Draft Plan Strategy Public Consultation Report - March 2021

Local Development Plan 2030

Draft Plan Strategy Public Consultation Report

March 2021 1

www.midandeastantrim.gov.uk/planning

DPS-142

Contents Chapter 1 Introduction ........................................................................................... 1

SGS5 Management of Housing Supply ................................................................. 62

Background .............................................................................................................. 1

Miscellaneous comments on Strategic Housing Allocation Strategy ..................... 69

What is the Local Development Plan? ..................................................................... 1

5.4 Economic Development Strategy ................................................................. 71

Draft Plan Strategy Public Consultation Report ....................................................... 2

SGS6 Strategic Allocation of Land for Economic Development ............................ 71

Chapter 2 Consultation .......................................................................................... 4

5.5 Retail Strategy ................................................................................................ 74

Engagement process ............................................................................................... 5

SGS7 Retail Hierarchy ........................................................................................... 74

Consultation process ................................................................................................ 6

5.6 Tourism Strategy ............................................................................................ 76

Communication ........................................................................................................ 7

SGS8 Tourism Strategy ......................................................................................... 76

Communication channels ......................................................................................... 8

5.7 Transport Strategy ......................................................................................... 78

Chapter 3 Representations to the LDP Draft Plan Strategy ............................. 11

5.8 Open Space Strategy ..................................................................................... 80

Approach to analysis of responses ........................................................................ 12

SGS9 Open Space Strategy .................................................................................. 80

Summary of responses received............................................................................ 14

5.9 Countryside Strategy ..................................................................................... 82

Soundness Tests – Analysis .................................................................................. 14

CS1 Sustainable Development in the Countryside ................................................ 82

Summary of main issues raised ............................................................................. 15

CS2 Special Countryside Areas ............................................................................. 83

Equality Monitoring ................................................................................................. 26

CS3 Areas of Constraint on High Structures.......................................................... 89

Chapter 4 Council’s response to main issues raised ...................................... 27

CS4 Rural Landscape Wedges .............................................................................. 96

1.0 Introduction .................................................................................................... 28

CS5 Antrim Coast and Glens Area of Outstanding Natural Beauty ....................... 96

2.0 Setting the Context ........................................................................................ 32

CS6 Developed Coast (Belfast Lough Shore)...................................................... 100

3.0 District Profile ................................................................................................. 34

CS7 Local Landscape Policy Areas ..................................................................... 101

4.1 Vision............................................................................................................... 36

CS8 Protection of Main River Corridors ............................................................... 102

4.2 Strategic Objectives ....................................................................................... 37

CS9 Development at Risk from Land Instability or Coastal Erosion .................... 103

5.1 SGS1 Spatial Growth Strategy ...................................................................... 41

Miscellaneous comments on the Countryside Strategy ....................................... 104

5.2 Settlement Hierarchy ..................................................................................... 44

6.0 General Policy for all Development ............................................................ 107

SGS2 Settlement Hierarchy ................................................................................... 44

Policy GP1 General Policy for all Development ................................................... 107

5.3 Strategic Housing Allocation Strategy ........................................................ 47

7.1 Economic Development .............................................................................. 112

SGS3 Strategic Allocation of Housing to Settlements ........................................... 47

Policy ECD1 Economic Development in Settlements .......................................... 112

SGS4 Protection of Zoned Housing Land .............................................................. 61

Policy ECD2 Retention of Economic Development Land .................................... 113

Policy ECD3 Development incompatible with Economic Development Uses ..... 114 Policy ECD4 Economic Development in the Countryside .................................... 115 Economic Development – Suggested New Policy ............................................... 117 7.2 Retailing and Town Centres ........................................................................ 118 Introduction........................................................................................................... 118 Policy RET1 Retail in Town Centres .................................................................... 120 Policy RET2 Retail Impact Assessment ............................................................... 121 Policy RET3 Retail in Villages, Small Settlements and Local Centres ................ 122 Policy RET4 Rural Shops and Roadside Service Facilities ................................. 122

Policy MIN6 Minerals Development – Development at Risk of Subsidence due to past or present underground mineral extraction .................................................. 142 Policy MIN7 Minerals Development – Peat Extraction ......................................... 143 Policy MIN8 Minerals Development – Restoration and Management of Mineral Sites .............................................................................................................................. 145 Minerals Development – Suggested New Policy ................................................. 147 Miscellaneous comments on Minerals Development ........................................... 149 8.1 Housing ......................................................................................................... 151 Policy HOU1 Quality in New Residential Development in Settlements ............... 151

7.3 Tourism ......................................................................................................... 123

Policy HOU2 The Conversion or Change of Use of Existing Buildings to Flats or Apartments ........................................................................................................... 154

Policy TOU1 Safeguarding of Tourism Assets..................................................... 123

Policy HOU3 Residential Extensions and Alterations .......................................... 154

Policy TOU2 Tourism Development in Settlements and Tourism Opportunity Zones ............................................................................................................................. 124

Policy HOU4 Protected Town Centre Housing Areas .......................................... 155

Policy TOU3 All Tourism Development in the Countryside ................................. 125 Policy TOU4 Tourist Amenities in the Countryside .............................................. 126 Policy TOU5 Hotels, Guest Houses and Tourist Hostels in the Countryside ...... 127 Policy TOU6 Self Catering Accommodation in the Countryside .......................... 128 Policy TOU7 New and Extended Holiday Parks in the Countryside .................... 128 Policy TOU8 Major Tourism Development in the Countryside – Exceptional Circumstances...................................................................................................... 129 Miscellaneous comments on Tourism .................................................................. 129 7.4 Minerals Development ................................................................................. 130

Policy HOU5 Affordable Housing in Settlements ................................................. 156 Policy HOU6 Housing Mix (Unit Types and Sizes) .............................................. 160 Policy HOU7 Adaptable and Accessible Homes .................................................. 162 Policy HOU8 Travellers Accommodation ............................................................. 164 Policy HOU9 Replacement Dwelling .................................................................... 165 Policy HOU10 Dwelling on a Farm Business ....................................................... 166 Policy HOU11 Dwelling for Non-Agricultural Business Enterprise ....................... 166 Policy HOU12 New Dwelling in Existing Clusters ................................................ 166 Policy HOU13 Ribbon/Infill Development............................................................. 167

Introduction........................................................................................................... 130

Policy HOU14 Personal and Domestic Circumstances ....................................... 167

Policy MIN1 Minerals Development – Extraction and Processing of Hard Rock and Aggregates ........................................................................................................... 133

Policy HOU16 Affordable Housing in the Countryside ......................................... 168

Policy HOU15 Residential Caravans and Mobile Homes .................................... 167

Policy MIN2 Minerals Development – Valuable Minerals .................................... 135

Suggested new policy for supported/specialist housing accommodation ............ 169

Policy MIN3 Minerals Development – Hydrocarbons........................................... 136

8.2 Open Space, Sport and Leisure .................................................................. 170

Policy MIN4 Minerals Development – Areas of Constraint on Mineral Development ............................................................................................................................. 137

Policy OSL1 Protection of Open Space ............................................................... 170

Policy MIN5 Minerals Development – Area of Salt Reserve, Carrickfergus ........ 140

Policy OSL3 New Open Space Provision ............................................................ 173

Policy OSL2 Greenways ...................................................................................... 171

Policy OSL4 Public Open Space in New Residential Development .................... 174

9.5 Water and Wastewater Infrastructure ........................................................ 209

Policy OSL5 Sport and Outdoor Recreation Facilities ......................................... 177

Policy WWI1 Development Relying on Non-Mains Wastewater Infrastructure.... 209

Policy OSL6 Community Growing Spaces and Allotments .................................. 178

9.6 Waste Management ...................................................................................... 210

Policy OSL7 Cemeteries and Burial Space ......................................................... 179

Policy WMT1 Environmental Impact of a Waste Management Facility ............... 210

Miscellaneous comments on Open Space, Sport and Leisure ............................ 180

Policy WMT2 Waste Collection and Treatment Facilities .................................... 211

8.3 Health, Education, Community and Cultural Facilities ............................ 181

Policy WMT3 Waste Disposal Sites ..................................................................... 212

Policy COM1 Education, Health, Community and Cultural Facilities ................... 181

Policy WMT4 Development in the vicinity of a Waste Management Facility ....... 213

9.1 Transportation .............................................................................................. 183

Policy WMT5 Land Improvement ......................................................................... 214

Policy TR1 Access to Public Roads ..................................................................... 183

Miscellaneous comments on Waste Management .............................................. 214

Policy TR2 Access to Protected Routes .............................................................. 184

10.1 Historic Environment ................................................................................. 216

Policy TR3 New Transport Schemes ................................................................... 185

Policy HE1 Archaeological Remains and their Settings ....................................... 216

Policy TR4 Disused Transport Routes ................................................................. 186

Policy HE2 Historic Parks, Gardens and Demesnes ........................................... 218

Policy TR5 Active Travel ...................................................................................... 187

Policy HE3 Listed Buildings – Change of Use or Extension/Alteration or Conversion of a Listed Building ............................................................................................... 219

Policy TR6 Parking and Servicing ........................................................................ 188 Policy TR7 Provision of Car Parks ....................................................................... 191 9.2 Flood Risk and Drainage ............................................................................. 192 Policy FRD1 Development within Floodplains ..................................................... 192 Policy FRD2 Protection of Flood Defence and Drainage Infrastructure .............. 192

Policy HE4 Listed Buildings - Demolition of a Listed Building.............................. 220 Policy HE5 Development affecting the Setting of a Listed Building ..................... 221 Policy HE6 Conservation Areas ........................................................................... 222 Policy HE7 Areas of Townscape Character ......................................................... 223

Policy FRD3 Management of Development in regard to Surface Water Flood Risk ............................................................................................................................. 193

Policy HE8 Non-listed Locally Important Building or Vernacular Building ........... 224

Policy FRD4 Sustainable Drainage (SuDS) ......................................................... 194

Miscellaneous comments on Historic Environment ............................................. 226

Policy FRD5 Artificial Modification of Watercourses ............................................ 196

10.2 Advertisements .......................................................................................... 227

Policy FRD6 Development in Proximity to Controlled Reservoirs ....................... 197

Policy AD1 The Control of Advertisements .......................................................... 227

9.3 Renewable Energy ....................................................................................... 198

10.3 Place-Making .............................................................................................. 229

Policy RE1 Renewable Energy Development ...................................................... 198

Policy SFA1 Strategic Focus Areas ..................................................................... 229

9.4 Telecommunications and Overhead Cables ............................................. 205

11.1 Natural Heritage.......................................................................................... 231

Policy TOC1 Telecommunications Development and Overhead Cables ............ 205

Policy NAT1 European and Ramsar Sites – International ................................... 231

Telecommunications and Overhead Cables – Suggested New Policies ............. 208

Policy NAT2 Species Protected by Law ............................................................... 232

Miscellaneous comments on Telecommunications and Overhead Cables ......... 208

Policy NAT3 Sites of Nature Conservation Importance – National ...................... 233

Policy HE9 Enabling Development for the Conservation of Heritage Assets ...... 225

Policy NAT4 Sites of Nature Conservation Importance - Local ........................... 234 Policy NAT5 Habitats, Species or Features of Natural Heritage Importance ...... 235 Natural Heritage - Suggested New Policy............................................................ 236 Miscellaneous comments on Natural Heritage .................................................... 237 Miscellaneous comments on the draft Plan Strategy .................................... 240 Technical Supplement 1: Monitor and Review................................................ 244 Chapter 5 Draft Habitats Regulations Assessment ........................................ 248 Chapter 6 Sustainability Appraisal of the draft Plan Strategy (incorporating Strategic Environmental Assessment) ............................................................ 250 Chapter 7 Draft Plan Strategy Counter Representations ............................... 266 The counter-representation process .................................................................... 267 Summary of responses received.......................................................................... 267 Summary of key issues raised ............................................................................. 268 Appendices ......................................................................................................... 270 Appendix 1 - Respondents to the Draft Plan Strategy ......................................... 271 Appendix 2 - Draft Plan Strategy Events ............................................................. 274 Appendix 3 - Documents available during consultation period ............................ 275 Appendix 4 - Equality Monitoring of Attendees at Consultation Events ............... 276

Chapter 1 Introduction

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Chapter 1 Introduction

1.4

The council is committed to engaging with local communities and other stakeholders and has sought to encourage inclusive discussions on the LDP and key planning policies that will guide future development within the Borough. Public consultation was therefore an essential part of the plan making process.

1.5

This report summarises the participation process that has been undertaken in relation to the draft Plan Strategy in accordance with the Statement of Community Involvement (SCI) and the Planning (Local Development Plan) Regulations (NI) 2015. It provides a summary of the key issues raised through the consultation process and an indication of the Council’s view in relation to them. This report, alongside a full copy of the representations submitted as part of the consultation, will form a key part of the assessment of the soundness of the draft Plan Strategy when it is submitted to DfI in preparation for the independent examination.

Background 1.1

The main purpose of the Local Development Plan (LDP) is to inform the general public, statutory authorities, service providers, developers and other interested parties of the policy framework and land use proposals that will implement the strategic objectives of the Regional Development Strategy (RDS) 2035 and the LDP objectives and guide decisions on planning applications for development in Mid and East Antrim until 2030.

1.2

The LDP is being prepared under the provisions of the Planning Act (Northern Ireland) 2011 and the Planning (Local Development Plan) Regulations (NI) 2015. The Planning Act (Northern Ireland) 2011 requires the LDP to be produced in two stages – the first being the Plan Strategy (PS), followed upon adoption, by the Local Policies Plan (LPP). In regard to the PS, the Planning Act (Northern Ireland) 2011 sets out the following requirements:   

1.3

The Council’s objectives in relation to the development and use of land in the District; Its strategic policies for the implementation of those objectives; and Such other matters as may be described.

To discharge this legislative duty, Mid and East Antrim Borough Council have prepared the draft Plan Strategy document for the period 2015-2030.

The draft Plan Strategy has been prepared taking account of the RDS, other policies and guidance issued by the Department for Infrastructure (DfI), and other relevant regional and local plans and strategies. The draft Plan Strategy is guided by an overall vision, which sets out that Mid and East Antrim will be shaped by high quality, sustainable and connected places for people to live, work, enjoy, invest and visit, so as to improve the quality of life for all.

What is the Local Development Plan?

1.6

The LDP will outline the Council’s local policies and site-specific proposals for new development and the use of land within Mid and East Antrim. Once complete, it will comprise of two development plan documents: 1.

Plan Strategy (PS) – The strategic policy framework for Mid and East Antrim across a range of topics. It will set out an ambitious but realistic vision that seeks to improve the quality of life for everyone, putting special emphasis on the particular place making role of the LDP that contribute to good place making.

Establishing this strategic direction early in the plan process will provide a level of certainty on which to base key development decisions in the area as well as the necessary framework for the preparation of the LPP.

2.

Local Policies Plan (LPP) – The council’s local policies and site specific proposals in relation to the development and use of land in Mid and East Antrim. It will contain site specific proposals, designations and land use zonings required to achieve the council’s vision, strategic objectives, strategies and strategic policies, as set out in the PS. 1

1.7

The LDP will aim to provide sufficient land to meet anticipated needs for housing, employment, and services; all supported by adequate infrastructure, over the Plan period. It will also seek to ensure that all new development is of high quality and located in suitable places – which themselves should be enhanced by the development.

(SEA Directive) which is to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with the view to promoting sustainable development. The SEA Directive was transposed into Northern Ireland legislation through the Assessment of Plans and Programmes Regulations (NI) 2004, which requires plans to be subjected to, and informed by a Strategic Environmental Assessment.

Draft Plan Strategy Public Consultation Report 1.12 1.8

This public consultation report details the engagement process undertaken in preparing and consulting on the draft Plan Strategy. It outlines the results of this process, including a summary of the key issues raised through representations in relation to each policy. It provides an indication of the Council’s consideration of these issues and will form a key part of the evidence to be considered as part of the preparation for the independent examination. The representations and counter-representations received are publicly available and can be read alongside this report.

Additional Assessments 1.9

1.10

1.11

Habitats Regulations Assessment 1.13

The draft Plan Strategy has been subject to a number of assessments and appraisals that are referred to in the summary below. Each of these is contained within a separate supporting document accompanying the draft Plan Strategy.

Sustainability Assessment

Appraisal

incorporating

Strategic

SA can be distinguished from SEA by virtue of its wider scope as it covers the social and economic effects of plans, as well as the more environmental implications. Whilst the requirement to carry out both assessments are distinct, it is possible to address both through a combined appraisal process, i.e. SA incorporating SEA. The Sustainability Appraisal that accompanies the draft Plan Strategy incorporates both these aspects and explains the rationale for the approach taken.

A further requirement placed upon Council, as the responsible planning authority, is to undertake a Habitats Regulations Assessment (HRA) in accordance with Article 6 (3) of the Habitats Directive in regard to the conservation of natural habitats and of wild flora and fauna. The HRA concerns Natura 2000 sites, the collective term for the protection and management of European sites and their habitats and species. These sites often cover extensive areas in Mid and East Antrim and consist of:

Environmental

The Planning Act (Northern Ireland) 2011 places a duty on Council in exercising its LDP function, to do so, with the objective of furthering sustainable development. It also requires a Sustainability Appraisal (SA) to be carried out for the Plan Strategy and for the LPP in order to promote sustainable development through the integration of social, economic and environmental considerations into the preparation process.

The SA also incorporates Strategic Environmental Assessment (SEA) in order to comply with the objective of the European Directive 2001/42/EC

  

1.14

Special Protected Areas (SPAs) – designated as sites important for birds.

Special Areas of Conservation (SACs) – designated to protect important habitats and species.

Ramsar sites – designated to protect wetlands of international importance.

The HRA is carried out so as to identify and assess whether the LDP policies and proposals, either individually or in combination, are likely to significantly affect a European Site.

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Rural Proofing 1.15

The Rural Needs Act (NI) 2016 places a duty on public authorities to have regard to rural needs in developing, adopting, implementing, or revising policies, strategies and plans. It is therefore incumbent upon Council to carefully consider the impact of the LDP policies and proposals upon the needs of rural dwellers and communities. A Rural Needs Impact Assessment, which incorporates the principles of rural proofing, accompanies the draft Plan Strategy.

Equality (Section 75) Screening Report 1.16

Section 75 of the Northern Ireland Act 1998, requires public authorities to carry out their functions with due regard to the need to promote equality of opportunity between:    

1.17

persons of different religious belief, political opinion, racial group, age, marital status, and sexual orientation; men and women generally; persons with a disability and persons without; and persons with dependant and persons without.

The Act also requires promotion of good relations between persons of different religious belief, political opinion and racial group. The draft Plan Strategy is accompanied by a draft Equality (Section 75) Screening Report examining the likely effects of its policies and proposals on the promotion of equality of opportunity amongst the listed groups.

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Chapter 2 Consultation

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Chapter 2 Consultation Project Management Team

Engagement process 2.1

The Planning (Local Development Plan) Regulations (Northern Ireland) 2015 state that the Council must provide an opportunity for all stakeholders, including the public, to participate and have their say in where and how development within their local area should take place. The following sets out the various oversight groups involved with assisting with the formulation of policies in the draft Plan Strategy and the public consultation that took place after the launch of the draft Plan Strategy.

2.4

In accordance with our SCI, the Council set up a Project Management Team (PMT) comprising of senior Council officers and representatives from key statutory consultees including government departments and agencies.

2.5

The purpose of the PMT was to ensure that key consultees engaged in the Plan making process and particularly in the development of the emerging policies and proposals. A series of nine meetings chaired by the LDP Principal Planning Officer were convened at regular intervals leading up to the publication of the draft Plan Strategy. The meetings related to the following thematic areas:

Local Development Plan Steering Group  2.2

In accordance with our Statement of Community Involvement the Council set up a Local Development Plan Steering Group (also known as the LDP Working Group) comprising the Planning Committee, the Chief Executive, Director of Development, Director of Operations, Head of Community Planning, Head of Planning, Development Plan Principal and Council Solicitor. This high-level coordinating body ensured oversight and strategic input on behalf of the whole community, as well as from planning professionals. The first meeting took place in August of 2016 and there have been seven meetings to date.

       

Spatial Growth Strategy, Settlement Hierarchy and Housing Allocation LDP Vision, Objectives and Principles Open Space Waste Management and Flood Risk Natural Environment Economic, Retail and Telecommunications Housing Policies and Historic Environment Policies Tourism and Transportation Countryside, Coast, Minerals and Renewable Energy

Elected Members Workshops

Metropolitan Area Spatial Working Group (MASWG)

2.3

2.6

A series of six workshops were held for all Elected Members over a fivemonth period to help inform, shape and agree the strategic policies and proposals that make up the draft Plan Strategy. Further to the workshops, a summary and overview report was presented to the full Council inviting any final comments from Elected Members on the emerging strategic policies and proposals.

Mid and East Antrim were also represented by planning officers and elected members on the Metropolitan Area Spatial Working Group. This provided a forum for Belfast City Council and surrounding councils within the wider Belfast metropolitan area to discuss cross-boundary issues alongside the development of the Local Development Plan.

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up and includes representatives from the LDP teams of coastal councils, including Mid and East Antrim, and representatives from DfI, DAERA, Department of Economy (DfE) and the National Trust.

Lough Neagh Forum 2.7

Mid and East Antrim along with Mid Ulster District Council, Antrim and Newtownabbey Borough Council, Lisburn and Castlereagh City Council and Armagh City, Banbridge and Craigavon Borough Council established the informal Lough Neagh Forum as a means of demonstrating a constructive and sound approach to policy formulation on cross-boundary issues centring on Lough Neagh. The first meeting of the forum took place on 27 April 2017.

Cross-boundary topics raised included, environmental designations, minerals development, renewables, flooding and tourism and greenways.

Minerals Working Group 2.11

Antrim Coast and Glens AONB Management Group 2.8

Mid and East Antrim were also represented on this Steering Group which focused on achieving synergy on the development of policies, practices, partnerships and projects within and around the AONB that promote, protect and enhance the Antrim Coast and Glens AONB status.

The Coastal Forum, Coastal Forum Working Group and Coastal Planning Working Group

Meetings with Adjoining Councils 2.12

2.9

The Coastal Forum is the mechanism through which coastal management issues are being considered and progressed collaboratively by central and local government and the National Trust. Mid and East Borough Council is a member of this forum which seeks to provide strategic leadership of the future direction of coastal policy. The Coastal Forum Working Group supports the Coastal Forum and aims to develop advice, guidance and recommendations on coastal management issues. Mid and East Antrim is also represented on this group along with those other councils with a coastline and representatives from DfI, Department of Agriculture, Environment and Rural Affairs (DAERA) and the National Trust.

Discussion through the Coastal Forum has included considering coastal change risk and the implications for emerging LDPs arising from the current deficit of robust data in this area. To help identify and address issues around planning and coastal erosion, a Coastal Planning Working Group was set

A series of three meetings took place in July 2019 with planning officers from each of our adjoining councils (Mid Ulster District Council, Antrim and Newtownabbey Borough Council and Causeway Coast and Glens Borough Council). At these meetings the layout and thrust behind the policies in the Mid and East Antrim draft Plan Strategy was outlined and cross boundary issues were discussed.

Consultation process 2.13

2.10

The Minerals Working Group was formed in June 2018. Membership included representatives from DfE, DfI and councils including Mid and East Antrim. The purpose of the group was initially to consider the supply and demand for aggregates across each council and NI as a whole and agree baseline data and methodology for annual reporting. This includes engaging with industry to encourage improved completion of data in Annual Returns, allowing Councils to better understand extraction and movement of minerals throughout Northern Ireland and the evidence to determine whether shortfalls of supply are likely to occur. Cross-boundary topics which will also be considered include broader consideration of mineral development issues including potential for high value and industrial minerals, the Mineral Licencing Regime, increasing the use of secondary and recycled aggregates and waste from construction.

In line with our Statement of Community Involvement, the draft Plan Strategy and supporting evidence was made available four weeks in advance of the statutory eight-week consultation period. The draft Plan Strategy was published on the 17 September 2019, with the formal consultation period running from 16 October 2019 to 11 December 2019.

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2.14

2.15

During the consultation period the plan team held a series of events to promote consultation and encourage engagement with the draft Plan Strategy. A full breakdown of these events is contained in Appendix 2.

A copy of all representations received during the public consultation were published on 31 January 2020, with an opportunity to submit counter representations provided until 27 March 2020.



Draft Habitats Regulations Assessment (dHRA) of the draft Plan Strategy



Draft Equality (Section 75) Screening Report of the draft Plan Strategy



Rural Needs Impact Assessment of the draft Plan Strategy



Addendum to Position Paper 1 Population and Growth – September 2019



13 Technical Supplements: 1. Monitoring and Review

Communication

2. Settlement Hierarchy and Strategic Settlement Evaluation 3. Housing

Consultation materials

4. Open space, sport and leisure 5. Economic Development

2.16

The following materials were used to inform audiences in relation to the LDP and particularly the draft Plan Strategy and the soundness-based consultation process:

6. Retail 7. Tourism 8. Minerals Development



2.17

Local Development Plan 2030 Draft Plan accompanying District Proposal Maps 1, 2 and 3

Strategy

9. Transportation

and

10. Countryside Assessment



Local Development Plan 2030 Draft Plan Strategy ‘Have your say leaflet’

11. Health, Education, Community and Cultural Facilities



Consultation Response Form

13. Built Heritage



Promotional pop-ups



Community Involvement Form

A range of supporting studies, topic papers and technical supplements were also prepared and published alongside the draft Plan Strategy providing evidence to help justify the policies proposed within it. These documents included: 

Sustainability Appraisal (SA) incorporating Strategic Environmental Assessment (SEA)



Sustainability Appraisal of the draft Plan Strategy Scoping Report



Sustainability Appraisal (incorporating Strategic Environmental Assessment) Non-technical Summary

12. Public Utilities

Supporting studies included in technical supplement appendices included: 

Urban Capacity Study, March 2019



Industrial Land Monitor Report 2018



Availability and Supply Report, CBRE, October 2018



UUEPC Employment Space Demand Report 2018, Ulster University Economic Policy Centre, November 2018



Retail & Commercial Leisure Need & Capacity Study, Nexus Planning, January 2019



Draft Mid and East Antrim Local Transport Study, DfI, Version 4.0 Revised 16 October 2019

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Other Supporting studies:  2.18

2.21

Housing Monitor Report

This full range of consultation materials was made available to view and download online via Mid and East Antrim Borough Council’s website.

Appendix 3 sets out the consultation material available to inspect at Council’s planning office in County Hall, Ballymena and at other council offices across the Borough. Copies of the draft Plan Strategy were also provided to all libraries in the Borough.

Publications 2.22

Communication channels Newspaper advertising 2.19

2.20

In line with the requirements of Council’s Statement of Community Involvement a public notice confirming advance publication of the draft Plan Strategy was published in the week beginning the 9 September 2019 in the following newspapers: 

Belfast Gazette



Ballymena Times



The Larne Times1



Ballymena Guardian

Upon publication of the representations received to the draft Plan Strategy a further public notice confirming the availability of representations for inspection was issued from week commencing 20 January 2020 in the same newspapers as above.

Council publications were used to inform staff and residents throughout Mid and East Antrim of the publication of the draft Plan Strategy and the public consultation period. This included our residents’ magazine ‘Connections’, sent to households throughout the borough (Winter 2019 edition) and council’s staff Yammer site (on 24 Sept 2019).

Press releases 2.23

A second public notice confirming the publication of the draft Plan Strategy accompanying Sustainability Appraisal (incorporating the draft Environmental Report, Non-Technical Summary and Scoping Report), the draft Habitats Regulations Assessment, the draft Equality (Section 75) Screening Report and the Rural Needs Impact Assessment and other supporting documents from the week commencing 7 October 2019 in the same newspapers as above.

A number of press releases were circulated to media outlets alongside the publication of the draft Plan Strategy. The first issued on 5 September 2019 giving advance notice of when the draft Plan Strategy would be published, where copies would be available and where to obtain information in relation to upcoming public events. The second issued on 18 September highlighting that the draft Plan Strategy had been officially launched the day before. As part of a wider article about planning in the Borough another press release on 30 September also highlighted the draft Plan Strategy consultation dates. On 14 October a further press release advised that the formal public consultation would open on 16 October 2019 and on the 3 December the press release included a reminder that the deadline for submitting a response was approaching on 11 December. On 17 January 2020 a further press release advised when and where representations could be viewed and that there would be an opportunity for the submission of counter-representations. A range of articles were also published including: 

Ballymena Guardian website, 11 September 2019 – This article highlighted that Mid and East Antrim Council were preparing to launch

1

The Larne Times, Carrick Times and Newtownabbey Times have shared pages meaning that the Larne Times is used in all editions across this group of newspapers .

.

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  



  

its draft Plan Strategy and that members of the public would have four weeks to consider the document before being invited to take part in the consultation process and advised of the consultation period. It highlighted that a number of events were planned for the coming weeks for citizens to find out more about the process and to discuss any queries or questions they have.

‘Mid and East Antrim LDP makes Progress’, 13 September 2019, The Planner, RTPI; ‘Mid and East Antrim Planning Strategy Deadline’, 3 December 2019, The Planner, RTPI; ‘Citizens urged to have their say on the future of Mid and East Antrim by helping shape borough’s Local Development Plan’, 17 September 2019, Ballymena Daily website; ‘Plan aims to be ‘a roadmap to create a stronger borough with more employment and improved quality of life’, 18 September 2019, Ballymena Daily website; ‘Public urged to help shape Local Development Plan, 18 September 2019, Intouch Magazine; ‘Council opens consultation on Local Development Plan’, 14 October 2019, Ballymena Daily website; ‘Council opens consultation on Local Development Plan’ 14 October 2019, InTouch Magazine;



Mid and East Antrim Council website 2.24

The Mid and East Antrim LDP webpage contains digital copies of all the consultation materials associated with the draft Plan Strategy. During both the pre and formal consultation periods there were 3,755 unique page views to this webpage, with the draft Plan Strategy document viewed 13,292 times

Explainer videos 2.26

A promotional video was produced for the day of the launch to let people know about the LDP, draft Plan Strategy and about soundness tests, the basis on which representations will be considered at the independent examination and dates of the consultation period. This video was published on the Mid and East Antrim LDP webpage and was also shared online via Facebook, Twitter, Linkedin and Youtube. It was also played at the public meetings and meetings with stakeholders and staff. In addition, a video was also recorded on the day of the launch and this was also shared on Youtube.

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Social media 2.27

To complement the press releases, Social media tools were used to maximise the audience reach, primarily Facebook and Twitter. Posts on these platforms sought to notify people of the consultation details, advertised key events and included the promotional video. Analysis of social media data relating to these platforms shows a combined reach of 43,164 user accounts. In addition, to a lesser extent LinkedIn and YouTube were also used to post the promotional and launch videos.

Social Media Activity Social Media Platform

Activity

Reach *

Facebook

17 posts (including post

Combined reach of 29,039

relating to PAC IE event)

Generated 830 video views

9 tweets & 3 retweets

Combined reach of 14,125



Online Map viewer 2.25

Alongside our draft Plan Strategy, a digital online map viewer was made available to access on our ArcGIS webpage. The map viewer provides a portal to view designations that are of relevance to the draft Plan Strategy against a more detailed map base of the Borough.

Twitter

*The number of people who had the page's post enter their screen. Posts include statuses, photos, links, videos and more. (Unique Users)

9

Community Involvement Register 2.28

The Council has maintained a community involvement register since November 2015 for all individuals and groups who have an interest in being informed about the key stages of the LDP. The register is kept under review and is continually updated. Individuals and/or groups can request to be included on the register at any time by completing and submitting a community involvement form which is available on the Councils website, at the Council planning office or on request. The Council is proactive in encouraging individuals and groups to sign up to the register in response to any queries received about the LDP either in writing or in person including at any of the public events associated with the launch of LDP documents.

Those on the register were contacted in relation to the draft Plan Strategy via their preferred method of contact as follows: 

20 September 2019 – A letter advising that the draft Plan Strategy had been published for a four-week period of preconsultation along with a copy of the Have Your Say leaflet.



30 January 2020 – Notification advising that representations to the draft Plan Strategy are available for inspection.



10 December 2020 - Notification advising that counter representations to the draft Plan Strategy are available for inspection.

10

Chapter 3 Representations to the LDP Draft Plan Strategy

11

Chapter 3 Representations to the LDP Draft Plan Strategy 3.1

Regulation 20 (2) (g) of The Planning (Local Development Plan) Regulations (Northern Ireland) 2015 require that when a development plan document, in this case, the draft Plan Strategy is submitted to the Department for Independent Examination, it is accompanied by a statement setting out the number of representations and counter representations received and a summary of the issues raised.

Approach to analysis of responses Council approach 3.2

The consultation response form was designed in accordance with Development Plan Practice Note 9: Submission and Handling of Representations and was intended to ensure that all responses provided the information necessary to inform independent examination. This form could be downloaded from the Council website. Council also set up an online consultation platform (CiviQ) and encouraged its use. However, a large proportion of respondents chose not to utilise the form or CiviQ when submitting their response, meaning it was not always possible to accurately ascertain the intention of the comments with respect to:   

3.4

In processing and analysing responses, the Council did however make a reasonable judgement as to the most relevant section or policy of the draft Plan Strategy a comment related to. The information presented in this report therefore reflects these assumptions, which are useful for broad analysis.

3.5

The following sections of this report follow the overall structure of the draft Plan Strategy, with the main issues from the responses summarised in relation to each section or policy. The Council have then provided an initial response to these issues to help inform discussions as part of the independent examination process.

3.6

As the information contained within the following sections of this report is presented in summary form, it is recognised that it has not been possible to address all issues as raised within individual comments. Resultantly, this provides a broad indication of the main issues that will need to be considered as part of the Independent Examination. All detailed responses as received included those referring to Technical Supplements will be submitted to DfI and made available to the Planning Appeals Commission (PAC).

Figure 1- Response Form Used 40 35 30

Whether a respondent was supporting or objecting to elements of the draft Plan Strategy; Which section, policy and/or paragraph the comments relate to; and The relevant soundness test(s) to which an objection would relate.

25 20 15 10

3.3

To ensure no bias in the information presented, the Council made no assumptions with regard to respondents’ views on the soundness of the plan or which soundness test(s) specific comments would relate to.

5 0

No

Yes

Portal

12

3.7

In line with Councils Privacy Policy representations received during public consultations and published on the Councils website, were pseudo anonymised, removing names, addresses, personal telephone numbers, email, signatures or any other personal data, however these details are held on our database. Council are required to share your personal data submitted along with any representation to a public consultation, with the DfI and the PAC as part of the Independent Examination of the draft Plan Strategy.

Once shared, these bodies will be responsible for processing this data in line with the prevailing legislation.

3.8

Where respondents had not used the formal consultation response form, it was not clear whether they wished their representation to be considered in written form only or whether they wished to present their representation orally at the public hearing. In such cases, respondents were therefore contacted to provide clarification on these points.

13

draft Plan Strategy was sound or unsound and did not refer to any of the 12 soundness tests within their representations.

Summary of responses received 3.9

There were a total of 80 representations received during the consultation period for the draft Plan Strategy. A list of all organisations, individuals and other interested parties who submitted valid representations is contained in Appendix 1. A copy of all the responses are available to view on the Council’s website.

Figure 2 - Respondent by Type

Statutory Consultee, 20%

Individual , 28%

Organisation / Company, 53%

3.12

Of the 80 representations received, 34 utilised the Council’s formal response form, with 22 of those ticking the tests of soundness on which they considered the draft Plan Strategy to have failed, in Section ‘M’ of the form.

The remaining 46 representations were not accompanied by the formal response form.

3.13

The ‘Coherence and Effectiveness’ tests (CE1 – CE4) and the ‘Consistency’ test C3 were stated most often by the respondents who address soundness.

Tests CE2 and CE4 were referred to by 49% and 41% of the respondents respectively. No respondent stated that the draft Plan Strategy failed against ‘Consistency’ test C2.

3.14

Figure 3 below is a percentage breakdown of reference to the 12 soundness tests, where respondents felt the draft Plan Strategy, or one of its policies failed one or more of the tests.

Figure 3 - Tests of Soundness

CE4, 41%

P1, 9%

P2, 19% P3, 8% P4, 6%

3.10

In summary, 52% of responses were received from organisation/company and just over 28% from individuals. The remaining 20% consisted of responses submitted by statutory consultees.

C1, 19%

CE3, 28%

C2, 0%

Soundness Tests – Analysis 3.11

Of the 80 representations received 2.5% considered the draft Plan Strategy to be sound, 55% considered it to have failed 1 or more soundness tests and just over 1% mentioned soundness tests within the body of the representation but did not specify whether they considered the draft Plan Strategy to have failed any of the 12 tests. Just over 41% did not state if the

C3, 31%

CE2, 49% CE1, 34%

C4, 8%

14

Summary of main issues raised 3.15

A total of 662 main issues have been identified in this public consultation report from the representations received to the draft Plan Strategy. Of these, 588 related to the draft Plan Strategy document, 13 related to Technical Supplement 1: Monitor and Review, 3 related to the Draft Habitats Regulations Assessment with the remaining 58 relating to the Sustainability Appraisal (incorporating Strategic Environmental Assessment).

3.16

The following supporting documents received no comments:

3.17



draft Equality (Section 75) Screening Report of the Draft Plan Strategy;



Rural Needs Impact Assessment of the Draft Plan Strategy; and



District Proposals Maps 1 – 3.

Supportive comments were received to each of the 11 chapters of the draft Plan Strategy. Of the 18 Strategic Planning Policies, 17 received positive comments and 70 out of the 83 subject policies also received supportive comments as did Technical Supplement 1: Monitor and Review, the draft HRA and the SA/SEA.

15

Figure 4- Main Issues Raised per Chapter 1.0 Introduction, 6

Main Issues - Draft Plan Strategy

2.0 Setting the Context, 3 3.0 District Profile, 1 4.0 Vision and Strategic Objectives, 11 5.0 Spatial Growth Strategy and Countryside Strategy, 187 6.0 General Policy for all Development, 23 7.0 Sustainable Economic Growth, 104 8.0 Building Sustainable Communities, 88 9.0 Transportation, Infrastructure and Connectivity, 99 10.0 Stewardship of our Built Environment and Creating Places, 37

11.0 Safeguarding our Natural Environment, 19

Main Issues Supporting Documents

Miscellaneous Comments on dPS, 10 Technical Supplement 1: Monitor and Review, 13 draft HRA, 3 Sustainability Appraisal/Strategic Environmental Assessment - Main Issues , 58 0

25

50

75

100

125

150

175

200

225

250

Number of Main Issues 16

Figure 5 - Main Issues Chapters 1.0 Introduction, 2.0 Setting the Context & 3.0 District Profile

Figure 6 - Main Issues Chapter 4.0 Vision and Strategic Objectives

3.0 District Profile- Main Issues 1

2.0 Setting the Context- Main Issues 3

4.1 Vision - Main Issues 1

10 Main Issues

11 Main Issues 1.0 Introduction Main Issues 6

3.18

2

A total of 10 (2%2) issues raised related to the introductory chapters of the draft Plan Strategy, the highest proportion 60% being related to Chapter 1 Introduction.

4.2 Strategic Objectives - Main Issues 10

3.19

Chapter 4.0 Vision and Strategic Objectives raised a total of 11 (2%) of main issues.

