Local Plan can help in this matter.

10. It was agreed at the Local Plan Inquiry that current investments in coastal defences are likely to provide adequate safeguards for the foreseeable future as far as the risk of flooding by the sea is concerned.

11. I conclude that no modification to Local Plan policy NE13 arises from objection 349/1.

Recommendations12. I recommend that PC73, PC74, PC75, PC76, PC77 and PC78 are advertised

as modifications to the Local Plan. 13. I recommend no modification to the Local Plan in response to objections

326/29 and 349/1.

Officers Recommendations The Inspector’s recommendation that PC73 to PC78 are advertised as

modifications to the Local Plan is accepted.

PC 73 Amend last sentence of Policy to read:‘Sustainable urban drainage systems will be used in new developments where practicable unless it can be demonstrated to the Council’s satisfaction that such a scheme is impractical.’

PC74 Add new sentence art the end of paragraph 8.50:

In accordance with PPG25 (Development and Flood Risk) applications in areas at risk of flooding should be accompanied by an appropriate flood risk assessment which complies with Appendix F of PPG25

PC75 Add new sentence after first sentence in paragraph 8.52 to state:

‘New developments will be permitted where there is adequate drainage capacity and should seek to minimise surface water run-off.’

PC76 Amend second sentence in paragraph 8.52 as follows:

Sustainable urban drainage systems (SUDS) can help to reduce the impact of built development while traditional drainage techniques using underground pipes increase the rate of run-off.’


PC77 Amend third sentence of paragraph 8.52 as follows:

‘SUDS involve techniques which control the rate of surface water run off as close to its source as possible…

PC78 .Delete paragraph 8.53a and replace with:

Indicative Flood Plain Maps showing those areas likely to be at 0.5% risk of tidal flooding and 1% risk of fluvial flooding have been prepared by the Environment Agency and are to be included in supplementary planning guidance.’


8.28 Conserving the Natural Environment Paragraphs 8.50 – 8.53The Objection109/15 English Nature (Cheshire to Lancashire Team) (Conditionally Withdrawn)

Summary of the ObjectionThe supporting text should recommend that developers consider more environmentally acceptable flood alleviation measures in ways that work with nature where possible, as opposed to hard engineering defences. Also strengthen the reference to sustainable drainage systems as a way of alleviating surface run-off from new developments. (109)

Proposed ChangesPC74 would add to paragraph 8.50 a requirement for flood risk assessments in areas at risk.

PC75 suggests adding the following as the second sentence in paragraph 8.52: “New developments will only be permitted where there is adequate drainage capacity and should seek to minimise surface water run off.”

PC76 would delete “urban” from the term “sustainable urban drainage systems” in paragraph 8.52 to accord with current usage

PC77 suggests a wording change to paragraph 8.52 (add “the rate of” surface water run off).

PC78 would amend the wording of paragraph 8.53A.

Inspector’s Reasoning and Conclusions 1. English Nature says that in the light of the proposed wording changes they

conditionally withdraw this objection. In any event I note that the latest form of words advanced by the Council refers to appropriate flood alleviation measures. I conclude that the Proposed Changes should be advertised as modifications to the Local Plan.

Recommendation2. I recommend that PC74, PC75, PC76, PC77 and PC78 are advertised as

modifications to the Local Plan.

Officers Recommendations The Inspector’s recommendation that PC74 to PC78 are advertised as

modifications to the Local Plan is accepted (see as set out under Policy NE13 above).


8.29 Conserving the Natural Environment Paragraph 8.52The Objection305/6 United Utilities

Summary of the ObjectionAdd the following to the current wording: "The statutory undertaker will not adopt SUDS facilities". (305)

Inspector’s Reasoning and Conclusions 1. The Council says that the adoption (or not) of infrastructure is not a Local Plan

matter. I agree and conclude that this objection should not succeed.


305/6.

Officers Recommendations The Inspector’s recommendation is accepted.


9.1 Accessibility and Safe Journeys for All Paragraph 9.7The Objection89/13 Countryside Agency, N W Division (Conditionally Withdrawn)

Summary of the ObjectionThis part of the Local Plan is welcome but the access needs of those who work or visit Blackpool and who live in surrounding rural areas should be considered. This could take the form of a transport interchange, linking trams/buses with a park and ride scheme. (089)

Inspector’s Reasoning and Conclusions 1. I note this objection has been conditionally withdrawn, although what the

withdrawal is conditional on is not clear. Be that as it may, I have commented elsewhere in this report on the failure to explore park and ride schemes as part of a comprehensive parking policy. In any event, no specific change to this paragraph is suggested by the Objector and in my view this matter is more appropriately pursued in relation to other parts of the Local Plan. Moreover, it is not clear that people from Blackpool’s rural hinterland have particular transport needs that are not shared by others.



objection.