Shown as a percentage of total issues raised to the draft Plan Strategy and Supporting Documents

17

Figure 7 - Main Issues Chapter 5.0 Spatial Growth Strategy and Countryside Strategy 5.4 Economic Development Strategy -Main Issues 6

5.3 Strategic Allocation of Housing to Settlements - Main Issues 64

5.5 Retail Strategy Main Issues 10

5.6 Tourism Strategy - Main Issues 6

7.1 Economic Development - Main Issues 19

5.7 Transport Strategy - Main Issues 3

187 Main Issues

5.2 Settlement Hierarchy - Main Issues 9 5.10 Land Instability and Coastal Erosion - Main Issues 9

Figure 8 - Main Issues Chapter 7.0 Sustainable Economic Growth

5.8 Open Space Strategy - Main Issues 9

7.4 Minerals Development - Main Issues 56

104 Main Issues

7.2 Retailing and Town Centres Main Issues 19

5.9 Countryside Strategy - Main Issues 64 7.3 Tourism - Main Issues 10

5.1 Spatial Growth Strategy - Main Issues 7

3.20

In analysing the main issues raised from the representations submitted, 28% (187) of the total related to the Spatial Growth Strategy and Countryside Strategy, with 43% of these issues related to SGS1 – SGS5. 34% of the 187 issues raised related to the Countryside Strategy with 12% relating specifically to Policy CS3 Areas of Constraint on High Structures. A total of 34% of the main issues related to the Strategic Allocation of Housing to Settlements. A total of 3% are related to SGS6 Strategic Allocation of Land for Economic Development and 5% relating to SGS7 Retail Hierarchy. A further 3% specifically relate to SGS8 Tourism Strategy, 2% to the Transport Strategy and 5% SGS9 to the Open Space Strategy.

3.21

A total of 23 (3%) of main issues raised related to the General Policy for all Development.

3.22

There were a total of 104 (16%) of main issues raised relating to Sustainable Economic Growth, just over half (53%) of issues raised related to Minerals Development, with Policy MIN1 Extraction and Processing of Hard Rock and Aggregates raising a total of 9 issues. Of the remaining issues raised, 10% related to Tourism, with 19% related to both Economic Development and Retailing and Town Centres.

18

Figure 9 - Main Issues Chapter 8.0 Building Sustainable Communities

Figure 10 - Main Issues Chapter 9.0 Transportation, Infrastructure and Connectivity 9.5 Water and Wastewater Infrastructure Main Issues 0

8.3 Health, Education, Community and Cultural Facilities Main Issues 3

9.6 Waste Management - Main Issues 6 9.2 Flood Risk and Drainage - Main Issues - Number of Main Issues 9

9.3 Renewable Energy - Main Issues 40 8.2 Open Space, Sport and Lesiure Main Issues 37

88 Main Issues

99 Main Issues

8.1 Housing - Main Issues 48

9.4 Telecommunication s and Overhead Cables - Main Issues 15

9.1 Transportation Main Issues 29

3.23

A total of 88 (13%) of main issues raised related to the Building Sustainable Communities Chapter, of which 55% related specifically to Housing. Policy HOU5 Affordable Housing in Settlements raised the highest number of issues with a total of 13% being recorded. 42% of issues were in regard to Open Space and 3% of issues raised were in relation to Health, Education, Community and Cultural Facilities.

3.24

A total of 99 (15%) main issues were raised in relation to Transportation, Infrastructure and Connectivity, of which 29% related to Transportation, with Policy TR7 Provision of Car Parks raising 14% of issues. 9% were related to Flood Risk and Drainage Policies and 40% were raised in relation to Renewable Energy with the remaining issues being distributed between Waste Management 6%, and Telecommunications 15%.

19

Figure 11 – Main Issues Chapter 10.0 Stewardship of our Built Environment and Creating Places

Figure 12 - Main Issues Technical Supplement 1: Monitor and Review, draft HRA, Sustainability Appraisal (incorporating Strategic Environmental Assessment

10.3 Place Making Main Issues 2 Technical Supplement 1: Monitor and Review Main Issues 13

10.2 Advertisements Main Issues 9

draft HRA - Main Issues 3

37 Main Issues

74 Main Issues 10.1 Historic Environment - Main Issues 26

3.25

3.26

There was a total of 37 (6%) main issues raised in relation to policies within the Stewardship of our Built Environment and Creating Places chapter. 70% were directly related to policies HE1 to HE9, a total of 19% relating specifically to Policy HE1 Archaeological Remains and their Settings. A further 24% of issues referred to Advertisements and the remaining 5% relate to Place-Making.

A total of 19 main issues (3%) are related to Chapter 11 Safeguarding our Natural Environment, with Policy NAT5 Habitats, Species or Features of Natural Heritage Importance raising 21% of the main issues recorded.

Sustainability Appraisal/Strategic Environmental Assessment - Main Issues 58

3.27

A total of 74 (11%) main issues raised related to Technical Supplement 1: Monitor and Review, draft HRA and the Sustainability Appraisal (incorporating Strategic Environment Assessment).

3.28

There were 10 (1%) main issues raised to the draft Plan Strategy document which were categorised as miscellaneous.

3.29

The figures on the following pages provide a breakdown of the total number of representations relating to each policy.

20

Figure 13 – Main Issues Raised per Policy 1.0 Introduction, 6

1.0 Introduction

2.0 Setting the Context, 3

2.0 Context

3.0 District Profile, 1

3.0 District Profile

4.1 Vision, 1

4.0 Vision & Strategic Objectives

4.2 Strategic Objectives, 10

5.0 Spatial Growth Strategy and Countryside Strategy

SGS1 Spatial Growth Strategy, 7 SGS2 Settlement Hierarchy, 9 SGS3 Strategic Allocation of Housing to Settlements, 38 SGS4 Protection of Zoned Land, 2 SGS5 Management of Housing Supply, 22 Miscellaneous comments on Strategic Housing Allocation Strategy, 2 SGS6 Strategic Allocation of Land for Economic Development, 6 SGS7 Retail Hierarchy, 10 SGS8 Tourism Strategy, 6 Transport Strategy, 3 SGS9 Open Space Strategy, 9 CS1 Sustainable Development in the Countryside, 2 CS2 Special Countryside Areas, 19 CS3 Areas of Constraint on High Structures, 22 CS4 Rural Landscape Wedges, 0 CS5 Antrim Coast and Glens AONB, 12 CS6 Developed Coast (Belfast Lough Shore), 3 CS7 Local Landscape Policy Areas, 3

CS8 Protection of Main River Corridors, 3 CS9 Development at risk from Land Instability or Coastal Erosion, 2 Miscellaneous Comments on Countryside Strategy, 7 GP1 General Policy for all Development, 23

6.0 General Policy

0

5

10

15

20

25

30

35

40

45

50

Number of Main Issues Raised 21

ECD1 Economic Development in Setlements, 3 ECD2 Retention of Economic Development Land, 2 ECD3 Development incompatible with Economic Development Uses, 0

ECD4 Economic Development in the Countryside, 13

Suggested New Policy, 1 Retailing and Town Centres Introduction, 5 RET1 Retail in Town Centres, 5

7.0 Sustainable Economic Growth

RET2 Retail Impact Assessment, 6 RET3 Retail in Villages, Small Settlements and Local Centres, 1 RET4 Rural Shops and Roadside Service Facilities, 2 TOU1 Safeguarding of Tourism Assets, 1 TOU2 Tourism Development in Settlements and Tourism Opportunity Zones, 1 TOU3 All Tourism Development in the Countryside, 1 TOU4 Tourist Amenities in the Countryside, 2 TOU5 Hotels, Guest Houses and Tourist Hostels in the Countryside, 2 TOU6 Self Catering Accommodation in the Countryside, 0 TOU7 New and Extended Holiday Parks in the Countryside, 1 TOU8 Major Tourism Development in the Countryside - Exceptional Circumstances, 1 Miscellaneous Comments on Tourism, 1 Minerals Development Introduction, 7 MIN1 Extraction and Processing of Hard Rock and Aggregates, 9 MIN 2 Valuable Minerals, 5 MIN3 Hydrocarbons, 2 MIN4 Areas of Constraint on Minerals Development, 7 MIN5 Area of Salt Reserve, Carrickfergus, 6 MIN6 Development at Risk of Subsidence due to past or present underground mineral extraction , 2 MIN7 Peat Extraction, 4

MIN8 Restoration and Management of Mineral Sites, 5 Suggested New Policy, 3 Miscellaneous Comments on Minerals, 6 0

2

4

6

8

10

12

14

16

Number of Main Issues Raised

22

HOU1 Quality in Residential Development in Settlements, 10 HOU2 The Conversion or Change of Use of Existing Buildings to Flats or Apartments, 1 HOU3 Residential Extensions and Alterations, 1 HOU4 Protected Town Centre Housing Areas, 1 HOU5 Affordable Housing in Settlements, 11 HOU6 Housing Mix (Unit Types and Sizes), 4

8.0 Building Sustainable Communities

HOU7 Adaptable and Accessible Homes, 6 HOU8 Travellers Accommodation, 2 HOU9 Replacement Dwelling, 4 HOU10 Dwelling on a Farm Business, 1

HOU11 Dwelling for Non-Agricultural Business Enterprises, 0 HOU12 New Dwelling in Existing Clusters, 1 HOU13 Infill/Ribbon Development, 1

HOU14 Personal and Domestic Circumstances, 0 HOU15 Residential Caravans and Mobile Homes , 0 HOU16 Affordable Housing in the Countryside, 4 Suggested New Policy, 1 OSL1 Protection of Open Space, 3 OSL2 Greenways, 10 OSL3 New Open Space Provision, 0 OSL4 Public Open Space in New Residential Development, 15 OSL5 Sport and Outdoor Recreation Facilities, 5 OSL6 Community Growing Spaces and Allotments, 1 OSL7 Cemeteries and Burial Space, 1

Miscellaneous Comments on Open Space, Sport and Leisure, 2 COM1 Education, Health, Community and Cultural Facilities, 3 0

2

4

6

8

10

12

14

16

18

Number of Main Issues Raised 23

TR1 Access to Public Roads, 3 TR2 Access to Protected Routes, 1 TR3 New Transport Schemes, 3

9.0 Transportation, Infrastructure and Connectivity

TR4 Disused Transport Routes, 1 TR5 Active Travel, 3 TR6 Parking and Servicing , 14 TR7 Provision of Car Parks, 4 FRD1 Development within Floodplains, 0 FRD2 Protection of Flood Defence and Drainage Infrastucture , 0 FRD3 Management of Development in regard to Surface Water Flood Risk, 0 FRD4 Sustainable Drainage (SuDS), 6 FRD5 Artificial Modification of Watercourses, 1 FRD6 Development in Close Proximity to Controlled Reservoirs, 2 RE1 Renewable Energy Development, 40

TOC1 Telecommunications and Overhead Cables, 12 Miscellaneous comments on Telecommunications and Overhead Cables, 3 WWI1 Development Relying on Non-Mains Wastewater Infrastructure, 0 WWT1 Environmental Impact of a Waste Management Facility, 0 WMT2 Waste Collection and Treatment Facilities, 1 WMT3 Waste Disposal Sites, 2 WMT4 Development in the Vicinity of a Waste Management Facility, 1 WMT5 Land Improvement, 1 Miscellaneous Comments on Watse, 1 0

5

10

15

20

25

30

35

40

45

50

Number of Main Issues Raised 24

10.0 Stewardship of our Built Environment and Creating Places

HE1 Archaeological Remains and their Settings, 7 HE2 Historic Parks, Gardens and Demesnes, 1 HE3 Listed Buildings - Change of Use or Extension/Alteration or Conversion of a Listed Building, 3 HE4 Listed Buildings - Demolition of a Listed Building, 1 HE5 Development affecting the Setting of a Listed Building, 0 HE6 Conservation Areas, 4 HE7 Areas of Townscape Character, 0 HE8 Non-listed Locally Important Building or Vernacular Building, 4

HE9 Enabling Development for the Conservation of Heritage Assets, 4 Miscellaneous Comments to Built Heritage, 2 AD1 Control of Advertisements, 9 10.3 SFA1 Strategic Focus Areas , 2

11.0 Safeguarding our Natural Environment

NAT1 European and Ramsar Sites - International Importance, 3 NAT2 Species Protected by Law, 2 NAT3 Sites of Nature Conservation Importance - National, 0 NAT4 Sites of Nature Conservation Importance - Local, 1 NAT5 Habitats, Species or Features of Natural Heritage Importance, 4 Suggested New Policy, 2 Miscellaneous Comments to Natural Heritage, 7 0

2

4

6

8

10

12

Number of Main Issues Raised 25

Miscellaneous

Miscellaneous Comments on dPS, 10 Technical Supplement 1: Monitor and Review, 13

Monitor & Review

draft HRA, 3

draft HRA

SA/SEA, 58

SA/SEA

0

10

20

30

40

50

60

70

Number of Main Issues Raised

Equality Monitoring 3.30

An Equality (Section 75) Screening Report was carried out in relation to the draft Plan Strategy in order to promote equality of opportunity throughout the LDP process.

3.31

In addition, the Council consulted a wide range of organisations representing Section 75 groups at various stages throughout the LDP process to date. In relation to the draft Plan Strategy and its accompanying documents they were consulted as follows: 



3.32

September 2019 during the pre-consultation period: Letter and Have Your Say leaflet was sent informing groups of the launch of the draft Plan Strategy.

October 2019 prior to beginning of the formal consultation period: Letter and Have Your Say leaflet was sent inviting comments on the draft Plan Strategy and its associated documents.

Equality monitoring was carried out in relation to those who attended the Council’s draft Plan Strategy public consultation events and this is summarised in Appendix 4 Equality Monitoring. The completion of an Equality Monitoring form was voluntary and so the report only includes those who completed the form.

26

Chapter 4 Council’s response to main issues raised Part 1 1.0 Introduction

27

1.0 Introduction Responses received Reference

Respondent

MEA-DPS-001

Antrim and Newtownabbey Borough Council

MEA-DPS-002

Belfast City Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-012

Donaldson Planning on behalf of Ballymena Development Consortium

MEA-DPS-013

Donaldson Planning on behalf of Individual

MEA-DPS-032

Inaltus on behalf of Alexander Property Holdings

MEA-DPS-033

Inaltus on behalf of Bridge Park Development Ltd

MEA-DPS-035

Inaltus on behalf of Galgorm Properties

MEA-DPS-037

Inaltus on behalf of N.K. Holdings Ltd

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-046

Ministerial Advisory Group

MEA-DPS-047

Individual

MEA-DPS-056

Quarry Plan

MEA-DPS-066

TSA Planning on behalf of Lotus Homes

MEA-DPS-067

TSA Planning on behalf of Rosemount Homes

MEA-DPS-069

Turley on behalf of ABO Wind (NI) Ltd

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-072

Turley on behalf of Clear Channel

MEA-DPS-073

Turley on behalf of Hagan Homes

28

MEA-DPS-074

Turley on behalf of Herron Bros

MEA-DPS-075

Turley on behalf of Northern Ireland Federation of Housing Associations

MEA-DPS-076

Turley on behalf of RES

MEA-DPS-077

Turley on behalf of Vaughan Homes

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Procedure Representations made at Preferred Options Paper (POP) stage have not been properly taken into account.

All representations submitted at POP stage were considered in the preparation of the draft Plan Strategy. A copy of the POP Public Consultation Report 2017 can be found on the Council's website here.

Gap in the evidence base and accordingly the Plan has failed to address procedural test 4.

The gap referred to is not clear. Council is content that the draft Plan Strategy is based on a robust evidence base. Any specific issues raised within the representations are addressed in the relevant chapters.

Plan Period Extend the LDP plan period to provide an effective 15 year development framework e.g. until 2035.

Neither the Planning Act 2011 nor the SPPS specify a time period for an LDP. The English National Planning Policy Framework (NPPF) is not relevant.

It is accepted that Development Plan Practice Note (DPPN) 01 states that LDPs should provide a 15 year plan framework to support the economic and social needs of a Council district, however: a) This is guidance not legislation; and b) There is no indication of when the 15 year period should commence and Council has interpreted 15 year period as starting when work on the plan started in 2015.

As such, an extension to the plan period would be at variance with the publically stated intention of the plan.

Plan review will be likely before 2030 and can be brought forward (e.g. two years after adoption) if deemed necessary to address any arising issues.

29

Timetable Timeframe of the publication, consultation period and adoption of the draft Plan Strategy conflicts with the plan timetable.

Council published the draft Plan Strategy within Q3 2019 as stated in the timetable. The other aspects of this part of the timetable will be separated out in any future revision to the timetable as in hindsight all the periods of consultation could not physically have taken place within a period of three months. In addition to this, DfI have advised there is a 3-6 month flexibility within the timetable.

Cross boundary Support for collaborative approach with other Councils, as such there are no perceived conflicts with Antrim and Newtownabbey Borough Council, Mid Ulster District Council and Belfast City Council.

Comments welcomed and noted.

Council should consider a joined-up approach with neighbouring Council’s with respect to its proposed LDP on minerals, as economic mineral deposits are located across several Council areas. Mid and East Antrim & Causeway Coast and Glens have a shortage of economic sand and gravel quarries and a wealth of operational basalt and industrial grade limestone therefore, the needs of other Council’s mineral requirements are required to be considered; indeed, the mineral requirement of the whole of Northern Ireland is a material consideration for the Council. Encourage Council to proactively engage with the established Minerals Forum.

Council sit on the highlighted Minerals Forum, which works with mineral operators’ representatives, Department for Economy (DfE) and DfI with the aim of gathering a wider range of data to accurately identify the value of the industry and establish local and regional supply and demand of mineral products.

Miscellaneous Outline marine legislative requirements for the determination of planning applications in paragraph 1.7.1.

Paragraph 1.7.1 of the draft Plan Strategy relates to the primacy of the LDP in the determination of planning applications, given that we are now in a Plan-led system. Within this paragraph and elsewhere in the document there is reference to ‘other material considerations. Section 2.1 of the draft Plan Strategy refers to regional policy context and includes both the UK Marine Policy Statement and the draft Marine Plan for Northern Ireland.

30

2.0 Setting the Context

31

2.0 Setting the Context Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture and Rural Affairs – Natural Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-052

Northern Health and Social Care Trust

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support Setting the Context and mixed tenure, affordable/accessible housing to help meet objectives of Community Plan particularly in terms of Building Sustainable Communities. It also ensures residential developments provide adequate homes for all.

Support for this chapter of the draft Plan Strategy is welcomed.

Consider adding suggested wording to the Regional Policy section of the draft Plan Strategy referring to the ‘Living With Water Programme (LWWP)’.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan. However, Council is content to add the suggested additional wording after paragraph 2.1.11 – see Schedule of Proposed Modifications - Reference Number PM-002.

Add reference to Northern Ireland Regional Landscape Character Assessment (NIRLCA) 2016.

For clarity, Council recommend the inclusion of reference to the Northern Ireland Regional Landscape Character Assessment (NIRLCA) 2016 - see Schedule of Proposed Modifications - Reference Number PM-003.

Add reference to Northern Ireland’s second Climate Change Adaption Programme 2019-24.

The second Northern Ireland Climate Change Adaption Programme 2019-24 was not published until after the draft Plan Strategy went to print. Council will refer to it in the adopted Plan Strategy.

32

3.0 District Profile

33

3.0 District Profile Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs – Natural Environment Division

MEA-DPS-026

Gravis Planning on behalf of EP UK Investments

MEA-DPS-038

Invest NI

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support the recognition of the importance of both Ballylumford and Kilroot Power Stations for power generation and employment.

Support for recognition of the importance of the power stations in the Borough welcomed.

There is an opportunity to emphasise the Council area’s linkages and boundary with the marine area at the outset of the District Profile.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as the issue is adequately covered in the document.

34

4.0 Vision and Strategic Objectives

35

4.1 Vision Responses received Reference

Respondent

MEA-DPS-007

Individual

MEA-DPS-018

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-019

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-020

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-023

Gravis Planning on behalf of Conway Estates Ltd

MEA-DPS-024

Gravis Planning on behalf of Conway Estates Ltd and Individuals

MEA-DPS-025

Gravis Planning on behalf of Individual

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-056

Quarry Plan

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the vision and welcome that it is primarily based on the vision of Council’s Community Plan.

Support for our vision is welcomed.

Amend vision to strengthen wording in relation to housing to read: 'the LDP will strive to deliver a generous provision of housing' - such wording would provide a more flexible and positive approach to housing provision. Currently the text states that 'the LDP will strive to deliver sufficient housing'.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

The SPPS at paragraph 6.1.36 requires the LDP to 'facilitate an adequate and available supply of quality housing to meet the needs of everyone’ and does not refer to a generous supply. The use of the term 'generous' could lead to too much growth for example in villages and small settlements and undermine the settlement hierarchy and housing allocation.

36

4.2 Strategic Objectives Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-009

Department of the Economy

MEA-DPS-010

Department for Infrastructure

MEA-DPS-013

Donaldson Planning on behalf of Individual

MEA-DPS-018

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-019

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-020

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-023

Gravis Planning on behalf of Conway Estates Ltd

MEA-DPS-024

Gravis Planning on behalf of Conway Estates Ltd and Individuals

MEA-DPS-025

Gravis Planning on behalf of Individual

MEA-DPS-026

Gravis Planning on behalf of EP UK Investments

MEA-DPS-027

Gravis Planning on behalf of Individual

MEA-DPS-028

Gravis Planning on behalf of Individual

MEA-DPS-029

Gravis Planning on behalf of Individual

MEA-DPS-030

Gravis Planning on behalf of Individual

MEA-DPS-034

Inaltus on behalf of Galgorm Group

MEA-DPS-035

Inaltus on behalf of Galgorm Properties

MEA-DPS-036

Inaltus on behalf of Individual

MEA-DPS-037

Inaltus on behalf of N.K. Holdings Ltd

MEA-DPS-038

Invest NI

MEA-DPS-041

Lightsource BP

MEA-DPS-045

Mid Ulster District Council 37

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-051

Northern Ireland Water

MEA-DPS-056

Quarry Plan

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the Strategic Objectives with specific mention of Economic Objectives a), c) and e), Social Objectives a), b), c), d) and f) and Environmental Objectives f), h) and i).

Support for the Strategic Objectives is welcomed.

Economic Objectives Question consistency between wording of Economic Objective a), paragraph 5.4.15 of the draft Plan Strategy and the SPPS Regional Strategic Objectives.

Council note the issue and consider that the SPPS also uses different wording when referring to the supply of economic land, e.g. 'generous' supply in regional strategic objectives. However, in the economic development policy text of the SPPS at paragraph 6.92 it requires LDPs to ensure there is an 'ample' supply of land to meet economic land needs within the plan area.

Council therefore consider the wording used in the draft Plan Strategy to be sound as it is over and above the 'ample' supply required of LDPs by the SPPS. However, for clarity and consistency, Council propose to amend the wording of Economic Objective a) – see Schedule of Proposed Modifications – Reference Number PM-004.

Social Objectives Amend Social Objective a) to include 'and grow'.

Council consider that although it is entitled a 'Growth' Strategy, in villages and small settlements the aim is to sustain rather than to grow significantly.

Council may wish to consider updating Social Objective c) to accord with the housing figure for period of the plan 2015-2030.

The plan period commences in 2015 because that is when work commenced on the LDP following transfer of planning powers to Council. Nevertheless, the plan is compelled to take account of dwellings built since 2012 as the relevant HGI at 2015 related to the period 201225. The objective is therefore considered to be sound. However, for clarity, Council suggest adding a footnote to provide clarity between the time period used in Social Objective c) and SGS3 – see Schedule of Proposed Modifications – Reference Number PM-004.

Plan is not reasonably flexible to deal with changing circumstances and urban capacity sites will not meet need stated in Social Objective c).

Council are not anticipating that every urban capacity site will come forward and given there is an oversupply of housing land within the Borough, Council are not relying on them all to come 38

forward. Should it arise that further lands are required this would be assessed through the Local Policies Plan process.

Social Objective c) is inconsistent with SGS3 and it should provide a higher level of housing requirement.

The plan period commences in 2015 as that is when work commenced on the LDP following transfer of planning powers to Council. Nevertheless, the plan is compelled to take account of dwellings built since 2012 as the relevant HGI at 2015 related to the period 2012-25. The objective is therefore sound. Council is content that there will be a 5 year supply at all times to 2030. This will be reviewed at Plan Review stage, which is likely to be before 2030.

Amend Social Objective c) to provide a generous supply of land.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

The SPPS at paragraph 6.1.36 requires the LDP to 'facilitate an adequate and available supply of quality housing to meet the needs of everyone’ and does not refer to a generous supply. The use of the term 'generous' could lead to too much growth for example in villages and small settlements and undermine the settlement hierarchy and housing allocation.

Environmental Objectives Question whether Environmental Objective f) wording is consistent with policy.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Council consider that the section is not operational policy and the strategic objectives referred to in Chapter 4.2 and Chapter 9 are high level strategic objectives”. Council do not consider this is a policy test, or something, which affects the soundness of the plan.

LDP could contain targeted and focused objectives, which demonstrate how renewable forms of energy are to be encouraged.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider this is already covered by the economic and environmental objectives and Policy RE1.

Biodiversity opportunities should be considered by Council and emphasis expressed in the draft Plan Strategy.

Council consider the Strategic Objectives should be read together as encompassing the three pillars of sustainable development which embrace economic, social and environmental priorities with no one objective or theme having priority over any other, recognising that all are to some degree inter-related.

Miscellaneous Beneficial if Strategic Objectives demonstrated links with marine policy or include objective for the marine.

Council does not consider it appropriate to refer to policy documents within strategic objectives.

Links to marine policy documents are found in Chapter 2.1 of the draft Plan Strategy - Setting the Context.

39

5.0 Spatial Growth Strategy and Countryside Strategy 40

5.1 SGS1 Spatial Growth Strategy SGS1 Spatial Growth Strategy Responses received Reference

Respondent

MEA-DPS-001

Antrim and Newtownabbey Borough Council

MEA-DPS-002

Belfast City Council

MEA-DPS-007

Individual

MEA-DPS-018

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-019

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-020

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-022

GM Design Associates Ltd on behalf of Individual

MEA-DPS-023

Gravis Planning on behalf of Conway Estates Ltd

MEA-DPS-024

Gravis Planning on behalf of Conway Estates Ltd and Individuals

MEA-DPS-025

Gravis Planning on behalf of Individual

MEA-DPS-026

Gravis Planning on behalf of EP UK Investments

MEA-DPS-027

Gravis Planning on behalf of Individual

MEA-DPS-028

Gravis Planning on behalf of Individual

MEA-DPS-029

Gravis Planning on behalf of Individual

MEA-DPS-030

Gravis Planning on behalf of Individual

MEA-DPS-038

Invest NI

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-049

Northern Ireland Housing Executive 41

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-062

TC Town Planning on behalf of Individual

MEA-DPS-065

TSA Planning on behalf of Individual

MEA-DPS-066

TSA Planning on behalf of Lotus Homes

MEA-DPS-067

TSA Planning on behalf of Rosemount Homes

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Heron Bros

MEA-DPS-077

Turley on behalf of Vaughan Homes

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the growth strategy and Policy Aims and it is considered appropriate to focus major population growth and economic development in the three main towns and facilitate appropriate growth in small towns.

Support for the proposed policy approach is welcomed.

Spatial Growth Strategy unsound particularly housing allocation figure and SGS3, SGS5, SGS2 and SGS6.

See SGS2, SGS3, SGS5, and SGS6 regarding concerns raised.

Concern about the impact of SGS2 and SGS3 on the Spatial Growth Strategy, for example by planning too few homes and under-allocating under SGS3 this has the potential to undermine the Spatial Growth Strategy.

See rebuttals for SGS2 and SGS3 regarding concerns raised. It is considered that allocating 62% of housing to the main towns tier will help to meet the Spatial Growth Strategy direction to focus major population growth in the three main towns. The allocation increases the 2011 Census status quo by 3.5 percentage points. This is in line with the RDS with most housing growth directed to main towns whilst ensuring the needs of the rural community are met in a sustainable manner.

Avoid disproportionate growth in smaller settlements, as it could affect role of larger settlements.

To sustain rural communities in line with the RDS it was considered reasonable to allocate 8.5% of housing to villages and 2.5% to small settlements with the majority (62%) going to our three main towns and a 15% share to small towns.

42

Ballygalley, Kells and Connor and Glenarm opportunities for housing and employment.

should

provide

Our villages such as Ballygalley, Glenarm and Kells and Connor will be sustained, consolidated and revitalised and land will not be zoned specifically for housing in villages to retain flexibility for meeting various local needs including housing, economic or community uses. Instead, where necessary, land will be identified as Housing Policy Areas in villages where it is anticipated that most new housing should be located.

There should be sufficient land to facilitate housing growth in Martinstown.

As Martinstown has already had high build rates in recent years (32 dwellings between 2012 and 2018) it has already surpassed its notional housing allocation. A number of live approvals and other undeveloped sites exist in the settlement therefore it is not considered that Martinstown should be allocated further housing at this time.

Conventional and renewable energy should be recognised in the Spatial Growth Strategy.

Council do not consider it appropriate to include specific reference in SGS1 to conventional and renewable energy, these are dealt with in Chapter 9 of the draft Plan Strategy.

Spatial Growth Strategy is to be delivered via a number of different strategies but there is no mention of a climate change strategy, biodiversity or environment strategy.

Landscapes and natural/historic assets of strategic significance will be protected through the Strategic Countryside Designations as set out in the Countryside Strategy in Part 1 of the draft Plan Strategy. In addition, Council recognises that under the Wildlife and Natural Environment Act (NI) 2011 it has a duty to further the conservation of biodiversity. Regard has also been had to both the EU and NI biodiversity Strategies to create Policies NAT1-5 that seek to protect our natural heritage assets. The policies of the draft Plan Strategy also have been the subject to a Habitats Regulations Assessment and Sustainability Appraisal incorporating Strategic Environmental Assessment.

43

5.2 Settlement Hierarchy SGS2 Settlement Hierarchy Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-014

Donaldson Planning on behalf of Individual

MEA-DPS-018

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-019

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-020

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-021

Glenarm Visitor Information Centre

MEA-DPS-038

Invest NI

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-054

O'Connor Kennedy Turtle on behalf of Individual

MEA-DPS-062

TC Town Planning on behalf of Individual

MEA-DPS-064

TSA Planning on behalf of Individual

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Heron Bros

MEA-DPS-079

White Young Green on behalf of Individual

44

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the settlement hierarchy and for the designation of Ahoghill as a small town, Martinstown being reclassified as a village and Slaght being designated as a small settlement.

Support for the proposed settlement hierarchy is welcomed.

Amend policy as Larne has no supporting small towns so additional opportunities for growth should be provided in Larne.

By focusing growth in Larne, rather than for example in supporting small towns, this is likely to enhance its role as a main town in accordance with the RDS. The designation of small towns is based on a Borough wide criteria, no villages in the former Larne Borough were close to meeting this. The suggested increased housing allocation to Larne is considered under SGS3.

Amend policy to change Glenoe from a small settlement to a village.

The Housing Evaluation Framework from the RDS was taken into account when appraising settlements to determine where they should sit in the hierarchy. Following this detailed settlement appraisal, Glenoe was not considered to have the supporting population and facilities to justify designation as a village.

Amend policy to retain Knocknagulliagh as a small settlement.

Knocknagulliagh whilst having a recognisable cluster of dwellings straddling the road does not benefit from any community/public buildings nor facilities. It fails to fully meet a recognised test applied by the Planning Appeals Commission (PAC) in the BMAP inquiry for considering designation of small settlements i.e. “...in order to constitute a settlement, there should be a concentration of buildings displaying an obvious sense of cohesion and place and offering one or more community facilities”.

Amend policy to retain Feystown as a small settlement.

It is accepted that Feystown has a community building, in the form of the church, but it is considered to lack cohesion in terms of the built form. It fails to fully meet a recognised test applied by the PAC in the BMAP inquiry for considering designation of small settlements i.e. “...in order to constitute a settlement, there should be a concentration of buildings displaying an obvious sense of cohesion and place and offering one or more community facilities”.

Furthermore, the settlement has had no development nor applications for development in many years, despite the existence of undeveloped land within the existing settlement limits.

Portglenone should be treated as an exceptional village that could support growth beyond other villages or promoted to a small town as it has the appropriate characteristics, scale and services.

The merits of a greater housing allocation to Portglenone is considered under the rebuttals to SGS3. It is accepted Portglenone has the characteristics and services of a small town, but it lacks population. Therefore, the decision was taken to retain the settlement as a village (see Technical Supplement 3).

Settlement hierarchy is not reasonably flexible to meet changing circumstances.

If necessary, the settlement hierarchy can be reviewed every five years to meet changing circumstances.

Undertake a Strategic Settlement Evaluation for each settlement and identify constraints and opportunities.

Position Paper 11 Strategic Settlement Evaluation evaluated the settlements to help determine their position on the settlement hierarchy. The three main towns were not subject to a 45

settlement evaluation as per the other settlements, as all three had self-evidently substantially larger population and range of services, amenities and facilities. They were however, analysed and considered during the housing allocation process which involved applying the RDS Housing Evaluation Framework to determine if there were differences between the three and if this should alter the portion of allocation to each.

The draft Plan Strategy contains contradictory comments about Greenisland.

Council are content with Greenisland remaining as small town (note it was indicated as a local town in BMAP) due to lack of services and facilities and its considerably less population than the three main towns. Position Paper 11 Strategic Settlement Evaluation evaluated the settlement of Greenisland to help determine its position on the settlement hierarchy.

Greenisland was included with the three main towns in SGS5 as it had a population of over 5,000 (the only small town which has) and for such settlements the SPPS requires the LDP to adopt a sequential approach for the release of housing land. As set out on page 65 of the draft Plan Strategy at paragraph 5.3.18, driven by the regional policy direction to locate the majority of new housing in appropriate brownfield sites within the urban footprint of larger towns, suitable sites within the urban footprint of our main towns and Greenisland will also be identified as phase 1 housing land.

DfI's Local Transport Study for the Borough (Appendix A of Technical Supplement 9) includes Greenisland within the study as it is one of the four towns within the Borough with a population over 5,000 (the threshold for inclusion in the study). Greenisland's inclusion in the study does not "place it on the same footing" as the three main towns of Ballymena, Larne and Carrickfergus.

New small settlements may have longer term sustainability implications.

The rationale for designating the new small settlements are contained in Technical Supplement 2: Settlement Hierarchy and Strategic Settlement Evaluation and Position Paper 11 Strategic Settlement Evaluation. The new small settlements came forward following analysis of built up nodes in the countryside, the local knowledge of the Plan team and Elected Members input.

The test was used that the Planning Appeals Commission applied in the BMAP inquiry, where they accepted that, “...in order to constitute a settlement, there should be a concentration of buildings displaying an obvious sense of cohesion and place and offering one or more community facilities”. Council considers that the following factors need to be taken into account. Firstly, only limited opportunities for development will be provided in small settlements (in accordance with the LDP Spatial Growth Strategy), so there will be no significant impact on the growth of the main hubs and this should not significantly lead to unsustainable forms of travel. Secondly, the designation of the eight new small settlements will be offset by the dedesignation of the 12 existing small settlements.

46

5.3 Strategic Housing Allocation Strategy SGS3 Strategic Allocation of Housing to Settlements Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-007

Individual

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-012

Donaldson Planning on behalf of Ballymena Development Consortium

MEA-DPS-013

Donaldson Planning on behalf of Individual

MEA-DPS-015

Farrans Construction

MEA-DPS-016

Ferguson Planning on behalf of Individual

MEA-DPS-018

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-019

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-020

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-022

GM Design Associates Ltd on behalf of Individual

MEA-DPS-023

Gravis Planning on behalf of Conway Estates Ltd

MEA-DPS-024

Gravis Planning on behalf of Conway Estates Ltd and Individuals

MEA-DPS-027

Gravis Planning on behalf of Individual

MEA-DPS-028

Gravis Planning on behalf of Individual

MEA-DPS-029

Gravis Planning on behalf of Individual

MEA-DPS-030

Gravis Planning on behalf of Individual

MEA-DPS-034

Inaltus on behalf of Galgorm Group

MEA-DPS-035

Inaltus on behalf of Galgorm Properties

MEA-DPS-037

Inaltus on behalf of N.K. Holdings Ltd

MEA-DPS-043

MBA Planning on behalf of CYM Properties 47

MEA-DPS-049

Northern Ireland Housing Executive (NIHE)

MEA-DPS-051

Northern Ireland Water

MEA-DPS-054

O’Connor Kennedy Turtle on behalf of Individual

MEA-DPS-055

Pragma Planning on behalf of Carnlough Dev Ltd

MEA-DPS-056

Quarry Plan

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-061

Individual

MEA-DPS-062

TC Town Planning on behalf of Individual

MEA-DPS-066

TSA Planning on behalf of Lotus Homes

MEA-DPS-067

TSA Planning on behalf of Rosemount Homes

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Herron Bros

MEA-DPS-077

Turley on behalf of Vaughan Homes

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the overall approach to housing allocation; for the changing percentage allocation of housing between the settlement tiers and countryside; and that the Strategic Housing Allocation recognises the importance of supporting rural communities.

Support for the proposed policy approach is welcomed.

Housing Growth Indicators (HGIs) HGI’s should not be relied on for housing allocation because: 

they are modest;



they will result in insufficient housing allocation;

The draft Plan Strategy takes account of the HGI’s as required by both the RDS and SPPS. HGI’s are based on the best available evidence, largely related to anticipated household formation and SGS3 uses them as the broad parameter for the housing allocation process to produce ‘notional’ housing allocation figures. Council accepts that the HGI’s only provide an 48



they are inflexible;



they have not been interrogated and other evidence has not been sought to inform housing allocation;



they do not consider all drivers of future housing need;



they do not take account of non-availability of land; and



they do not reflect the RDS objectives and have not been subject to recent public consultation.

estimate of future housing need throughout NI and that they should be used as a guide to where development should happen to meet DRD (now DfI) objectives. SGS3 does not treat the HGI as a target, cap or rigid figure and this is demonstrated by the following:  Potential housing land supply significantly exceeds housing allocation to settlements based on HGI, as illustrated on pages 323 -325 of the draft Plan Strategy;  The draft Plan Strategy will be zoning suitable uncommitted urban capacity sites in urban footprint of main towns as phase 1 housing land irrespective of allocation;  Existing commitments can be developed and for many settlements this largely meets or exceeds the notional allocation;  The draft Plan Strategy allows for phase 2 land to be brought forward in main towns. In addition, in the remaining small towns where urban capacity sites or windfall potential would not meet affordable housing need, additional land may be zoned for housing if it is sustainable to do so; and  HGIs will continue to be reviewed by DfI and taken into account in review of the LDP .

Whilst it is accepted that not all sites may be suitable there is still a significant ‘cushion’ over and above the notional allocation in existing settlements. Accordingly, there is sufficient flexibility for the LDP to react to variants such as housing need, population and economic factors.

In addition to the HGI, the housing allocation process also takes account of other relevant factors such as the RDS direction in favour of main towns, demographics and those factors considered through the Housing Evaluation Framework.

Following a public consultation, an agreed HGI methodology was established in 2005 by DfI (then DRD) and that has been replicated as closely as possible for all HGI updates since then.

The HGI’s are published by DfI and it is their responsibility to decide if and when to carry out public consultation in regard to the figures and/or methodology.

The purpose of the LDP is to ensure that the housing need for the remainder of the plan period can be met. Council is content that housing land supply exceeds housing allocation and that many settlements have more than sufficient land to allow them to exceed their notional allocation based on the HGI by the end of the plan period. As part of the Local Policies Plan process the status of sites will be re-examined to consider their potential for housing and housing land supply will also be considered at Plan Review stage, prior to 2030.

Extend plan period LDP plan period should be extended beyond 2030 to ensure a 15 year plan framework and to ensure a 5 year supply of housing land.

Development Plan Practice Note 01 (DPPN 01) provides guidance that LDPs should provide a 15 year framework, but there is no indication of when this should commence. Council has interpreted the 15 year period as starting when work on the LDP started in 2015. The POP clearly stated that the LDP will be used as the policy framework for development in Mid and East Antrim until 2030 and this was reiterated in the draft Plan Strategy, and this date was 49

stated in the public notices and correspondence accompanying the publication and consultation of these two documents. Neither the Planning Act (Northern Ireland) 2011 nor The Planning (Local Development Plan) Regulations (Northern Ireland) 2015 includes a provision to extend the plan period and therefore at this stage of the LDP, it is not possible for Council to revise the plan period past 2030. Any extension to the plan period would be at variance with the publicly stated intention and advertised plan period. Nevertheless, given the statutory requirements for LDPs to be monitored annually and reviewed within 5 years of adoption, the end date of 2030 is not significant.

The proposed notional housing allocation is not restrictive as the potential housing land supply significantly exceeds the notional allocation, as illustrated in pages 323 - 325 of the draft Plan Strategy which shows capacity significantly exceeds anticipated housing need and affordable housing need to 2030 in many settlements, and many of these already benefit from planning permission. The proposed approach to the notional housing allocation is considered sound and a 5 year supply can be maintained and will be subject to review at Local Policies Plan and Plan Review stage, prior to 2030.

HGI, Housing Allocation and plan period different The start of the plan period of 2015 is at variance with the start date of Social Objective c) and the HGI, both of which are from 2012.

The plan period commences in 2015 because that is when work commenced on the LDP following transfer of planning powers to Council. The relevant HGI in 2015 related to the period 2012-2025, and therefore 2012 formed the baseline for the assessment of the proposed notional housing allocation over the plan period and dwellings built since then have been taken account of.

Take account of revised HGI The draft Plan Strategy must take account of the revised HGI’s, published in September 2019.

The September 2019 revised HGI’s were released after the draft Plan Strategy had been published. For information purposes pages 16-22 of the Further Evidence Report - Housing illustrate the effect of the revised Mid and East Antrim HGI on the strategic allocation of housing within the Borough.

HGI and Housing Allocation not the same thing The draft Plan Strategy relies on the HGI’s as a rigid figure for the strategic housing allocation rather than using it as a starting point or a guide.

Council accepts that the HGI’s only provide an estimate of future housing need throughout NI and that they should be used as a guide to where development should happen to meet DRD (now DfI) objectives. The HGI is therefore used in the draft Plan Strategy as the broad parameter for the housing allocation process to produce notional housing allocation figures in the Borough. The HGI is not treated as a target, cap or rigid figure and this is demonstrated by the following:

50

 Potential housing land supply significantly exceeds housing allocation to settlements based on HGI, as illustrated on pages 323 -325 of the draft Plan Strategy;  The draft Plan Strategy will be zoning suitable uncommitted urban capacity sites in urban footprint of main towns as phase 1 housing land irrespective of allocation;  Existing commitments can be developed and for many settlements this largely meets or exceeds the notional allocation;  The draft Plan Strategy allows for phase 2 land to be brought forward in main towns.

In addition, in the remaining small towns where urban capacity sites or windfall potential would not meet affordable housing need, additional land may be zoned for housing if it is sustainable to do so; and  HGIs will continue to be reviewed by DfI and taken into account in review of the LDP. Whilst it is accepted that not all sites may be suitable there is still a significant ‘cushion’ over and above the notional allocation in existing settlements.

Distribution of Housing Allocation Use of the historic share of households for future housing allocation is not a robust or sustainable approach; they may not necessarily further sustainable patterns of development.

The methodology in regards to the allocation to settlements is considered sound. Whilst the allocation is reflective of the 2011 Census household distribution it also takes account of the RDS direction in favour of main towns as well as those factors considered through the Housing Evaluation Framework (see Technical Supplement 3, page 27). The 2011 Census illustrates that 58.5% of the Borough's households are living in our main towns and 14% are living in our small towns. These are the most sustainable locations in the Borough and this is considered to provide a sound foundation to the approach to a sustainable housing allocation. The draft Plan Strategy aims to further reinforce these existing sustainable patterns of development as the methodology for SGS3 increases the 2011 Census status quo in terms of the proportion of households in main towns, with marginal increases to the percentage in small towns, villages and small settlements.

Housing allocation figure is a significant reduction from the Preferred Options Paper (POP) and the allocation between the tiers is not in line with the POP.

The proposed housing allocation is not a reduction on the figure proposed in POP 2017. The allocation of 7,477 for 2012-2030, as set out in the POP, was used as the baseline for the housing allocation strategy, however, it has been adjusted to take account of housing completions between 2012-2018 as required by paragraph 6.136 of the SPPS (see Appendix A and Technical Supplement 3 for full details of the methodology). In response to comments received as part of the POP consultation process the percentage allocations were revised within the draft Plan Strategy in order to prevent disproportionate growth to the lower tiers of the settlement hierarchy (see the Preferred Options Paper Consultation Report and Appendix H of Technical Supplement 3).

Percentage allocation to each of the settlement tiers is too low. A range of options put forward on how the allocation should be distributed,

The allocation of housing to the settlement tiers and countryside was explored through Key Issue 4 of the POP. In response to the comments received to the POP consultation process, 51

primarily increases to upper tiers sought and reduction of the allocation to the countryside.

the allocations were revised to ensure growth in the main towns and prevent disproportionate growth in the lower tiers of the settlement hierarchy.

The draft Plan Strategy significantly increases the 2011 Census status quo in terms of the proportion of households in main towns. In addition, the potential housing land supply in all three main towns exceeds the notional housing allocation.

The draft Plan Strategy increases the 2011 Census status quo in terms of the proportion of households in small towns. This is considered to be appropriate to the size and role of the settlements within this tier and will allow opportunities for growth.

The draft Plan Strategy increases the 2011 Census status quo in terms of the proportion of households in villages and small settlements. The allocation is considered sound and in line with SGS1 as it provides sufficient numbers to sustain them and the surrounding rural communities. Council interprets ‘sustain’ rural communities living in and around villages and small settlements as meaning allowing for a level of development proportionate to location, scale and character of the settlement.

The allocation to the countryside is a reduction on the current status quo and it would be unrealistic for the Council to reduce it further given the existing context and SPPS direction.

The housing allocation between tiers is considered sound as it is in line with the RDS and the Spatial Growth Strategy and it aims to balance focusing growth in the three main towns, facilitating appropriate growth in our small towns, sustaining our villages and small settlements and facilitating sustainable development in the countryside.

Under allocation of housing to: All main towns; All small towns; Villages of Portglenone, Ballygalley, Glenarm, Kells and Connor and Cargan; and Small settlements and specifically Glenoe.

Allocations to the individual settlements has been undertaken on a Borough wide basis and are considered sound as they take account of the RDS direction and household trends alongside tailoring to reflect the facilities, services and constraints which may be present in the individual settlements as assessed in the Housing Evaluation Framework.

The notional allocations to the main towns are considered sound as they are reflective of their size and strategic role. Table A2 page 317 of the draft Plan Strategy sets out the housing allocation before completions were deducted and illustrates that Ballymena is allocated the most between the three main towns, followed by Carrickfergus and then Larne. The proposed notional allocation should not constrain growth in any of the main towns as the potential land supply exceeds the housing allocation based on the HGI (Figure A4, page 323) and the approach to its management as set out in SGS5.

The notional housing allocations to individual small towns are considered sound. The allocations as indicated in Table A2, page 317 of the draft Plan Strategy, are appropriate to the size and role of the settlements within this tier and allow opportunities for growth. Any appearance of lower allocations in some of the small towns compared to others is reflective of the number of dwellings built between 2012 -2018. Notwithstanding this however, Figure A5, page 324 of the draft Plan Strategy illustrates that in all of the small towns with the exception of Whitehead the remaining potential housing land supply exceeds the notional allocation 52

based on the HGI. It is also recognised that there is an issue of affordable need in Broughshane and Ahoghill in particular. SGS5 however, makes provision for any deficit in small towns to be addressed through the zoning of additional land if it is sustainable to do so as part of the Local Policies Plan process.

The notional housing allocations to individual villages are considered sound. The allocations are appropriate to the individual size and role of the settlements within this tier and will ensure that the Borough’s villages will be sustained, consolidated and revitalised. To retain flexibility for meeting various local needs land will not be zoned for housing in villages. Instead, where necessary, land will be identified as Housing Policy Areas in villages to indicate where it is anticipated that most new housing should be located. Figure A6, page 325 of the draft Plan Strategy illustrates that in the majority of villages the potential housing land supply exceeds housing allocation to settlements based on the HGI. As part of the Local Policies Plan process the status of existing approvals and the capacity of the villages will be re-examined to consider the potential for housing within the settlement. In settlements where there are capacity issues such as Ballygalley, Council will consider how the housing allocation can be sustainably achieved.

There is no detailed allocation to Glenoe at this stage as it has been grouped with the other small settlements. The starting point for allocating housing in each tier was based on their 2011 household share and therefore is reflective of what is sustainable for those settlements.

The notional allocation to small settlements reflects SGS1; Council interprets ‘sustain’ rural communities living in and around villages and small settlements as meaning allowing for a level of development proportionate to location, scale and character of the settlement.

Over allocation of housing to the open countryside will undermine the role of the villages/small settlements and weaken the focused growth strategy in urban areas.

The strategic housing allocation is in keeping with the RDS as growth is focused in the main towns and is sequentially reduced down through the tiers of the settlement hierarchy. The proposed distribution of the notional housing allocation is not considered disproportionate because:  The allocation to the countryside represents a 6.2% decrease relative to 2011;  The allocation to villages and small settlements represents a 1% and 0.7% increase relative to 2011; and  The allocation to the countryside is based on what is realistic within the existing context and SPPS direction.

Allocation of housing to smaller settlements and the open countryside reinforces an unsustainable trend.

Following consultation on the POP the housing allocation to the main towns has been increased at the expense of lower tier settlements. The notional housing allocation to the countryside has been reduced from the current position and is considered to be realistic given the existing context and SPPS direction. This approach is supported by policies that have been developed to help reduce development in the countryside and comply with the SPPS. SGS3 is not reinforcing a disproportionate amount of growth in smaller settlements and open countryside.

The Strategic Housing Allocation will support sustainable patterns of development and aims to 53

strike a balance between growing the main towns whilst facilitating growth in our small towns, sustaining rural communities living in and around our villages and small settlements and by facilitating sustainable development in the open countryside. SGS2 reduces the number of small settlements in the Borough, which will consolidate the allocation to that tier and help to counteract a dispersed settlement pattern.

RDS Housing Evaluation Framework Allocation to settlements is unsound as it has not taken proper account of the RDS Housing Evaluation Framework – Cargan merits a higher score.

Full account has been taken of the RDS Housing Evaluation Framework and it is considered that Cargan’s score is justified. Full details of the methodology can be found in Technical Supplement 3: Housing.

The Strategic Housing Allocation was not informed by detailed assessment of the settlements.

A strategic settlement evaluation of settlements within Mid and East Antrim, below the main town tier, was carried out and is included in Strategic Settlement Evaluation Paper 11 and associated Appendix (March 2016). This was then built upon within the Housing Evaluation Framework, including the main towns, and used to inform the Strategic Housing Allocation (see Technical Supplement 3: Housing and associated Appendix E).

Housing unit completions Housing completions should not be deducted from the housing allocation at all or only those from 2015 should be deducted given this is the start of the plan period.

The SPPS states that housing allocations should be informed by allowance for existing housing commitments, and that Councils should take account of dwellings already constructed, approvals not yet commenced and residential development proposals likely to be approved.

Completions from 2012 have informed the notional housing allocation as the period of the relevant HGI period relates to 2012-2025. Dwellings built from then until 2018 (the date of the latest Housing Monitor prior to the publication of the draft Plan Strategy) have therefore been deducted from the housing allocation figures.

Existing housing commitments (live permissions) Account has not been taken of an existing housing commitment in Cargan.

The site referred to had expired according to housing monitor records. Approval has since been granted on the site. Moving forward therefore it will be considered as an existing commitment and will contribute to the notional housing allocation.

Urban Capacity Study Lack of adequate realistic urban capacity sites to provide sufficient housing lands to cover likely housing requirements. Site put forward as an urban capacity site for housing in Ballymena.

Urban capacity sites are not solely being relied on to meet housing requirements, as illustrated in Figures A4-A6, pages 323-325 of the draft Plan Strategy. Whilst it is accepted that not all sites may be suitable there is still a significant ‘cushion’ over and above the notional allocation in existing settlements. The site referred to in the representation is located within the existing

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settlement limit of Ballymena, however it is located outside the urban footprint as it is not considered to be part of the continuous and built up form.

Urban Capacity Study did not consider deliverability: many of the sites identified will not come forward.

As part of the Local Policies Plan process the status of sites will be re-examined to consider their potential for housing. It is not anticipated every urban capacity will come forward, but this is not being relied upon given the oversupply of housing identified within the Borough.

Urban Capacity Study did not consider policy constraints, access considerations, surrounding context etc. and amenity land is included.

The Urban Capacity Study provisionally assessed sites for their suitability to support housing development, including consideration of constraints. This will be refined as part of the Local Policies Plan process through consultation with statutory/non-statutory bodies. The sites referred to as amenity land were previously developed Northern Ireland Housing Executive housing that have temporarily been left as open space. Further information on the methodology of the Urban Capacity Study including the selection and assessment of sites is included within Technical Supplement 3, Appendix I Urban Capacity Study, Section 5.0.

Urban Capacity Study implies there is no need for any additional lands.

Urban capacity studies are required by the SPPS to inform the allocation of housing land. The interim study provides an initial assessment of the potential future housing land within the urban footprint of main and small towns.

Housing Needs Assessment/Housing Market Analysis Social housing need should be included in the overall estimates of housing requirements and land allocated accordingly.

Affordable housing needs, including social rented housing needs, will be addressed through SGS5 and Policy HOU5.

There should be flexibility to the housing allocation figures over the plan period to account for existing or arising affordable housing need.

Flexibility is built into the draft Plan Strategy through the identification of a housing land supply that exceeds the notional housing allocation and through the required review process to ensure it is fit for purpose. SGS5 allows for flexibility in the small towns in relation to affordable housing as it states that 'where urban capacity sites or windfall potential would not meet the affordable housing need identified by NIHE, additional land may be zoned where it is sustainable to do so and it is not reasonable for the need to be met in a nearby settlement'.

Delivery/lack of available land The overall housing supply relies on a significant number of longstanding sites that have not delivered houses to date.

It is acknowledged that there are a number of longstanding sites and there could be numerous reasons why such sites have not come forward. However, they are not the only potential source for housing supply. During the plan review stage of the LDP, Council will consider the level of commitment and investment made by landowners to release and progress delivery of phase 1 housing land to provide an adequate and available housing land supply.

Not all sites identified in the Housing Monitor as part of the potential housing land supply may be suitable, available and deliverable; therefore a 5 year supply cannot be maintained.

The Housing Monitor includes sites already with planning permission and undeveloped zoned sites, it does not contain uncommitted whiteland. Council’s assessment of the potential land supply therefore undertook a more extensive analysis than the Housing Monitor, see pages 322 to 325 of the draft Plan Strategy for further detail. Figures A4-A6 on pages 323 to 325 55

indicate a potential housing land supply in excess of the notional housing allocation. Further assessment of the potential sites will be carried out as part of Local Policies Plan process.

Given the extent of the oversupply Council is currently content that a 5 year supply can be maintained.

Contrary to the RDS and SPPS there is an ongoing lack of housing supply in the Borough, therefore there is a lack of adequate and available land supply in a number of the Borough’s settlements.

The level of existing commitments in settlements, which largely meets the notional housing allocation for settlements, indicates provision of an ongoing supply.

In the main towns initial assessments, see Figure A4 page 323 of the draft Plan Strategy illustrates a potential land supply in excess of the notional allocation from various sources. As part of the Local Policies Plan process the status of existing approvals and the capacity of settlements will be examined further. It is accepted that not all sites may be suitable. However, given the extent of the oversupply the Council is content at this stage that land supply should not be an issue in the main towns.

Council is aware that there is limited capacity within some of the small towns, particularly in relation to affordable housing need. SGS5 however, makes provision for any deficit in small towns to be addressed through the zoning of additional land if it is sustainable to do so as part of the Local Policies Plan process.

In the villages as illustrated on Figure A6, page 325 of the draft Plan Strategy there is a potential land supply in excess of the proposed allocation in the majority of cases. As part of the Local Policies Plan process the status of existing approvals and the capacity of settlements will be examined further. In relation to villages with limited capacity, Council will consider how to sustainably achieve their notional allocation.

5 year supply A housing trajectory should be provided to demonstrate how housing will be delivered and to ensure there will be a 5 year housing supply.

Council is content that there will be a 5 year supply at all times to 2030 and the plan review stage will address this issue, prior to 2030. The availability of housing land will be assessed further through the Local Policies Plan process to ensure shortages do not arise and should further land be required this can be addressed through the provision of SGS5 parts c) and d).

The extent of over-supply especially in the main towns should safeguard against this.

Consider build rates Housing allocation should take account of local evidence, particularly build rates.

Past build rates are not the key issue. The key issue is the future build rates needed to meet the anticipated housing need over the remainder of the plan period. The draft Plan Strategy is based on evidence of likely future growth rather than aspirations that are likely to be unrealistic.

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Housing allocation is insufficient when compared to past build rates, so the supply of housing land will be restricted and also a 5 year supply will not be maintained.

SGS3 will not constrain the supply of housing land as it is a ‘notional’ housing allocation that will be applied in tandem with SGS5.

Pages 323 – 325 of the draft Plan Strategy highlight that there are potential sources of housing over and above the notional housing allocation including urban capacity and windfall sites, and in many settlements, these significantly exceed the notional housing allocation. This demonstrates that the housing allocation figures are not restrictive.

Whilst it is accepted that not all sites may be suitable there is still a significant ‘cushion’ over and above the notional allocation in existing settlements and Council is content that there will be a 5 year supply at all times to 2030 and the plan review stage will address this issue, prior to 2030.

Overzoning Council should have regard to the need for over zoning by a percentage of the final agreed housing requirement figures.

Council do not consider this to be necessary as the housing land supply exceeds the notional housing allocation to settlements based on the HGI in the majority of settlements. The draft Plan Strategy allows for over zoning as it proposes to zone suitable uncommitted urban capacity sites in the urban footprint of main and small towns irrespective of allocation. Existing commitments can be developed and for many settlements, this exceeds the allocation.

Consider inward migration/population The draft Plan Strategy relies on the HGI, which was influenced by a recessionary period and underestimates population growth, particularly migration. The data which informs the HGI in relation to population and migration has not been interrogated.

It is understood that HGI’s are based on household projections and they provide an estimate of future housing need and are therefore only to be used as a guide. It is accepted that the HGI is the broad parameter for the housing allocation process in the Borough. Council is content that housing land supply exceeds housing allocation to settlements based on the HGI. Whilst it is accepted that not all sites may be suitable, there is still a significant ‘cushion’ of potential sources of housing land supply over and above the notional allocation in existing settlements, as illustrated on pages 323 to 325 of the draft Plan Strategy to deal with variants such as population and economic factors.

The methodology which accompanies the publication of the HGI’s illustrates that the starting point used to calculate the HGI is household projections, which includes population projections.

These population projections include a net estimation of international and cross border inflows and outflows. Given that Council has taken account of the HGI it is therefore content that population and migration have adequately informed the notional housing allocation figures within the draft Plan Strategy.

Council will continue to monitor whether there is sufficient housing land through the Local Policies Plan process. In addition, housing allocation will be reviewed through the plan review, prior to 2030.

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Consider economic factors By relying on the HGI the important relationship between housing and the economy has not been adequately explored.

Future employment projections do not suggest significant growth in jobs over the plan period, and there is no evidence to support future household growth above that anticipated by the HGI. Nevertheless, the potential housing land supply exceeds the notional housing allocation to settlements based on the HGI and therefore there is sufficient flexibility for the LDP to react to changing economic circumstances.

Council will continue to monitor whether there is sufficient housing land through the Local Policies Plan process. In addition, housing allocation will be reviewed through the plan review, prior to 2030.

Consider locational needs or regional policy The Strategic Housing Allocation has been a mathematical exercise with limited appreciation of specific locational needs or regional policy.

The broad methodology used for the strategic housing allocation followed the requirements of the SPPS, is based on robust evidence and is considered sound. Whilst there is an element of the Housing Evaluation Framework that includes mathematical calculations, the information which informed these is based on detailed settlement evaluations which considered various aspects.

Consider relationship with Belfast Housing allocation should have considered the relationship between Mid and East Antrim and Belfast, which has ambitious plans for growth.

The evidence base appears not to have been informed by a Council specific or Belfast Metropolitan Area wide Housing Market Analysis by NIHE or others.

Council followed the requirements of the SPPS in the allocation of housing, and the distribution represents a proportionate approach to the three main towns in the Borough. Council has engaged with Belfast City Council and other Councils through the Metropolitan Area Spatial Working Group and with neighbouring Councils throughout this process and will continue to do so.

Belfast City Council are proposing to accommodate new housing entirely within their own Council area as they have identified sufficient capacity. Belfast City Council consider this is the most sustainable option given their volume of brownfield land. It will reduce commuting into Belfast via the private car and will encourage walking and cycling. They do not consider it necessary to overspill new housing into the Mid and East Antrim Council Area.

A sound understanding of the functional housing market area is important when developing housing policies. The SPPS states that the NIHE will carry out the Housing Market Analysis required to inform the LDP. In the absence of an up to date Housing Market Analysis the Council have had regard to The Mid and East Antrim Housing Market Analysis Update (June 2018) prepared by NIHE. The implications of any up-to-date housing market analysis for the Ballymena and Belfast Housing Market Area will be considered when available.

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Consider infrastructure Housing allocation should consider that local WwTW infrastructure capacity issues may hinder development in some settlements.

WwTW capacity is considered as part of the Housing Evaluation Framework. WwTW capacity is subject to ongoing change and if it arises that a settlement has capacity constraints there are options for development relying on non-mains wastewater infrastructure under Policy WWI1.

Transport issues Deferral to Local Policies Plan stage of a full analysis of the problems and opportunities associated with Transport Assessments at main hub level may result in housing allocations that are too low to justify the scale of expansion necessary for developer led transport schemes.

Council agree that the LDP is an opportunity to assess transport needs, problems and opportunities and acknowledge an assessment of transportation is a factor in arriving at housing allocation. However, as the LDP and the Local Transport Strategy/Study are both 2 stage processes, full analysis of individual schemes and sites cannot be completed until the Local Policies Plan process, in conjunction with DfI’s Local Transport Plan.

The draft Plan Strategy has fully considered transport matters at a strategic level, with further analysis to be undertaken as part of the Local Policies Plan process. The Transport Test element of the Housing Evaluation Framework has also been fully considered as part of the evidence base for the housing allocation. Council consider the viability of any specific nonstrategic transport scheme is inappropriate to discuss at draft Plan Strategy stage. Comments on specific sites are a matter for the Local Policies Plan process.

Too much housing/concern about environment Tension between more housing and finite environmental capacity.

SPPS states that sustainable development is at the heart of the SPPS and the planning system.

Planning authorities are required to deliver on all three pillars of sustainable development in formulating policies and plans. This requires the integration and balancing of complex social, economic and environmental factors when plan-making. SPPS paragraph 3.3 states that this includes facilitating sustainable housing growth in response to changing housing need (including delivery of social and affordable homes). The draft Plan Strategy aims to provide sufficient land to meet anticipated needs for housing that all new development is of high quality and located in suitable places i.e. where the development proposal can help meet economic and social needs without compromising the quality of the environment (often referred to as sustainable development). The proposed housing allocation is based on a sound evidence base. Consideration of settlement limits and zonings is a matter for the Local Policies Plan Process.

Introductory paragraph 5.3.4 is not restrictive enough and could allow manipulation of projected totals particularly in countryside areas.

Paragraph 5.3.10 on page 63 of the draft Plan Strategy notes that the allocation of housing in the open countryside does present a challenge. However, the operational strategic subject policies for residential development in the countryside in part 2 of the draft Plan Strategy have been designed to provide opportunities for the sustainable development of mainly single 59

dwellings. However, it is not possible to accurately predict or control the number of rural opportunities likely to come forward over the plan period.

Miscellaneous Questioned if the RDS approach may be wrong and the impact on Carrickfergus.

The LDP is specifically required under the Planning (Northern Ireland) Act 2011 to take account of the RDS. It is the role of the LDP to ensure that the conditions are in place to encourage growth in the identified hubs, with opportunities in relation to employment etc. normally being directed/provided for within the larger settlements and this has been reflected in the Strategic Housing Allocation Strategy for the Borough.

Remaining potential within villages cannot be assessed as no maps/evidence have been provided.

For villages the 'remaining potential within settlement limits' is an estimate from remaining whiteland within existing settlement limits, and Technical Supplement 3: Housing highlights that it is not a conclusion on the suitability/availability of lands for housing, nor does it serve to provide a determination that planning permission for housing or housing of this quantity would be granted. Such lands will be further investigated through the Local Policies Plan process.

The SPPS only requires Council to carry out an urban capacity study of settlements at 5000+ population, and none of the settlements within the village tier met this threshold.

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SGS4 Protection of Zoned Housing Land Responses received Reference

Respondent

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which will protect housing land, in order to meet housing need over the Plan period.

Support for the proposed policy approach is welcomed.

Clarify if policy exceptions apply to both phase 1 and 2 of housing land.

The wording of SGS4 is considered self-explanatory and applies to both phase 1 and 2 lands.

Protection of current housing sites, prior to Local Policies Plan adoption that do not meet the sequential test is undesirable. Sustainable development should be a material consideration in their assessment.

The intent of the policy is not to protect existing zonings. The justification and amplification states that sites will be selected for zoning, and where applicable phasing in the Local Policies Plan and it is these sites that will be protected.

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SGS5 Management of Housing Supply Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-012

Donaldson Planning on behalf of Ballymena Development Consortium

MEA-DPS-013

Donaldson Planning on behalf of Individual

MEA-DPS-020

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-035

Inaltus on behalf of Galgorm Group

MEA-DPS-037

Inaltus on behalf of N.K. Holdings Ltd

MEA-DPS-055

Pragma Planning on behalf of Carnlough Dev Ltd

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-061

Individual

MEA-DPS-062

TC Town Planning on behalf of Individual

MEA-DPS-066

TSA Planning on behalf of Lotus Homes

MEA-DPS-067

TSA Planning on behalf of Rosemount Homes

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-077

Turley on behalf of Vaughan Homes

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Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy approach and the windfall assessment. Specific support for the approach that allows additional land to be zoned for housing if it is sustainable in small towns such as Whitehead.

Support for the proposed policy approach is welcomed.

Support also for not zoning housing land in villages and small settlements but it is suggested that this text is included in the policy box of SGS5.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor alterations to the policy wording should be made – see Schedule of Proposed Modifications – Reference Number PM-008.

Phasing Phasing considered unnecessary as land for housing will be restricted and growth constrained. An in-depth rationale as to the need for phasing has not been provided and how this could impact on the delivery of housing in the main towns has not been interrogated.

Phasing is necessary in order to actively manage the release of legacy housing zonings and whiteland outside the urban footprint of the Borough’s four largest towns, especially in Ballymena. It will only restrict development for housing in the urban fringe of main towns and Greenisland in the short term. Phasing will ensure that the RDS/SPPS approach to sequential housing development is carried through in the interest of sustainable development and achieving compact urban forms. During reviews of the LDP, consideration will be given to the level of commitment and investment made by landowners to release and progress delivery of phase 1 housing land.

Council consider that if a landowner seeks and gains permission for housing this land should be considered available and as such it is considered that it should be identified as phase 1 housing land within main towns and Greenisland, where the site is of 0.2 hectares or above or could accommodate 10 or more dwelling units. As currently written paragraph 5.3.28 identifies that during reviews of the LDP, consideration will be given to the level of commitment and investment made by landowners to release and progress delivery of phase 1 housing land. At the time the draft Plan Strategy was published existing approvals in the main towns had largely already met their notional housing allocation.

Unclear how phasing pertains to the housing allocation for each town e.g. what proportion of the allocation is for phase 1 and phase 2 and what mechanism is there for release of phase 2 land where phase 1 is land banked.

At the time the draft Plan Strategy was published existing approvals in the main towns had largely already met their notional housing allocation (see Figure A4 Appendix A of the draft Plan Strategy). Where live approvals fall a little short in Carrickfergus and Larne there are a large number of potential urban capacity sites that could help meet the allocation. As set out in SGS5 live permissions and previously developed and undeveloped land within the urban footprint will be zoned as phase 1 housing land through the Local Policies Plan process.

Paragraphs 5.3.28 and 5.3.29 of the draft Plan Strategy set out that the progress of the release of phase 1 housing lands will be considered during plan reviews as will the potential to release phase 2 land to meet affordable housing needs where it has been demonstrated that there is insufficient uncommitted phase 1 land.

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However, in light of the comments made, for clarity, Council suggest additions to the policy wording should be made – see Schedule of Proposed Modifications – Reference Number PM007.

Phasing approach may favour small towns.

The policy is required to be worded as laid out to comply with the RDS that requires the adoption of a sequential approach for the release of housing land within settlements over 5,000 population in the interests of achieving compact urban forms. Furthermore, the yield of housing units from the main towns should be of a greater volume than the small towns.

Amend policy- Phasing of housing should correlate with sufficient WwTW infrastructure capacity.

This is not considered to be necessary given the changing nature of WwTW capacity. If there is not adequate WwTW capacity the development will still have to meet Policy WWI1 Development Relying on Non-Mains Wastewater Infrastructure.

Approach fails to consider areas outside settlement limits which may deliver benefits and help meet other objectives. Phase 2 land should include urban fringe land outside of existing settlement limits.

Considering areas outside settlement limits where there is scope to meet housing needs within the settlement limit would be contrary to RDS/SPPS direction. There is currently enough capacity in the urban fringe of main towns to avoid having to extend settlement limits. In other settlements, sites outside of existing settlement limits will be considered, where there is insufficient capacity within the settlement to meet either the housing allocation to 2030 or affordable housing need.

Deliverability Fails to consider deliverability.

Council consider that if a landowner seeks and gains permission for housing this land should be considered available and as such it is considered that it should be identified as phase 1 housing land within main towns and Greenisland, where the site is of 0.2 hectares or above or could accommodate 10 or more dwelling units. As currently written, paragraph 5.3.28 identifies that during reviews of the LDP, consideration will be given to the level of commitment and investment made by landowners to release and progress delivery of phase 1 housing land.

Similarly, in the remaining small towns, it is considered reasonable to zone those sites which at the time of the Local Policies Plan benefit from live planning permission as it is considered that these sites are available with a degree of commitment. At the time the draft Plan Strategy was published existing approvals in the main towns had largely already met their notional housing allocation. This was also the case for the majority of small towns save for Ahoghill and Whitehead.

Amend justification and amplification to ensure all land is available before zoning and there is commitment for sites with live approvals.

Council consider that if a landowner seeks and gains permission for housing this land should be considered available and as such it is considered that it should be identified as phase 1 housing land within main towns and Greenisland, where the site is of 0.2 hectares or above or could accommodate 10 or more dwelling units. As currently written paragraph 5.3.28 identifies that during reviews of the LDP, consideration will be given to the level of commitment and investment made by landowners to release and progress delivery of phase 1 housing land.

Similarly, in the remaining small towns, it is considered reasonable to zone those sites which 64

at the time of the Local Policies Plan benefit from live planning permission as it is considered that these sites are available with a degree of commitment. As wastewater infrastructure capacity can change through time and may be upgraded during the plan period or alternative temporary solutions put in place, it may be unreasonable to discount such sites at Local Policies Plan stage.

Existing zonings Housing Evaluation Framework should be applied to the designation of undeveloped zoned land to ensure all zonings brought forward further sustainable development. Such lands should not be automatically carried over.

Existing uncommitted zoned housing land outside the urban footprint will be assessed along with other potential phase 2 land.

New sites should be zoned to direct future development, rather than zoning existing planning permissions.

As lands with planning permission can be developed immediately, it is not realistic to ignore this. SGS5 attempts to ensure that the most sustainable sites in the urban footprint are developed first (as phase 1 housing land). The extent of phase 2 lands will be further considered through the Local Policies Plan process. The LDP will not be zoning in small settlements.

Figure A5 in Appendix A of the draft Plan Strategy demonstrates that current live approvals already meet the notional housing allocation for Cullybackey. In addition, there is also significant urban capacity potential for Cullybackey much greater than any other small town.

Some urban capacity sites to be zoned will not have planning permission. New zonings will be required in some settlements e.g. Broughshane and Whitehead – to meet shortfalls in relation to their housing allocation and affordable housing need. There is potential for some phase 2 land in main towns to be new zonings. Paragraph 5.3.28 of the draft Plan Strategy sets out in the justification and amplification of Policy SGS5 that during reviews of the LDP, consideration will be given to the level of commitment and investment made by landowners to release and progress delivery of phase 1 housing land. Where no demonstrable progress has been made, consideration will be given to re-designating the land at review stage. The re-zoning of specific sites is a matter to be considered through the Local Policies Plan process.

Existing zonings in Larne West are not sustainable locations, the LDP presents an opportunity to select sustainable sites.

The housing zonings in Larne West continue to be developed and the majority have now gained planning approvals. A legacy of approvals should substantially help meet the notional housing allocation in main towns and Greenisland assisted by a substantial number of urban capacity sites within the urban footprint of these settlements (both of which will be zoned for phase 1 housing). In the remaining small towns where land has to be selected to be zoned for housing, priority will be given to sites accessible to community facilities/services and public transport.

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Existing planning permissions Consider the merit of making an allowance to account for not all existing commitments being built.

Existing commitments (dwelling units with live planning permission) are considered to be an available land supply. Table A3 on page 321 of the draft Plan Strategy indicates there is potential for the existing live residential planning permissions in settlements (2018) to deliver the majority of the housing growth requirements for the Borough until the end of the plan period.

It is accepted that not all these commitments will be built, potentially around 10% less. Such a scenario is set out in Table 4 on page 8 of the Further Evidence Report- Housing. As progress is made through the LDP process some may lapse and other planning permissions will be forthcoming. This will be reviewed at Local Policies Plan stage.

However, at this stage it is worth noting the level of additional potential with existing settlements as a result of the legacy of previous area plans. Table 4 on page 8 of the Further Evidence Report- Housing illustrates that there is potential for a further 5,667 units from windfall, urban capacity sites (in main and small towns) and settlement capacity sites (in the villages). This far exceeds the remaining allocation of 582 not met by existing commitments (minus 10%). Of this total, a potential of 3,585 units lie within main towns and 511 units within small towns. In addition, further substantial potential exists within the urban fringe of these settlements, particularly in main towns. It is anticipated that these various sources of housing land supply within existing settlements will help compensate for any live residential planning permissions that do not come forward and provide flexibility and choice. Exceptionally, if supply is limited additional land may be identified at Local Policies Plan stage in order to provide sufficient flexibility and avoid over-reliance on extant approvals alone to deliver the housing allocation at the level of individual settlements.

Consider if assigning all live permissions to phase 1 supports sequential approach.

Accepted that approvals in the urban fringe being designated as phase 1 will not immediately assist the creation of compact urban forms. However, this is unavoidable given the legacy of existing area plans. To have live approvals zoned as phase 2 lands could add confusion.

Tighten approach to avoid undermining sustainability Prematurity- allowing additional sites to come forward could lead to a rush in ad-hoc planning applications being submitted to secure a phase 2 zoning at the draft Local Policies Plan stage. This could prejudice the sustainable approach to development.

It is difficult to prevent this pre-adoption. Due to the two stage nature of the LDP, zonings and phasing are not identified until Local Policies Plan stage. The need to refuse on the grounds of prematurity will be monitored. In addition, it should be noted that since the draft Plan Strategy was published in September 2019, Council have not received an influx of applications to date.

In introductory paragraph 5.3.15 of SGS5, there is insufficient strategy for the clawback of the over approval rate.

The LDP has to deal with the legacy of existing extant plans. It aims to actively manage the release of this legacy of housing zonings and whiteland outside the urban footprint of main towns and Greenisland by holding it in reserve as phase 2 housing land at Local Policies Plan stage. The extent of urban fringe sites in the remaining small towns is significantly lower. In the case of Ahoghill and Broughshane such sites in the urban fringe may be required to meet 66

the social rented need. Council is not in a position to revoke planning permissions for sites within settlement development limits.

Zoning land in small towns for housing where there are live permissions combined with many settlements exceeding their allocation may result in an over provision of housing land – the provisions of paragraph 5.3.20 of the draft Plan Strategy should be revisited.

It is accepted that in main towns there is an over provision but SGS5 aims to phase development so as to release the most sustainable sites first.

The LDP has to deal with the legacy of existing extant plans. It aims to actively manage the release of this legacy of housing zonings and whiteland outside the urban footprint of main towns and Greenisland by holding it in reserve as phase 2 housing land at Local Policies Plan stage. The extent of urban fringe sites in the remaining small towns is significantly lower. In the case of Ahoghill and Broughshane such sites in the urban fringe may be required to meet the social rented need. The LDP cannot put an embargo on granted planning permission for sites within the settlement development limits and valid planning approvals have to be honoured.

Miscellaneous issues Amend policy/justification and amplification to clarify the relationship between Policy HOU1 and SGS5 and phasing.

Council note the issue and consider the draft Plan Strategy to be sound. Paragraphs 1.7.4, 1.7.5 and 1.7.8 of the draft Plan Strategy state that the LDP should be read in its entirety with no one policy read in isolation. For example, Policy HOU1 would apply to any housing site whether it is zoned land (phase 1 or phase 2) or unzoned land. There could still be a presumption to refuse planning permission for Phase 2 sites on the grounds of prematurity and prejudice to the sequential approach to housing development in settlements over 5,000 population under SGS5. In the event of a successful appeal, Policy HOU1 would be needed to ensure quality development on such sites. However, in light of the comments made, for clarity, Council suggest minor additions to the policy of SGS5 and justification and amplification wording of Policy HOU1 – see Schedule of Proposed Modifications – Reference Numbers PM006 and PM-100.

Clarify if paragraph 5.3.29 in justification and amplification is actually policy for providing for the development of phase 2 land before LDP amendment.

In light of the comment made, for clarity, Council suggest additions to the policy – see Schedule of Proposed Modifications – Reference Number PM-007.

Clarify criteria for identifying suitable previously developed/ undeveloped land in urban footprint at Local Policies Plan stage.

Council consider that the urban capacity sites identified through the urban capacity study are already in sustainable locations given they are situated in main or small towns within the urban footprint e.g. services, amenities, employment opportunities, public transport will be in close proximity given the relatively small size of these settlements. The urban capacity sites will be further assessed and consulted on to ensure they are free from development constraints e.g. access, flooding and topography. This will help refine the potential yield from individual sites.

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Approach unsound as Housing Allocation process is based on old area plans.

The approach is considered sound as it is based on RDS/SPPS direction to deliver most housing development in the most sustainable locations and adopt a sequential approach to housing development in order to: 

maintain compact urban forms and avoid urban sprawl;



maximise re-use of previously developed land; and



locate housing close to the town centre, public transport and services.

The approach is not based on old plans. Old development plans (e.g. Ballymena Area Plan) did not define urban footprints and seek to manage housing development in line with the RDS/SPPS. Amend policy to include further criteria to prioritise land with good transport to surrounding employment and service centres.

Paragraph 5.3.27 in the draft Plan Strategy highlights that when determining phase 2 lands to be released for phase 1 in main towns and Greenisland account will be taken of its accessibility to the town centre (where there may be employment opportunities) and core services. In the remaining small towns where there is a need to zone housing, in addition to sites with live approvals/proposals likely to be approved/sites within the urban footprint, accessibility to community facilities/services and public transport will be one of the criteria used to assess the priority of sites.