9.2 Accessibility and Safe Journeys for All Policy AS1The Objections026/1 J R Dewhurst

089/14 Countryside Agency, N W Division (Conditionally Withdrawn)



Summary of the ObjectionsThe word "appropriate" access in criterion (d) is too vague. The supporting text should refer to the Disability Discrimination Act 1995, which would clarify the term "appropriate access". (026)

The Plan should consider Park and Ride schemes that would link into other transport modes and increase access for those living outside Blackpool, particularly those travelling from rural areas. (089)

The Structure Plan parking standards should be reviewed to ensure they do not result in a disincentive to development in Blackpool. If the standards set out in the Structure Plan are adopted, the Council should devise its own parking standards consistent with guidance set out in PPG6 and PPG13. (239)

The policy is too detailed and contains too many requirements. This may prevent some sites being developed, especially difficult urban sites. (287)

The policy refers to car parking standards that have been derived from the (Draft) Structure Plan. Tesco have objected to the standards in the Structure Plan, so they should not be used here. The standards do not comply with national guidance. (287)


Inspector’s Reasoning and Conclusions The Disability Discrimination Act 1995 (Objector 026)

1. The change sought by Objector 026 was made in the Second Deposit. I conclude that no (further) change is required.

Park and Ride (Objector 089)

2. I note this objection has been conditionally withdrawn, although what the withdrawal is conditional on is not clear. Be that as it may, I have commented elsewhere in this report on the failure to explore park and ride schemes as part of a comprehensive parking policy. In any event, no specific change to this paragraph is suggested by the Objector and in my view this matter is more appropriately pursued in relation to other parts of the Local Plan. Moreover, it is not clear that people from Blackpool’s rural hinterland have particular transport needs that are not shared by others.


Parking Standards (Objectors 239, 287)

4. Sainsbury and Tesco object to the car parking standards derived from the current Structure Plan review. Both say they have objected to the Structure Plan in relation to its parking standards. Tesco say the standards do not comply with national guidance. Sainsbury say the standards are too restrictive and could deter investment in the town centre and edge-of-centre sites. The Council on the other hand say that the standards do comply with PPG13 and will be brought up-to-date as and when the Structure Plan is adopted.

5. As far as compliance with national guidance is concerned, neither side has given me any evidence or reasons for what they say. I cannot make bricks without straw and cannot realistically take this matter further.

6. As to updating the standards to reflect the latest position and the outstanding objections to the Structure Plan, I am of the view that the advantages of having a unified and agreed set of standards for the whole of the (geographical) county are so great that this is the most sensible way to proceed. Any other approach could lead to an anarchic situation in which towns seek to compete with each other by varying their parking requirements. Any up-dating will be able to take into account the success (or otherwise) of the objections to the Structure Plan. It is my understanding that the Structure Plan will be adopted before the modifications stage of the Local Plan is reached.

7. I conclude that the Local Plan should not be modified in response to these objections but that the situation should be reviewed at the modifications stage in the light of progress on the Structure Plan.

Detail (Objector 287)

8. As to detail and the alleged excess of requirements, Tesco say that they accept the majority of the criteria in principle and do not identify any with which they disagree. If I was to strike out some of the criteria on this basis, I might be removing the ones with which they agree.

9. They may be right that not every development at every site will be able to satisfy all the criteria. It may be that exceptions will have to be made to bring some difficult urban sites into use. But this will need to be assessed on a site by site basis and it would not be sensible to try and alter the generality of the Local


Plan in an attempt to anticipate particular site conditions.



026/01 and 089/14. 12. I recommend no modification to the Local Plan in response to objections

239/5 and 287/24. However, I recommend that the matter of parking standards is reviewed at the modifications stage to reflect the adopted Structure Plan.

Officers CommentsIn accordance with the Inspector’s recommendation the position is that the parking standards in the adopted Joint Lancashire Structure Plan show no changes. A minor typographical error requires clarification to confirm that the baseline standard for coach space provision for stadia is 1 per 1,500 seats or standing spaces.

Officers Recommendations The Inspector’s recommendations are accepted.

Correct the baseline standard for coach space provision for stadia to 1 per 1,500 seats.

9.3 Accessibility and Safe Journeys for All Policy AS2The Objections089/16 Countryside Agency, N W Division (Conditionally Withdrawn)


Summary of the ObjectionsTravel plans should be required from smaller firms as well as major ones. (089)

Research has shown that the development of food stores can help to reduce the net distance of journeys undertaken by shoppers, especially in areas where there is a lack of desirable services. Food stores also enable the public to buy food in bulk which reduces the amount of journeys that would normally have to be undertaken. (287)

Inspector’s Reasoning and Conclusions 1. I note that objection 089/16 has been conditionally withdrawn, although what

this is conditional on is not clear. Be that as it may, the Council says that the size threshold in relation to travel plans has been agreed across the whole of the geographical county of Lancashire. In my view such an approach has considerable merit. In any event, it would be unreasonable to impose a requirement to produce travel plans on very small businesses.


3. What Tesco say may be true but it does not follow that the Local Plan should include this material. I do not consider that any purpose would be served by including this material in the Local Plan. In any event, the Objector has not identified any specific change to the Local Plan that they want.




089/16 and 287/25.