A number of indicators were suggested to be considered when examining existing settlement limits so that the full potential of SGS3 and SGS5 is met.

Amendments to settlement limits where required will be considered through the Local Policies Plan process, taking account of a number of factors including the strategic direction in SGS5.

Designating limits should be consistent with estimated windfall component.

Comment noted.

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Miscellaneous comments on Strategic Housing Allocation Strategy Responses received Reference

Respondent

MEA-DPS-023

Gravis Planning on behalf of Conway Estates Ltd

MEA-DPS-024

Gravis Planning on behalf of Conway Estates Ltd and Individuals

MEA-DPS-027

Gravis Planning on behalf of Individual

MEA-DPS-028

Gravis Planning on behalf of Individual

MEA-DPS-029

Gravis Planning on behalf of Individual

MEA-DPS-030

Gravis Planning on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Ballymena Area Plan is almost 20 years out of date and likely to be around 23 years or more out of date by the time the LDP is fully adopted.

Council's research has demonstrated in Figure A4, Appendix A on page 323 of the draft Plan Strategy that there is estimated to be a significant additional amount of land within the existing settlement limit of Ballymena, exceeding the notional housing allocation figure. There is also a significant additional amount of land within the existing settlement limit of Kells and Connor exceeding the notional housing allocation figure (see Figure A6, Appendix A on page 325 of the draft Plan Strategy).

It was designed to provide enough housing land to meet the projected needs of the Council area up until 2001, not 2022 and beyond. With a rising population trend across the Borough since this time there is a significant shortfall of land remaining within the settlement limits of Ballymena and Kells and Connor under the area plan to provide “adequately” for the housing needs of these settlements before the adoption of the next LDP in 2022 or longer if delays occur.

The Urban Capacity Study carried out a robust analysis of potential capacity within Ballymena and Kells and Connor and exact numbers will be refined as part of the Local Policies Plan process.

At present Council is content that there is a sufficient amount of land to address the housing needs of Ballymena and Kells and Connor up to 2030.

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The Larne Area Plan is out of date and was designed to provide land up to 2010, not 2022 and beyond.

With a rising population trend across the Borough, there is a significant shortfall of land within the settlement limits of Ballygalley and Glenarm to provide adequately for the housing needs of the settlement before the adoption of the next LDP or indeed longer if delays occur.

It is agreed that there would appear to be insufficient land in the existing settlement limit of Ballygalley to meet the notional housing allocation, however, this will be assessed further through the Local Policies Plan process.

In Glenarm the status of sites within the existing settlement limits will be re-examined as part of the Local Policies Plan process to consider their potential for housing.

In either case, should further land be required this can be addressed through the provision of SGS5 parts c) and d).

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5.4 Economic Development Strategy SGS6 Strategic Allocation of Land for Economic Development Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-007

Individual

MEA-DPS-009

Department for the Economy

MEA-DPS-010

Department for Infrastructure

MEA-DPS-020

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-036

Inaltus on behalf of Individual

MEA-DPS-037

Inaltus on behalf of N.K. Holdings Ltd

MEA-DPS-038

Invest NI

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-053

O'Connor Kennedy Turtle on behalf of Individual

MEA-DPS-065

TSA Planning on behalf of Individual

MEA-DPS-068

TSA Planning on behalf of Silverwood Business Park Ltd

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for Economic Development Strategy (EDS) approach

Support for the EDS is welcomed.

Question approach and if vacant or under-utilized lands last used for economic development should only be included if within the urban footprint. Also, question if this land was discounted as possible housing land.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as it is consistent with paragraph 6.89 of the SPPS which uses terms such as ‘well located and suited to such purposes’ and ‘unzoned land within settlements’ whilst paragraph 6.93 then refers to 'within settlements' generally.

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Council would therefore question why vacant or underutilised industrial land outside the urban footprint but ‘well located and suited to such purposes’ within the settlement limit would not be encouraged for economic re-use, or considered for housing land at this stage of the LDP process as such an approach would be inconsistent with existing policy to protect former industrial sites within settlements for economic use where possible rather than lose to other non-industrial uses.

Question EDS approach regarding ‘sufficient amount of land’ which suggests there is unlikely to be any new economic land use zonings.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as all that has been presented at this strategic stage is the gross amount of economic land to be allocated across the three towns. This is well in excess of the amount of economic land anticipated to be required over the Plan period, but ensures the SPPS regional strategic objective of ensuring a generous supply of available economic land is met.

Although extensive work has been carried out in relation to constraints and the delivery of each zoned site in the extant plans, this information will not be finalised until Local Policies Plan stage and as part of the completion of the RDS Employment Land Evaluation Framework (ELEF) stages as stated in the draft Plan Strategy. As stated in paragraph 5.4.11 of the draft Plan Strategy, new sites will also be zoned as part of the Local Polices Plan process, Council will not simply be relying on previously zoned land as suggested by the respondent.

Question approach of an EDS from which policies don’t logically flow and which does not set out clearly where future industrial land will be accommodated.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as the EDS makes it clear that economic land will be zoned within the three main towns in the Borough.

The economic policies support the EDS approach in relation to where appropriate economic development will be accommodated and assessed in towns, other settlements and in the countryside.

Question flexibility of EDS approach and assessment of existing zoned land remaining undeveloped.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as Council have stated in the draft Plan Strategy that new economic land is required in Ballymena and will be making provision for that. Initial work has been carried out in relation to the delivery of undeveloped zoned land including any constraints on these lands which may prevent development.

Lack of evidence base and methodology behind the allocation of economic development land without the benefit of an ELEF Stage 3 assessment.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Technical Supplement 5 states that the commissioned studies, the Industrial Monitor and Stage 1 and 2 ELEF have been used primarily as the basis for allocation, but that parts of Stage 1 of the ELEF remain to be completed as part of the Local Policies Plan process. Council also remain of the view that Stage 3 of ELEF is appropriate for the Local Policies Plan process and that the draft Plan Strategy is only for strategic matters.

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Question methodology behind the allocation of economic development land and propose a revised allocation of economic land based on the population in each town.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Whilst Council acknowledge there is a link between the size of a town and its economic development, it would not consider population to be the primary basis for the quantity of economic land to be allocated to a town. Other factors such as the economic activity of a town, the accessibility and attractiveness of its location for economic development, as well as the availability of land and buildings for economic development, are all factors which should feed into the mix for allocating economic development land.

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5.5 Retail Strategy SGS7 Retail Hierarchy Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-007

Individual

MEA-DPS-010

Department for Infrastructure

MEA-DPS-033

Inaltus on behalf of Bridge Park Development Ltd

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Village centres should rank above local centres in the retail hierarchy to align more with settlement hierarchy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Local centres were positioned to follow town centres and small town centres in the retail hierarchy as they are normally located within large or small town settlement limits. Villages and small settlement centres serve rural communities outside of town centres and were therefore positioned after all tiers associated with town settings.

Representations supporting the proposed Retail Hierarchy in the Preferred Options Paper (POP), which included suggested district centres were not taken into account.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. While the preferred option identified in the POP was designed to largely align with the proposed settlement hierarchy, the assessment undertaken by Councils’ retail consultants identified that in practical terms the retail hierarchy of centres deviated slightly from the proposed settlement hierarchy, recommending a four-tier retail hierarchy of town centres, small town centres, local centres and village centres. All potential local or district centres were considered however, none of the centres were found to fall within the definition of a district centre so this tier was omitted from the LDP Retail Hierarchy.

Suggest the hierarchy of centres should include district centres. If a shopping centre complements the town centre and is the focus for local day-to-day shopping (i.e. convenience shopping) then it can be considered as a district centre.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council interpret the SPPS reference to defining a network and hierarchy of centres as intending to define such centres where they exist in the Borough as opposed to identifying locations to fit each of these labels.

Strategy does not include a robust assessment of need and subsequent designation of district centres.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council have a robust evidence base in the Retail and Commercial Leisure Need & Capacity Study, which includes a report on the Retail Hierarchy. All potential local or district 74

centres were considered, whether suggested in the POP or identified by the consultants.

However, none were considered to fulfil the role of a district or local centre, so it was recommended that this tier be omitted from the LDP Retail Hierarchy.

Retail allocations should be designated at draft plan strategy stage.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The Retail Strategy and Retail Hierarchy are set out in part 5.5 of the draft Plan Strategy. However, designation of retail allocations such as town centre or local centre boundaries, being site specific in nature, will be addressed during the Local Policies Plan process. The evidence base available in the Retail & Commercial Leisure Needs & Capacity Study will be updated ahead of the Local Policies Plan.

The draft Plan Strategy should clarify if forecasted floorspace need can be entirely accommodated in preferred town centre locations.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The retail study outlines capacity/need for future convenience, comparison and leisure floorspace over four-year intervals and outlines in percentage terms how it would be distributed over the three main towns. However, specific sites to accommodate this floorspace will not be identified until the Local Policies Plan stage. Vacant buildings have been identified on the land use maps in the Technical Supplement 6: Retail, which showed a vacancy rate of 20.7% in Ballymena town centre in March 2018. This figure may be higher now given the economic impacts of the pandemic.

There are also large areas of vacant land existing in edge of town locations in Harryville, shown on Map 1 – Ballymena Industrial Monitor, Technical Supplement 5: Economic Development (Appendix B – Industrial Economic Land Monitor Report 2018), which would be sequentially preferable to an out-of-centre location. The extant town centre boundaries also have the opportunity to be adjusted through the Local Policies Plan process if necessary, and a 'call for sites' consultation exercise will take place ahead of the Local Policies Plan to assist in identifying available, suitable and viable Development Opportunity Sites.

Clarify difference in Portglenone’s position as a village in the Settlement Hierarchy and a small town in the Retail Hierarchy.

Council notes the issue and considers the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest an additional sentence be added to the end of paragraph 5.5.7 – see Schedule of Proposed Modifications – Reference Number PM-011.

Define 'necessary local services' in the Retail Hierarchy justification and amplification paragraph 5.5.8.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Table 5.6 describes the type of uses and functions acceptable in local centre and village centre tiers, commensurate to their role in the Retail Hierarchy.

Mixed Developments should be prioritised in all areas to include housing and business.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Retailing and town centres introduction text paragraph 7.2.9 explains how in addition to retail and town centre policies, the LDP will promote diversity in a range of town centre uses through housing policies HOU2 and HOU4 and Economic Policy ECD1 to facilitate class B1 Business uses.

Town centre analysis is required to identify unique properties and gaps.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Land use surveys were completed in March 2018. Maps and findings/recommendations are incorporated into Technical Supplement 6: Retail.

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5.6 Tourism Strategy SGS8 Tourism Strategy Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs (DAERA)- Natural Environment Division

MEA-DPS-007

Individual

MEA-DPS-008

Department for Communities - Historic Environment Division (HED)

MEA-DPS-009

Department for the Economy

MEA-DPS-010

Department for Infrastructure

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-055

Pragma Planning on behalf of Carnlough Developments Ltd

MEA-DPS-062

TC Town Planning on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the balanced approach between protecting built and natural assets and accommodating sustainable development.

Support for the proposed policy approach is welcomed.

Amend Proposal/Policy Aims of SGS8 to include additional bullet point, which goes wider than safeguarding assets or accommodating sustainable tourism in appropriate locations. The capacity of the road network, the infrastructure of the villages, the routes to and from the tourist assets, parking, and the spreading of the impact of tourism within the Council area deserve appropriate planning:

Council note the issue and consider the draft Plan Strategy to be sound. The Proposal/Policy Aims in the draft Plan Strategy are considered sufficient. The suggested aim is considered too cross-cutting and it is not one of the high level aims for Tourism in the SPPS.

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To support the planning and implementation of appropriate infrastructure in relation to Mid and East Antrim's tourist assets.

All text changes recommended in draft Habitats Regulations Assessment Report of the draft Plan Strategy, September 2019, pages 16-20, must be accepted in full to achieve conformity and meet the legal requirements of the Conservation (Natural Habitats, etc.) Regulations (NI) 1995 (as amended).

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor addition to the justification and amplification should be made – see Schedule of Proposed Modifications – Reference Number PM-012.

There is no obvious connection linking the policy to the categories of tourism potential in the justification and amplification.

The policy provides broad direction for tourism development. The justification and amplification pulls out the policy i.e. protection/safeguarding of tourism assets and identification of tourism growth areas. The justification and amplification is directional and provides helpful information.

Consider how much more development can be sensitively integrated in the tourism opportunity zone at Carnfunnock Country Park without compromising the integrity of its distinctive historic environment characteristics and adjacent Cairndhu.

Through the Local Policies Plan process, the tourism opportunity zone at Carnfunnock Country Park will be considered in detail. The areas of the site suitable for development will be identified in consultation with DAERA, HED and Council Tourism Team, ensuring that the setting and assets of the site are protected.

In identifying Carnfunnock as a tourism opportunity zone a balance will be met between permitting sustainable development and respecting the historical features within/adjacent to the site. This approach is reflected in Policy TOU2 para 7.3.11 which specifically states proposals within Carnfunnock Country Park should be sensitive to its coastal location and historic and natural features and also comply with Policy HE2.

Tourism should be supported as a key growth sector, and town centres should be a priority tourism asset.

Town centres are included within the urban area and therefore fall under the opportunity category of tourism potential in SGS8.

SGS8 supports tourism through the promotion of appropriate tourism development and identification of potential tourism growth areas.

LDP should take strategic approach to developing long-distance walking routes and a route in Larne is suggested.

Details of designated community greenways will be set out in the Local Policies Plan.

Alongside regional greenways these can provide multiple benefits including connectivity between tourism attractions and becoming a tourism attraction in their own right. Council consider it inappropriate to discuss site specific representations at draft Plan Strategy stage.

Comments on specific sites are a matter for the Local Policies Plan process.

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5.7 Transport Strategy Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-007

Individual

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-012

Donaldson Planning on behalf of Ballymena Development Consortium

MEA-DPS-038

Invest NI

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-063

Translink

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the Transport Strategy approach, Transport Objectives and Transport Measures.

Support is welcomed.

Support promotion of integrated transport and new development approach but express caution in relation to industrial sites.

Council acknowledge concerns but consider that efforts can still be made to improve linkages to economic development sites to encourage active travel without compromising safety.

Question wording used in Introduction paragraph 5.7.3. Updated wording suggested in order to be consistent with the draft Local Transport Study.

The wording used in paragraph 5.7.3 was the wording used in the latest draft Local Transport Study available at the time of going to print. Whilst Council consider the draft Plan Strategy to be sound, in light of the comment made, for consistency, Council propose to update the wording of paragraph 5.7.3 as suggested - see Schedule of Proposed Modifications – Reference Number PM-013.

Insufficient evidence base for the outcomes based approach of the draft Local Transport Study, in particular the second transport measure which states any road capacity schemes are to be developer led.

Council has been working closely with DfI in relation to road schemes within the Borough. DfI have confirmed that none of the legacy schemes are considered 'strategic' so these schemes, if required to be retained for capacity issues for future development, will now be considered 'non-strategic' schemes to be delivered by those developers whose developments may have an impact on future traffic flow and road capacity etc.

This is despite lack of assessment/evidence relating to the operation of the existing road network. Delaying this detailed assessment of the

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specific transport measures required to meet transport needs to a later stage of the LDP ignores the contribution which this element of infrastructure makes.

Any assessment of a specific road scheme is a matter for the Local Transport Plan, which is to be prepared by DfI in conjunction with the Local Policies Plan.

Lack of specific reference in Technical Supplement No. 9 to the Belfast Metropolitan Transport Study and the relationship to the wider Belfast Metropolitan Urban Area.

Technical Supplement 9 (paragraph 2.15) does refer to the Council's Local Transport Study relationship with the Belfast Metropolitan Transport Plan as part of the Belfast Metropolitan Urban Area.

Technical Supplement Appendix A - the draft LTS Introduction - also contains numerous references to the initial Belfast Metropolitan Transport Plan (BMTP) Local Transport Study (LTS) which has been prepared by DfI in collaboration with the Councils that fall, at least in part within the Belfast Metropolitan Urban Area (BMUA).

Council continue to sit on the BMTP Project Board and liaise with DfI in relation to the BMTP including the role Mid and East Antrim can play within the wider BMUA.

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5.8 Open Space Strategy SGS9 Open Space Strategy Responses received Reference

Respondent

MEA-DPS-001

Antrim and Newtownabbey Borough Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-007

Individual

MEA-DPS-020

Jobling Planning and Environment Ltd on behalf of Individual

MEA-DPS-042

Individual

MEA-DPS-043

MBA Planning on behalf of CYM Properties

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-055

Pragma Planning on behalf of Carnlough Developments Ltd

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the regional greenway corridors and the intention to provide a strategic policy framework for the provision of green and blue infrastructure.

Support for the proposed policy approaches is welcomed.

Amend policy- Add extra element to strategy to elevate the link between the community and nature through open space to read: Facilitating the link between the community and nature through existing and new areas of open space: The LDP will support firm proposals for existing and proposed public open spaces which cater for the education needs of children in particular and the community in general in relation to nature and wildlife.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

It is considered that the importance of the provision and access to open space in terms of its educational benefits has been generally captured within paragraph 5.8.1 of the strategy as well as within the third bullet point of the Policy Aims. Council consider it inappropriate to focus in on education only in the policy box as there are other issues e.g. obesity. It is noted that the SPPS does not single education out as a benefit.

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Provide policy for greenways to be funded by developer contributions and their delivery with housing.

Policy OSL2 Greenways sets out how community greenways will be supported. Policy OSL4 Public Open Space in New Residential Developments sets out how much open space is required in a particular development. In some cases this may take the form of a community or regional greenway. Policy OSL4 sets out that the developer will have to satisfy council that suitable arrangements will be put in place for the future management and maintenance in perpetuity of areas of public open space. Paragraph 8.2.16 of the justification and amplification of Policy OSL4 notes that where appropriate, planning agreements may be used to secure open space. A guidance framework on planning agreements and developer contributions will be developed by Council at some stage in the future.

Specific details within the UK Marine Policy Statement (MPS) (and Draft Marine Plan for NI) could be drawn out across common policy areas within the various strategies e.g. recreation is included within UK MPS (and draft Marine Plan for NI) but this or outdoor coastal recreation facilities is not referenced within the Open Space Strategy.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Coastal development will be considered under a range of policies including CS2 and CS6, and in both these policies direct reference is made to having regard to the UK MPS and the draft Marine Plan for NI.

Make specific mention to the marine area with the explanation of blue infrastructure.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Coastal development will be considered under a range of policies including CS2 and CS6, and in both these policies direct reference is made to having regard to the UK MPS and the draft Marine Plan for NI.

Do not support greenway route on disused railway between Greenisland and Mossley.

Council will continue to engage and work with our neighbouring councils on the cross-boundary issue of greenways.

Route of Ballymena to Cushendall regional greenway should be changed to take account of permission.

Council note the issue raised, however proposed greenway routes are a matter for further consideration through the Local Policies Plan process. The route of the proposed greenway on maps accompanying the draft Plan Strategy is indicative only. Where greenway routes are compromised alternative provision will have to be made.

Regional greenways should not stifle development.

Proposed greenway routes are a matter for further consideration through the Local Policies Plan process. The route of the proposed greenways on maps accompanying the draft Plan Strategy is indicative only.

Opportunity to develop comprehensive open space strategies and create open space network.

The open space network will be examined further through the Local Policies Plan process.

This will include identifying community greenways which will link existing and proposed open spaces and connect into the wider regional greenway network. In assessing this account will be taken of other Council Strategies such as the Cycling Routes Masterplan.

LDP must take account of the Greenway Strategy and the Cycling Routes Masterplan.

In preparing the draft Plan Strategy, account has been taken of DfI's Strategic Plan for Greenways (2016) and Councils Cycling Routes Masterplan. These documents will also help inform the Local Policies Plan process.

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5.9 Countryside Strategy CS1 Sustainable Development in the Countryside Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-010

Department for Infrastructure

MEA-DPS-061

Individual

MEA-DPS-069

Turley on behalf of ABO Wind (NI) Ltd

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Welcomed the policy approach.

Support is noted and welcomed.

The principles of the policies referenced in CS1 have been ignored in the past and a more restrictive approach is required.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council highlights that the implementation of previous policy is not a matter that is addressed through the LDP process. When adopted, the LDP will be subject to a monitor and review process that will consider compliance with the LDP policies.

CS1 is unsound by virtue of cross reference to other policies in the plan.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council have stated in paras 1.7.4, 1.7.5 and 1.7.8 of the draft Plan Strategy that the LDP should be read in its entirety with no one policy read in isolation.

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CS2 Special Countryside Areas Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-029

Gravis Planning on behalf of Individual

MEA-DPS-044

Individual

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-050

Northern Ireland Renewables Industry Group

MEA-DPS-056

Quarry Plan

MEA-DPS-057

RPS Group on behalf of Northern Ireland Electricity Networks

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-061

Individual

MEA-DPS-069

Turley on behalf of ABO Wind (NI) Ltd

MEA-DPS-076

Turley on behalf of RES

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Welcomed the policy approach to protect these sensitive areas and protections for Lough Beg and Lower Bann River.

Support noted and welcomed.

Concerned the term 'adverse impact' is not qualified by the use of 'unacceptable' or 'significant'. Amend policy wording, add ‘unacceptable adverse impacts’ and ‘potentially unacceptable adverse impacts’ to exception a).

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. In these exceptional areas of the Borough, the quality of the landscape and unique amenity value is such that development should only be permitted in exceptional circumstances.

The term 'adverse impact' is applied in this policy as this designation is the most stringent 83

spatial policy area designated within the LDP and seeks to ensure the protection of these special areas from unnecessary and inappropriate development.

Council is satisfied that there is no conflict between CS2 and the wording of other regional policies such as the SPPS, or with the regional legislation referred to, or with Policy GP1. Given the rationale for the designation of Special Countryside Areas (SCAs), these designations must have a higher level of protection than that offered by Policy GP1.

The suggested wording amendments would weaken the policy and allow for development which would undermine the rationale for the designation.

No criteria for a project to demonstrate regional significance.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The interpretation of 'national or regional importance' remains with the Council and is a matter for professional judgement during the assessment of a proposal.

Amend policy, add ‘sympathetic in character’ to exception b) to strengthen the policy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. All proposals will be required to accord with Policy GP1, which sets out a number of policy tests under criteria f) which seek to ensure that only appropriate forms of development in our countryside are permitted. Furthermore, CS2 states that, ‘A proposal must fully demonstrate that it constitutes one of the exceptions below and that it will not result in an adverse impact on the landscape quality, or landscape character, or unique amenity value, or the environmental assets of the SCA.’

Policy exceptions should not permit development that would diminish the quality of the SCA with particular reference to exception f).

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Any proposal permitted under exception f) will have to be located at an existing tourist/visitor site. Policy wording highlights that development proposals which meet one of the exception tests under CS2 should not result in adverse impacts on the SCA.

The following wording should be included as an exception to the policy: ‘where the proposal assists with the delivery of environmental benefit (for example through the protection of wildlife or habitat)'.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. These designations are exceptional areas within the Borough, wherein the quality of the landscape and unique amenity value is such that development should only be permitted in exceptional circumstances.

The suggested exception is too broad in scope and deemed inappropriate as it would weaken the policy and allow for development which could undermine the rationale for the designation.

Therefore, the policy would not meet the tests of soundness as it could undermine the sustainable approach to development promoted throughout the draft Plan Strategy, particularly in regard to support for development in appropriate locations.

Policy should state that proposals must be made in accordance with appropriate marine policy documents.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Under this policy, Council consider it sufficient for all development proposals within the coastal SCAs to take account of the Marine Policy Statement (MPS) and draft Marine Plan for Northern Ireland.

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It is unclear if seascape quality and character is considered under CS2.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The last sentence in the policy box highlights that all development proposals within the coastal SCAs must take account of the MPS and draft Marine Plan for NI and, where relevant, seascape character and quality are considered throughout the Landscape Character Assessment and Technical Supplement 10.

To provide greater certainty/clarity, include the following sentence from paragraph 5.9.13 within the policy box of CS2: ‘Where development is permitted under this exception, adequate mitigation and/or compensatory measures must be agreed with Council in advance of planning permission being granted.’

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council are content that having the wording of para 5.9.13 in the justification and amplification is sufficient as this wording clearly relates to exception a) of CS2.

Amend justification and amplification text and add ‘and character’ to paragraph 5.9.12.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, Council suggest the minor change to the wording should be made – see Schedule of Proposed Modifications – Reference Number PM-018.

Amend justification and amplification text and add ‘or landscape character of the area’ to paragraph 5.9.16.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider that the suggested wording amendment is not necessary as it would not strengthen the policy or provide further clarity.

Policy CS2 is developed using evidence from LCA which is based on a flawed methodology.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The exceptional landscape character and scenic quality of these areas and their wider function are key assets for the Borough. In these exceptional areas the quality of the landscape and unique amenity value is such that development should only be permitted in exceptional circumstances.

The Landscape Character Assessment methodology is based on best practice guidance contained within 'An Approach to Landscape Character Assessment' (2014) by Christine Tudor for Natural England and 'Landscape Character Assessment Guidance for England and Scotland' (2002) by Countryside Agency and Scottish Natural Heritage.

Various sources of evidence have informed the need for, and extent of, SCAs. These documents include the Council’s Landscape Character Assessment and Candidate Sensitive Landscape Report (part of Technical Supplement 10 of the draft Plan Strategy) and other publications such as the NI Regional Landscape Character Assessment, NI Regional Seascape Character Assessment and 'Wind Energy Development in NI Landscapes'. Council consider that these documents represent a robust and informed evidence base for assessing the landscape sensitivity and value of the Borough’s landscapes.

The inclusion of some SCAs within the Area of Outstanding Natural Beauty (AONB) designation means that SCAs are not required in such areas. Designating SCAs within the AONB weakens the AONB designation.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. SCAs have been designated in accordance with Paragraph 6.75 of the SPPS in order to protect exceptional landscapes and their unique amenity value from unnecessary and inappropriate development.

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The Larne Area Plan 2010 has a designated SCA along the Larne Coast which provides protection for this coastal landscape over-and-above the protection provided by the AONB designation. Council consider that this two-tier approach to protecting the landscape is appropriate, as it recognises that areas within SCAs are so special and of such value to the Borough, that they should be protected from new development except in exceptional circumstances. Other areas within the AONB are also sensitive landscape areas of high value to the Borough, however the landscape in these other areas may have more capacity to absorb new development and may not be subject to the same development pressure.

The draft Plan Strategy is weighted against renewable energy and lacks balanced approach of SPPS. Council fails to assess the cumulative impact of SCAs against draft Plan Strategy objectives that relate to supporting renewable energy. CS2 fails to take account of, or is flexible enough to adapt to, emerging energy policy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. SCAs have been designated in accordance with Paragraph 6.75 of the SPPS in order to protect exceptional landscapes and their unique amenity value. The exceptional landscape character and scenic quality of these areas and their wider function are key assets for the Borough. In these exceptional areas, the quality of the landscape and unique amenity value is such that development should only be permitted in exceptional circumstances.

Exceptions are included within this policy to allow some flexibility for cases where development may be necessary under exceptional circumstances.

There is no conflict between the Regional Development Strategy (RDS), Sustainable Development Strategy (SDS), or the Executive's energy strategy and CS2. Paragraph 4.22 of the draft Plan Strategy affirms that 'no one objective or theme is regarded as having priority over any other'. The draft Plan Strategy seeks to take a balanced approach to delivering sustainable development for the Borough and Council considers that a balance has been struck between supporting renewable energy development and protecting landscapes of value within the Borough.

Exceptions are included within this policy to allow some flexibility for circumstances where development may be necessary under exceptional circumstances. Under exception a) of CS2, renewable energy development may be considered acceptable in principle where the proposal is of such national or regional importance that it outweighs any potential adverse impact on the SCA. Council highlights that designated SCAs areas are limited in extent.

Landscape Character Assessment analysis is flawed and foregoes assessment of renewable proposals on a case by case basis.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 4.22 of the draft Plan Strategy affirms that 'no one objective or theme is regarded as having priority over any other'. The draft Plan Strategy seeks to take a balanced approach to delivering sustainable development for the Borough and Council considers that a balance has been struck between supporting renewable energy development and protecting landscapes of value within the Borough.

The exceptional landscape character and scenic quality of these areas and their wider function are key assets for the Borough. In these exceptional areas, the quality of the landscape and unique amenity value is such that development should only be permitted in exceptional circumstances.

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In a Plan-led system there is an expectation for developers and other interested parties to be made aware of what development is acceptable in principle and what development is not likely to be permitted. Therefore, assessing proposals on a case-by-case basis alone is not considered appropriate in designated areas. Where the principle of development is considered acceptable, each proposal will be assessed on its own merits. Under exception a) of CS2, a renewable energy development may be considered acceptable in principle, where the proposal is of such national or regional importance that it outweighs any potential adverse impact on the SCA. Lack of provision for extraction of Ulster White Limestone in SCAs is not a sustainable approach.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 6.155 of the SPPS states that, in particular LDPs should: [bullet point 3] identify areas which should be protected from minerals development because of their intrinsic landscape, amenity, scientific or heritage value (including natural, built and archaeological heritage). There should be a general presumption against minerals development in such areas.

SCAs have been designated in accordance with Paragraph 6.75 of the SPPS in order to protect exceptional landscapes and their unique amenity value from unnecessary and inappropriate development. Minerals development would lead to adverse impacts on the exceptional landscape character, landscape quality and unique amenity value of SCAs. Exception a) of CS2 in principle, allows proposals of national or regional importance that outweigh any potential adverse impact on the SCA. Proposals for mineral extraction which are of such importance would be assessed against this policy exception.

Technical Supplement 10 and other landscape appraisal documents have informed the need for, and extent of, SCAs. Notably, there is a dearth of information on the demand and supply of minerals within Northern Ireland. However a Minerals Forum comprising DfI, the Department for Economy (DfE), Councils and industry representatives is now established to gather evidence on supply and demand of the minerals sector regionally and beyond. This will help determine whether supplies of Ulster White Limestone currently available outside of SCAs are sufficient to meet demand.

Designated SCAs on the Council boundary with Mid Ulster differ in extent and raise the issue of adopting a consistent policy approach along this Council boundary.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The approach of CS2 and that of Mid Ulster District Council ‘s LDP are consistent, whereby both seek to protect the important heritage assets and landscape character and quality of Lough Beg and the Lower Bann River and their fringes.

Amend SCA boundary to allow growth in Glenarm.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. SCAs in line with SPPS 6.75 are designated as exceptional areas within the Borough, wherein the quality of the landscape and unique amenity value is such that development should only be permitted in exceptional circumstances. The Larne Coast SCA protects the unique setting of the Coast Road and coastal settlements which are strategically important for the Borough. Various sources of evidence such as Technical Supplement 10: 87

Countryside Assessment and other landscape appraisal documents have informed the need for, and extent of SCAs. Comments on specific sites and settlement development limits are a matter for the Local Policies Plan process.

The principles of this policy have been ignored in the past. Suggest a more restrictive approach is required.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed.

These designations are exceptional areas within the Borough, wherein the quality of the landscape and unique amenity value is such that development should only be permitted in exceptional circumstances. Various sources of evidence such as Technical Supplement 10: Countryside Assessment and other landscape appraisal documents have informed the need for, and extent of, SCAs. Council also highlights that the implementation of policy is not a matter that is addressed through the LDP process. When adopted the LDP will be subject to a monitor and review process.

SCA designations are not recognised in SPPS and there is no evidence they are required.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. SCAs have been designated in accordance with Paragraph 6.75 of the SPPS in order to protect exceptional landscapes and their unique amenity value from unnecessary and inappropriate development. Various sources of evidence such as Technical Supplement 10 and other landscape appraisal documents have informed the need for, and extent of, SCAs.

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CS3 Areas of Constraint on High Structures Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-050

Northern Ireland Renewables Industry Group

MEA-DPS-057

RPS Group on behalf of Northern Ireland Electricity Networks

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-059

Scottish Power Renewables

MEA-DPS-069

Turley on behalf of ABO Wind (NI) Ltd

MEA-DPS-076

Turley on behalf of RES

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Welcomed that the strategic/regional importance of the energy network proposal can be given appropriate weight in the planning balance. Also wording of last sentence of paragraph 5.9.25 is welcomed.

Comment welcomed.

Suggests adding new siting and design criteria to the ‘Up to 15 metres’ and ‘above 15 metres and up to 25 metres’ categories and removing all other existing criteria as well as removing the first criteria from the ‘above 25 metre’ category, amending the second criteria to add ‘site design’ and removing the last two sentences of the policy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council considers that the suggested wording amendments would not provide sufficiently stringent policy tests to protect these landscapes of high sensitivity and value from the adverse visual impacts of high or obtrusive structures. The suggested wording amendments would weaken the policy and allow for development which would undermine the rationale for the designation.

Technical Supplement 12 identifies that since 2002, 269 single turbines and only 10 wind farms have been approved in the same period, suggesting the proliferation of turbines that are concerning Council, is as a result of the dispersed nature of single turbines. This policy would

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 6.75 of the SPPS states that local policies may be brought forward to maintain the landscape quality and character of Areas of High Scenic Value. The high scenic quality of these areas and their contribution to creating a distinctive and highly valued setting 89

permit the ongoing proliferation of small, single turbines under 15 metres high, subject to policy provisions, across the Borough. This could be more harmful to the landscape character than carefully selected and designed wind farm schemes and runs contrary to the intent of the policy. This highlights Council’s view, that tall structures are more harmful to the character, whilst the SPPS does not endorse this approach.

for settlements, important landmark features or recreation and tourist sites within the Borough mean that the landscape sensitivity of these strategically important areas is such that they require an additional layer of protection from the impacts of high structures and obtrusive development.

Height restrictions are inappropriate and not based on a robust evidence base.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Various sources of evidence including 'Wind Energy Development in NI Landscapes' have informed the height restrictions. The height thresholds have also been informed by analysis of the visibility of these areas from key receptors such as settlements, key tourist routes and key recreation sites and a consideration of the impact of any existing high structures permitted within sensitive areas such as the AONB and Areas of Scenic Quality (ASQ). This analysis focussed on the height and visual impact of existing high structures and the potential visual impact of further high or obtrusive structures.

Height restrictions conflict with paragraph 6.230 of the SPPS.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 6.230 outlines that the visual impact of wind farms will not necessarily have negative effects but caveats that the ability of the landscape to absorb development depends on several factors including the inherent characteristics of the landscape such as landform, ridges, hills, valleys and vegetation.

In a Plan-led system there is an expectation for developers and other interested parties to be made aware of what development is acceptable in principle and what development is not likely to be permitted. Therefore, assessing proposals on a case-by-case basis alone is not considered appropriate in designated areas. Where the principle of development is considered acceptable, each proposal will be assessed on its own merits. The policy allows for structures up to 15m and restricted types of development are permitted in exceptional circumstances to ensure an appropriate level of flexibility is built into the policy.

SPPS 6.75 states that local policies may be brought forward to maintain the landscape quality and character of Areas of High Scenic Value. Areas of Constraint on High Structures (ACHS) are designated to provide protection for landscapes of high scenic quality and of high amenity value from the adverse visual impacts of high or obtrusive structures. This policy does not preclude wind energy development.

There is no evidence in the Landscape Character Assessment for the selection of the 15m and 25m heights, or that proposals over 25m high will be harmful to the landscape and only permissible in exceptional circumstances. Why apply a height threshold if all forms of development will be required to meet the same policy test?

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. All development proposals are not required to meet the same policy tests. Structures above 15m up to 25m have the additional test of need, proving no alternative site is available outside ACHS and mitigation measures to minimise impact. Proposals above 25m have to demonstrate that they are of such regional significance to outweigh detrimental impact.

Permission for high structures should be limited to agricultural and telecommunication uses. Wind turbines could be permitted where they do not have an adverse impact on the landscape.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Development over 15 metres would be obtrusive in this distinctive landscape and result in adverse impacts on the high scenic quality and amenity value. The policy allows for 90

structures over 15 metres in exceptional circumstances where there is a need for the structure, where there are no alternative sites outside of the designated area and when all other relevant policy tests are met.

It is unclear how 'regional significance' will be defined for structures above 25 metres – Does this relate to all development which falls under Section 26 of the Planning Act?

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity and consistency, Council suggest the minor alteration to policy wording should be made – see Schedule of Proposed Modifications – Reference Number PM027, PM-028 and PM-029.

The term 'detrimental impact' is not consistent with the terminology of existing policy or legislation.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider that the terms 'adverse' and 'detrimental' can be used interchangeably and that the interpretation of the term 'detrimental impact' is a matter for professional judgement during the assessment of a proposal.

Council are satisfied that there is no conflict between CS3 and the wording of the SPPS or legislation, nor between CS3 and Policy GP1. The high scenic quality of designated ACHS and their contribution to creating a distinctive and highly valued setting for settlements, important landmark features or recreation and tourist sites within the Borough, means that the landscape sensitivity requires a higher level of protection than that offered by Policy GP1.

Questioned if proposals that are not 'High Structures' should be assessed under this policy as referred to in second last sentence of policy.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest the alteration to the policy title, policy wording and justification and amplification wording should be made to include obtrusive development see Schedule of Proposed Modifications – Reference Numbers PM-019, PM-020, PM-021, PM-022, PM-026 and PM-030.

Amend justification and amplification text to make reference to the need to submit an appropriate Landscape and Visual Assessment.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments, for clarity, Council suggest the minor alteration to the wording should be made – see Schedule of Proposed Modifications – Reference Number PM-031.

There is inconsistency between CS3 and Policy TOC1 relating to when demonstration of need is required.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor alteration to the policy wording of TEI1 (previously TOC1) should be made - see Schedule of Proposed Modifications - Reference Number PM-132.

Council also suggest the minor alteration to the wording of justification and amplification paragraph 5.9.25 so that it is explicit that, under the category 'Structures above 15m and up to 25m in Height', there is provision for proposals to serve recognised 'not spots' or those for essential electricity transmission or supply – see Schedule of Proposed Modifications – Reference Numbers PM-032, PM-033, PM034 and PM-135.

The extent of the area of constraint is based on a flawed evidence base which assumes that tall structures have an adverse impact and fails to consider renewable energy as a force for change in the character of the

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The methodology used to conduct the Landscape Character Assessment is based on approved methodologies within the following documents: 91

landscape. The detailed assessment of sensitive landscapes has only been undertaken ‘broadly’ in accordance with best practice guidance. A more robust approach would be to fully align with best practice guidance from elsewhere.

Council is seeking to further protect sensitive landscapes from development that it sees as obtrusive. Given that the areas proposed already benefit from landscape designations, including AONB, ASSI and SPAs it is not considered appropriate to apply a further policy protection. Each development can be considered on its own merits.

Draft CS1, CS2, CS4 and CS5 all require proposals to demonstrate there is no adverse harm to views and landscape character so CS3 is duplicating other policy requirements and is therefore incoherent.

i) Landscape Character Assessment guidance for England and Scotland (2002); and ii) An Approach to Landscape Character Assessment (2014).

The Council used the principles and guidance in these documents to produce an appropriate methodology for undertaking a Landscape Character Assessment within the Borough which was reviewed by a qualified Landscape Architect and no concerns were raised. Various sources of evidence such as Technical Supplement 10 and other landscape appraisal documents have informed the need for, and extent of, ACHS. Renewable energy is considered under the Landscape Character Assessment, Development Pressure Analysis and Candidate Sensitive Landscape Report in Technical Supplement 10.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 6.75 of the SPPS states that local policies may be brought forward to maintain the landscape quality and unique amenity value of exceptional areas. The high scenic quality of these areas and their contribution to creating a distinctive and highly valued setting for settlements, important landmark features or recreation and tourist sites within the Borough, means that the landscape sensitivity of these strategically important areas is such that they require an additional layer of protection from the impacts of high structures and obtrusive development.

Other areas within the AONB are also sensitive landscape areas of high value, however these landscapes may have more capacity to absorb high structures or obtrusive development.

Council notes that the Larne Area Plan 2010 has a two-tier approach to protecting parts of the AONB. In a Plan-led system there is an expectation for developers and other interested parties to be made aware of what development is acceptable in principle and what development is not likely to be permitted. Therefore, assessing proposals on a case-by-case basis alone is not considered appropriate in designated areas. ASSIs and SPAs seek to protect and conserve natural heritage features however designations such as ACHS can help to support the aims and objectives of nature conservation designations.

The draft Plan Strategy should present evidence base for designating ACHS. They are not recognised in SPPS and the AONB offers sufficient landscape protection. ACHS were not proposed in Preferred Options Paper (POP) so have not been consulted on and do not serve any legitimate environmental purpose.

The POP consulted on the need for an additional policy layer in the AONB and Areas of Scenic Quality. Providing additional protection for these areas was generally supported. ACHS relate to landscapes within these 'Key Issue' areas. The draft Plan Strategy is itself a consultation document which provided an opportunity to respond to the detail of the policy.

The draft Plan Strategy fails to provide evidence that ACHS are required. AONB provides sufficient protection for these areas.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. ACHS provide protection from the adverse visual impacts of high or obtrusive structures for areas of the AONB exposed to views from, or on approach to, the Larne coast and also for areas close to the Larne coast that have high landscape value for the Borough.

The high scenic quality and exceptional setting of these areas along the coast are particularly

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important for the Borough as this coastal area forms part of the Causeway Coastal route which is a major draw for tourists and visitors.

The unique coastal setting, undisturbed ridgelines and the ASAI at Knockdhu, amongst other landscape features, mean that the landscape sensitivity in this part of the AONB is such that it requires an additional layer of protection from high structures and obtrusive forms of development. Larne Area Plan 2010 has a two-tier approach to protecting parts of the AONB. Various sources of evidence such as Technical Supplement 10 and other landscape appraisal documents have informed the need for, and extent of, ACHS. Additional protection required for areas important to birds. Policy should seek to prevent any adverse individual and cumulative impacts from development on such areas.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. ACHS are primarily a landscape designation but can help support the aims and objectives of nature conservation designations and thereby contribute to conservation of biodiversity and help the draft Plan Strategy to meet the aims of the NI, EU and Council's own biodiversity strategies.

Justification and amplification paragraph 5.9.22 states that, 'Any development proposals which individually or cumulatively prejudice the overall integrity of the ACHS will be refused.' The presence of a priority species or nature conservation sites will be given due regard in the decision-making process as each proposal will also be assessed against the Council's Natural Heritage policies and European legislation.

The SPPS (paragraph 6.223) advocates a cautious approach to renewable developments within designated landscapes. SPPS para 6.250 says proposals for telecommunications will be considered having regard to potential impact on amenity and should avoid areas of landscape sensitivity. This does not endorse this policy. If that was the intent, the SPPS would have specifically identified the use of such designations, as it has done in the case of Areas of Constraint on Minerals Development.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 6.223 and paragraph 6.250 outlines the SPPS position in regard to renewable energy development and power lines respectively when considering the location of these types of development in sensitive locations.

In a Plan-led system there is an expectation for developers and other interested parties to be made aware of what development is acceptable in principle and what development is not likely to be permitted. This policy provides more clarity for developers in regard to what type of development is not acceptable in these areas of high scenic value and high amenity value.

SPPS 6.75 advocates protection of such areas from unnecessary and inappropriate development.

Various sources of evidence such as Technical Supplement 10 and other landscape appraisal documents have informed the need for, and extent of Areas of Constraint on High Structure.

The approach to renewable energy development lacks the balance that is evident in the SPPS. Exemptions should be permitted for renewables, in line with the strategic objectives of the SPPS, RDS and SDS and should be considered on a case-by-case basis allowing the applicant to demonstrate how the project can co-exist with the natural landscape and how impacts can be mitigated.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council does not perceive there to be a conflict between the SPPS, RDS, SDS and Policy CS3. Paragraph 4.22 of the draft Plan Strategy affirms that 'no one objective or theme is regarded as having priority over any other'. The draft Plan Strategy seeks to take a balanced approach to delivering sustainable development for the Borough and Council considers that a balance has been struck between supporting renewable energy development and protecting landscapes of value within the Borough.

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In a Plan-led system there is an expectation for developers and other interested parties to be made aware of what development is acceptable in principle and what development is not likely to be permitted. Therefore, assessing proposals on a case-by-case basis alone is not considered appropriate in designated areas. ACHS are designated to provide protection for landscapes of high scenic quality and of high amenity value from the adverse visual impacts of high or obtrusive structures.

Various sources of evidence such as Technical Supplement 10 and other landscape appraisal documents have informed the need for, and extent of, ACHS. The draft Plan Strategy should not designate areas which restrict on shore wind development. All proposals should be assessed on their individual merits, using a more supportive policy context, with emphasis on achieving the revised legal obligations to meet net zero targets.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council does not perceive there to be a conflict between government energy policy and CS3 and considers that a balance has been struck between supporting renewable energy development and protecting landscapes of value within the Borough.

The draft Plan Strategy considered any Government targets, which were in place at the time of printing. Net zero targets were set in June 2019, after printing had commenced. DfE very recently called for ‘evidence’ to update NI's strategic direction, which may adjust current energy targets. Any recent developments in relation to climate change emergency, net zero targets or updated Strategic Energy Framework targets will be reflected in the adopted draft Plan Strategy.

In a Plan-led system there is an expectation for developers and other interested parties to be made aware of what development is acceptable in principle and what development is not likely to be permitted. Therefore, assessing proposals on a case-by-case basis alone is not considered appropriate in designated areas. CS3 does not preclude renewable energy development.

Restrictions on the location of and heights of strengthening works to overhead lines and associated infrastructure required to support reinforcement of the network, could result in undue challenges in achieving RDS RG5. Costly infrastructure diversions or solutions could increase customer bills. Policy needs to build in an element of reasonable flexibility to allow appropriate planning judgement in weighing up proposals and must allow for every case to be considered separately and on its own merits.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed and does not perceive there to be a conflict between the RDS and CS3. The high scenic quality of these areas and their contribution to creating a distinctive and highly valued setting for settlements or important landmark features within the Borough mean that the landscape sensitivity of these strategically important areas is such that they require an additional layer of protection from the impacts of high structures and obtrusive of development.

The presence of electricity infrastructure within an ACHS does not set a precedent that further development of such infrastructure is acceptable in principle or that such infrastructure would be acceptable in other areas of the ACHS. In a Plan-led system there is an expectation for developers and other interested parties to be made aware of what development is acceptable in principle and what development is not likely to be permitted. Therefore, assessing proposals on a case-by-case basis alone is not considered appropriate in designated areas.

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CS3 fails to take account of, and lacks flexibility to adapt to, emerging government policy in relation to decarbonisation and the drive to secure more energy from renewable sources. If NI targets increase in line with GB, new electricity infrastructure would be required to meet this target and facilitate growth.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council does not perceive there to be a conflict between government energy policy and Policy CS3. Paragraph 6.75 of the SPPS states that local policies may be brought forward to maintain the landscape quality and character of Areas of High Scenic Value. ACHS are designated to provide protection for landscapes of high scenic quality and of high amenity value from the adverse visual impacts of high or obtrusive structures.

The proposal to restrict wind turbine development is contrary to the Council's objectives relating to renewable energy provision and tackling climate change and undermines the ability of the Council to meaningfully contribute to the Regional objectives. It is unclear how a policy approach endorsing smaller scale turbines with a lower energy output would ensure that the Council makes a continued contribution towards the environmental objectives of the Plan and the Regional Energy Strategy, namely tackling climate change.

Council does not perceive there to be a conflict between government energy policy or the draft Plan Strategy strategic objectives and CS3. Paragraph 4.22 of the draft Plan Strategy affirms that 'no one objective or theme is regarded as having priority over any other'. The draft Plan Strategy seeks to take a balanced approach to delivering sustainable development for the Borough and Council considers that a balance has been struck between supporting renewable energy development and protecting landscapes of value within the Borough. CS3 seeks to protect the distinctive qualities and important amenity value of these high-quality landscapes in accordance with the aims of the RDS, SPPS and the objectives of the draft Plan Strategy.

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CS4 Rural Landscape Wedges Responses received Reference

Respondent

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the designation of Rural Landscape Wedges.

Support for the proposed policy is welcomed.

CS5 Antrim Coast and Glens Area of Outstanding Natural Beauty Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-056

Quarry Plan

MEA-DPS-057

RPS Group on behalf of Northern Ireland Electricity Networks

MEA-DPS-069

Turley on behalf of ABO Wind (NI) Ltd

MEA-DPS-076

Turley on behalf of RES

96

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for CS5 as it will help conserve the natural beauty and landscape of the area, thereby contributing to the well-being of local people and visitors.

Support for the proposed policy is welcomed.

The draft Plan Strategy should have regard to Nature Conservation and Amenity Lands Order (NI) 1985 (NCALO) and objectives of the Area of Outstanding Natural Beauty (AONB).

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The objectives of the AONB designation are listed in paragraph 5.9.31 of the justification and amplification of Policy CS5. This policy has been developed with regard to these objectives, the requirements of the Nature Conservation and Amenity Lands Order (NI) 1985 and the objectives of the Antrim Coast and Glens AONB Management Plan (2008 - 2018).

Policies should apply consistently across the AONB, taking into account landscape sensitivity and the needs of local communities.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. CS5 seeks to protect the exceptional landscape quality, distinctive character, heritage and wildlife of the AONB. This policy applies across the AONB within the Borough.

Other policies within the draft Plan Strategy may apply to specific areas of the AONB based on the aims of the policy. Causeway Coast and Glens Borough Council have been consulted on this policy and have not indicated any conflict between Policy CS5 and their AONB policies.

A Rural Needs Impact Assessment (RNIA) has been conducted by the Council to ensure due regard has been had of the potential impacts the draft Plan Strategy could have on the Rural Community. The RNIA did not find that the rural community would be negatively impacted by Policy CS5. This policy strives to protect the exceptional landscape and heritage assets of the AONB which can deliver positive economic, environmental and social benefits for the rural community.

Amend policy criterion a) to read as follows: ‘The nature, scale and location of the proposed use is compatible with the landscape and distinctive character of the AONB’.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The suggested wording amendment is not necessary as the policy wording in its entirety is sufficient to assess if the scale and location of a proposed development is acceptable in principle within the AONB.

Amend policy criterion f) to clarify the meaning of the term 'closely interlinked’.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor alterations to the policy wording should be made - see Schedule of Proposed Modifications – Reference Number PM-035.

Examples should be given of important features within the AONB.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council does not consider it necessary to list examples of important features found within the AONB in the justification and amplification of this policy as readers are signposted to AONB guidance documents 'Building on Tradition', 'The Antrim Coast and Glens Design Guide' and 'the latest AONB Management Plan' under paragraph 5.9.37. Details of important features within the Antrim Coast and Glens AONB can be found in these guidance documents.

97

CS5 is sufficient for assessing minerals proposals. Additional protection, specifically constraining minerals development, is not considered to be a sustainable approach.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 4.22 of the draft Plan Strategy affirms that 'no one objective or theme is regarded as having priority over any other'. The draft Plan Strategy seeks to take a balanced approach to delivering sustainable development for the Borough and Council considers that a balance has been struck between supporting minerals development and protecting landscapes of value within the Borough.

Paragraph 6.75 of the SPPS states that local policies may be brought forward to maintain the landscape quality and character of Areas of High Scenic Value. Various sources of evidence such as Technical Supplement 10 and other landscape appraisal documents have informed the need for, and extent of, additional designations within the AONB.

Designating SCAs within parts of the AONB weakens the AONB designation.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. SCAs have been designated in accordance with Paragraph 6.75 of the SPPS in order to protect exceptional landscapes and their unique amenity value from unnecessary and inappropriate development. Given the rationale for the designation of SCAs, these designations must have a higher level of protection than that offered by Policy CS5. Various sources of evidence such as Technical Supplement 10 and other landscape appraisal documents have informed the need for, and extent of, SCAs.

Policy approach is too stringent whereby it appears to preclude development that might result in any adverse individual or cumulative impact on the AONB and is inconsistent with other policy approaches.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council notes that this policy seeks to prevent development that would have an adverse impact (individually or cumulatively) on the exceptional landscape quality, distinctive character, heritage and wildlife of the AONB, which would prejudice its overall integrity. The intention of this part of the policy is to protect the overall integrity of the AONB designation, whilst facilitating appropriate and sympathetically designed development proposals.

Council are satisfied that there is no conflict between Policy CS5 and the wording of other regional policies such as the SPPS or with the legislation referred to and is also satisfied that there is no conflict between CS5 and Policy GP1. Given the rationale for the designation of SCAs, these designations must have a higher level of protection than that offered by Policy GP1.

CS5 fails to take account of, or has enough flexibility to adapt to, government energy policy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council does not perceive there to be a conflict between government energy policy and CS5. Paragraph 4.22 of the draft Plan Strategy affirms that 'no one objective or theme is regarded as having priority over any other'. The draft Plan Strategy seeks to take a balanced approach to delivering sustainable development for the Borough and a balance has been struck between supporting renewable energy development and protecting landscapes of value within the Borough.

Council would contend that the presumption in favour of renewables is very much retained in the draft Plan Strategy for the vast majority of the Council area with a balanced approach to 98

supporting renewables in 65% of the Borough, a cautious approach in a further 20% (AONB) as per the SPPS requirements, and the tightest restrictions within ACHS and SCA only 15% and 3% of council area respectively (there are some overlaps in these designations).

CS5 is unsound by virtue of cross reference to other policies in the plan, of which Policy RE1 is linked.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. It is stated in paragraphs 1.7.4, 1.7.5 and 1.7.8 of the draft Plan Strategy that the LDP should be read in its entirety with no one policy read in isolation.

Landscape Character Assessment evidence is not robust but will be used to assess proposals within the AONB.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The methodology used to conduct the Landscape Character Assessment is based on approved methodologies within the following documents: i) Landscape Character Assessment guidance for England and Scotland (2002); and ii) An Approach to Landscape Character Assessment (2014).

Council used the principles and guidance in these documents to produce an appropriate methodology for undertaking a Landscape Character Assessment within the Borough.

Council's methodology was reviewed by a qualified Landscape Architect and no concerns were raised regarding the Council's approach to the Landscape Character Assessment.

Various sources of evidence have informed the Council’s Landscape Character Assessment, including documents such as the NI Regional Landscape Character Assessment, NI Regional Seascape Character Assessment and 'Wind Energy Development in NI Landscapes'. This is a robust and informed evidence base for assessing the landscape sensitivity and value of the Borough’s landscapes.

Amend policy to include wording to take account of any social or economic benefits that may arise as a result of a proposal. It is considered that the policy approach is contrary to SPPS.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council does not consider there to be a conflict between CS5 and the objectives of the SPPS. Paragraph 4.22 of the draft Plan Strategy affirms that 'no one objective or theme is regarded as having priority over any other'. The draft Plan Strategy seeks to take a balanced approach to delivering sustainable development for the Borough and a balance has been struck between protecting the high scenic quality, distinctive character and natural and built heritage assets of the AONB and supporting development.

This policy seeks to protect the assets of the AONB and prevent development that would have an adverse impact (individually or cumulatively) on the exceptional landscape quality, distinctive character, heritage and wildlife of the AONB, which would prejudice its' overall integrity. Therefore, the policy seeks to protect the overall integrity of the AONB designation and does not preclude development or any type of development.

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CS6 Developed Coast (Belfast Lough Shore) Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Welcome policy as it will help protect the coast from unacceptable development and assist the regeneration of coastal areas and will encourage recreation.

Support for the proposed policy is welcomed.

Amend wording under the aims section of the policy to include reference to the delivery of educational benefit.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The addition of 'the delivery of educational benefit' to the ‘aims section’ within the policy box of CS6 would add a policy test that is considered too broad in scope. Council notes that projects that provide educational benefit could be assessed against the aim which supports proposals that enhance public enjoyment of the coast.

Amend policy to state that proposals must accord with the appropriate marine policy documents.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Under this policy, Council consider it sufficient for all development proposals to have regard to the Marine Policy Statement and Draft Marine Plan for Northern Ireland.

Explicit reference to seascape should be used in draft Plan Strategy, where relevant.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Protection of the seascape is covered by other wording e.g. landscape character, coastal setting or reference to the Marine Plan for NI. Paragraph 2.6.5.1 of the UK Marine Policy Statement (MPS) (2011) states that there is no legal definition for seascape in the UK. Paragraph 2.6.5.1 goes on to state that, in the context of the UK MPS 2011, 'seascape should be taken as meaning landscapes with views of the coast or seas, and coasts and the adjacent marine environment with cultural, historical and archaeological links with each other.'

Council considers that the terms 'landscape' and 'coastal setting' are appropriate and sufficient for LDP policies that seek to protect the landscape character and setting of the coast, and key views of, and from, the coast.

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CS7 Local Landscape Policy Areas Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-056

Quarry Plan

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support the designation of Local Landscape Policy Areas (LLPAs) which protect environmental assets.

Support for the proposed policy is welcomed.

The term ‘landscape character’ should be used in the policy wording.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed.

LLPAs seek to protect landscape character and townscape character and/or the settings of archaeological sites and monuments and listed and other locally important buildings. Only referring to 'landscape character' may not provide sufficient protection for all features that contribute to the character of an area designated as an LLPA. The policy wording is consistent with the thrust of paragraph 6.30 of the SPPS which states, ‘LDPs should, where appropriate, designate LLPAs and bring forward local policies and guidance to maintain the intrinsic landscape, environmental value and character of such areas.’

Review LLPA designations to establish a consistent approach if they are to amend or bring forward any further designations.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed.

Council will review existing LLPAs and consider new LLPA designations for elsewhere in the Borough during the Local Policies Plan process (see paragraph 5.9.42 in the justification and amplification to CS7).

Future LLPAs should avoid existing and proposed minerals development sites.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed.

LLPAs do not preclude development but seek to protect areas within and adjoining settlements which are considered to be of greatest amenity value, landscape quality or local significance. LLPAs are designated during the Local Policies Plan process. Any future LLPAs will take account of existing quarries or 'approved' extensions to these quarries.

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CS8 Protection of Main River Corridors Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the protection of river corridors to maintain or enhance biodiversity, water quality and to restrict development that could result in increased flooding.

Support for the proposed policy is welcomed.

Amend policy wording of criteria b) and d) to make it clearer that access may be restricted in the interests of biodiversity.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider that the protection of biodiversity interests is sufficient in relation to the aims of the policy and note that these interests are also protected by other policies in the draft Plan Strategy, for example, the policies contained within the Natural Heritage section of the draft Plan Strategy (Policies NAT1 - NAT5).

Amend justification and amplification text for consistency of terminology, replace ‘ecology’ with ‘biodiversity’.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity and consistency, Council suggest replacing the term 'ecology' with 'biodiversity' in paragraph 5.9.50 of the justification and amplification – see Schedule of Proposed Modifications – Reference Number PM-036.

All river corridors, not just main rivers, because biodiversity is not solely found along main river corridors.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The designation of 'Main River Corridors' will be undertaken through the Local Policies Plan process. Where development pressure is likely to be high along a river, the designation of a 'Main River Corridor' will seek to provide additional protection for any nature conservation interests and opportunities for public access provision to riverside areas. Each planning application is assessed on its own merits and the presence of nature conservation interests will be given due regard in the decision-making process.

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CS9 Development at Risk from Land Instability or Coastal Erosion Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-009

Department for the Economy (DfE)

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy.

Support for the proposed policy approach is welcomed.

Amend policy to state that proposals must accord with the appropriate marine policy documents.

Council note the issue and consider the draft Plan Strategy to be sound. Paragraph 1.7.1 of the draft Plan Strategy relates to the primacy of the LDP in the determination of planning applications, in a Plan-led system. Within this paragraph and elsewhere in the document there is reference to ‘other material considerations’. Section 2.1 of the draft Plan Strategy refers to regional policy context and includes both the UK Marine Policy Statement (MPS) and the Draft Marine Plan for Northern Ireland.

Council consider those references sufficiently direct development proposals to have regard to the MPS and Draft Marine Plan for Northern Ireland. However, in light of the comment made, and for clarity and consistency of approach, Council suggest that a minor addition to the policy wording should be made - see Schedule of Proposed Modifications – Reference Number PM037.

Policy CS9 applies to any area of land instability, whether coastal or not, but SPPS 6.42 only refers to coastal areas.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The SPPS refers to land instability in terms of coastal erosion however, DfE has provided evidence of known areas of land instability within the Borough in locations away from the coast. The policy is fully intended to apply to both inland areas, where there are known areas of land instability and coastal areas. Known areas of land instability can be accessed through Geological Survey NI map viewer which is referenced in paragraph 5.10.3.

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Miscellaneous comments on the Countryside Strategy Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-007

Individual

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-056

Quarry Plan

MEA-DPS-061

Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Helpful to give explicit reference to seascape, where relevant, within the Countryside Strategy and include consideration of impact on marine, coastal and transitional waters alongside river pollution and impact on water quality.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council highlight that designations associated with CS2, CS3, CS5 and CS6 seek to protect landscape assets and the coastal setting of areas located on the coast of Mid and East Antrim and Policies NAT1 - NAT 5 seek to protect natural heritage assets. Policy NAT5 includes wetlands (including river corridors) as a feature of natural heritage importance to be protected.

Amend the second sentence of paragraph 5.9.2 of the Countryside Strategy to read 'Landscape and seascape are often of high quality'.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, Council suggest amending the wording of the second sentence of the Countryside Strategy - see Schedule of Proposed Modifications – Reference Number PM-016.

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No reference to strategies for biodiversity, climate change or the environment.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider that the draft Plan Strategy has sufficient regard to issues concerned with biodiversity, climate change and the environment. One of the Countryside Strategy aims (paragraph 5.9.6) is to protect, conserve, and where possible, enhance the rural landscape, seascape, natural environment, and historical and cultural heritage assets associated with the countryside of Mid and East Antrim.

Paragraph 11.1.3 of draft Plan Strategy sets out the Council's duty to further the conservation of biodiversity under the WANE Act (2011) and the aims of the EU and NI Biodiversity Strategies.

Paragraph 11.1.6 sets out the Policy Aims of the Natural Heritage section of the draft Plan Strategy and the protection of natural heritage assets is explicit within these aims and has regard to the SPPS's five regional strategic objectives relating to natural heritage (paragraph 11.1.5 and 11.1.6 of the draft Plan Strategy) and seeks to help meet these objectives.

Amend first aim of paragraph 5.9.6 of the Countryside Strategy to promote development that contributes to a sustainable rural community, not solely the rural economy.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, Council suggest amending the wording of the first aim of the Countryside Strategy – see Schedule of Proposed Modifications – Reference Number PM-017.

Countryside will be open to exploitation under this strategy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Countryside Strategy policies seek to facilitate sustainable development in the countryside where appropriate, and protect, conserve and where possible enhance the rural landscape, seascape, natural environment, and historical and cultural heritage within this area.

Rural areas and the seascape have the need for a more restrictive policy as this policy, like previous policies, is open to manipulation.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The implementation of previous policy is not a matter that is addressed through the LDP process. When adopted the LDP will be subject to a monitor and review process.

Clarify what defines unnecessary or inappropriate development.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 6.65 of the SPPS uses the term 'inappropriate development'. In some cases, it may be considered appropriate to be able to demonstrate the need for a development, and where this demonstration of need is not sufficiently achieved, the proposal could be considered unnecessary. The interpretation of the terms 'inappropriate' and 'unnecessary' remains with the Council and is a matter for professional judgement during the assessment of a proposal.

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Part 2 GP1 General Policy for all Development

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6.0 General Policy for all Development Policy GP1 General Policy for all Development Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs – Natural Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-038

Invest NI

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-052

Northern Health and Social Care Trust

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Herron Bros

MEA-DPS-077

Turley on behalf of Vaughan Homes

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy approach.

Support for the proposed policy approach is welcomed.

Amend policy criterion a) to include the word 'landscape'.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

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Council consider that the term 'inherent character' refers to both townscape character and landscape character. Council does not consider that a change in the policy wording is necessary as in urban areas development proposals shall have regard to both townscape character and landscape character and landscape character is referred to in criteria f) 'Criteria relating to Development in the Countryside'.

Questions the use of the terms 'character' and 'setting' in Criterion a).

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Council consider the term 'character' covers a wider scope to cover both townscape and landscape character and setting.

Amend criterion b) as it is considered inflexible in cases where new development cannot be sited to maintain sufficient separation distance from existing or approved infrastructure.

Council consider the policy is sound and the suggested change could cause detrimental harm to future residents.

Amend policy wording to include the need for Transport Assessments as an additional criterion under subsection c).

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Council consider Transport Assessments to be just one form of assessing if the existing road network is sufficient or can be upgraded to manage additional traffic generated by a development, and therefore already adequately covered within Policy GP1 c) iii.

Inconsistency between policy aim and Policy GP1 c) criteria relating to access, movement and car parking. The criteria relating to Access, Movement and Car Parking needs to be rewritten to highlight reference to sustainable patterns of development.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council would contend that the transportation policies against which applicable development proposals will have to be assessed against fully embrace this policy aim and will help Council to deliver sustainable patterns of development. Policy GP1 criteria c) ii is a catchall in addition to the specific transportation policies which together will ensure a sustainable movement pattern is achieved.

An expansion of the need for any development to maximise the use of public transport, walking and cycling should be added. Policy GP1 should also expand on travel time accessibility and Local Car Parking Strategy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider the public transport, walking and cycling elements are already covered by Policy TR5 and would be unnecessary repetition if also included in Policy GP1.

Travel time accessibility is not considered appropriate for policy. Council also consider Policy GP1 should not refer to the Local Car Parking Strategy as it relates to any parking associated with development proposals, not just development proposals for public and private car parks.

It is anticipated that the Local Car Parking Strategy will relate more to the provision of public and private car parks and on street parking etc. rather than being of relevance to individual development proposals.

Amended wording regarding the Local Car Parking Strategy.

Council consider this criterion should not refer to the Local Car Parking Strategy as it relates to any parking associated with development proposals, not just development proposals for public and private car parks. It is anticipated that the Local Car Parking Strategy will relate

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more to the provision of public and private car parks and on street parking etc. rather than being of relevance to individual development proposals.

Transport Assessments should appear in Policy GP1 at the beginning of the section headed Access/Movement/Car Parking rather than justification and amplification.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Council consider Transport Assessments to be just one form of assessing whether the existing road network is sufficient, or can be upgraded to manage additional traffic, generated by a development, and therefore already covered within the wording of Policy GP1 c) iii.

General Policy should cover matters relating to land contamination, groundwater risk and risk to environmental receptors from development. Should risks from contaminated land potentially affect developments then certain risk assessments may need to be carried out and development may need to be in conjunction with a remediation strategy.

Council note the issue and consider the draft Plan Strategy to be sound. However, for clarity, Council suggest adding an additional criterion to subsection d) and , clarification in justification and amplification 6.1.10 and a definition in the Abbreviation and Glossary - see Schedule of Proposed Modifications – Reference Numbers PM-038, PM-040 and PM-156

Additional wording should be added on energy consumption and sustainable design.

Council not the issue and consider the draft Plan Strategy to be sound. The points raised go beyond the remit of the LDP and are more appropriately controlled by building regulations.

Criterion e) should take account of the efficient use of energy, water and other resources but more detail should be added to policy or a new policy dedicated to climate change and resilience developed.

Council not the issue and consider the draft Plan Strategy to be sound. Council considers criterion e) point v and paragraph 6.1.15 adequately address climate change and resilience of development through the LDP.

Policy is inconsistent with SPPS regarding sustainable development and lacks clarity.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan. Council consider a policy amendment is not required as the issue of material considerations is adequately addressed under paragraph 1.7.1 of page 22 of the draft Plan Strategy.

Amended wording in paragraph 6.1.8 relating to withdrawn DCANs.

Council note the comments. For clarity council suggest the minor alteration to the wording should be made - see Schedule of Proposed Modifications – Reference Number PM-039.

Clarify terminology used in justification and amplification paragraph 6.1.22.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Council consider in the context of the paragraph 6.1.22 the correct terminology has been used.

Policy is not general in nature as it refers to specific types of development within a General Policy.

Criterion b) of Policy GP1 is concerned with safeguarding residential amenity. This criterion is not relevant for other development types. Policy GP1 states, 'All development proposals requiring planning permission with the exception of minor proposals, will be assessed against the following general policy criteria a) - e) and will, where relevant, be required to demonstrate compliance with them'. This sentence makes it clear that the criteria only apply where relevant.

Cross Reference is needed between GP1 and flood risk policies as has been done with other policies in the draft Plan Strategy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The reference to Policy GP1 is not made in the flood risk policies as flooding is not a form of proposed development, whereas economic development, housing, open space etc. are 109

all forms of development i.e. it is only a development proposal that will be required to meet Policy GP1 and other provisions in the LDP, including the flood risk policies.

Proposals should be assessed with reference to effects they will have on economic, environmental and social factors.

Economic, environmental and social factors are the three pillars of sustainable development.

The opening paragraph within the policy box of Policy GP1 states that, 'Planning permission will be granted for sustainable development where the proposal accords with the LDP and there is no demonstrable harm to interests of acknowledged importance'. Therefore, Council consider the draft Plan Strategy to be sound and does not need changed as Policy GP1 addresses this issue.

General Policy should include restrictions for development that may present a potential risk to health and that any adverse effects are mitigated against.

Council note that all development will be assessed against Criteria d) Safety and the Safeguarding of Human health/Wellbeing. Further, Council consider that policies already exist in the draft Plan Strategy to address these potential risks, for example Policies GP1 d) i, TOC1, RE1, WMT1, WMT4 etc.

Absence of the reference to 'general policy' in some policy boxes may imply it is not applicable.

Council note the issue and consider the draft plan strategy to be sound and does not need changed. The reference to meeting the General Policy is inserted in all policies where it is applicable.

Include provision to ensure development is also in accordance with the UK Marine Policy Statement and the Marine Plan for NI.

Council considers the UK Marine Plan, draft Marine Policy Statement, and marine planning issues, are adequately acknowledged in Section 2.1 'Regional Policy Context' of the draft Plan Strategy.

Additional wording should be added referring to Health Impact Assessments for major development.

Council consider that the point raised does not affect the soundness of the plan and is not required by legislation or the SPPS.

Policy wording conflicts with biodiversity duty. Additional criterion should be added in relation to biodiversity.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Policy GP1 is an overarching policy and the issues raised are adequately addressed under the Natural Heritage section of the plan.

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7.0 Sustainable Economic Growth

111

7.1 Economic Development Policy ECD1 Economic Development in Settlements Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

MEA-DPS-025

Gravis Planning on behalf of Individual

MEA-DPS-032

Inaltus on behalf of Alexander Property Holdings

MEA-DPS-033

Inaltus on behalf of Bridge Park Development Ltd

MEA-DPS-038

Invest NI

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support Policy approach to economic development in settlements.

Support for the Policy approach is welcomed.

Question if wording in Paragraph 7.1.12 of justification and amplification in relation to retailing and commercial leisure should be policy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 7.1.12 relating to retailing or commercial leisure is clarifying that these uses are not economic development uses for the purpose of this policy and will therefore not be permitted on land zoned for economic development.

Amend policy wording to clarify use classes permitted.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council propose to add wording into policy to state explicitly that this includes B2 and B3 Industry and B4 Storage or Distribution – see Schedule of Proposed Modifications – Reference Number PM-042.

Amend policy to include ‘District Centres’.

There are no District Centres proposed within the Plan Area so this policy wording is reflective of that.

112

Policy ECD2 Retention of Economic Development Land Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-025

Gravis Planning on behalf of Individual

MEA-DPS-038

Invest NI

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-063

Translink

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy approach to safeguard economic development land.

Support for the policy approach is welcomed.

Support for policy approach but would like to see the policy state that if employment land is to be released for alternative uses, an adequate supply of employment land is retained to meet the needs of the Borough.

Support for the proposed policy approach is welcomed. Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as it considers Policy criterion c) adequately addresses this concern.

Question policy wording in relation to period of active marketing and suggest alternative timeframes.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as Council consider the timeframes suggested by various respondents are not appropriate.

Six months is not a sufficient amount of time to see if there is any interest in the site for economic development purposes. It should be noted the timeframe is about market interest in the site rather than a completion of sale.

Also, three years is too long a timeframe. The policy states ‘active marketing’, so if the site is vacated through bankruptcy as an example, this would not be classed as ‘active marketing’. Council consider the term 'active marketing' to be self-explanatory with the onus on the applicant to provide verifiable evidence such as information from a commercial estate agent in order to demonstrate the site has been actively marketed.

Council remain of the view that a period of one-year active marketing is a reasonable amount of time and a compromise of the differing views.

Policy should permit the development of Park and Ride facilities and public transport interchanges on land identified for economic development.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Policy ECD2 seeks to protect land zoned for economic development for Class B uses. Park and Rides facilities are not considered ‘a sui-generis employment use’ and therefore would not be permitted on zoned economic land.

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Policy ECD3 Development incompatible with Economic Development Uses Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-038

Invest NI

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy approach.

Support for the policy approach is welcomed.

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Policy ECD4 Economic Development in the Countryside Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

MEA-DPS-038

Invest NI

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-056

Quarry Plan

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the Policy approach to sustainable economic development in the countryside.

Support for the Policy approach is welcomed.

Question if paragraph 7.1.24 of justification and amplification relating to existing enterprises in an urban area not being permitted to relocate to the countryside should be in policy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as this terminology was taken from paragraph 5.23 of justification and amplification for Policy PED5 of Planning Policy Statement 4: Planning and Economic Development (PPS4).

Council consider it appropriate for justification and amplification rather than policy.

Suggest that circumstance d) permits other uses than economic development and paragraph 7.1.25 of justification and amplification is consistent with Policy circumstance d).

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Circumstance d) does not permit other uses as suggested. Paragraph 7.1.25 in justification and amplification is consistent with and supports the policy circumstance d) wording.

Question paragraph 7.1.29 referring to call centres and offices in the countryside - suggest they are not 'B' uses but town centre first uses under the SPPS.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 7.1.29 in justification and amplification outlines the difficulties in accommodating these uses in the countryside and clarifies the sentence at the end of the Policy box which states that ‘proposals for new offices, call centres, or storage and distribution will not be permitted unless ancillary to the main use’.

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Council would also point out that the SPPS states "...Class B1 business uses (such as offices and call centres) should be permitted if located within town centres, and in other locations that may be specified for such use in an LDP".

Suggest the last paragraph in the policy box appears to sit under circumstance (g) rather than as a separate aspect.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council confirm that the last paragraph is a separate issue covering all of ECD4. Council propose to amend the Policy box formatting to space out the last sentence from circumstance g) and put in bold to save confusion. Also, for the avoidance of doubt, add in wording to clarify that the last sentence applies to all of the circumstances a) g) in the Policy Box. – see Schedule of Proposed Modifications - Reference Number PM-047.

Suggest policy wording 'established' should be defined.

This terminology was taken from PPS4 Policy PED4 and remains a matter for professional judgement during the assessment of a proposal.

Question inclusion of e) and f) in this Policy given the footnote on page 122 refers to Class ‘B’ of the Use Classes Order and if circumstances e) and f) are intended to only be for economic development uses.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council agree that the footnote in Section 7.1 and title of Policy ECD4 should be amended to address ECD4 (f) ‘Agricultural and Forestry Development’ not being a Class B Use – see Schedule of Proposed Modifications – Reference Numbers PM-041 and PM-043.

Suggest policy wording in circumstance a) relating to ‘no major increase in the site area of the enterprise’ should be defined.

This terminology was taken from PPS4 Policy PED4 and remains a matter for professional judgement during the assessment of a proposal.

Suggest paragraph 7.1.24 of justification and amplification wording not consistent with paragraph 6.88 of SPPS which includes ‘transport impacts’.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council propose to add the suggested wording to paragraph 7.1.24 of justification and amplification – see Schedule of Proposed Modifications – Reference Number PM-048.

Seek clarification on criteria i. in d) relating to demonstrating ‘there is an unmet need’.

Acknowledge that wording in circumstance f) is reflective of SPPS paragraph 6.73, however, suggest it would benefit from clarity that proposed new buildings will also need to meet all the criteria i - iv.

Question that the policy does not reference industry related to minerals development (manufacturing and other industries).

Council note the issue and consider the draft Plan Strategy to be sound. Council consider this criterion seeks to protect from speculative development in the countryside. However, in light of the comment made, for clarity, Council suggest adding the word ‘locational’ into the policy box wording of criteria i. in d). Council also propose amending paragraph 7.1.25 of justification and amplification to reflect this Policy wording change – see Schedule of Proposed Modifications – Reference Numbers PM-044 and PM-049.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council propose to insert the suggested additional policy box wording into criteria iv. in f) – see Schedule of Proposed Modifications – Reference Number PM-045.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The footnote on page 122 in Chapter 7.1 ‘Economic Development’ states for the purposes of these policies (ECD1-4) Economic Development is defined as those use classes 116

within Part B. Council consider manufacturing or other industries in the countryside, whether they ultimately serve the minerals industry or not, will be assessed under this policy.

Suggest amendments to policy to include ‘other provisions of the LDP’ wording.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council have stated in paragraphs 1.7.4, 1.7.5 and 1.7.8 of the draft Plan Strategy that the LDP should be read in its entirety with no one policy read in isolation.

Suggest the insertion of the wording 'significant' adverse impacts in circumstance (f) of this Policy for agriculture and forestry development effectively lowers the level of protection to natural heritage interests.

Suggest should use 'no adverse impacts' wording in order to be consistent with the RDS, SPPS and CTY12 of Planning Policy Statement 21: Sustainable Development in the Countryside (PPS21), interests in furthering sustainable development and to be consistent with the biodiversity duty on public bodies by the Wildlife and Natural Environment Act (NI) 2011.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council have stated in paragraph 1.7.9 of the draft Plan Strategy that the interpretation of such terms remains with the Council in the exercise of its statutory planning functions.

Economic Development – Suggested New Policy Responses received Reference

Respondent

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Request new policy that encourages the use of social clauses, for major development to deliver positive social benefits. These clauses can secure employment opportunities, and training and skills development for local unemployed and underemployed residents.

Council consider any such agreements considered appropriate can be delivered through the proposed draft Plan Strategy Policies. In addition, a developer contribution framework will be considered by Council at some stage in the future.

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7.2 Retailing and Town Centres Introduction Responses received Reference

Respondent

MEA-DPS-032

Inaltus on behalf of Alexander Property Holdings

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Council has not properly taken into account representations made at the Preferred Options Paper (POP) stage such as designating Alexander Street in Ballymena town centre, a priority for regeneration and a Development Opportunity Site suitable for mixed uses, including B1 uses.

Council consider the draft Plan Strategy to be sound and does not need changed. Full consideration was given to all representations made to the POP. Development Opportunity Sites will not be identified spatially until the Local Policies Plan stage but that does not preclude applications being submitted for consideration against the Retailing and Town Centre aims and policies. Paragraph 7.2.9 also highlights housing and economic policies, which promote other acceptable mixed uses in the town centres.

Account has not been taken of the SPPS regarding promotion of town centres as the first location for all main town centre uses.

Council consider the draft Plan Strategy to be sound and does not need changed. The Retailing and Town Centres Introduction text and 'Policy Aims' promote established main town centres as the appropriate first choice location of retailing and other main town centre uses. The 'Implementation' section expands on what is considered retail, which types of office developments are acceptable and which other uses are considered suitable in town centres.