9.4 Accessibility and Safe Journeys for All Policy AS3The Objections019/1 Peter Scott

019/2 Peter Scott


092/1 Mr D Galvin



331/1 Mr P Wright

Summary of the ObjectionsTo attract more visitors and trips to the town without restraining car-use is not sustainable. Cycling should be encouraged by purpose-built cycle routes separated from roads and traffic (as in Morecambe and Lancaster). The Local Plan should include a network of cycle routes linking the outlying residential areas to the centre, local schools and local shopping areas. Cycle hire should be available at stations and park and ride locations. (019/1) (First Deposit)

Recreational routes are welcome but cycling should not be seen only as a leisure activity. It should be integrated into the transport policy for the town. To achieve this safe, convenient, (segregated) off-road and well lit cycle tracks are needed. Three new cycle routes are suggested: (1) Grange Park to local schools and Layton to Queens Park and central Blackpool; (2) Mereside to the Lancashire cycleway and (3) Ashfield Road and Blackpool and Fylde College to Bispham Village. (019/2) (Second Deposit)

Cycle path links into the network should be provided from surrounding rural areas. (089)

Routes must be kept free of parked cars. Safe crossings at main roads and junctions are needed. Cycle-only routes should be provided in congested areas. A route from the Thornton Cleveleys coastal boundary to Little Bispham is needed. An “escalated” route from Middle Walk to the Pleasure Beach should be provided. (092)

Cycle lane provision in Blackpool is inadequate and some traffic calming has made matters worse. Car-free cycle ways should be introduced on all major routes, including if necessary contra-flow operation on one way streets. (183)

Tesco have no objection to the principle of this policy. However, walking and cycling are not always the most convenient and safest ways to travel. For instance, the benefits that are brought to families from a weekly bulk food shop cannot be achieved efficiently and safely by walking or cycling. (287)

The complete segregation of cyclists and traffic is needed. White lines on the carriageway are not sufficient. (331)

Inspector’s Reasoning and Conclusions Matters of Principle


1. Between the First Deposit and Second Deposit the wording of this policy and the accompanying text in the Local Plan were altered. Also, an extensive draft Strategic Cycling Network was added to the Proposals Map.

2. I have strong reservations as to whether it is appropriate to show a draft network on the Proposals Map but there are no objections to this effect and none of the individual routes in the draft network have been objected to. I therefore make no recommendation on this matter.

3. The clear preference amongst the majority of the objectors to policy AS3 is for segregated cycle routes that are separated from other traffic and are used for more than recreation. The Council says it also wishes to promote cycling as a means of travel and prefers off-road segregated routes. However, the new elements of the proposed draft cycle network are overwhelmingly shown as “proposed on road”.

4. The safety and attractiveness of such routes will depend on the extent to which other traffic is to be removed from the designated routes, the design of crossing facilities and junctions, the use of barriers and pavements and a host of detailed design decisions that cannot be resolved in a Local Plan. Obstructions to cyclists caused by parked vehicles is another issue that should, in my view, be addressed at the detailed scheme design stage. I agree with the Objector who says that painting a white line along the side of the road is not enough, especially if safety is an important consideration. However, it is not clear what more, if anything, is intended.

5. The Local Plan stops short of saying that priority will be given to cyclists on the designated cycle network and some of the routes appear to be important traffic distributor roads. So the meaning and impact of this policy are less than clear. On the face of it, most of the objections to policy AS3 (B) remain unmet, in spite of the Council claiming that it is making progress.

6. I note and accept that the Council regards its network as a draft that needs further consultation and that matters are to be progressed through the Local Transport Plan. I also note that a range of measures have been implemented and that targets have been set and are being monitored. I also recognise that some cyclists would prefer to be accorded greater priority and consideration on the existing road network rather than having a less than satisfactory alternative network. However, even allowing for all this, it is not clear how committed the Council is to improving conditions (and safety) for cyclists. This is because, in my view, the cycling element of the transport policies lacks clarity beyond that which is to be achieved in association with development proposals or the National Network.

7. Even though there are no objections that make specific suggestions as to how the policy should be changed, the consensus amongst the objectors is in favour of more segregated routes. The Council has not provided any evidence as to why greater emphasis cannot or should not be placed on segregated cycle routes in the Local Plan or its draft network. Indeed, the Council says it is in favour of segregated routes, although the draft network does not appear to show this. In my view, the objectors have logic and safety on their side. A less dense network for which there is a real prospect of improvement and a strong commitment to achieving more segregation would be better than a dense and impressive network that failed to progress beyond the planning stage.

8. I therefore conclude that paragraph 9.16 of the Local Plan and the draft


Strategic Cycle Network (Proposals Map, AS3PM1) should be reviewed and revised either before the Local Plan is adopted or as part of the new Local Development Framework. On the basis of the evidence before me I conclude that the objective of such a review should be to place greater emphasis on segregated off-road cycle routes and to clarify how safety is to be secured where segregation is not possible.

Suggested Routes

9. Objector Mr Scott suggests three possible additional cycle routes and Mr Galvin suggests one. In as far as the Council comments on the specific suggestions, it appears to welcome them. The balance of the evidence is therefore in support of these suggested routes. I therefore conclude that the review of the Strategic Cycle Network recommended above should include these routes.

Cycle Hire

10.Mr Scott’s suggestion that cycle hire facilities should be provided in the town is also welcomed by the Council, although it is not thought to be an appropriate subject for inclusion in the Local Plan. I agree and conclude that no modification to the Local Plan arises in this instance.

Tesco Stores and the Countryside Agency

11.Tesco Stores say they do not object to this policy in principle. It is not clear from their objection what changes to the Local Plan, if any, they are seeking.