In addition, there are signposts to housing and economic policies which promote diversity in the range of town centre uses.

Council has not set out a Strategy from which all policies logically flow, as the draft Plan Strategy does not use the assessment of need to designate town centre boundaries and development opportunity sites.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The assessment of need referred to is the Retail and Commercial Leisure Need and Capacity Study (Jan 2019) which had many remits other than assessing existing floorspace and predicting a four-yearly need/capacity. The study also reviewed relevant planning policy, retail and market trends and consumer behaviour. It carried out quantitative and qualitative analysis of the three main towns in the borough and provided policy guidance to inform the emerging plan. The assessment of need will be updated and a 'call for sites' consultation exercise completed to help identify Development Opportunity Sites for site specific designation as part of the Local Policies Plan process.

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The designation of Development Opportunity Sites is a strategic matter informed by the available evidence base so they should be designated at draft Plan Strategy stage.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The Retail Strategy and Retail Hierarchy are set out in part 5.5 of the draft Plan Strategy and the retail policies are set out in part 7.2 of the draft Plan Strategy. Designations such as town centre boundaries and Development Opportunity Sites, being site specific in nature, will be addressed during the Local Policies Plan process. The assessment of need in the Retail and Commercial Leisure Needs and Capacity Study (Jan 2019) will be updated ahead of the Local Policies Plan process.

The draft Plan Strategy is not flexible to deal with changing circumstances as it deferred designation of Development Opportunity Sites to the Local Policies Plan. An up to date draft Plan Strategy, which sets the context for what is likely to be allowed, improves marketability and attraction and can secure land users.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Designation of Development Opportunity Sites are a site specific matter for the Local Policies Plan. The lack of such a designation on the site in question which lies within the extant Ballymena town centre boundary, does not prevent marketing, investor interest or the submission of a planning application for consideration in line with the retail aims, policies and other associated policies, which promote diversity in the town centre, outlined in the draft Plan strategy.

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Policy RET1 Retail in Town Centres Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-032

Inaltus on behalf of Alexander Property Holdings

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Policy should include reference to alternative sequentially preferable sites within the whole catchment.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest the following minor change to the policy wording of c) – see Schedule of Proposed Modifications – Reference Number PM-050.

Policy and justification and amplification differ regarding the definition of 'edge of centre'.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest the following minor change to the policy wording of a) – see Schedule of Proposed Modifications – Reference Number PM-051.

Suggest Paragraph 7.2.17 reference to 'city' should be amended to 'town' centre in line with policy.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest the following minor change to the wording of the 'Suitability' bullet point in paragraph 7.2.17- see Schedule of Proposed Modifications – Reference Number PM-052.

Clarify what is meant by 'business uses' and clarify that hospitality and tourism uses are also appropriate in town centres.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The ‘Implementation’ section of 7.2 Retailing and Town Centres Introduction adequately explains appropriate business uses and lists other acceptable town centre uses including hospitality and tourism examples.

Suggest Policy RET1 should refer to housing and B1 office uses as well as retail.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Policy RET1 deals with retail proposals in town centres however, paragraph 7.2.8 refers to Class B1 Business uses. Paragraph 7.2.9 also signposts to housing and economic policies that protect and promote appropriate types of housing and B1 business uses in town centres.

120

Policy RET2 Retail Impact Assessment Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Clarify which centres a proposal requires a Retail Impact Assessment (RIA) to take account of.

Council note the issue and consider the draft Plan Strategy to be sound, However, in light of the comments made, for clarity, Council consider the following minor wording change to the policy - see schedule of modification – Reference Number PM-053.

Clarify if a) and b) refer to local centres as well as town centres.

Council note the issue and consider the draft Plan Strategy to be sound, However, in light of the comments made, for clarity, Council consider the following minor wording change to the policy- see Schedule of Proposed Modifications – Reference Number PM-054.

Clarify whether RIA thresholds apply to the size of a proposed extension alone, or the combined size of a proposed extension when added to the existing development.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the following sentence should be added to the end of justification and amplification 7.2.19 – see Schedule of Proposed Modifications – Reference Number PM-055.

Amend justification and amplification paragraph 7.2.21 to include the factors listed in SPPS paragraph 6.290 to be included in a RIA.

Council note the issue and consider the draft Plan Strategy to be sound, However, in light of the comments made, for clarity, Council consider the following minor wording change to justification and amplification 7.2.21 - see Schedule of Proposed Modifications – Reference Number PM-056.

Clarify in what circumstances permission would be refused.

Council note the issue and consider the draft Plan Strategy to be sound, However, in light of the comments made, for clarity, Council consider an additional sentence should be added to justification and amplification 7.2.21 - see Schedule of Proposed Modifications – Reference Number PM-057.

Wording 'proportionate response' in policy box does not comply with SPPS 6.283.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The reference to proportionate response is due to the fact that the RIA could vary in detail depending on location. This sentence also indicates the requirement to incorporate an assessment of need, impact and sequential approach into any RIA. For additional clarity, justification and amplification 7.2.21 is being amended to list the factors required in an RIA – see Schedule of Proposed Modifications – Reference Number PM-056.

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Policy RET3 Retail in Villages, Small Settlements and Local Centres Responses received Reference

Respondent

MEA-DPS-010

Department for Infrastructure

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Reflect paragraph 6.2.76 of the SPPS to highlight circumstances whereby extensions are acceptable in local centres.

Council note the issue and consider the draft plan strategy to be sound. However, in light of the comment made, for clarity, Council suggest the following amendment to policy – see Schedule of Proposed Modifications – Reference Number PM-058.

Policy RET4 Rural Shops and Roadside Service Facilities Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Policy does not acknowledge the issue of retail in villages and settlements. Query if garden centres be assessed under this policy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Policy RET3 addresses retail in villages and small settlements. Garden centres were intentionally omitted from the list of acceptable rural shops to avoid the opportunity for ancillary retail uses that so often accompany them nowadays. The view was to assess garden centre applications on their individual merits.

Clarify what is meant by 'modest floorspace' and ‘modest size’ in retail terms as it may be open to interpretation.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council considers this to be a matter for professional judgement during the assessment of a proposal.

122

7.3 Tourism Policy TOU1 Safeguarding of Tourism Assets Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-009

Department for the Economy

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy relating to safeguarding of tourism assets.

Support for the proposed policy approach is welcomed.

Amend policy to also refer to the term ‘landscape character’.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Policy TOU1 already refers to 'setting’, this term covers a broad range of considerations including landscape and historic setting for example. The justification and amplification for Policy TOU1 at paragraph 7.3.5 expands upon 'visual impact' which includes reference to areas of high landscape quality.

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Policy TOU2 Tourism Development in Settlements and Tourism Opportunity Zones Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-009

Department for the Economy

MEA-DPS-025

Gravis Planning on behalf Individual

MEA-DPS-045

Mid Ulster District Council

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy and the draft Plan Strategy approach within Tourism Opportunity Zones for tourism development to be sustainable, environmentally sensitive and of high-quality design has also been adopted by Mid Ulster District Council.

Support for the proposed policy approach is welcomed.

All text changes recommended in draft Habitats Regulations Assessment Report of the draft Plan Strategy, September 2019, pages 16-20, must be accepted in full to achieve conformity and meet the legal requirements of the Conservation (Natural Habitats, etc.) Regulations (NI) 1995 (as amended). Specific reference to Policy NAT1 should be added.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor additions to the policy and justification and amplification wording should be made – see Schedule of Proposed Modifications – Reference Numbers PM-060 and PM-061.

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Policy TOU3 All Tourism Development in the Countryside Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-009

Department for the Economy

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy for tourism development in the countryside.

Support for the proposed policy approach is welcomed.

All text changes recommended in Draft Habitats Regulations Assessment Report of the Draft Plan Strategy, Sept 2019 pages 16-20, must be accepted in full to achieve conformity and meet the legal requirements of the Conservation (Natural Habitats, etc.) Regulations (NI) 1995 (as amended). Specific reference to Policy NAT1 should be added.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor additions to the policy and justification and amplification wording should be made – see Schedule of Proposed Modifications – Reference Numbers PM-062 and PM-063.

125

Policy TOU4 Tourist Amenities in the Countryside Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-009

Department for the Economy

MEA-DPS-010

Department for Infrastructure

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy.

Support for the proposed policy approach is welcomed.

Clarify what the term ‘overall development’ means extension/expansion of an existing tourist facility section.

under

This terminology was taken from Planning Policy Statement 16 (PPS 16) Policy TSM 2 and remains a matter for professional judgement during the assessment of a proposal.

Query how in the absence of a published Council tourism strategy will proposals be considered in the context of the justification and amplification at paragraph 7.3.18. This paragraph makes reference to the requirement for a tourism benefit statement to demonstrate the value of the proposal in terms of tourism revenue and employment opportunity, and also how it will further the aims of any regional or Council tourism strategy.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor alteration to paragraph 7.3.18 wording should be made – see Schedule of Proposed Modifications – Reference Number PM-064.

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Policy TOU5 Hotels, Guest Houses and Tourist Hostels in the Countryside Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-009

Department for the Economy

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy.

Support for the proposed policy approach is welcomed.

Amend justification and amplification paragraph 7.3.20 in regard to b) Replacement of an Existing Rural Building point iv. to clearly articulate what type of evidence will be required to show that a vernacular building is not reasonably capable of being made structurally sound or otherwise improved and include a more detailed explanation of how the ‘…environmental benefit of full or partial replacement.’ will be assessed, to aid consistent interpretation of the policy.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest minor alterations to the wording of paragraph 7.3.20 should be made – see Schedule of Proposed Modifications – Reference Number PM067.

Also, cross reference to the first two sentences of paragraph 10.1.62 of Policy HE8 Non-listed Locally important Building or Vernacular Building.

Amend justification and amplification for Conversion and re-use of an Existing Rural Buildings by deleting paragraph 7.3.19 as it repeats text in policy box.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

The text at paragraph 7.3.19 will be retained for ease of reading.

127

Policy TOU6 Self Catering Accommodation in the Countryside Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-009

Department for the Economy

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy.

Support for the proposed policy approach is welcomed.

Policy TOU7 New and Extended Holiday Parks in the Countryside Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-009

Department for the Economy

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy.

Support for the proposed policy approach is welcomed.

Amend justification and amplification to direct applicants to the new 'Model Licence Conditions 2019' for caravan sites, published by Department for Infrastructure.

It is considered that Appendix C of the draft Plan Strategy adequately covers the broader planning considerations in terms of holiday parks and as the Model Licence Conditions are out with planning regulations it is not necessary to include reference to them under this policy.

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Policy TOU8 Major Tourism Development in the Countryside – Exceptional Circumstances Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-009

Department for the Economy

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy.

Support for the proposed policy approach is welcomed.

Amend justification and amplification paragraph 7.3.36 to widen its scope as it is too narrow of a consideration, as areas which are adjacent to, proximate or linked in some way e.g. hydrologically to such designations should also be required to have important consideration.

If the site is a European Protected Site, then there is a legislative requirement to undertake such wider considerations as part of the Habitats Regulation Assessment.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Paragraph 7.3.35 already states that a sustainable benefit statement taking account of the considerations set out in Appendix B Tourist Amenities in the Countryside - Sustainability Assessment will be required to accompany applications for major tourism in the countryside.

This assessment already includes a range of environmental criteria that should be met.

Miscellaneous comments on Tourism Responses received Reference

Respondent

MEA-DPS-044

Individual

Issues raised by respondent are site specific and not relevant to this stage of the Local Development Plan process.

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7.4 Minerals Development Introduction Responses received Reference

Respondent

MEA-DPS-009

Department for the Economy (DfE)

MEA-DPS-010

Department of Infrastructure (DFI)

MEA-DPS-056

Quarry Plan

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for Introduction correctly noting the important economic contribution of the minerals industry. Support for policy aims and also for detail in paragraphs 7.4.7 and 7.4.8 regarding the need for better understanding of supply and demand to inform Mineral Reserve Areas (MRA) and Areas of Constraint on Mineral Development (ACMD).

Support noted and welcomed.

Reliance on 'value' figure from DfE Annual Mineral Statement is of limited significance. True 'value’ of minerals industry significantly higher than £15.1m.

Council note the issue and consider the draft Plan Strategy to be sound. Council are aware of the true 'value' of the minerals industry after extracted minerals are processed. Technical Supplement 8: Minerals Development paragraph 3.10 states that after processing, Mineral Products Association Northern Ireland (MPANI) estimated in 2017 the industry was worth around £65m to the Borough’s economy. In light of the comments made, for clarity, Council suggest amending the wording in Introduction paragraph 7.4.2- see Schedule of Proposed Modifications – Reference Number PM-070.

Encourage Council to re-engage with companies to improve evidence base.

Council note the issue. It is understood that MPANI have recently held a number of events, in partnership with DfE, to inform the Industry about the use of this data and the importance of it.

Council sit on the Regional Minerals Working Group, which works with mineral operators’ representatives, DfE and DfI with the aim of gathering a wider range of data to accurately identify the true value of the industry and establish a regional picture for supply and demand of mineral products.

Councils need to undertake thorough evidence gathering and assessment, which allows it to accurately identify the value of the

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council individually does not have the authority to demand this information and rely 130

minerals industry including employment, taxation and value of related manufacturing business.

on DfE to liaise with mineral operators and their representative bodies to encourage disclosure of same.

Agree that it is premature to proceed with the designation of MRAs or ACMDs without the evidence base, however proceeding with the legacy ACMD’s designations is also unsound, as the designations are based on a poor and outdated evidence base.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Legacy ACMD designations were proposed under another planning authority and Council do not have access to this information, which was subject to a Public Inquiry process.

Given the lack of supply and demand evidence, which is anticipated by the first plan review, Council took a precautionary approach to retain the existing layer of protection, adding exceptions and removing the established quarry that lies within the ACMD. DfI note that extant ACMD and Mineral Reserve Areas (salt mines) have been retained and further designations may follow when evidence is available. DfE also note the delay in MRA and ACMD designations and acknowledge that Councils intention to review proposed ACMDs gives no immediate cause for concern.

Insufficient improvement of evidence that ACMDs have protected the landscape from adverse effects of mineral development or that their absence would result in significant adverse impacts on the landscape.

Lack of pressure analysis from mineral development in Countryside Assessment such as those carried out on residential and wind energy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The most sensitive landscape areas have been identified using a 'scoring matrix’, and the existing ACMD has been considered within the Candidate Sensitive Landscape Report (Appendix E) of Technical Supplement 10: Countryside Assessment. Using evidence collated within the Landscape Character Assessment review and other documents within Technical Supplement 10, it provides information on the sensitivity of landscapes to obtrusive development.

Council will carry out landscape vulnerability studies ahead of considering designation of any additional ACMDs. In relation to pressure analysis, all applications received from the quarry that lay within the extant ACMD were approved. There is no record of other applications for minerals development having been refused and the Council is not aware of any Pre-Application Discussions for new mineral development in the ACMD, that were resisted.

The provisions within the draft Plan Strategy to rely upon historic legacy designations and assess proposals on a case-by-case basis are not considered fit for purpose or conducive to consistent plan making.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The Minerals Policies have been amended and updated in line with SPPS to recognise the importance of the minerals industry to the economy, employment and construction sector and the importance of a sustainable approach, through balancing the need for minerals development against safeguarding the environment. The legacy designations have been subject to a public inquiry process.

The designation of new MRAs, review of existing ACMDs and consideration of additional ACMDs will be reassessed at plan review stage when it is anticipated that a sufficient evidence base will be in place. DfE state that the Council’s retention of extant ACMDs gives no immediate cause for concern in terms of current Mineral Petroleum Licensing (MPL) and quarry operations.

Paragraph 7.4.9 says ‘our understanding from the sector is that there is no immediate demand for new quarries in the Council area’. POP

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. DfE advised Council during consultation 'there was no immediate demand for new 131

representations highlighted that some operators want to expand or invest in new mineral workings, subject to gaining planning permission and acquiring land, so flexibility should be built in to the LDP policies to allow for the sustainable extraction of minerals via existing and new workings in the future.

quarries in the Borough'. They 'welcomed the inclusion of a separate policy for hard rock and aggregates', which has a presumption in favour, outside Special Countryside Areas and Areas of Constraint on Mineral Development, for both new mineral development and extensions to existing quarries, where the listed interests are protected. No existing quarry lies within either designation.

Council consulted all mineral developers in the Borough following the POP. Two thirds replied so there remains an overall lack of knowledge locally and regionally on supply and demand, meaning it is not yet possible to determine the extent to which Mineral Reserve Areas are required in the Borough. In the meantime, all hard rock/aggregate quarries that indicated their wish to expand or develop new mineral workings during the plan period can apply under Policy MIN1.

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Policy MIN1 Minerals Development – Extraction and Processing of Hard Rock and Aggregates Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division (NED)

MEA-DPS-009

Department for the Economy

MEA-DPS- 010

Department for Infrastructure

MEA-DPS-017

FP McCann

MEA-DPS-040

James Stevenson Quarries Ltd

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-048

Mineral Products Association Northern Ireland

MEA-DPS-056

Quarry Plan

MEA-DPS-078

Wardell Armstrong LLP on behalf of The Crown Estate

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy.

Support for the proposed policy is noted and welcomed.

Change 'permission can be granted' to 'permission will be granted' in line with similar policies to offer more certainty and a presumption in favour.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor amendment to the policy wording should be made – see Schedule of Proposed Modifications – Reference Number PM-073.

Add an additional criteria 'indigenous landscape character' to interests a-f.

Council note the issue and consider the draft Plan Strategy to be sound. However, following agreement with NED, Council considers that amending interest c) instead adds clarity and addresses the issue raised. Similar wording in justification and amplification paragraph 7.4.15 will also be amended - see Schedule of Proposed Modifications – Reference Number PM-074 and PM-075.

There is no evidence why 'well-being' in interest f) relates to minerals development or how to test it.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the policy wording should be made – see Schedule of Proposed Modifications – Reference Numbers PM-076 and PM-077.

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All text changes recommended in draft Habitats Regulations Assessment (HRA) Report of the draft Plan Strategy, September 2019 pages 16-20, must be accepted in full to achieve conformity and meet the legal requirements of the Conservation (Natural Habitats, etc.)

Regulations (NI) 1995 (as amended). Specific reference to Policy NAT1 should be added.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor addition to the policy wording and justification and amplification should be made – see Schedule of Proposed Modifications – Reference Number PM-072, PM-079 and PM080.

Amend justification and amplification to add reference to potential groundwater and water quality.

Council consider this issue is adequately addressed in Policy MIN1 and its justification and amplification. Upon further discussion with DAERA and their re-assessment of the comment, they no longer request this amendment.

Landscape Character Assessment should not be used to assess impacts of a proposal on local landscape character as referenced in justification and amplification 7.4.15.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The most sensitive landscape areas have been identified using a 'scoring matrix’, and the existing ACMD has been considered within the Candidate Sensitive Landscape Report (Appendix E) of Technical Supplement 10: Countryside Assessment. Using evidence collated within the Landscape Character Assessment review and other documents within Technical Supplement 10, it provides information on the sensitivity of landscapes to obtrusive development.

Remove 'cautious approach' in justification and amplification paragraph 7.4.16. Instead, reflect how principles of SPPS paragraph 6.155 are applied.

Council note the issue and consider the draft Plan Strategy be sound and does not need changed. SPPS paragraph 6.155 advises to 'carefully consider' scope for some mineral development in AONBs that avoids key sites, would not unduly compromise the integrity of the area as a whole or threaten to undermine rationale for the designation. A 'cautious approach' is necessary in the AONB because of its acknowledged public value and status. Policy CS5 refers to the integrity of the AONB, therefore the careful assessment of a proposal on the overall integrity of the AONB amounts to the application of a 'cautious approach'.

When sufficient supply and demand evidence is available locally and regionally, Council will designate Mineral Reserve Areas, if necessary, to safeguard resources from sterilisation by surface development. Policy MIN1 permits extraction and/or processing of hard rock and aggregates from existing or new mineral workings to meet local and regional need, where proposals do not have an unacceptable adverse impact on interests a-f listed in the policy.

Justify reason for presumption against extraction and processing of hard rock and aggregates in Special Countryside Areas, similar to justification and amplification paragraph 7.4.19 of Policy MIN 2.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest an additional paragraph should be added to the justification and amplification – see Schedule of Proposed Modifications – Reference Number PM-081.

Policy approach should balance likely impacts with environmental, social and economic benefits.

Council note the comment and consider the draft Plan Strategy to be sound and does not need changed. The Technical Supplement 8: Minerals Development and the Introduction to the Minerals Development policies in the draft Plan Strategy recognises the contribution of the minerals industries to employment and Gross Value Added (GVA). The suggested revised MIN1 policy now has a presumption in favour, where certain interests are protected. The justification and amplification also acknowledges the importance of hard rock and aggregate extraction and processing to the local and regional economy and notes Council support for proposals that comply and acknowledges that sensitively restored quarries can enhance nature conservation.

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Policy MIN2 Minerals Development – Valuable Minerals Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-009

Department for the Economy

MEA-DPS-010

Department for Infrastructure

MEA-DPS-017

FP McCann

MEA-DPS-078

Wardell Armstrong LLP on behalf of The Crown Estate

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Policy MIN2 is more restrictive than the SPPS by excluding Special Countryside Areas (SCA) and indicating a cautious approach in other designated areas. Suggest absolute protection for SCA is removed. Also suggest removing double negative.

Council note the issue and consider the draft Plan Strategy to be sound. SPPS paragraph 6.75 allows areas of countryside that exhibit exceptional landscapes, wherein the quality of the landscape and unique amenity value is such that development should only be permitted in exceptional circumstances, to be designated as Special Countryside Areas, and appropriate policies brought forward to ensure their protection from unnecessary and inappropriate development. However, in light of the comments made, Council suggest minor alterations to the policy wording - see Schedule of Proposed Modifications – Reference Number PM-082, PM-083 and PM-089.

Clarify the parts of Policy MIN1 with which proposals under Policy MIN2 have to comply.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the following changes to the policy – see Schedule of Proposed Modifications – Reference Number PM-078, PM-084 and PM-085.

As policy MIN2 has a presumption in favour of mineral exploitation in all other areas apart from SCAs , it implies that it would be permitted in European Designations. Wording should be changed to reflect this and meet the requirements of the legislation.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the following changes to the policy – see Schedule of Proposed Modifications – Reference Number PM-086

Policy should include text from paragraph 7.4.19 to explain the reason for protection of SCA.

Council note the issue and consider that the amended wording of Policy MIN2 along with justification and amplification paragraph 7.4.19, removes the need for additional text in the policy box.

Salt extraction is licenced by DfE, and therefore considered a valuable mineral to be considered under Policy MIN2.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed.

This policy assesses proposals for valuable mineral exploitation in accordance with the definition of 'Valuable Minerals' in the Abbreviation and Glossary, page 312. The justification and amplification of Policy MIN2 refers to high value metalliferous minerals, precious metals and base metals. Salt extraction is considered separately under Policy MIN5.

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Policy MIN3 Minerals Development – Hydrocarbons Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-009

Department for the Economy

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

All text changes recommended in draft Habitats Regulations Assessment (HRA) Report of the draft Plan Strategy, Sept 2019 pages 16-20, must be accepted in full to achieve conformity and meet the legal requirements of the Conservation (Natural Habitats, etc.) Regulations (NI) 1995 (as amended). Specific reference to Policy NAT1 should be added.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made and to provide clarity it is proposed to amend the wording in the first sentence of policy box to comply with the draft HRA - see Schedule of Proposed Modifications – Reference Number PM-087.

Remove the term 'gases' in Policy MIN3 as the term 'hydrocarbons' encompasses gases.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, Council suggest a minor amendment the policy wording - see Schedule of Proposed Modifications – Reference Number PM-088.

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Policy MIN4 Minerals Development – Areas of Constraint on Mineral Development Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council (CCGBC)

MEA-DPS-009

Department for the Economy (DfE)

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-017

FP McCann

MEA-DPS-040

James Stevenson Quarries Ltd

MEA-DPS-056

Quarry Plan

MEA-DPS-078

Wardell Armstrong LLP on behalf of The Crown Estate

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy.

Support for the policy is noted and welcomed.

Reflect SPPS by adding 'short term extraction', but no timeframe, instead good design and operational practice.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. In SPPS paragraph 6.164 there is an option for Councils to consider whether particular processes should be justified as exceptions within ACMD and gives 'short term extraction' as an example. It does not however instruct its inclusion. Further, given the varying nature of extraction methods for differing commodities and the difficulty measuring a reasonable extraction time and economic value against amenity impacts, it was considered that to include 'short term excavation' with a time frame may not be reasonable and without a timeframe would not be a measurable or enforceable.

ACMDs could sterilise mineral reserves without knowing the quantity of minerals required in plan period.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The ACMDs were previously designated under Larne Area Plan 2010, which went through a public inquiry process. Council took a precautionary approach to maintain the existing layer of protection rather than remove it in the DPS. Council have stopped short of designating any additional MRAs, reviewing existing ACMDs or considering additional ACMDs ahead of a sufficient evidence base being available to help understand supply and demand for 137

mineral products across Northern Ireland and beyond, through the established Minerals Forum which involves representatives from local councils, DfE, DfI and the minerals industry.

Legacy ACMDs are designated using the same approach as ACMDs in Magherafelt Area Plan 2015, designated irrespective of site circumstances, based on unreliable and obsolete criteria and no tangible economic need considered. PAC said MAP 2015 approach did not suggest adequate consideration given to balancing economic and environmental considerations.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council advise that these designations were proposed under another planning authority. Council do not have access to this information and the legacy designations have been subject to a public inquiry process, unlike those in Magherafelt Area Plan 2015.

No evidence of effectiveness of ACMDs so far or that their absence would have adverse impact on landscape.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. In relation to pressure analysis, all applications received from the quarry that lay within the extant ACMD were approved. There is no record of other applications for minerals development having been refused and the Council is not aware of any Pre-Application Discussions for new mineral development in the ACMD, that were resisted.

Given this and the lack of supply and demand evidence, which will hopefully be more readily available at the first plan review, Council took a precautionary approach to maintain the existing layer of protection rather than remove it in the draft Plan Strategy. However, by adding exceptions to the policy and removing from the designation, the one quarry that lies within the ACMD, Council consider they have taken a reasonable path until new evidence will more clearly define whether resources, which exist within the ACMD, will be required to meet local and regional demand in future.

The most sensitive landscape areas have been identified using a 'scoring matrix’, and the existing ACMD has been considered within the Candidate Sensitive Landscape Report (Appendix E) of Technical Supplement 10, which provides information on the sensitivity of landscapes to obtrusive development. Council will carry out landscape vulnerability studies ahead of considering designation of any additional ACMDs. No commitment to review ACMDs or their effectiveness so there is an imbalance in favour of protectionism rather than a balanced approach.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Section 7.4 Mineral Development - Introduction (Implementation section) outlines that the ultimate aim is to adopt a more comprehensive plan led approach to balance the need for minerals development against the need to protect and conserve the environment and that it is envisaged that this will eventually result in Mineral Reserve Areas (MRAs) in addition to the salt mine at Kilroot.

DfI acknowledge that Council have identified ACMDs in their proposals map in line with the SPPS paragraph 6.155 and note that ACMD and Mineral Reserve Areas (salt mines) from extant plans have been brought forward and further designations will not be made until the conclusion of the ongoing work of the regional mineral’s forum. DfI advise that clarity provided in Introduction paragraphs 7.4.8 & 7.4.9 is welcomed. DfE note the delay in MRA and ACMD designations until the Minerals Forum gathers evidence and agree to continue working with

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this forum. DfE acknowledge that Councils intention to review proposed ACMDs gives no immediate cause for concern in terms of minerals planning licences.

Section 7.4 also advises that there may be a need to consider the designation of additional Areas of Constraint on Mineral Development. The text should also have noted that existing ACMDs will be reviewed at plan review stage, to consider whether resources that are currently sterilised by the designation are required to meet the supply and demand in the Borough, or regionally over the plan period. So, in light of the comments made, for clarity, Council suggest an alteration to the wording of paragraph 7.4.7 should be made - see Schedule of Proposed Modifications – Reference Number PM-071.

No evidence why on-site processing of excavated material in ACMDs is harmful. The term 'unlikely' gives scope for some processing.

Council notes the issue and considers the draft Plan Strategy to be sound and does not need changed. Areas of Constraint on Mineral Development are designated for their intrinsic landscape, amenity, scientific or heritage value and for their nature conservation importance and Council consider that noise, vibration and dust associated with processing would have a detrimental impact on such assets. However, the policy says processing is 'unlikely to be permitted', allowing the developer to demonstrate if a method of processing were to have minimal adverse effects.

Suggest the term "valuable" in Policy MIN4 is defined clearly to avoid debate. Clarify that gold and silver is also included.

Council note the issue and consider the draft Plan Strategy to be sound. The reference to 'valuable' in Policy MIN4 is referring to the 'valuable minerals' as defined in policies MIN2 and MIN3. Justification and amplification paragraph 7.4.28 also refers to valuable minerals in the context of policies MIN2 and MIN3, which clearly describe them as ‘high value metalliferous metals or hydrocarbons’.

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Policy MIN5 Minerals Development – Area of Salt Reserve, Carrickfergus Responses received Reference

Respondent

MEA-DPS-009

Department for the Economy

MEA-DPS-010

Department for Infrastructure

MEA-DPS-017

FP McCann

MEA-DPS-039

Irish Salt Mining & Exploration Co. Ltd

MEA-DPS-048

Mineral Products Association Northern Ireland

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy.

Support for the policy is noted and welcomed.

Unfair emphasis is placed on the importance of valuable minerals.

Similar protection should be given to all mineral workings.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Further Mineral Reserve Areas will be designated to protect hard rock and aggregates when the supply and demand evidence supports it, as explained in the Minerals Introduction paragraphs 7.4.7-7.4.8.

MIN5 reads that it is acceptable to prejudice exploitation of salt reserves in certain exceptions. Instead the wording should indicate that development may be permitted within Areas of Salt Reserve."

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The intention of this policy is to strike a balance which permits the exceptions listed, where they meet this criterion in the related policies HOU3 and HOU9 so as not to prejudice the expansion of existing businesses/farms or existing dwellings, while refusing all other types of new surface development. This approach will minimise prejudice to the exploitation of the salt reserve as far as is reasonably possible.

Description of salt as valuable mineral in 7.4.29 is not replicated in the definition of ‘Valuable Minerals’ in the Abbreviations and Glossary.

Council note the issue and consider the draft Plan Strategy to be sound. Council acknowledge that salt is a valued resource regionally and beyond. However, in light of the comments made, for clarity and consistency, Council suggest the minor alteration to the wording should be made - see Schedule of Proposed Modifications – Reference Number PM-090.

Reference should be made to both ‘new and old shafts’ and ‘new and old mining’ in justification and amplification paragraph 7.4.30, rather than just ‘old shafts and new mining’.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest the minor alteration to the wording should be made - see Schedule of Proposed Modifications – Reference Number PM-091.

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Liability disclaimer is not appropriate or logical in justification and amplification paragraph 7.4.30.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The terminology is taken from the long-established Salt Reserves policy explanation in the Carrickfergus Area Plan 2001.

Add reference to the possibility of noise/vibration from blasting within mining areas into paragraph 7.4.30.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. There are multiple informatives that may be applicable to specific applications which will be added to their permissions accordingly, so it is not considered reasonable to highlight some and not others in the justification and amplification.

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Policy MIN6 Minerals Development – Development at Risk of Subsidence due to past or present underground mineral extraction Responses received Reference

Respondent

MEA-DPS-009

Department for the Economy (DfE)

MEA-DPS-010

Department for Infrastructure

MEA-DPS-017

FP McCann

MEA-DPS-037

Inaltus on behalf of N.K. Holdings Ltd

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support policy approach. Acknowledge limited coastal information.

Support for policy approach is noted and welcomed.

Welcomes policy direction to consult DfE Geological Survey Northern Ireland.

Support for policy approach is noted and welcomed.

Some areas shown on Map 7.1 have already collapsed. Council should do its own Mine Risk Assessment to provide more detailed mapping.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council defer to experts in DfE GSNI for guidance on areas of subsidence and are advised that appraisal of risk associated with all four areas shown on Map 7.1 is ongoing and no changes are suggested to the extent of these Areas of Subsidence, whilst underlying voids exist.

Expand policy to provide similar protection for hard rock quarries. New developments located close to mineral workings may be subjected to other impacts such as noise, dust, vibration. Numerous single dwellings have been approved too close to active mineral sites - so a protective policy would eliminate this risk.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. This policy specifically deals with known areas of potential subsidence and cannot be expanded to protect quarries from complaints of noise dust and vibration. Such potential impacts have to be dealt with under policy GP1 part d) Criteria relating to safety and the safeguarding of human health/wellbeing and if necessary, in consultation with HSENI during the application process.

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Policy MIN7 Minerals Development – Peat Extraction Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division (NED)

MEA-DPS-010

Department for Infrastructure

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Welcome this policy in principle.

Support for the policy in principle is noted and welcomed

Clarify policy applies to new, extended and renewal sites.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest the following minor change to the wording should be made – see Schedule of Proposed Modifications – Reference Number PM-093.

Policy fails to explain 'not reasonably capable of restoration' Explain or remove completely.

Council note the issue and considers the draft Plan Strategy to be sound. The suggested definition is already included in the third sentence of justification and amplification paragraph 7.4.36.

Add to justification and amplification paragraph 7.4.36 'peatland with a peat layer of 0.5m or more is considered capable of restoration'.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. NED advised that peat depth is only a guide and one of three aspects along with hydrology and vegetation composition, to take into consideration when assessing how difficult or appropriate restoration would be at any given site. NED advise that this information and the text in the draft Plan Strategy uses tested language from the Interpretation Manual of European Habitats and is less likely to be challenged.

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If MEA is to take climate change commitments seriously, then applications/proposals, which increase the release of CO 2, in situations where peatland is drained, removed or disturbed, should be resisted.

Suggest removing exceptions from policy. Suggest replacing paragraph 7.4.37 with ‘For those sites currently being extracted, restoration plans should be in place for them, and that the developer will need to demonstrate that the proposed management structures and finance are in place for the restoration of these sites. In such cases, a planning agreement between relevant parties may be required’.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. NED agreed the need for this exception to the policy advising of the possibility it may need to be used in exceptional circumstances. Further, DfI encouraged its inclusion as these scenarios are mentioned in the Water Strategy. The wording in justification and amplification paragraph 7.4.37 highlights the same requirements as the suggested re-wording.

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Policy MIN8 Minerals Development – Restoration and Management of Mineral Sites Responses received Reference

Respondent

MEA-DPS-009

Department for the Economy

MEA-DPS-017

FP McCann

MEA-DPS-040

James Stevenson Quarries Ltd

MEA-DPS-048

Mineral Products Association Northern Ireland

MEA-DPS-056

Quarry Plan

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-078

Wardell Armstrong LLP on behalf of The Crown Estate

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Welcome policy. Note financial guarantee options sufficiently covers all options.

Support for policy approach noted and welcomed.

Supports management plans & acknowledgement of difficulty in sourcing sufficient restoration materials on site.

Support for the policy approach is noted and welcomed. However, Council emphasise that importation should only be used where it is not practicable to source materials on site.

Several respondents suggested adding additional community, economic or environmental benefits to the list of benefits to be secured by restoration plans, to allow other sustainable options.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, Council consider the alteration to the policy wording and clarification in the justification and amplification should be made - see Schedule of Proposed Modifications – Reference Numbers PM-094 and PM-095.

Biodiversity should be compulsory not optional to comply with SPPS & public sector duty to conserve it.

Council note the issue and consider the draft plan strategy to be sound and does not need changed. The SPPS Minerals section does not state that restoration proposals should provide enhanced biodiversity in every case. SPPS 6.161 acknowledges that 'applications must include satisfactory restoration proposals but the preferred types of reclamation and after use depend on a number of factors...'

Larger extraction sites cannot always be restored in phases. Phased progressive restoration should be assessed on a case-by-case basis

Council note the issue and consider the draft Plan Strategy to be sound. However, Council accept that not all larger schemes can be restored in phases. The ‘timescale’ referred to in the 145

and specific policy is therefore not necessary. Extraction is ultimately dictated by market demand. As such, flexibility should be applied to restoration linking timescales to the extraction of the mineral. This could be done via planning conditions. It is too rigid currently and cannot be applied to all types of working.

policy is an agreed period of time within which either the exhausted quarry or a particular phase begins restoration, as opposed to a date in time by when it has to be restored. For clarity, Council suggest two minor alterations to the policy wording and clarification in the justification and amplification should be made - see Schedule of Proposed Modifications – Reference Numbers PM-096 and PM-097.

Clarify what is meant by 'legitimate concerns over an operator’s financial security.' in the policy. Suggest that bonds may be appropriate for 'rogue' operator with a history of non-compliance, but care should be taken to ensure reputable mineral operators are not unfairly subjected to significant cost associated with a bond to secure restoration.

Council notes the issue and considers the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest the minor alteration to the wording in paragraph 7.4.41 should be made - see Schedule of Proposed Modifications – Reference Number PM098.

Add 'access to site by officers shall be provided' to ensure aftercare plans being implemented correctly.

Council note the issue and consider the draft plan strategy to be sound and does not need changed. Council officials are permitted to the 'right to enter' under Article 236 of the Planning Act (Northern Ireland) 2011.

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Minerals Development – Suggested New Policy Responses received Reference

Respondent

MEA-DPS-017

FP McCann

MEA-DPS-040

James Stevenson Quarries Ltd

MEA-DPS-048

Mineral Products Association Northern Ireland

MIN-DPS-056

Quarry Plan

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Need Mineral Reserve Areas (MRAs) designated to safeguard basalt reserves. Inconsistent to retain Areas of Constraint on Mineral Development (ACMDs) without designating MRAs. Mid and East Antrim produces 31% of all basalt in Northern Ireland. Previously advised Council that based on current outputs, expect permitted reserves at Loughside Quarry would be exhausted before end of plan period. Intend seeking planning permission to extend beyond existing quarry boundary and ask that these lands be protected with MRA.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The retained ACMD designations have been subject to a public inquiry process.

Council took a precautionary approach to retain the existing layer of protection, adding exceptions and removing the established quarry that lies within the ACMD. Department for Infrastructure (DFI) note that the extant ACMD and MRAs (salt mines) have been retained and further designations may follow when evidence is available. Department for Economy (DfE) also note the delay in MRA and ACMD designations and acknowledge that Councils intention to review proposed ACMDs gives no immediate cause for concern.

The designation of new MRAs, review of existing ACMDs and consideration of additional ACMDs will be reassessed at plan review stage when it is anticipated that a sufficient evidence base will be in place. Specifically, the Loughside Quarry map shows an area in green, within its ownership, which is approximately equivalent in size to one third of the existing quarry area.

It was not made clear how many years of excavation this area would yield. Policy MIN1 allows for extensions to existing and new mineral workings where certain interests are protected, so ahead of MRAs being considered, expansion is still possible.

Need MRAs designated to protect operators from sterilisation by other forms of development and ensure supply. Failure to designate MRAs has the potential to impact upon mineral development and conversely the potential to impact upon potential new sensitive receptors.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. DfE indicated the need for clearer understanding of supply and demand for minerals products across NI to properly inform designation of MRAs and ACMDs and also note the delay in MRA and ACMD designations and acknowledge that Council’s intention to review proposed ACMDs gives no immediate cause for concern. The Minerals Working Group is tasked to

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gather this evidence base to assess supply and demand regionally and help inform LDPs. Council regard it as premature to designate MRAs pending the outcome of this work.

Include a positive policy to promote Secondary Aggregate Protocol.

Promote recycling of construction waste.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The Waste & Resources Action Programme does not specifically mention the requirement for LDPs to include a policy on Secondary Aggregate Protocol. However, Policy WMT2 - Waste Collection and Treatment Facilities, allows for proposals such as recycling of secondary aggregates in suitably located sites within an active or worked out quarry and provides criteria for the determination of planning applications for various types of recycling facilities as well as other waste facilities. The policy seeks to support proposals for the development of waste collection and treatment facilities, subject to the Waste Management Strategy and the Council Waste Management Plan (currently arc21).

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Miscellaneous comments on Minerals Development Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-017

FP McCann

MEA-DPS-056

Quarry Plan

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-078

Wardell Armstrong LLP on behalf of The Crown Estate

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Given 'cautious approach' proposed in paragraph 7.4.16 of Policy MIN1, there is no need for a further layer of policy protection in ACMDs.

Council note the comments. addressed in MIN4 comments.

In Policy MIN2 - Sufficient buffer zones and/or policy should ensure mineral prospecting sites are not restricted.

Council are unclear of the nature of this point so are unable to respond.

Note that Area of Constraint on Mineral Development abuts the boundary of Causeway Coast and Glens Borough Council.

Council note the comment and will continue to engage with Causeway Coast and Glens Borough Council on cross boundary issues.

In Policy MIN4, the presumption against does not apply to valuable minerals but they do not provide materials to facilitate construction in the Borough in the way hard rock and aggregates do.

Council note this comment.

Questions the proposed approach of designating ACMDs but note plan to review at Local Policies Plan stage.

Council are unable to rebut this issue, as the respondent does not elaborate on what is questionable about the approach to designating ACMDs.

What opportunity is there for public to scrutinise new evidence gathered

by Minerals Forum?

Council advise that the public would be consulted on any proposed new designations as part of the plan review process and the evidence base would form the justification for such proposals.

However, consideration of the designation of ACMDs is

149

8.0 Building Sustainable Communities

150

8.1 Housing Policy HOU1 Quality in New Residential Development in Settlements Responses received Reference

Respondent

MEA-DPS-005

Co-Ownership Housing Association Limited

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive (NIHE)

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Heron Bros

MEA-DPS-075

Turley on behalf of Northern Ireland Federation of Housing Associations

MEA-DPS-077

Turley on behalf of Vaughan Homes

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which will aid good design, sustainable and safe residential environments and place making. Support for reference to Departmental guidance.

Support for the proposed policy approach is welcomed.

Amend policy/justification and amplification to clarify the relationship between Policy HOU1 and SGS5 and phasing.

Council note the issue and consider the draft Plan Strategy to be sound. Paragraphs 1.7.4, 1.7.5 and 1.7.8 of the draft Plan Strategy state that the LDP should be read in its entirety with no one policy read in isolation. For example, Policy HOU1 would apply to any housing site whether zoned land (phase 1 or phase 2) or unzoned land. There could still be a presumption to refuse planning permission for Phase 2 sites on the grounds of prematurity and prejudice to the sequential approach to housing development in settlements over 5,000 population under SGS5. In the event of a successful appeal, Policy HOU1 would be needed to ensure quality 151

development on such sites. However, in light of the comments made, for clarity, Council suggest minor additions to the policy of SGS5 and justification and amplification wording of Policy HOU1 – see Schedule of Proposed Modifications – Reference Number PM-100.

Amend policy- Size standards in Appendix F should apply to all new housing.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as the size or the reduced size of dwellings has only been identified as an issue, largely, in established residential areas. Applying the standards in established residential areas will help to ensure the character of such areas are safeguarded.

Amend policy/justification and amplification to state that open space should be in a variety of formats and native species planting is encouraged.

Council note the issues and consider the draft Plan Strategy to be sound and does not need changed. Policy OSL4 elaborates on open space requirements and indicates that it can be in a variety of different forms. The planting issue is addressed in ‘Creating Places’ and Policy HOU1 signposts to ‘Creating Places’ in the policy box.

Amend policy to promote energy efficient homes and buildings that can easily incorporate renewable energy technology e.g. renewable heating sources.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Policy GP1 (e)(v) states that the development should take account of efficient use of energy, water and other resources where feasible and practicable, integrating microgeneration and passive solar design. It is considered that extending this further would diverge into Building Control Regulations, beyond the remit of the LDP. Appendix D of the draft Plan Strategy is referred to in the policy box and includes guidance on Sustainable Design (page 330).

Amend justification and amplification to clarify when developers will need to provide neighbourhood facilities.

This will be identified where necessary through the Local Policies Plan process and in consultation with Community Planning.

Concept Masterplans should demonstrate the comprehensive planning of the site and how affordable housing obligations will be met.

Council will continue to engage with NIHE in regard to the practical mechanisms required for the delivery of affordable housing in those settlements where a need has been identified.

Lack of evidence to justify new Concept Master Plan threshold which is lower than is currently applied within Planning Policy Statement 7 (PPS7) Policy QD2.

Council consider the proposed threshold for the submission of a Concept Master Plan is appropriate to reflect the potentially smaller sizes of housing development in the Borough that will come forward across the LDP period. This will ensure that well-designed Concept Master Plans will be applicable over a larger number of smaller developments rather than a limited number of larger ones. Analysis of applications received in the Borough from January 2011 to March 2018 indicated two applications over 200 units and one application over 300 units.

Amend policy as text at the start of the second paragraph is unclear as the policy sets a requirement for a concept master plan for all development but then goes on to specify that it is only required in particular circumstances.

Council consider the policy wording is clear that either a Design Concept Statement or a Concept Master Plan will be required for all proposals for residential development.

152

Amend policy as it has failed to consider the legislative requirement for some applications to be accompanied by a design and access statement.

Council have fully considered the legislative requirement for some forms of planning applications, including major residential applications to be accompanied by a Design and Access Statement. By only relying on the submission of a Design and Access Statement through the current legislation would mean applications below the 50 units threshold would not be required to submit either a Design and Access Statement nor a Design Concept Statement.

Design and Access Statements and Design Concept Statements are considered two slightly different elements but in certain applications they could be used to complement each other to help achieve a quality residential environment.

Density levels should be applied on a site-by-site basis and the design of residential development based on a robust assessment of need.

Council note the issues and consider the draft Plan Strategy to be sound and does not need changed. The policy requires design to take into account local context and individual site characteristics and it is not prescriptive in regard to density. The requirement to submit a Design Concept Statement for residential development is to ensure that a site assessment has taken place and that development has been designed on the basis of the findings. Council are of the opinion that the policy has the flexibility to allow assessment on a site by site basis where necessary.

153

Policy HOU2 The Conversion or Change of Use of Existing Buildings to Flats or Apartments Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Justification and amplification paragraph 8.1.20 contradicts policy as it refers to instances where less than 150sqm gross may be acceptable.

Council note the issue and consider the draft Plan Strategy to be sound. This terminology was taken from the Addendum to Planning Policy Statement 7: Safeguarding the Character of Established Residential Areas Policy LC2 and remains a matter for professional judgement during the assessment of a proposal.

Policy HOU3 Residential Extensions and Alterations Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which can enhance the flexibility, resilience and endurance of a dwelling.

Support for the proposed policy is welcomed.

Justification and amplification paragraph 8.1.29 refers to house extensions – does this mean it is not relevant to flats or apartments.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest a minor change to the wording of paragraph 8.1.29 – see Schedule of Proposed Modifications – Reference Number PM-101.

154

Policy HOU4 Protected Town Centre Housing Areas Responses received Reference

Respondent

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Strong support for the policy.

Support for the proposed policy is welcomed.

Would like to see planning permission granted for town centre living accommodation where there is adequate access, and facilities for essential services such as refuse and fuel storage; and flexibility in car parking standards for town centre housing schemes.

Council note the issues and consider the draft Plan Strategy to be sound and does not need changed. Residential development schemes for town centre living will be assessed under policies such as GP1, HOU1 and HOU2 which require criterion to be met to ensure adequate access and provision of amenity space for refuse and fuel storage. Policy TR6 allows for flexibility in car parking requirements i.e. in highly accessible locations such as town centres.

155

Policy HOU5 Affordable Housing in Settlements Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-005

Co-Ownership Housing Association Limited

MEA-DPS-023

Gravis Planning on behalf of Conway Estates

MEA-DPS-024

Gravis Planning on behalf of Conway Estates and Individuals

MEA-DPS-025

Gravis Planning on behalf of Individual

MEA-DPS-027

Gravis Planning on behalf of Individual

MEA-DPS-028

Gravis Planning on behalf of Individual

MEA-DPS-029

Gravis Planning on behalf of Individual

MEA-DPS-030

Gravis Planning on behalf of Individual

MEA-DPS-043

MBA Planning on behalf of CYM Properties

MEA-DPS-049

Northern Ireland Housing Executive (NIHE)

MEA-DPS-066

TSA Planning on behalf of Lotus Homes

MEA-DPS-067

TSA Planning on behalf of Rosemount Homes

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Heron Bros

MEA-DPS-075

Turley on behalf of Northern Ireland Federation of Housing Associations

MEA-DPS-077

Turley on behalf of Vaughan Homes

MEA-DPS-079

White Young Green on behalf of Individual

156

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy, thresholds, justification and amplification paragraph 8.1.39 and the principle of securing a mix of tenure. It is considered the policy will add to the delivery of affordable housing.

Support for the proposed policy approach is welcomed.

Policy lacks flexibility and affordable housing should be dealt with at Local Policies Plan stage.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The removal of policy HOU5 would leave a policy gap until such times as affordable housing would be addressed through key site requirements at Local Policies Plan stage.

Strategic subject Policy HOU5 provides a hook for the Local Policies Plan to include the requirement of affordable housing through zonings/key site requirements where necessary. In addition, as villages and small settlements will not have housing zonings, affordable housing could not be delivered in these tiers through key site requirements. As zoned sites with key site requirements may not be sufficient to meet affordable housing needs in some settlements the SPPS allows for affordable housing to be considered on sites coming forward through the development management process.

Paragraph 6.142 of the SPPS requires LDPs to identify settlements where the Housing Needs Assessment has found there to be an affordability pressure. Also, paragraph 6.143 states that zoning/key site requirements will not preclude other sites coming forward through the development management process.

Policy HOU5 will only apply where there is a need for affordable housing as identified in the Housing Needs Assessment from NIHE or other relevant housing authority.

Conflict between policy and justification and amplification as paragraph 8.1.39 refers to minimum threshold and policy does not.

This paragraph also suggests the possibility of higher affordable provision being identified in the Local Policies Plan which is at odds with the draft Plan Strategy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. There is not a conflict between the policy and the justification and amplification.

Amend Policy/justification and amplification to state the development should be tenure blind and integrated with market housing or give flexibility for pepper-potting of shared ownership homes including both apartments and houses in developments, and it would be preferable to state that “where possible and practical” the affordable housing units should be dispersed throughout the development.

It is acknowledged that there are advantages and disadvantages to including the reference to pepper-potting but by not specifically referring to it allows flexibility.

Amend justification and amplification to expand the definition of affordable housing to include the following criteria:

Council do not consider it necessary to include the three criteria suggested as the definition of 'social rented housing' within the glossary of the draft Plan Strategy addresses the first two

Strategic subject Policy HOU5 provides a hook for the Local Policies Plan to include the requirement of affordable housing through zonings/key site requirements where necessary. The draft Plan Strategy builds in flexibility, which enables a higher provision of affordable housing to be sought at Local Policies Plan stage.

157

1. the affordable housing is delivered by a registered housing association;

proposed criteria. In terms of the third proposed criteria, the LDP has no control over the price of affordable housing.

2. the affordable housing is allocated by a housing association to eligible households who cannot access market housing; and 3. the affordable housing units remain at an affordable price for future eligible households or if these restrictions are lifted, the subsidy shall be recycled for alternative affordable housing provision.

Amend justification and amplification to state that social housing should be delivered to Department for Communities (DfC) Housing Association Guide Standards.

Council note the issue and consider the draft Plan Strategy to be sound. In light of the comment made, for clarity, Council suggest a minor change to the wording of paragraph 8.1.38 – see Schedule of Proposed Modifications – Reference Number PM-102.

Amend thresholds as there is a lack of evidence to justify them nor has it been demonstrated alternatives were considered.

Possible alternatives suggested including:

The thresholds and quotas for this policy were set taking into account the draft Plan Strategy Strategic Spatial Framework, land availability, the level of committed housing sites, local need and projections in the Housing Needs Assessment and discussion with NIHE.



The policy should only apply when proposals meet/exceed 'major residential development threshold' (50 units/1ha+).



1 to 20 Units – Nil, 21 to 50 Units – 10%, 51 to 250 Units – 15%, 250 Plus Units – 20%.

The policy is not flexible to ensure viability and the policy is vague about responsibility for delivery or funding of the affordable housing.

An analysis of potential yield for affordable housing was considered in those settlements where the Housing Needs Assessment identified a need. As many of the housing sites in the Borough are already committed, a low threshold was considered necessary, and supported by NIHE, to maximise the number of sites from which affordable housing units that could be sought in order to provide an adequate supply of affordable housing, especially for rural areas. The threshold of 10 units or more was therefore considered the most appropriate. If set any lower (e.g. 5 units) it may be difficult for a development to incorporate affordable housing units or achieve a meaningful mix of units. NIHE did not support higher thresholds, as these would reduce the provision of social rented and intermediate housing and the policy aim of mixed tenure development. In terms of the second part of the threshold (a site of 0.2 hectare or more), the results of a density analysis of Mid and East Antrim settlements found that sites of 0.2 hectares or more were most likely to accommodate 10 units or more.

Pages 39 and 40 of Technical Supplement 3: Housing sets out how the quotas for the policy was determined. This includes how alternative quotas were considered and dismissed.

Affordable housing has economic benefits and is a multiplier for many areas in the market and supports the construction industry. NIHE have advised that social rented housing is typically funded through a combination of DfC grant funding, which is administered by NIHE, and a registered housing association’s own funding. Social rented housing development is controlled within financial parameters, set out by the DfC under Total Cost Indicators (TCI), an ‘all-in’ forecast on unit costs based on land and property costs from Land and Property Services. Policy HOU5 allows for housing that will be used for social renting to be purchased from the developer by a registered housing association at TCI. This typically provides a 15% profit to developers.

As grant will only be payable to registered housing associations, who acquire properties from the developer; therefore, the developer should discuss proposals, TCI levels and financing with a registered housing association at an early stage in the process. Intermediate housing will also be fully funded and will provide a profit for developers. As the affordable housing units will be 158

financed by registered housing associations, it is understood that schemes should be financially viable. In addition, the provision of affordable housing will guarantee the developer certain sales, delivering a cash flow to provide finance for the market housing.

NIHE have also outlined that negotiations to reduce affordable housing requirements will only be necessary where site circumstances result in exceptional or abnormal costs. However, the presence of these issues should reduce land value. The price paid for land will not be considered in the assessment of viability, rather land value will be the current value as independently calculated. It is only at this point that viability should be considered and this would require the applicant to provide a full viability appraisal of the submitted proposal. As such, viability will be a material consideration during the processing of the application. The exact mechanism and considerations may be contained in supplementary planning guidance.

It is considered that the policy provides adequate flexibility. It allows for consideration of affordable housing on a case-by-case basis dependant on the need (including mix of social rented/intermediate housing) in a particular settlement based on the up-to-date Housing Needs Assessment. In circumstances where the number of affordable housing units required by this policy would exceed the need identified by NIHE, a lower number of units will be acceptable.

2018 Housing Needs Assessment has not been published to establish if the draft Plan Strategy complies with soundness test C3.

The 2018 Housing Needs Assessment has been submitted as part of the documents for consideration during the Independent Examination.

Weaknesses in urban capacity methodology means lands may not deliver affordable housing.

Council note the issue and consider the methodology of the interim Urban Capacity Study to be sound.

Policy does not reflect the variances of affordable housing across the Borough.

Paragraph 6.142 of the SPPS requires LDPs to identify settlements where the Housing Needs Assessment has found there to be an affordability pressure. Policy HOU5 will only apply 'where a need for Affordable Housing is established by the Northern Ireland Housing Executive or other relevant housing authority through a Housing Needs Assessment'. The policy quotas will only apply in those settlements where the up to date Housing Needs Assessment identifies a need for affordable housing. The policy sets out that developers should liaise with a registered Housing Association and NIHE to discuss the exact mix of affordable housing (social rented and/or intermediate housing) required in each case, reflecting the variances of need across the Borough. Policy HOU5 enables other sites to come forward through the development management process.

Council should consider any potential exceptions to the provision of affordable housing e.g. elderly housing or development that would facilitate the reuse of heritage assets.

The policy seeks to help achieve balanced communities and provide a mix of social groups regardless of the age of the occupants. The reuse of a heritage asset is not considered an exception to this policy.

The intermediate housing definition in the glossary of the draft Plan Strategy should be aligned with the definition that is approved by DfC to ensure future affordable housing products can be accommodated under this policy.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest a minor change to the wording in the glossary – see Schedule of Proposed Modifications – Reference Number PM-158.

159

Policy HOU6 Housing Mix (Unit Types and Sizes) Responses received Reference

Respondent

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Heron Bros

MEA-DPS-077

Turley on behalf of Vaughan Homes

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy in strong and broad terms.

Support for this proposed policy is welcomed.

Amend policy to cross-reference Policy HOU6 with Policy HOU1 in relation to established residential areas and the minimum sizes set out in Appendix F of the draft Plan Strategy.

Council consider that cross referencing of the policies is not necessary as Council have stated in paragraphs 1.7.4, 1.7.5 and 1.7.8 of the draft Plan Strategy that the LDP should be read in its entirety with no one policy read in isolation.

The policy does not provide a detailed breakdown of the preferred housing mix and does not provide clarification in regard to 'smaller schemes'. Amend policy/justification and amplification to incorporate flexibility for developments to respond to local market context and need/demand as the current wording is overly restrictive.

The policy does not provide a detailed breakdown in order to allow for flexibility as this will vary across settlements and individual sites. The justification and amplification recognises that the appropriate mix of house types and sizes will be for consideration on a case-by-case basis depending on the location, site characteristics and local housing need patterns, therefore allowing the freedom for negotiation. Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor alteration to the policy wording should be made – see Schedule of Proposed Modifications – Reference Number PM-103.

160

Policy conflicts with the SPPS as it does not specify a threshold for when a mix of house sizes/tenures is required.

Council would argue that the proposed threshold does not conflict with the SPPS. It is within the Council's remit to produce a policy that is appropriate to local circumstances.

Lack of evidence provided to justify retaining the thresholds as set out in Planning Policy Statement 12: Housing in Settlements Policy HS4 or to consider viability implications.

Council are content that Policy HOU6 is justified. It reinforces the need to promote choice and assists in meeting community needs and achieves balanced communities as set out in the SPPS. The POP set out the intention to carry forward the existing policy threshold of sites of 25 units or more and his issue was not challenged at that stage. The existing policy threshold is appropriate in the Mid and East Antrim context. The provision of a variety and mix is an important design principle in all residential development and is set out in documents such as 'Creating Places'. This policy seeks to reinforce that this is particularly important in larger schemes. The policy is not prescriptive and the viability of a development is recognised as it states in the justification and amplification that the appropriate mix of house types and sizes in each case will be influenced by the location, site characteristics and local housing need patterns. Where a mix of unit types may not be viable, sufficient flexibility exists for this to be taken into account.

161

Policy HOU7 Adaptable and Accessible Homes Responses received Reference

Respondent

MEA-DPS-010

Department for Infrastructure

MEA-DPS-023

Gravis Planning on behalf of Conway Estates

MEA-DPS-024

Gravis Planning on behalf of Conway Estates and Individuals

MEA-DPS-025

Gravis Planning on behalf of Individual

MEA-DPS-027

Gravis Planning on behalf of Individual

MEA-DPS-028

Gravis Planning on behalf of Individual

MEA-DPS-029

Gravis Planning on behalf of Individual

MEA-DPS-030

Gravis Planning on behalf of Individual

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-052

Northern Health and Social Care Trust

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Heron Bros

MEA-DPS-075

Turley on behalf of Northern Ireland Federation of Housing Associations

MEA-DPS-077

Turley on behalf of Vaughan Homes

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy criteria and the overall intention of policy is welcomed as it will help improve the attractiveness of the housing product

Support for the policy criteria and overall intention of the policy is welcomed.

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provided. Council are also commended for commitments to Building Sustainable Communities, including adaptable and accessible homes.

Remove policy as it should not be a planning requirement.

Council note the issue and consider the draft Plan Strategy to be sound. Legislation or regional planning guidance does not preclude the addition of this policy.

Amend policy to clarify it applies to all residential development rather than just ‘a new dwelling’.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for consistency, Council suggest a minor change to the policy wording – see Schedule of Proposed Modifications – Reference Number PM-104.

Request a requirement for the private sector to deliver a proportion of wheelchair standard dwellings. This would help meet the needs of wheelchair users who wish to own their own homes. It is also highlighted that Section 75 of the Northern Ireland Act 1998 requires public authorities to have regard to the need to promote equality of opportunity between nine equality categories, including persons with a disability.

The specific needs of disadvantaged and marginalised groups have been considered and Policy HOU7 is the best and most practical way to meet these needs through the planning remit. A policy for wheelchair accessible homes was put forward at POP stage and discounted following discussion with Building Control as given the technical nature it was not practicable to bring such a policy forward (see Technical Supplement 3: Housing).

Exceptional circumstances test in justification and amplification paragraph 8.1.47 is too high a threshold for justifying a relaxation of policy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraph 8.1.47 of the justification and amplification recognises there may be exceptional circumstances where not all the policy criteria can be met.

Lack of evidence to support the policy or why it should apply to every new home and how Council assessed the implications of the proposed policy with respect to development viability. The policy lacks flexibility for constrained sites and could unintentionally restrict the regeneration of brownfield sites.

At POP stage Council's preferred option was a policy for all ground floor apartments in blocks of two storey or above to be wheelchair accessible units. Following consultation on this preferred option it was realised this proposed policy approach was too narrow and would only have targeted smaller niche households. The policy approach was amended to try to meet the needs of wider society and comply with the Community Plan. Our evidence shows that in most residential schemes the criteria in this policy are already being met and our policy aim is to formalize their inclusion in all residential schemes. Paragraph 8.1.47 of the justification and amplification offers the flexibility to address potentially constrained sites in exceptional circumstances.

Lack of evidence in terms of figures in relation to the ageing population and those with mobility issues does not justify applying the policy to every new home.

Lifetime Homes are designed for people at all stages of life or if someone took unwell, we have used what standards planning can apply to assist with this. With an ageing population, it is necessary to adopt a proactive approach towards increased accessibility of housing stock. The standards can be included for relatively little additional cost compared to adaptions at a later stage. The need for the proposed policy is based on demographic realities and the inaccessibility of existing housing stock.

163

Policy HOU8 Travellers Accommodation Responses received Reference

Respondent

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-049

Northern Ireland Housing Executive (NIHE)

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy to ensure that travellers' needs are adequately catered for.

Support for the proposed policy is welcomed.

Council to be satisfied that evidence supports the approach set out in Policy HOU8, and that the Housing Needs Assessment prepared by NIHE will, as appropriate, indicate need for single family sites.

NIHE have advised that they are reviewing their needs assessment for Travellers Accommodation. It is intended to include Traveller Accommodation within the annual Housing Needs Assessment, thus providing need figures on an annual basis. This will take into account the need for transit sites and single family sites.

Amend justification and amplification to refer to the new Model Licence Conditions 2019 for Caravan Sites (DfI) and draft Design Guide for Travellers' Sites 2019 (Department for Communities).

As the guidance documents suggested are out with the remit of planning it is not considered necessary to refer to them in this policy.

164

Policy HOU9 Replacement Dwelling Responses received Reference

Respondent

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-031

Individual

MEA-DPS-061

Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Amend justification and amplification under the subtitle ‘Non-Residential Building’ to provide examples of eligible ‘permanent redundant nonresidential buildings’ and give guidance on what can be considered ‘significant environmental impacts’ to provide greater clarity and consistent decision making.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

It is considered that applications will be assessed on a case-by-case basis using planning judgement as policy cannot legislate for every scenario.

Amend justification and amplification to emphasise the importance of good design and to refer to the supplementary guidance, Building on Tradition: A Sustainable Design Guide for the Northern Ireland Countryside.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

Policy HOU9 specifically refers to the General Policy (GP1) in which part f) applies to development in the countryside. The justification and amplification of Policy GP1 states that the document 'Building on Tradition' should be considered.

Policy HOU10 should be closely linked with Policy HOU9 as farmers are using small buildings to obtain planning permission and are then selling them on to the non-farming community which circumvents each of the Policy Aims.

The draft Plan Strategy policies HOU9 and HOU10 are standalone policies that allow for a dwelling under both policies if the applicant meets the required criteria. The LDP has no control over who owns buildings that meet Policy HOU9 or who the site is sold to.

Amend policy and justification and amplification by removing both the subtitle ‘Listed Buildings’ from the policy box and associated justification and amplification text under paragraph 8.1.55.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

The subtitle is directional, and the same applies to non-listed vernacular dwellings.

165

Policy HOU10 Dwelling on a Farm Business Responses received Reference

Respondent

MEA-DPS-010

Department for Infrastructure

MEA-DPS-061

Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for justification and amplification clarification on the definition of a farm business for the purpose of applying the policy.

Support for the proposed policy approach is welcomed.

Policy HOU10 should be closely linked with Policy HOU9 as farmers are using small buildings to obtain planning permission and are then selling them on to the non-farming community which circumvents each of the Policy Aims.

Draft Plan Strategy policies HOU9 and HOU10 are standalone policies that allow for a dwelling under both policies if the applicant meets the required criteria. The LDP has no control over who owns buildings that meet Policy HOU9 or who the site is sold to.

Policy HOU11 Dwelling for Non-Agricultural Business Enterprise No representations received

Policy HOU12 New Dwelling in Existing Clusters Responses received Reference

Respondent

MEA-DPS-031

Individual

Issues raised by respondent are site specific and not relevant to this stage of the Local Development Plan process.

166

Policy HOU13 Ribbon/Infill Development Responses received Reference

Respondent

MEA-DPS-010

Department for Infrastructure

MEA-DPS-016

Ferguson Planning on behalf of Individual

MEA-DPS-031

Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the approach which seeks to apply SPPS policy to local circumstances.

Support for the proposed policy approach is welcomed.

Guidance provided within Policy HOU13 conflicts with guidance contained within Policy CTY8 of Planning Policy Statement 21: Sustainable Development in the Countryside (PPS 21). That guidance allows up to two units whereas the draft policy appears to be providing a restriction to a single unit.

This requires further investigation/amendment.

Councils have the primary responsibility for the implementation of key planning functions including local plan making. This allows Councils to bring forward operational policies tailored to local circumstances. When the draft Plan Strategy has been adopted the existing PPS 21 policy shall cease to have effect.

Policy HOU14 Personal and Domestic Circumstances Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

No issues raised by respondent and wording changes between Policy HOU14 and PPS 21 Policy CTY6 are noted.

Policy HOU15 Residential Caravans and Mobile Homes No representations received 167

Policy HOU16 Affordable Housing in the Countryside Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-005

Co-Ownership Housing Association Limited

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive (NIHE)

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy as it will provide flexibility if needed during the plan period and the thresholds give local expression to the policy approach set out in the SPPS.

Support for the policy is welcomed.

Amend policy and justification and amplification to include NIHE as one of those permitted to make an application and state the onus is on developer to demonstrate that there are no alternative available sites in settlement limits.

Council note the issues and consider the draft Plan Strategy to be sound. NIHE has confirmed that it is reasonable to expect them to submit applications for affordable housing in the countryside. In light of the comments made, for clarity, Council suggest minor alterations to the policy and justification and amplification wording should be made – see Schedule of Proposed Modifications – Reference Numbers PM-106 and PM-107.

Policy to give flexibility for pepper-potting of shared ownership homes including both apartments and houses in developments. It would be preferable to state that “where possible and practical” the affordable housing units should be dispersed throughout the development.

It is acknowledged that there are advantages and disadvantages to stipulating in policy that affordable homes should be pepper-potted throughout a development. However, by not specifically referring to this requirement in policy it provides flexibility for applications to be assessed on a case-by-case basis.

Development in the Antrim Coast and Glens AONB should be sympathetically sited, of vernacular design and materials should be used as laid out in the Antrim Coast and Glens AONB Design Guide.

The policy box text requires proposals to be sited and designed to integrate sympathetically with their surroundings, meet the General Policy and accord with other provisions of the LDP. This will include General Policy criteria specific to the countryside and the Antrim Coast and Glens AONB Design Guide.

The intermediate housing definition in the glossary of the draft Plan Strategy should be aligned with the definition that is approved by the Department for Communities.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest a minor change to the wording in the glossary - see Schedule of Proposed Modifications – Reference Number PM-158.

168

Suggested new policy for supported/specialist housing accommodation Responses received Reference

Respondent

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Herron Bros

MEA-DPS-077

Turley on behalf of Vaughan Homes

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

The draft Plan Strategy should include a development management policy for supported/specialist housing accommodation.

Whilst the draft Plan Strategy does not include a specific policy for the assessment of supported/specialised accommodation applications, Council is of the opinion that there is nothing within the draft Plan Strategy that would prejudice or prevent their development.

Paragraph 1.7.8 of the draft Plan Strategy states that all policies considered relevant to the proposed development will be taken into account when determining an application. For example, this may include relevant policies such as GP1, HOU1 and TR6. Policy TR6: Parking and Servicing allows for the precise amount of car parking to be determined according to the specific characteristics of the proposal. In addition, the justification and amplification of Policy COM1 states that this policy applies to residential care homes and nursing homes.

169

8.2 Open Space, Sport and Leisure Policy OSL1 Protection of Open Space Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-049

Northern Ireland Housing Executive (NIHE)

MEA-DPS-052

Northern Health and Social Care Trust

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the approach to protect open space.

Support for the proposed policy approach is welcomed.

Amend justification and amplification to include affordable housing as an example of substantial community benefit.

It is not appropriate to single out affordable housing as an exception as there could be many examples of community benefits. Listing some exceptions and not others potentially limits the flexibility of the policy.

Amend justification and amplification to state that generally the community should be in support of the development and applications should demonstrate the community have been consulted, even if the development is not classed as ‘major’.

The proposed justification and amplification states that proposals have to be supported by the community and this should be demonstrated. This applies to all applications that would result in a loss of open space which fall under exception a) not just applications classified as ‘major’.

Retain joint protocol between NIHE and DOE for operation of open space exception policy in Planning Policy Statement 8: Open Space, Sport and Outdoor Recreation.

Discussion on a similar protocol between Council and NIHE for the operation of Policy OSL1, will take place outside the LDP process.

170

Policy OSL2 Greenways Responses received Reference

Respondent

MEA-DPS-001

Antrim and Newtownabbey Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-007

Individual

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-043

MBA Planning on behalf of CYM Properties

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-052

Northern Health and Social Care Trust

MEA-DPS-055

Pragma Planning on behalf of Carnlough Developments Ltd

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy approach to protect and enhance greenways.

Support for the proposed policy approach is welcomed.

Route of the potential greenways in and adjacent to the Area of Outstanding Natural Beauty (AONB) should be protected from development.

Council is satisfied that Policy OSL2 is sufficient to address the point raised. Planning permission will not be granted for development either within or adjacent to a designated regional or community greenway which could prejudice the retention, enhancement or further development of an identified route. It is not considered necessary to distinguish greenways in or close to the AONB from other locations. All merit equal protection as provided for in Policy OSL2.

Regional greenways should not stifle development.

Proposed greenway routes will be considered through the Local Policies Plan process. The route of the proposed greenways on maps accompanying the draft Plan Strategy is indicative only.

Council should work with adjacent councils to facilitate greenways across boundaries.

Council will continue to engage and work with our neighbouring councils on the cross-boundary issue of greenways.

171

Do not support greenway route on disused railway between Greenisland and Mossley.

Council will continue to engage and work with our neighbouring councils on the cross-boundary issue of greenways.

Route of Ballymena to Cushendall regional greenway should be changed to take account of permission.

Proposed greenway routes are a matter for further consideration through the Local Policies Plan process. The route of the proposed greenway on maps accompanying the draft Plan Strategy is indicative only. Where greenway routes are compromised alternative provision will have to be made.

LDP should have strategic policies for specific walking routes to Larne.

Proposed greenway routes are a matter for further consideration through the Local Policies Plan process.

Provide policy for greenways to be funded by developer contributions and their delivery with housing.

Policy OSL2 Greenways sets out how community greenways will be supported. Policy OSL4 Public Open Space in New Residential Developments sets out how much open space is required in a particular development. This may take the form of a community or regional greenway. Policy OSL4 sets out that the developer will have to satisfy Council that suitable arrangements will be put in place for the future management and maintenance in perpetuity of areas of public open space. Paragraph 8.2.16 of the justification and amplification of Policy OSL4 notes that where appropriate, planning agreements may be used to secure open space.

A guidance framework on planning agreements and developer contributions will be developed

by Council at some stage in the future.

Heritage led approach should be employed when disused transport corridors are being reused.

The importance of the historic environment has been adequately addressed. The policy states that proposals will have to meet the General Policy and accord with other provisions of the LDP. This includes policies protecting the historic environment.

LDP must take account of the Greenway Strategy and the Cycling Routes Masterplan.

Account has been taken of DfI's Strategic Plan for Greenways (2016) and Council’s Cycling Routes Masterplan to inform the Local Policies Plan process.

Would like bike hire stations along greenways.

Comment noted.

172

Policy OSL3 New Open Space Provision Responses received Reference

Respondent

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-052

Northern Health and Social Care Trust

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support this small and succinct policy.

Support for the proposed policy approach is welcomed.

173

Policy OSL4 Public Open Space in New Residential Development Responses received Reference

Respondent

MEA-DPS-005

Co-Ownership Housing Association Limited

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-052

Northern Health and Social Care Trust

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Heron Bros

MEA-DPS-075

Turley on behalf of Northern Ireland Federation of Housing Associations

MEA-DPS-077

Turley on behalf of Vaughan Homes

MEA-DPS-079

White Young Green on behalf of Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the requirement to provide adequate open space provision, the potential for developer contributions for new or upgraded play facilities and production of a guidance note.

Support for the proposed policy approach is welcomed.

Amend policy to include requirement that children's play areas should be easily accessible to meet the needs of disabled people and that children can access them safely.

The policy text states that public open space required by this policy should provide safe and easy access for the residents and in addition, proposals must meet the General Policy that includes criteria c) ii - a movement pattern supports active travel and meets the needs of those with disabilities.

174

Amend policy to incorporate an appropriate degree of flexibility for open space requirements for sites that have development constraints e.g. topographical, ecological, environmental sensitivities, contamination, access, and/or built heritage issues.

The policy is adequately flexible stating that where open space is required the precise amount, location, type and design of such will be negotiated with applicants taking account of the specific characteristics of the development.

Amend justification and amplification to state that open space should be in a variety of forms dependent on the type of units and that it encourages the use of native species.

The policy states the amount, location, type and design of open space provision will be negotiated taking account of the specific characteristics of the development, site and context.

The justification and amplification also states that open space can be provided in a variety of different forms. Council are also content that the requirements and guidance within Policy HOU1 and ‘Creating Places’ are sufficient in this regard.

Insufficient evidence to support changing PPS 8 Policy OS2 requirement of 15% from sites of 300 units/15 hectares to sites of 10 hectares or more.

Policy OSL4 of the draft Plan Strategy states that ‘the precise amount, location, type and design of such provision will be negotiated with applicants taking account of the specific characteristics of the development, the site and its context’.

The policy does not introduce an arbitrary threshold of requiring 15% of the total site area for sites of 10 hectares or more but sets out a normal expectation and includes possible exceptions.

It is considered by Council that due to the exceptionally low number of applications received for developments of 15 hectares or more and to support social objective d) the delivery of quality residential environments (including associated public open space and linkages to green infrastructure networks); it is appropriate to lower this expectation to sites of 10 hectares or more.

Insufficient evidence to support changing PPS 8 Policy OS2 (iii) from ‘ease of access’ to ‘direct an unobstructed access’.

The terms are self-explanatory and remain a matter for professional judgement during the assessment of a proposal. The rationale behind the wording is that there could be open space located adjacent to a development but direct access is restricted by a wall or fence, for example. Areas of existing open space in close proximity to the development should not be relied on for reduced standards if they are not readily accessible.

Insufficient evidence to support changing PPS 8 Policy OS2 to remove reference to Home Zone concept.

From examination of historical applications, there is no demand in the Council area to justify the inclusion of Home Zones as an exception to the policy.

Insufficient evidence for removing exception for equipped play space to be provided in residential developments and replacing with key site requirement at Local Policies Plan.

Sites of a size that require play parks will be zoned through the Local Policies Plan process.

Key site requirements may not require one as there might already be a play park nearby and this will be assessed on a site by site basis. The policy wording is included to fill the gap period before key site requirements apply.

Insufficient evidence for removing the following criterion from PPS 8 Policy OS2: 'its design, location and appearance takes into account the amenity of nearby residents and the needs of people with disabilities'.

The criteria 'its design, location and appearance takes into account the amenity of nearby residents and the needs of people with disabilities' has been incorporated into Policy GP1 Parts b) and c).

175

Insufficient evidence for removing the following criterion from PPS 8 Policy OS2: 'it retains important landscape and heritage features and incorporates and protects these in an inappropriate fashion'.

The criterion 'it retains important landscape and heritage features and incorporates and protects these in an inappropriate fashion' has been incorporated in Policy GP1 Parts a) and b).

Insufficient evidence for removing arrangements with respect to management of public open space from policy text currently in PPS 8 Policy OS2 to justification and amplification.

Whilst relocated to the justification and amplification it still makes clear in the policy that the developer has to satisfy Council that suitable arrangements have to be in place - this is not exhaustive.

Insufficient evidence for removing developers to be responsible for layout of open space from the policy text currently in PPS 8 Policy OS2 to justification and amplification.

It is considered that the requirement for all developers to be responsible for the layout and landscaping of open space is satisfactorily covered through the justification and amplification and in addition, this also states that conditions will be attached where applicable.

Insufficient evidence for justification and amplification introducing developer contributions.

The reference to developer contributions is included by way of information to advise that further guidance on planning agreements and developer contributions will be developed in the future.

Council should be more ambitious in setting targets for new public open space in residential developments to further sustainable development and conserve biodiversity.

Policy is required to find a balance between the delivery of housing and the provision of public open space and the thresholds proposed are considered to achieve this.

Planning agreements securing affordable housing provision should state that service charges associated with the maintenance of open space should be fair and reasonable to ensure that they do not ultimately render the affordable units unaffordable.

The rate of service charges associated with the maintenance of open space in residential developments are outside the remit of the LDP.

Policies for provision of open space should assess the existing quantity of provision and consider what is required to meet future need and assess quality and consider off site provision or maintenance of existing provision as a reasonable alternative.

The policy allows for exceptions and flexibility. It states that open space will be negotiated with applicants taking account of the specific characteristics of the development. There is a degree of provision for off-site/exceptions in part b) of the policy.

The draft Plan Strategy contains sufficient measures to encourage and support sustainable development as per the SPPS. The Open Space Strategy paragraph 5.8.1, the General Policy, Policy HOU1 and Sustainable Urban Drainage all encourage and support measures for sustainable development.

176

Policy OSL5 Sport and Outdoor Recreation Facilities Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-052

Northern Health and Social Care Trust

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy.

Support for the proposed policy approach is welcomed.

All text changes recommended in draft Habitats Regulations Assessment Report of the draft Plan Strategy, September 2019, pages 16-20, must be accepted in full to achieve conformity and meet the legal requirements of the Conservation (Natural Habitats, etc.) Regulations (NI) 1995 (as amended). Specific reference to Policy NAT1 should be added.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor additions to the policy and amplification and justification wording should be made – see Schedule of Proposed Modifications – Reference Numbers PM-108, PM-109, PM-110 and PM-113.