12.However, they raise two issues. The first is that walking and cycling are not always safe. Whilst this is true, it is government policy to make them so and to encourage them. They also refer to unspecified advantages of the weekly bulk buying of food. It is not clear how this could be reflected in the Local Plan, so it is difficult for me to respond.


14.As far as the Countryside Agency is concerned, it is not clear why their objection has been conditionally withdrawn. It is also not clear whether their interest in routes to and from rural areas is primarily for the benefit of rural residents or for the recreational enjoyment of Blackpool’s urban residents. However, as things stand I have no evidence that would lead me to recommend that the Local Plan should accord particular priority to routes in (or to and from) rural areas, as opposed to improving urban ones. Indeed, safety considerations are likely to indicate the opposite.

15.The Council says that in any event it is pursuing the provision of a wider network with the neighbouring authorities and that it is hopeful that improved links with the surrounding rural areas will be the result.

16. In the absence of any specific proposals for new routes from this Objector, I conclude that no modification to the Local Plan arises from objection 089/17.

Recommendations17. I recommend that paragraph 9.16 of the Local Plan and the draft Strategic

Cycle Network (Proposals Map, AS3PM1) is reviewed and revised either before the Local Plan is adopted or as part of the new Local Development Framework. The objective of such a review should be to place greater emphasis on segregated off-road cycle routes and to clarify how safety is to be secured where segregation is not possible.


18. I further recommend that the cycle routes suggested in objections 019/2 and 092/1 should be included in the above review.

19.Otherwise I recommend no modification to the Local Plan as a result of these objections.

Officers CommentsThe Council’s position is that a Strategic Cycling Network is being implemented through the Local Transport Plan process, and that the issues he raises will be fully considered as part of this process, including extensive consultation. The Council is itself fully in favour of segregated routes, but there is more of an emphasis on promoting cycling on the existing road network in Blackpool simply because there are insufficient opportunities in the densely urbanised area for off-road segregated routes. Each of the specific suggested routes made by objectors to the Local Plan will be considered through the LTP process.

In response to the major concerns raised by the Inspector about a draft network being shown on the Proposals Map, it is considered a full review of the cycle network should be assessed and revised through the LTP and then be incorporated as part of the new Local Development Framework.

In advance of this review process, reflecting the Inspector’s conclusions, it is considered that the cycle routes to be shown on the Proposals Map should be limited to the existing established network and the key proposals for the National Cycle Network and the proposed off-road routes. The wider draft Strategic Cycling network is recommended is retained in the Local Plan supporting text to Policy AS3 for information, but is not shown on the Proposals Map.

Officer Recommendations The Inspector’s recommendations are accepted, with a review of the draft

strategic cycle network to take place through the LTP process and be incorporated as part of the new local development framework.

In advance of this review process, the cycle routes to be shown on the Proposals Map should be limited to the existing established network, the key proposals for the National Cycle Network, and the proposed off-road routes.

The wider draft Strategic Cycling Network is retained in the Local Plan supporting text to Policy AS3 for information, but is not shown on the Proposals Map.

9.5 Accessibility and Safe Journeys for All Policy AS4The Objections


026/4 J R Dewhurst

033/1 Fylde Borough Council (Conditionally Withdrawn)


092/2 Mr D Galvin

126/ 3 / 4 Blackpool & Fylde Rail Users Association

159/2 Network Rail Infrastructure Limited (Conditionally Withdrawn)


292/2 Mr Adrian Gleadhill

331/3 Mr P Wright (Conditionally Withdrawn)

Summary of the ObjectionsThe supporting text should state that all forms of public transport should be fully accessible to all those who are “mobility impaired”. The Town Centre Inset Proposals Map should indicate a site for dedicated Ride-ability parking. This site should have a dropped kerb and should be as close as possible to the shop-mobility unit. (026)

Reword criterion (c) (ii) as follows: "creating a new on-street route to Blackpool North Station and developing a link to the southern borough boundary to facilitate a possible link to centres within Fylde Borough including St Annes and Lytham." (033)

When the proposed public transport interchange is being developed the surrounding rural areas should be taken into account because such interchanges can provide important links from rural areas into town centres. The Countryside Agency would also welcome more details concerning the Blackpool North Transport Development Area. (089)

The speed of public transport services would be improved by: (1) re-routing tram tracks overhead from the Cabin, up Dickson Road, down Church Street and along Bank Hey Street to run above the old railway route to South Station and join the railway to Lytham; (2) prohibiting all vehicle parking along bus routes; (3) providing bus and taxi lanes where possible eg Devonshire Road from the Devonshire Hotel up to Anchorsholme, Fleetwood Road could be slightly widened to accommodate this. (092)

If the tramway is to be extended towards Lytham, it should share a track and ticketing with the heavy rail service so not to be in competition with it. It is not clear whether Blackpool North Station would be connected to the South Fylde rail line – ideally an extension through the central corridor would be made. (126/4) (Second Deposit) Map AS4(B)PM1 is realistic. (126/3) (Second Deposit)

AS4 (c) should exclude the possibility of joint light and heavy rail services running between Blackpool North and Poulton. (159)

Delete "examining in detail the possibility of" from AS4 (c) (iii) and add the AS4 (c) tramway designation to the Blackpool / Poulton-le-Fylde route on the Proposals Map. (186)

Bylaws and traffic regulations should be enforced so that bus stops are kept free for buses. Remove shared taxi ranks and bus stops. “Compliance with the EU disabled access to public transport law.” (292)

The use and effectiveness of public transport will be enhanced if more jobs are concentrated in the town centre. (331) (Conditionally Withdrawn)

Inspector’s Reasoning and Conclusions The Location of Development (Objector 331)

1. This objection has been conditionally withdrawn, although on what basis this has been done is not clear. Be that as it may; the government, Council and Local Plan all place considerable emphasis on the importance of supporting town centres in general and Blackpool town centre in particular. The Local Plan already contains policies and proposals to this end. In the absence of specific proposals from this Objector, it is not clear what more he would want done.



Improving Facilities for Disabled Travellers (Objectors 026, 292)

3. Objector 026 wants all public transport services to be usable by those who, for whatever reason, have difficulties with mobility. And Objector 292 wants full “compliance with the EU disabled access to public transport law”, which I think amounts to much the same thing.

4. However, the Local Plan is not a document to regulate the nature of public transport services and vehicles and neither can it change whatever legal requirements public transport service providers have to meet. I am not denying the importance of what these objectors are saying but I do not think the Local Plan can help them in setting general standards of this sort for public transport.

5. Objector 026 is also seeking dedicated facilities in the town centre for the ride-ability services. Without denying the importance of this matter, I regard it as a matter of detail that it would be inappropriate to include in the Local Plan. As the traffic management arrangements for the town evolve any stop for ride-ability services might need to be moved – it does not seem to me likely that it would remain in the same place throughout the Local Plan period to 2016. This makes it difficult to include in the Local Plan.

6. For these reasons I conclude that no modifications arise from these objections.

Measures to Improve Bus Services (Objectors 092, 292)

7. Objector 092 says all parking should be prohibited on bus routes. The Council says in response that it considers such matters on a case by case basis. I see no logical necessity to restrict parking on all bus routes – in some cases it may be necessary and in other cases not. For example, I can foresee particular difficulties arising – especially at night – in residential areas with bus routes running through them if parking restrictions are introduced.

8. I conclude that there is no reason to regard every bus route as an area in which parking should be restricted.

9. The same Objector suggests that there should be bus and taxi lanes “where possible” and suggests some specific locations. In my view the introduction of such measures should always be “where justified” or “where needed” and never only “where possible”. Be that as it may, the Council again says that this is a matter to be pursued on a case by case basis through the Local Transport Plan. In my view, although the Local Plan could go further in setting out the objectives for traffic management and could indicate in general terms where bus priority measures are likely to be needed, I accept that the Local Plan is not the right place to get into the details and particulars of every bus priority measure.

10.Objector 292 is concerned that bus stops should be kept free for buses and that shared bus and taxi stops should be discontinued. Again, whilst I accept that this is important it does not seem to me that it is a Local Plan matter.

11.Accordingly I conclude that no modification to the Local Plan arises from these particular detailed objections.

Alternative Tram Route in the Town Centre (Objector 092)

12.The alternative tram route suggested by this Objector generally follows streets in the town centre and would include some overhead (or elevated) sections of track. The Council says that on the basis of its consultations it prefers another route and that to elevate the route would be prohibitively expensive. This certainly seems to me to be the case, and elevating a tramway in town centre


streets would also present some environmental problems. For these two reasons I accept that the route proposed by this objector is not feasible.

13. I conclude that the tram route proposed in objection 092/2 should not be included in the Local Plan.

Tram Link to St Annes and Lytham (Objector 033, 126)

14.As far as objection 033/1 to the First Deposit from Fylde Borough Council is concerned, they seem satisfied with the re-wording that was introduced in the Second Deposit. I conclude that no (further) change arises from this objection.

15.However, objection 126/4 raises more fundamental issues about the desirability of including any such proposal in the Local Plan.

16. I note that the proposal in the Local Plan is not specifically included in either the Structure Plan or the Local Transport Plan (LTP). This raises doubts as to whether it should be included in the Local Plan at all. These doubts are reinforced by the way the Council responds to the objection because it talks in terms of hopes and aspirations rather than firm plans and known alignments. However, both PPG12 (paragraph 5.23) and PPG13 (paragraph 74) give some latitude in respect of including new rail links and proposals in Local Plans if little blight would be created.

17.Objector 126 wants a direct (heavy) rail link to be created to Blackpool North Station along the central corridor. The Council says this is not feasible and I see no prospect of it happening. This being the case, the only way of establishing any sort of rail link from the south to Blackpool North Station would be by extending the tram network at each end to provide a link from the Fylde coast rail line and Blackpool North. This must surely be desirable in principle and the Council says it would be in accord with the policies in the LTP and Structure Plan even if there is no proposal to achieve it in these plans. It would also be desirable to provide a tram link to the airport and improve the interchange between heavy rail and trams. I therefore see some merit in this proposal being retained in the Local Plan. It does not appear to me that it is causing widespread blight.

18.However Objector 126 wants commitments to track-sharing between Blackpool and Lytham and to through-ticketing. In my view, even if these were both matters that should be included in the Local Plan, the proposals are not well enough advanced at this stage for such commitments to be given. Neither have the technical difficulties of light and heavy rail track-sharing been resolved.

19.Objector 126 also commented on map AS4 (B) PM1 in the Second Deposit. They appear to support this change to the Proposals Map. I conclude that no (further) modification arises.

20.Taking all these considerations into account, on balance, I conclude that the proposal contained in policy A4C (ii) should be retained in the Local Plan in its present (Second Deposit) form.

Rail Link to Poulton-le-Fylde (Objectors 159, 186)

21.At the moment the Local Plan policy – AS4 (c) (iii) – talks in terms of “examining the possibility of creating a new (tram) link between Blackpool and Fleetwood via Poulton and Thornton”. Wyre Borough Council wants this “firmed up” to a definite commitment and for a line to be shown on the Proposals Map. BBC says the proposed new link still has to be fully assessed in design and feasibility


terms. Moreover, in the absence of funds and government support for Phase 1 of the tramway it would be unwise to commit public funds to such preliminary work. The scheme also depends on establishing safety procedures and good design practice for track sharing by light and heavy rail. There is, as yet, no firm commitment to the scheme in any Local Transport, Structure or Regional Plan.

22.All of this indicates to me that it is premature for such a proposal to be included in the Local Plan in any shape or form. In any event, it does not seem to me that a commitment to “examine the possibility of creating” a new tram link amounts to a Local Plan policy. Wyre Borough Council must be aware of government guidance on the inclusion of transport proposals in Local Plans, so one wonders why they drew attention to this matter.

23.Objector 159 is concerned about the joint use of track by heavy and light rail on this corridor. In view of my conclusions immediately above this is not an issue I need to consider further.

24. I conclude that AS49 (C) (iii) should be deleted.

Countryside Agency (Objector 089)

25. It is not clear to me why this objection is conditionally withdrawn (as opposed to withdrawn completely). Be that as it may, I see no reason why the Local Plan would need to single out the needs of passengers from rural areas in connection with the design of interchanges. It does not seem to me that the needs of rural residents are any different from, say, suburban residents in this context. In any event the objector advances no evidence that they are different and gives no specific indication of how the Local Plan should be altered.

26. I conclude that no modifications arise from objection 089/20.

Recommendations27. I recommend that AS4 (c) (iii) is deleted from the Local Plan.28.Otherwise I recommend no modification to the Local Plan in response to

these objections.


9.6 Accessibility and Safe Journeys for All Policy AS6The Objections089/21 Countryside Agency, N W Division (Conditionally Withdrawn)

092/3 Mr D Galvin



244/ 5 / 6 Fylde Bird Club (Conditionally Withdrawn)

246/4 Mr Jeremy J Walker (Conditionally Withdrawn)

248/9 Blackpool Pleasure Beach


296/1 Susan R. Garlick (Conditionally Withdrawn)


331/2 Mr P Wright

350/1 J M Rawlinson

353/1 Derek Cracknell

357/1 Mrs Maxine Chew

359/1 M Brookes

Summary of the ObjectionsAll road schemes included in the Local Plan need to be clearly described and justified. (089)

Concern expressed about the inclusion of the Fylde Coast Easterly Bypass in the First Deposit. (089, 145, 246, 296, 326)

Concern expressed about the deletion of the Fylde Coast Easterly Bypass in the Second Deposit. (186, 331, 350, 353, 359)

Concern expressed about the Moor Park / Norcross Link Road because of its environmental impact. There should be a low speed limit and tunnels for animals to protect wildlife. (244)

Concern expressed about deletion of the Moor Park / Norcross Link Road in the Second Deposit. (357)

Major road works are suggested to create a town centre bypass in the longer term. (092)

There should be no major road schemes in the Local Plan. (145)

There should be a roundabout and proposed road from Yeadon Way at Yeadon Way Inn, under Lytham Road Bridge and along the embankment/cutting to Bond Street at (north of) Burlington Halt. (248)

Inspector’s Reasoning and Conclusions 1. The main areas of contention and objection relate to the (now abandoned)

Norcross-M55 Link Road and the Fylde Coast Easterly Bypass (also now deleted from the Structure Plan). Although there is a reference in the Structure Plan to the Norcross to M55 corridor, there is no scheme or alignment.

2. In general, those opposing a bypass scheme objected to the First Deposit and those supporting such a scheme have objected to the Second Deposit.

3. In the absence of any firm scheme or commitment, I take the view that PPG12 (paragraph 5.17) indicates that nothing should be included in the Local Plan that could give rise to blight.

4. Objector 353 has written to say that he and his wife are experiencing difficulty selling their house and they attribute this to the heavy traffic on existing roads. Whatever the truth of this, there is no point in the Local Plan retaining the bypass until it is clear that the Highway Authorities are going to build it.

5. I conclude that, in the absence of a firm and programmed scheme, all reference to pursuing schemes in the Norcross-M55 corridor should be deleted from the Local Plan. This would mean that all of part (A) of policy A6 should be deleted, together with the first word (“other”) of part (B) of the policy.

6. I note that Objector 092 has some suggestions for road schemes in the town centre but without further investigation and justification I cannot recommend that these should be included in the Local Plan.

7. I consider that my conclusions above are also an adequate response to objections 089/2 and 145/25.


8. As far as Blackpool Pleasure Beach are concerned, whilst I appreciate their wish to improve direct road links to their site, as long as there is no such scheme included in either the Structure Plan or the Local Transport Plan, it should not appear in the Local Plan.

Recommendations9. I recommend that all of part (A) of policy A6 is deleted, together with the

first word (“other”) of part (B) of the policy. 10.Otherwise, I recommend no modification to the Local Plan in response to

these objections.

Officers Recommendation The Inspector’s recommendation (9) is accepted that all of part (A) of policy A6

is deleted, together with the first word (“other”) of part (B) of the policy.


9.7 Accessibility and Safe Journeys for All Paragraph 9.24The Objections089/22 Countryside Agency, N W Division (Conditionally Withdrawn)

109/16 English Nature (Cheshire to Lancashire Team)

(Objection met in Second Deposit)

109/21 English Nature (Cheshire to Lancashire Team)

(Objection Conditionally Withdrawn in view of PC82)

188/20 Wildlife Trust (Lancashire, Manchester & North Merseyside)

Summary of the ObjectionsAll alternative options to the creation of the Fylde Coast Easterly Bypass eg improved public transport, traffic calming and traffic management options should be thoroughly investigated before proceeding with a new road. (089)

Amend last sentence of paragraph 9.24 as follows: "The Council is likely to require an Environmental Impact Assessment to ensure that the preferred route is environmentally acceptable. A comprehensive package of environmental measures will be an integral part of the scheme, in particular to minimise any impact on Marton Mere SSSI (see Policy NE7)." (109)

Recommend the supporting text is amended so as to ensure that the most environmentally acceptable solutions to traffic issues are considered within the Route Management Strategy. (109)

Insert a cross reference to Policies NE7, NE8 and NE9 in the paragraph. (188)

Proposed ChangesPC82 would add a sentence to paragraph 9.24c talking about the most environmentally acceptable solutions being used.

PC112 suggests amended wording for paragraphs 9.24b and 9.24c.

Objections to the Proposed Changes308/4 Highways Agency

Summary of the ObjectionThis paragraph relates to a joint study being commissioned by LCC, BBC and others and not to the Highways Agency Route Management Study, which does not look at specific schemes. “The Highways


Agency does not, as part of the government’s investment criteria for (the) environment, aim to protect and enhance the built and natural environment. These are considered as part of the RMS procedures.” The suggested wording should be amended or moved. (308)

Inspector’s Reasoning and Conclusions 1. I note that English Nature conditionally withdrew their outstanding objection in

the light of PC82 and PC112 but that the Highways Agency has made a counter objection.

2. Objections and counter objections have been made to paragraph 9.24 as it evolved. It would seem the proposed changes were managing to satisfy English Nature at the expense of provoking the Highways Agency. However, if the Highways Agency is right, the text as currently proposed is factually misleading. I certainly found it hard to follow.

3. Be that as it may, the conclusion I draw is that it is unnecessary for the Local Plan to be drawn into these matters at all. None of what is now in paragraphs 9.24 (a) (b) and (c) relates to a firm scheme or proposal that is contained in the Local Plan, Structure Plan or Local Transport Plan. Neither are these matters the direct responsibility of the Local Planning Authority. No harm would result if the Local Plan did not contain this material and no proposals would be set back or lost as a result of deleting it. Neither would nature conservation suffer. Until the various studies are completed there will be no proposals and no implications for land uses in the area.

4. I conclude that paragraphs 9.24 (a) (b) and (c) should be deleted from the Local Plan in their entirety along with the first word in paragraph 9.26, which would then start with the word “Major”. It follows that PC82 and PC112 should not be progressed.

Recommendations5. I recommend that paragraphs 9.24 (a) (b) and (c) are deleted from the

Local Plan. 6. I further recommend that the first word in paragraph 9.26 should be

deleted so that paragraph would start with the word “Major”. 7. I recommend that PC82 and PC112 are not progressed.

Officers Comments

Whilst fully accepting the Inspector’s recommendation that part (A) of Policy AS6 is deleted, the deletion of the whole of paragraphs 9.24 (a), (b), and (c) as recommended is not supported. The longstanding nature of the earlier firm proposal for the Fylde Coast easterly Bypass and the continuing need to address the problems of the north-south distribution of traffic from the M55 terminus means it is considered desirable that the Local Plan should continue to provide some information as to how this problem is being addressed.

It is therefore considered a reduced and updated version of the supporting text should be retained within the Plan, deleting all references in paragraphs 9.24 (b) and (c) to the more detailed content of the Highway Agency’s Route Management Strategy, but continuing to


inform that the Bypass is no longer included in the Plan and that alternative improvements are being progressed. .

Officers Recommendations The Inspector’s recommendation (5) that paragraphs 9.24 (a), (b), and (c) are

deleted from the Local Plan is not accepted, but reflecting the Inspector’s conclusion that there is no need to set out this level of detail, the following alternative reduced and updated wording is recommended:

Retain paragraph 9.24(a):A longstanding proposal for a Fylde Coast Easterly Bypass was designed to solve two problems; to relieve local villages in Fylde and Wyre and to reduce congestion and provide increased capacity along the A585 and the key north south routes in Blackpool. The Bypass proposal is no longer included in the Plan and alternative solutions need to be sought to the growth of north-south traffic movements in the Norcross M55 Corridor.

Amended paragraphs 9.24 (b) and 9.24(c):The Highways Agency is currently preparing a Route Management Strategy for the A585 that will identify identifies relatively small-scale improvements which will ease traffic flows along this route. This 10 year management plan will make the best use of the route by improving safety, accessibility and transport integration. The Rotue Management Strategy will also ensure that the most environmentally acceptable solutions to traffic issues are considered, promoting biodiversity and conservation and minimising any adverse impact on townscape and landscape quality.

Blackpool Council Lancashire County Council, in consultation with Blackpool and other affected local authorities, will evaluate improvements to principal roads in the Fylde Coast sub-region, taking into account the proposed Fylde Coast Light Rapid Transit scheme and other proposals to accommodate traffic associated with the regeneration of Blackpool and Fleetwood. This study could include assessment of is assessing on-line improvements to the main easterly north south road corridor, traffic management measures on other routes, tramway extension options and town centre distributor road proposals. The study will be conducted in accordance with government guidance on Multi-Modal Studies. Support for this study and for any major improvements arising from it, will be pursued through the Regional Transport Strategy.

The Inspector’s recommendation (6) that the first word in paragraph 9.26 should be deleted so that paragraph would start with the word “Major” is accepted.

Recommendation (7) is accepted

9.8 Accessibility and Safe Journeys for All Policy AS7The Objection194/74 Government Office for the North West (Conditionally Withdrawn)

Summary of the Objection


The word 'aeronautical' in the title, policy and Proposals Map should be changed to 'aerodrome', in line with ODPM Circular 1/2003 (194) (Conditionally Withdrawn after PC83 and PC84)

Proposed ChangesPC83: delete “aeronautical”, substitute “aerodrome” in policy AS7.

PC84: similarly delete “aeronautical”, substitute “aerodrome” on Proposals Map.

Inspector’s Reasoning and Conclusions 1. This objection was conditionally withdrawn as a result of PC83 and PC84. I

conclude that these should be advertised as modifications to the Local Plan.

Recommendation2. I recommend that PC83 and PC84 are advertised as modifications to the

Local Plan.Officers Recommendation

The Inspector’s recommendation that PC83 and PC84 are advertised as proposed modifications to the Local Plan is accepted:

PC 83 Policy AS7 amended as follows:

AS7 Aeronautical Aerodrome safeguarding

Blackpool Airport will be consulted where appropriate, on proposed development within the Borough. The Airport will be consulted on all developments within the aeronautical aerodrome safeguarding area shown on the Proposals Map

PC84 Amend map description to read as follows:

Aeronautical Aerodrome Safeguarding Area’


10.1 Planning Obligations Policy PO1The Objections254/7 The Gables Balmoral Hotel (Blackpool) Limited


349/3 D E Warder

Summary of the ObjectionsReferences to the purposes of planning obligations should be limited to the provision and improvement of infrastructure and any damaging impacts of development on the environment. Delete "services and amenities" from line 1 of the policy; “services and community facilities in part (a) of the policy and "or local amenity" from part (b). (254)

The policy should be limited to infrastructure and mitigating the damaging impacts on the environment. Therefore, remove the reference to services, amenities, local amenity and community facilities" (295)

Unless investigations and measures are undertaken to alleviate existing flooding problems, no more houses should be built in the parts of the Borough that are affected. (349)

Inspector’s Reasoning and Conclusions Objectors 254 and 295

1. These objectors take a very narrow view of what may legitimately be dealt with in planning obligations. However in my experience obligations can encompass education facilities, affordable housing, playing fields, public open space, fire services, library services, village halls, communal buildings and all the other matters listed in paragraph 10.5. It may just be semantics but I consider these matters are better described as “services, amenities and community facilities” than simply as “infrastructure”. However, the key test is how well the provisions of a S106 relate to the development in question not how the matters covered by an obligation are described.


Objector 349

3. As far as Mr Warder is concerned, I deal with his concerns in greater detail under policy NE13. He is anxious that more attention is paid – especially by United Utilities – to existing flooding problems in certain areas, particularly in the north of the Borough. However, he accepts there is no specific modification to policy PO1 that would achieve what he wants. In any event, in my view, planning obligations can only properly be used to deal with problems that arise from new development and not to rectify existing deficiencies or problems.


Recommendation5. I recommend no modification to policy PO1 in the Local Plan.

Officers RecommendationThe Inspector’s Recommendation is accepted

329Planning Obligations Chapter 10

10.2 Planning Obligations Paragraph 10.4The Objection109/17 English Nature (Cheshire to Lancashire Team) (Conditionally Withdrawn)

Summary of the ObjectionAmend paragraph 10.4 to read "required to mitigate impacts or compensate for the consequential costs of development". (First Deposit) (109)

Inspector’s Reasoning and Conclusions1. The suggested wording change was made in the Second Deposit. As a result

the objection was conditionally withdrawn. I conclude that no further action is needed from me.


objection.

Officers Recommendation The Inspectors recommendation is accepted.

330Planning Obligations Chapter 10

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