Criteria in Policy OSL5 section on Development of Facilities Ancillary to Water Sports should apply in coastal locations.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor addition to the policy wording should be made – see Schedule of Proposed Modifications – Reference Number PM-111.

Amend policy to include the wording 'and accord with other provisions of the LDP' in section regarding Floodlighting.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor addition to the policy wording should be made – see Schedule of Proposed Modifications – Reference Number PM-112.

Amend policy to include criteria regarding proposals should not negatively impact on the amenity of existing residents.

As proposals assessed under Policy OSL5 will also have to comply with Policy GP1 which sets out criteria to safeguard residential amenity, it is not considered necessary to reiterate this consideration in the policy text of Policy OSL5.

Amend policy to include PPS8 Policy OS6 criteria vii- there is no conflict with provisions of any local management plan.

This is already included in Policy OSL5 under Development of Facilities Ancillary to Watersports (page 203 of draft Plan Strategy) as per the existing Policy OS6 in PPS 8.

177

Policy OSL6 Community Growing Spaces and Allotments Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-052

Northern Health and Social Care Trust

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the development of community growing spaces and allotments.

Support for the proposed policy approach is welcomed.

Policy OSL6 could be amalgamated with Policy OSL3 and new part of Policy OSL5.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Supporting the delivery of growing spaces is a key issue in Mid and East Antrim Borough Council as our Community Plan recognises the positive contribution they make to health and wellbeing and the creation of shared space. It is considered appropriate to retain Policy OSL6 as a separate policy as this demonstrates co-ordination with Council's Community Plan.

178

Policy OSL7 Cemeteries and Burial Space Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-052

Northern Health and Social Care Trust

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the flexible approach to future cemetery provision.

Support for the proposed policy approach is welcomed.

Policy OSL7 could be amalgamated with Policy OSL3 and new part of Policy OSL5.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. It is considered appropriate to retain Policy OSL7 as a separate policy for a number of reasons: 1. The provision of cemeteries and burial spaces is a specific issue within Mid and East Antrim Borough Council due to existing capacity issues; 2. Cemeteries have the potential to be a cross boundary issue; and 3. This type of open space has specific policy criteria.

179

Miscellaneous comments on Open Space, Sport and Leisure Responses received Reference

Respondent

MEA-DPS-011

Department of Justice

MEA-DPS-047

Individual

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Designing out Crime should be embedded in the principles and guidance which support the implementation of open space. Doing this at an early stage can reduce costs arising from anti-social behaviour and crime as well as deliver social and economic benefits.

This point has been addressed through GP1: General Policy for all Development under criterion d) iii. which seeks to ensure that development is designed to deter crime and promote personal safety. Open space proposals will have to meet Policy GP1. In addition, Policy HOU1 and its associated Appendix D provide guidance that will be taken into account in seeking to provide quality residential environments. This includes 'Secured by Design', which sets out principles for designing out crime from the built environment.

Green space vital for healthy population and it should be the basis of future development and not an add-on to plans.

Comments noted.

180

8.3 Health, Education, Community and Cultural Facilities Policy COM1 Education, Health, Community and Cultural Facilities Responses received Reference

Respondent

MEA-DPS-007

Individual

MEA-DPS-009

Department for the Economy

MEA-DPS-011

Department of Justice

MEA-DPS-012

Donaldson Planning on behalf of Ballymena Development Consortium

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-052

Northern Health and Social Care Trust

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the allocation and protection of land for education, health, community and cultural facilities.

Support for the proposed policy approach is welcomed.

Designing out Crime should be embedded in the principles and guidance which support the implementation of the built environment and open space. Doing this at an early stage can reduce costs arising from anti-social behaviour and crime as well as deliver social and economic benefits.

Council are content that this point has been addressed through GP1: General Policy for all Development under criterion d) iii. which seeks to ensure that development is designed to deter crime and promote personal safety. In addition, Policy HOU1 and its associated Appendix D provide guidance that will be taken into account in seeking to provide quality residential environments. This includes 'Secured by Design', which sets out principles for designing out crime from the built environment.

A developer contribution policy, where the uplift in land values generated by the granting of planning permission should help fund additional community infrastructure that is needed to contribute to the development of sustainable communities and their well-being.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. If appropriate, Council have the mechanism to contribute to infrastructure through the existing draft Plan Strategy policies.

Public transport infrastructure to Northern Regional College’s campuses should support student and staff mobility. This is especially important given the emphasis on social inclusion and the wider rural agenda.

Comments noted.

181

9.0 Transportation, Infrastructure and Connectivity

182

9.1 Transportation Policy TR1 Access to Public Roads Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach relating to development proposals accessing on to the public road.

Support for the proposed policy approach is welcomed.

Question if policy approach supports the Policy Aims and Strategic Objective to focus new developments in accessible locations for public transport services and promote integration between transportation and new development.

Council consider that both the General Policy GP1 c) and the Transport policies (in particular Policy TR5 on Active Travel) will help Council achieve this objective and the Policy Aims.

Policy should refer to the need for all developments to include an assessment of the transport implications of the development to include a travel time accessibility assessment.

Council consider that this request would place an onerous burden on applicants to require a travel time accessibility assessment for all development. In any case, it is not clear which locations the travel time assessment would be required to be based upon.

Developments which generate significant transport demand will require the preparation of a formal Transport Assessment.

Additional description of Transport Assessments, reflecting their focus on maximising the use of public transport, walking and cycling should be included in the justification and amplification section.

Council agree that a transport assessment would be required for developments which generate significant travel movements. General Policy GP1 c) iii. requires applicants to demonstrate the existing road network has sufficient capacity or can be upgraded to safely manage any extra traffic from a proposed development. Transport Assessments are then referred to within Paragraph 6.1.9 of General Policy GP1 justification and amplification, which also highlights Departmental guidance on Transport Assessments.

In addition, it is not until the Local Policies Plan process that actual locations for new development will be designated, along with potential Key Site Requirements relating to the integration of transport and active travel.

183

Policy TR2 Access to Protected Routes Reponses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

MEA-DPS-063

Translink

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach to restrict access on to Protected Routes.

Support for the proposed policy approach is welcomed.

Question if policy approach supports the Policy Aims and Strategic Objective to focus new developments in accessible locations for public transport services and promote integration between transportation and new development.

Council consider that both the General Policy GP1 c) and the Transport policies (in particular Policy TR5 on Active Travel) will help Council achieve this objective and the Policy Aims.

In addition, it is not until the Local Policies Plan process that actual locations for new development will be designated, along with potential Key Site Requirements relating to the integration of transport and active travel.

184

Policy TR3 New Transport Schemes Reponses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-012

Donaldson Planning on behalf of Ballymena Development Consortium

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach to help protect and deliver transport schemes.

Support for the proposed policy approach is welcomed.

Question if policy approach supports the Policy Aims and Strategic Objective to focus new developments in accessible locations for public transport services and promote integration between transportation and new development.

Council consider that both the General Policy GP1 c) and the Transport policies (in particular Policy TR5 on Active Travel) will help Council achieve this objective and the Policy Aims.

Lack of evidence base for Policy TR3 and question why policy is silent on strategic or non-strategic road schemes. Suggest it would have been appropriate to seek to identify road schemes at this stage in the development of the plan.

Policy TR3 refers to ‘transport schemes’ and is silent on the issue of strategic or non-strategic road schemes because none of the existing legacy road schemes within our Borough are considered 'strategic' by DfI, as highlighted in both Technical Supplement 9: Transportation and previously in our Preferred Options Paper.

In addition, it is not until the Local Policies Plan process that actual locations for new development will be designated, along with potential Key Site Requirements relating to the integration of transport and active travel.

Council consider the assessment of non-strategic road schemes is a matter for the Local Policies Plan process when zonings and other considerations have been finalised. Council consider this approach is consistent with the SPPS and DfI guidance on the preparation of Transport Policies.

Suggest inconsistency between Policy TR3 which states that developer contributions to new transport schemes would be commensurate to the scale of that development which relies on the transport scheme and Transportation Technical Supplement or Local Transport Study (LTS) which indicates that any capacity schemes will be delivered by developers.

Council consider that the draft Plan Strategy Transport Strategy, paragraph 5.7.3 and Policy TR3 do all complement each other. The evidence contained within the draft LTS and Technical Supplement 9: Transportation is that the existing road schemes in the Borough are all considered by DfI to be non-strategic and therefore would be required to be developer led if retained for implementation.

In addition, Policy TR3 is more than road schemes alone as it also refers to transport schemes which potentially may be required in the future.

185

Policy TR4 Disused Transport Routes Reponses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for Policy approach to protect disused transport routes.

Support for the proposed policy approach is welcomed.

Question if policy approach supports the Policy Aims and Strategic Objective to focus new developments in accessible locations for public transport services and promote integration between transportation and new development.

Council consider that both the General Policy GP1 c) and the Transport policies (in particular Policy TR5 on Active Travel) will help Council achieve this objective and the Policy Aims.

In addition, it is not until the Local Policies Plan process that actual locations for new development will be designated, along with potential Key Site Requirements relating to the integration of transport and active travel.

186

Policy TR5 Active Travel Reponses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

MEA-DPS-038

Invest NI

MEA-DPS-055

Pragma Planning on behalf of Carnlough Dev Ltd

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach encouraging Active Travel.

Support for the proposed policy approach is welcomed.

Question if policy approach supports the Policy Aims and Strategic Objective to focus new developments in accessible locations for public transport services and promote integration between transportation and new development.

Council consider that both the General Policy GP1 c) and the Transport policies (in particular Policy TR5 on Active Travel) will help Council achieve this objective and the Policy Aims.

Policy should include wording on Transport Assessments.

Council consider adequate reference to Transport Assessments has been made within General Policy GP1 c) iii. which requires applicants to demonstrate the existing road network has sufficient capacity or can be upgraded to safely manage any extra traffic from a proposed development. Transport Assessments are then referred to within Paragraph 6.1.9 of General Policy GP1 justification and amplification, which also highlights Departmental guidance on Transport Assessments.

Support promotion of integrated transport and new development approach but express caution in relation to industrial sites.

Council acknowledge concerns but consider that efforts can still be made to improve linkages to economic development sites to encourage active travel without compromising safety.

In addition, it is not until the Local Policies Plan process that actual locations for new development will be designated, along with potential Key Site Requirements relating to the integration of transport and active travel.

187

Policy TR6 Parking and Servicing Reponses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-063

Translink

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-071

Turley on behalf of Clanmil Housing Group

MEA-DPS-073

Turley on behalf of Hagan Homes

MEA-DPS-074

Turley on behalf of Herron Bros

MEA-DPS-077

Turley on behalf of Vaughan Homes

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach addressing Parking and Servicing arrangements associated with development proposals.

Support for the proposed policy approach is welcomed.

Question if policy approach supports the Policy Aims and Strategic Objective to focus new developments in accessible locations for public transport services and promote integration between transportation and new development.

Council consider that both the General Policy GP1 c) and the Transport policies (in particular Policy TR5 on Active Travel) will help Council achieve this objective and the Policy Aims.

References to planning guidance that is now outdated or which could become outdated should be removed.

Council propose to update the wording used when referring to planning guidance - see Schedule of Proposed Modifications – Reference Numbers PM-039, PM-114, PM-115 and PM131.

Policy should include wording on Transport Assessments.

Council consider adequate reference to Transport Assessments has been made within General Policy GP1 c) iii. which requires applicants to demonstrate the existing road network has sufficient capacity or can be upgraded to safely manage any extra traffic from a proposed

In addition, it is not until the Local Policies Plan process that actual locations for new development will be designated, along with potential Key Site Requirements relating to the integration of transport and active travel.

188

development. Transport Assessments are then referred to within Paragraph 6.1.9 of General Policy GP1 justification and amplification, which also highlights Departmental guidance on Transport Assessments.

Highlight importance of controlling parking to change travel behaviour and question the policy approach to parking restraint.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council are content not to designate areas of parking restraint and instead rely on the policy wording which contains an element of parking restraint as well as a flexible approach to parking in accessible locations such as town centres. The proposed policy will ensure future land use plans are sustainable with regards to parking restrictions.

Policy should be flexible in the application of parking standards in affordable housing schemes, due to lower car ownership levels for social housing, than other tenures of development.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Flexibility is afforded in the policy wording and in paragraph 9.1.34 of justification and amplification stating it may not always be required. As stated in policy, this will be determined by specific characteristics of the development and location, as well as meeting one of the five circumstances for reduced parking standards.

Lack of evidence base for new criteria within Policy TR6 and request that Council provide further evidence to support the variations to the existing policy provisions contained within PPS3 Policy AMP7.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council have worked closely with DfI Roads on ensuring the drafting of parking policy is sound and includes the relevant aspects of Policy AMP7 of Planning Policy Statement 3: Access, Movement and Parking (PPS3). Council considers that the evidence is included in the policy formulation text which has evolved from discussions with various stakeholders including DfI and Elected Members.

Lack of evidence base for not including reference to Areas of Parking Restraint in the wording of Policy TR6.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. There are no existing Areas of Parking Restraint (APR) in the 3 legacy adopted plans. One ARP was proposed in Carrickfergus through draft BMAP but was the same boundary as the town centre boundary. It is considered Policy TR6 in relation to 'accessible locations' can have the same effect as designating APR. DfI Roads are content with our approach and considered this policy to be sound.

Policy fails to acknowledge other important considerations such as occupier/market requirements and project/development viability when considering ‘precise amount of parking’.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider that the policy wording 'specific characteristics of the development' covers these points raised.

Paragraph 9.1.37 of justification and amplification in relation to what is 'exceptional circumstances' for parking in excess of the published standards should be in Policy and also be expanded upon in justification and amplification.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed and should remain as justification and amplification. Council consider the onus will be on the applicant to demonstrate exceptional circumstances to justify parking in excess of published standards.

Question criterion b) and what is to be considered as a 'highly accessible location'.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. This terminology was taken from PPS 3 Policy AMP7 and remains a matter for professional judgement during the assessment of a proposal.

189

Question criterion c) and what is to be considered as 'nearby'.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. This terminology was taken from PPS 3 Policy AMP7 and remains a matter for professional judgement during the assessment of a proposal.

Question criterion e) and justification and amplification paragraph 9.1.35 on what is to be considered as ‘broader planning gain’.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider the onus will be on the applicant to demonstrate broader planning gain and public benefit in a specific proposal and how that outweighs reduced parking.

Question wording of justification and amplification paragraph 9.1.38 and what is considered ‘an 'appropriate proportion' of disabled spaces.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Development Control Advice Note 11: Access for All (DCAN 11) has been withdrawn

by DfI since publication of the draft Plan Strategy. It is Council’s intention to produce Supplementary Planning Guidance on this.

Question wording of justification and amplification paragraph 9.1.38 and what is considered an 'appropriate amount' of electric charging points.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council had sought guidance on this from both DfI and the Department for Economy prior to publication of the draft Plan Strategy and were informed these standards are still unknown. Once standards are available, it is Council’s intention to produce Supplementary Planning Guidance on this.

190

Policy TR7 Provision of Car Parks Reponses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-063

Translink

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy approach relating to the provision of car parks.

Support for the proposed policy approach is welcomed.

Question if policy approach supports the Policy Aims and Strategic Objective to focus new developments in accessible locations for public transport services and promote integration between transportation and new development.

Council consider that both the General Policy GP1 c) and the Transport policies (in particular Policy TR5 on Active Travel) will help Council achieve this objective and the Policy Aims.

In addition, it is not until the Local Policies Plan process that actual locations for new development will be designated, along with potential Key Site Requirements relating to the integration of transport and active travel.

All text changes recommended in draft Habitats Regulations Assessment (dHRA) Report of the draft Plan Strategy must be accepted in full to achieve conformity and meet the legal requirements of the Conservation (Natural Habitats, etc.) Regulations (NI) 1995 (as amended). Specific reference to General Policy and other provisions of the LDP should be added.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council propose that the minor alterations to the policy wording suggested in the dHRA should be made – see Schedule of Proposed Modifications – Reference Number PM-116.

Policy should include wording on Transport Assessments.

Council consider adequate reference to Transport Assessments has been made within General Policy GP1 c) iii. which requires applicants to demonstrate the existing road network has sufficient capacity or can be upgraded to safely manage any extra traffic from a proposed development. Transport Assessments are then referred to within Paragraph 6.1.9 of General Policy GP1 justification and amplification, which also highlights Departmental guidance on Transport Assessments.

Highlight the importance of controlling parking in changing travel behaviour.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider the parking policies ensure a balance between control and flexibility in relation to parking. Council would consider that the proposed policy will ensure future land use plans are sustainable with regards to parking.

191

9.2 Flood Risk and Drainage Policy FRD1 Development within Floodplains Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support policy approach to managing development within floodplains.

Support for the proposed policy approach is welcomed.

FRD1 Development within Floodplains

Policy FRD2 Protection of Flood Defence and Drainage Infrastructure Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy protecting flood defence and drainage infrastructure.

Support for the proposed policy approach is welcomed.

192

Policy FRD3 Management of Development in regard to Surface Water Flood Risk Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach to managing development outside of floodplains in regard to surface water flood risk.

Support for the proposed policy approach is welcomed.

193

Policy FRD4 Sustainable Drainage (SuDS) Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-051

Northern Ireland Water

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-077

Turley on behalf of Vaughan Homes

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support policy approach to protecting flood defence and drainage infrastructure.

Support for the proposed policy approach is welcomed.

Question policy approach to groundwater flood risk.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The SPPS, Planning Policy Statement 15: Planning and Flood Risk (PPS15), and the draft Plan Strategy all refer to the four main types of flooding, of which groundwater flooding is not one. There are no existing policies on groundwater flooding within the SPPS or existing PPS15, with that PPS only referencing groundwater in relation to flood-proofing and how SuDS could encourage infiltration and natural groundwater recharge.

Policy FRD4 on Sustainable Drainage and Appendix I of the draft Plan Strategy (which brings over the references to groundwater from existing PPS) covers this issue. DfI Rivers have also found the proposed Flood Risk policies to be sound.

NI Water do not adopt permeable paving - suggest alternative wording in paragraph 9.2.39 of justification and amplification.

Council note the issue and consider the draft Plan Strategy to be sound. However, Council propose amending paragraph 9.2.39 of justification and amplification to accurately reflect what 194

will be adopted by NI Water – see Schedule of Proposed Modifications – Reference Number PM-117.

Policy not formulated on an up-to-date evidence base; does not contain an appropriate degree of flexibility; and does not contain clear mechanisms for implementation.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. This policy is based on sound evidence including the RDS, 'A Long Term Water Strategy for NI', the SuDS Manual, the SPPS and now wider societal thinking that the use of SuDS is needed as a means of preventing flood risk, improving drainage and water quality, and the more efficient use of water generally.

Question flexibility of policy approach that 'enforces' SuDS. State that the policy wording in the SPPS identifies a reference for SuDS, whilst Policy FRD4 is enforcing the use of SuDS which does not consider the viability of smaller schemes.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. This policy is not enforcing SuDS, rather it is promoting a ‘SuDS first approach’ which the Council wishes to do to help address flood risk in the Borough and more efficient use of our water resource. It is considered that all schemes, no matter how small, can include at least ‘Hard SuDS’ in some way, with very few exceptions.

Question policy wording in relation to the management and maintenance of SuDS and state there are currently no management companies within Northern Ireland who would take on the management and maintenance of SuDS.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as the section on management and maintenance is clear. It is Council's understanding that companies, including NI Water, will adopt most types of hard SuDS. At this stage, Council are not talking about widespread 'soft SuDS' - a point that is acknowledged in the draft Plan Strategy.

Soft SuDS could be managed and maintained in the same manner as other aspects of new developments such as landscaping are currently managed and maintained. Council consider that every scheme, no matter how small, can implement some form of SuDS without much additional cost so this policy would not add significant financial burden to schemes. In actual fact, it may even make it more attractive to a potential buyer and attract a higher price.

Policy should be withdrawn and instead just rely on the SPPS.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The SPPS does not promote SuDS to the extent that the Council wishes to. Council consider all developments will be able to implement some type of SuDS. Hard SuDS should be expected now. The draft Plan Strategy acknowledges that soft SuDS are more problematic.

195

Policy FRD5 Artificial Modification of Watercourses Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach to protecting flood defence and drainage infrastructure.

Support for the proposed policy approach is welcomed.

Policy FRD5 should include consideration of impacts on marine ecology and species such as salmon.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed as reference to the impact on fish and the unnatural movement of sediment etc. in paragraph 9.2.45 of justification and amplification.

196

Policy FRD6 Development in Proximity to Controlled Reservoirs Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-051

Northern Ireland Water

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy approach for development within the potential flood inundation area of a controlled reservoir.

Support for the proposed policy approach is welcomed.

Reservoir list referred to in paragraph 9.2.49 and attached as Appendix I, Part C of the draft Plan Strategy needs updated as some reservoirs on the list have not had their capacities confirmed and another has been abandoned.

Council note the issue and consider the draft Plan Strategy to be sound. The list was supplied

by DfI prior to draft Plan Strategy publication. However, Council propose amending paragraph 9.2.49 and Appendix I, Part C of the draft Plan Strategy to reflect the abandonment of this reservoir – see Schedule of Proposed Modifications – Reference Number PM-118.

Typographical error in paragraph 9.2.50 of justification and amplification needs amended to ‘ensue’ rather than ‘ensure’.

Council note the issue and consider the draft Plan Strategy to be sound. Council propose correcting the typographical error in the first sentence of paragraph 9.2.50 of justification and amplification – see Schedule of Proposed Modifications – Reference Number PM-119.

197

9.3 Renewable Energy Policy RE1 Renewable Energy Development Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-009

Department for the Economy (DfE)

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-026

Gravis Planning on behalf of EP UK Investments

MEA-DPS-041

Lightsource BP

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-050

Northern Ireland Renewables Industry Group

MEA-DPS-056

Quarry Plan

MEA-DPS-057

RPS Group on behalf of Northern Ireland Electricity Networks

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-059

Scottish Power Renewables

MEA-DPS-069

Turley on behalf of ABO Wind (NI) Ltd

MEA-DPS-076

Turley on behalf of RES

198

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for the policy approach.

Support for the policy approach is welcomed

Question how the weight given to the 'economic and social benefits' are determined in policy.

This terminology was taken from Policy RE1 of Planning Policy Statement 18: Renewable Energy (PPS18) and remains a matter for professional judgement during the assessment of a proposal.

Question if paragraph 9.3.11 in relation to mitigation means no application would be refused on adverse impact.

Council consider that paragraph 9.3.11 which requires applicants to bring forward mitigation measures and compensatory measures for consideration, addresses this point. If these measures are not deemed to be acceptable, then the application will be considered for refusal.

This terminology was taken from PPS 18 Policy RE1 and remains a matter for professional judgement during the assessment of a proposal.

Definition of 'larger-scale' needed in paragraph 9.3.12.

Council consider there is no need to further define this. Paragraph 9.3.12 of justification and amplification simply states that larger scale wind energy developments, as in either taller turbines or multiple turbines, will be visible over distances. Therefore, Landscape and Visual Impact Assessments will be needed for these types of development to enable full assessment.

This terminology is similar to that used in PPS 18 Policy RE1 and Best Practice Guidance and remains a matter for professional judgement during the assessment of a proposal.

Policy wording 'large-scale solar farms' needs defined.

Council note the issue and consider the draft Plan Strategy to be sound. However, the wording of the last paragraph in the policy box could be construed as ambiguous. In light of the comments made, for clarity, Council propose to remove the last paragraph and instead rely on the first half of Policy RE1 for all Renewable Energy proposals as well as 'other provisions of the LDP', as applicable, to assess solar farms - see Schedule of Proposed Modifications Reference Number PM-127.

Additional policy wording for criteria c) to include restricting public access to the 'coast'.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council propose to add the suggested wording to criteria c) – see Schedule of Proposed Modifications - Reference Number PM-123.

Suggest additional policy wording for criteria a) to include 'heritage assets and their settings'.

Comments noted, however Council consider this is already covered by the line 'other provisions of the LDP' within the policy which would send the applicant to other relevant policies including the historic and built environment policies which deal with heritage assets and their settings.

In addition, paragraph 9.3.14 of justification and amplification also mentions the impact within the setting of heritage assets.

'Unacceptable impacts' and 'cautious approach’ wording need defined.

This terminology was taken from PPS 18 Policy RE1 and remains a matter for professional judgement during the assessment of a proposal.

199

Question paragraph 9.3.9 of justification and amplification does not reflect benefits of renewable technology.

Council consider the preceding paragraph 9.3.8 highlights the benefits of renewable energy such as amount of energy produced and contribution to renewable energy targets, as well as how any impacts are minimised or mitigated against. This paragraph also states these benefits are material considerations. Paragraph 9.3.9 then focusses on impacts and what the applicant has to demonstrate in relation to these.

Highlight updated information with regard to Renewables Figures.

Council are aware these figures are continually updated every three months, however this was the latest figure available at the time of the draft Plan Strategy going to print. Council propose to include more up to date figures when submitting the draft plan to DfI for Independent Examination and also upon adoption of the Plan Strategy – see Schedule of Proposed Modifications - Reference Numbers PM-120 and PM-121.

Question policy does not include 'local natural resources...' as paragraph 6.224 of SPPS. Suggest amendments.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan. However, in light of the comment made, for consistency with the SPPS wording, Council agree to the suggested wording change to criteria g) – see Schedule of Proposed Modifications - Reference Number PM-124.

Question if paragraph 9.3.8 of justification and amplification on ‘siting, scale, design and layout’ should be in policy wording as in PPS18.

Comment noted. Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change to the Policy wording as the siting, scale, design and layout of a proposal can all be considered under criteria a) of draft Policy RE1 in relation to ensuring no adverse unacceptable impact on visual amenity or landscape character, as well as under General Policy GP1. In addition, this terminology, whilst used in PPS18 is not in the SPPS.

Support for policy approach, however, suggest policy wording be amended so that the weighting afforded to environmental, economic and social benefits are 'significant' rather than 'appropriate.

Council disagree with the issue raised and consider the draft Plan Strategy to be sound and does not need changed. The SPPS updated Policy RE1 of PPS18 in this respect and removed the wording 'significant' and replaced it with 'appropriate'.

Council therefore consider that the wording 'appropriate' is consistent with the SPPS and should be retained as it allows appropriate assessment of the specific benefits of any individual proposal.

Policy should also encourage the use of renewable fuels.

Council consider the policy is adequate and flexible enough to deal with the rapidly developing renewables sector and the wider environmental, economic and social benefits of renewable energy proposals are material considerations that will be given appropriate weight in the assessment of a proposal.

Support for policy approach, however question justification and amplification wording on brownfield sites for solar.

Council consider that paragraph 9.3.14 wording is appropriate and the use of brownfield sites for solar will be encouraged. It is not a requirement as Council recognise that this may not always be possible due to size of site, cost etc of brownfield sites, and that greenfield sites will often be required. However, as these brownfield sites are often close to the end users, Power Purchase Agreements (PPAs) could be used as suggested in the response.

200

Should elaborate on the potential for Power Purchase Agreements (PPA).

Council consider this is outside the remit of planning, however any solar farm application which had a PPA would be given appropriate weight to that added benefit in the assessment of the proposal.

Policy should include additional wording on co-location.

Comment noted. In light of the comment made by several respondents, Council propose to add wording on co-location after paragraph 9.3.18 of justification and amplification – see Schedule of Proposed Modifications - Reference Number PM-130.

Policy adds additional restrictions for renewables in contradiction of SPPS, RDS and LDP objectives.

Council consider that this policy, whilst adding criteria for renewable energy development proposals to be assessed against, does not unduly restrict renewables and remains a promotive and well-balanced policy to accommodate renewables within the Borough.

Council would also contend that this policy is not in contradiction to the SPPS, RDS nor the objectives of the LDP.

Policy has a significant number of additional criteria added and is inconsistent with Regional Policy.

Council do not agree that the Policy RE1 has "added a significant number of additional criteria under which renewable applications could be refused".

Council consider that only one additional criterion has been added from that in PPS18, whilst several others have been re-worded. In addition, policy criteria are for assessment rather than refusal of proposals.

Encourage policy to balance visual impact against climate emergency.

Council agree that the visual (and other) impacts of a proposal must be balanced against the wider environmental, economic or social benefits.

Policy should reflect climate emergency and include wording on 'net zero'.

Comment noted. Updated figures and targets in relation to climate change, renewables and ‘net zero’ will be included once published in Northern Ireland.

Policy removes presumption in favour of renewables and is inconsistent with SPPS and Preferred Options Paper

Council would contend that the presumption in favour of renewables is very much retained in the draft Plan Strategy for the vast majority of the Council area and is consistent with the SPPS and the Preferred Options Paper (POP) approach.

Paragraph 4.22 affirms that 'no one objective or theme is regarded as having priority over any other'. The draft Plan Strategy seeks to take a balanced approach to delivering sustainable development for the Borough and Council considers that a balance has been struck between supporting renewable energy development and protecting landscapes of value within the Borough.

Question Policy wording of criteria l) in relation to ‘temporarily unoccupied’ and ‘approved dwelling’. Suggest retaining SPPS wording instead.

Council note the issue and consider the draft Plan Strategy to be sound. However, the wording of the last paragraph in the policy box could be construed as ambiguous. In light of the comment made by several respondents, Council propose to amend the wording of criterion l) – see Schedule of Proposed Modifications - Reference Number PM-126.

Suggest policy should have explicit support for renewable energy development at existing or former minerals sites.

Council consider that the policy as written is flexible enough to deal with renewables at existing or former quarry sites if desired.

201

Policy RE1 inconsistent with CS2, CS3 and CS5 and at odds with Government policy on renewables.

The draft Plan Strategy seeks to take a balanced approach to delivering sustainable development. Council consider that a balance has been struck between supporting renewable energy development and protecting landscapes of value within the Borough. The SPPS (a Government policy document) also restricts development in certain designated areas and their wider settings.

Question lack of references to renewable targets within the draft Plan Strategy.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan. Council consider sufficient reference has been made to the Strategic Energy Framework, the draft Programme for Government and other Government policies on energy. It is Council's understanding DfE are currently working on updating targets which Council are content to reference once available.

Question policy wording consistency with justification and amplification and SPPS wording 'and their wider settings'. Suggest this effectively narrows the application of the ‘cautious approach’ in paragraph 6.223 of the SPPS.

Council note the issue and consider the draft Plan Strategy to be sound. Council note the Policy wording differs from the SPPS wording, however the SPPS wording 'and their wider settings' is included in the justification and amplification of Policy RE1. However, in light of the comment made, for clarity and consistency with justification and amplification and the SPPS, Council propose to add ‘and their wider settings’ into the Policy Box – see Schedule of Proposed Modifications - Reference Number PM-125.

Policy wording on solar farms is too restrictive and inconsistent with Regional Policy.

Council note the issue and consider the draft Plan Strategy to be sound. However, the wording of the last paragraph in the policy box could be construed as ambiguous. In light of the comments made, for clarity, Council propose removing the last paragraph and instead rely on the first half of Policy RE1 for all Renewable Energy proposals as well as the 'other provisions of the LDP' line, as applicable, to assess solar farms – see Schedule of Proposed Modifications - Reference Number PM-127.

Policy wording in relation to 'cumulative assessment' is inconsistent with the SPPS – additional wording suggested to include all types of renewables.

Council do not consider this additional wording is required as the cumulative effect of other forms of renewable energy development, such as solar farms, is generally not an issue within the Borough. However, paragraph 9.3.14 of justification and amplification enables a Landscape and Visual Impact Assessment to be requested as required to assess a particular renewable energy proposal.

Council consider this also reflects paragraph 6.229 of the SPPS which states, 'factors to be considered on a case by case basis will depend on the scale of the development and its local context, and proposals assessed in accordance with normal planning criteria including such considerations as…:' Those considerations then listed include cumulative impact.

Paragraph 9.3.17 of justification and amplification in relation to development on active peatland with respect to IROPI (overriding reasons of public interest) needs to be further clarified.

Council do not consider this additional wording is required as the exact wording requested by the respondent is already included within Policy wording. This wording was also taken from PPS18 Policy RE1.

202

Question paragraph 9.3.17 of justification and amplification wording in relation to 'mitigation and compensatory measures' and mechanisms for implementation of this.

Comment noted. Council would agree with the respondent that lands for restoration would be required to be within red line of application/blue line of ownership.

Countryside designations may encourage sink holes for development elsewhere.

Council consider the areas restricting certain forms of development, designated because of their sensitive landscapes, are limited in size compared to the plan area. Council do not consider these designations would lead to 'sink holes' for development elsewhere.

Request additional designations for other areas sensitive to wind energy development.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council have stated in paragraphs 1.7.4, 1.7.5 and 1.7.8 of the draft Plan Strategy that the LDP should be read in its entirety with no one policy read in isolation. Other topics such as the protection of Natural Heritage Assets are provided for in the Natural Heritage Policies.

Question flexibility of policy wording to deal with evolving technology.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. It is considered Policy RE1 is written in a way that future-proofs the policy and accommodates whatever new renewable technologies may come forward over the Plan period.

Question policy wording consistency with Countryside Strategy and designations.

Council note the issue and consider the draft Plan Strategy to be sound. However, the wording in the policy box in relation to Special Countryside Areas (SCAs) could be construed as ambiguous. In light of the comments made, for clarity, Council propose to remove any cross Reference to the Countryside Strategy and designations, and instead rely on the ‘accords with other provisions in the LDP’ line in the Policy Box – see Schedule of Proposed Modifications Reference Numbers PM-122 and PM-129.

Question policy wording that only carries through three of the five PPS18 Policy RE1 key considerations.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider all these established criteria have been carried through, with four of the five criteria contained within Policy RE1, and the other by Policy GP1.

Question policy criteria c) wording in relation to unacceptably restricting recreational and tourism use of the area is not based on sufficient evidence.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. As tourism is one of the Council's top economic priorities, Council are seeking to ensure no development unacceptably restricts the recreational or tourism use of the area.

Policy criterion h) wording in relation to not prejudicing the operational effectiveness of energy infrastructure is not reflective of SPPS.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. This criterion is clear in its intention and has been added on the advice of SONI and in the interests of protecting vital energy infrastructure which will ultimately benefit renewable companies seeking connection e.g. ensure solar farms do not wrap-around an NIE substation restricting way-leave. Paragraph 9.3.15 of the justification and amplification also explains this.

Council do not consider that the inclusion of wording that isn't in PPS18 or the SPPS necessarily makes a policy unsound.

203

Question policy criterion i) wording in relation to the cumulative impacts of existing wind turbines, including extant permissions and undetermined applications.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. This criterion is clear in its intention and is not worded openly or ambiguously, nor creates uncertainty about what to include. The cumulative assessment should include existing wind turbines, extant permissions for wind turbines, and current applications for wind turbines which are valid and under consideration.

Consider policy is based on the context of the Council’s concerns regarding the proliferation of turbines in the area (refer to Technical Supplement terminology) and is inconsistent with plan objectives.

Paragraph 3.2.13 of Technical Supplement 12: Public Utilities states there are concerns regarding the proliferation of turbines in the area and the impact on landscape and amenity, however it is considered a leap to then state it is clear that it is within this context Policy RE1 has been written.

Council do not agree that Policy RE1 seeks to introduce more control over the development of renewable energy schemes, and in particular wind energy. Rather, Council consider Policy RE1 is a well-balanced promotive policy to support renewables, consistent with existing regional policy, which seeks to balance landscape and visual issues with other material considerations such as the wider environmental, economic and social benefits.

Consider policy is based on Strategic Energy Framework targets having already been met (refer to Technical Supplement terminology).

Council do not agree that Paragraph 3.2.2 of Technical Supplement 12: Public Utilities states it is within the context of the 40% target having been met that this Policy has been set.

Council strongly agree with the respondent that the 40% is not a ceiling - in fact the same paragraph 3.2.2. states 'continued development of renewable energy resources is vital to facilitating the delivery of international and national commitments on both greenhouse gas emissions and renewable energy'. It is on that basis that Policy RE1 is considered as a promotive policy for renewables.

204

9.4 Telecommunications and Overhead Cables Policy TOC1 Telecommunications Development and Overhead Cables Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-009

Department for the Economy

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-050

Northern Ireland Renewables Industry Group

MEA-DPS-057

RPS Group on behalf of Northern Ireland Electricity Networks

MEA-DPS-060

SONI

MEA-DPS-069

Turley on behalf of ABO Wind (NI) Ltd

MEA-DPS-076

Turley on behalf of RES

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach.

Support for the policy approach is welcomed.

Additional policy wording on supporting fixed and mobile infrastructure.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made around promoting ducting in new developments, for clarity, Council propose additional wording to reference Section 12 of 'Creating Places' after paragraph 9.4.13 of justification and amplification – see Schedule of Proposed Modifications - Reference Number PM-136.

Question consistency of policy wording with Countryside Strategy wording.

Council note the issue and consider the draft Plan Strategy to be sound. However, the wording in the policy box in relation to Special Countryside Areas (SCAs) and cross-referencing Policy CS3 could be construed as ambiguous.

205

In light of the comments made by numerous respondents, for clarity, Council propose to remove the reference to SCAs and the cross-references to Policy CS3, and instead just rely on the ‘other provisions of the LDP’ line within the Policy – see Schedule of Proposed Modifications - Reference Numbers PM-133 and PM-135.

Question policy wording in relation to criteria a) ‘there is a need for the development at that location’ and paragraph five in the policy box.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made by numerous respondents, for clarity, Council propose to remove this paragraph in the policy box and instead just rely on the ‘other provisions of the LDP’ line within the policy see Schedule of Proposed Modifications - Reference Number PM-135.

Telecoms development should be considered on a case by case basis where a need is demonstrated.

Council note the issue and consider the draft Plan Strategy to be sound as policy is already written to enable each proposal to be assessed on its own merits and against criteria - one of which is (criteria a) where there is a need for the proposed development at that location.

Policy wording doesn’t cover all aspects of energy / electricity infrastructure.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan. Council consider the provision of other types of infrastructure are adequately dealt with and would be assessed under General Policy GP1.

Council, however, do see merit in clarifying and rewording both the policy and Justification & Amplification to reflect respondents' concerns that other types of electrical / energy infrastructure are not explicitly referenced in this policy.

Therefore, Council propose amending the title and wording of this policy to include ‘Electricity Infrastructure’ in order to make it clearer that it includes various other aspects of energy / electricity infrastructure than overhead cables. Such infrastructure will be assessed under this Policy and General Policy GP1. – see Schedule of Proposed Modifications - Reference Numbers PM-132, PM-134 and PM-137

Combining telecoms with overhead cables dilutes the importance of energy infrastructure. Request stand-alone policy for energy / electricity infrastructure.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider that the merging of these utility infrastructures into one policy for assessment does not dilute the importance of energy provision – rather it just means proposed developments for any such utilities or infrastructure are assessed under the relevant parts of the one policy. Council also note that the SPPS 'groups' Telecommunications and other utilities together.

Question flexibility of policy wording to adapt to change.

Council consider that this policy (along with Policy RE1 for renewable energy sources) is written in a flexible manner and is future-proofed to adapt to future changes in energy sources.

Question flexibility of policy wording for essential electricity infrastructure projects that are required to support economic and social development.

Council note the issue and consider the draft Plan Strategy to be sound as the policy wording is flexible and permits an exception for essential electricity transmission or supply within the countryside designations.

However, the wording in the policy box in relation to cross-referencing Policy CS3 could be construed as ambiguous. In light of the comments made by numerous respondents, for clarity, 206

Council propose to remove this paragraph in the Policy Box and instead just rely on the ‘other provisions of the LDP’ line within the policy – see Schedule of Proposed Modifications Reference Number PM-135.

Policy wording in relation to site sharing is not workable and inconsistent with SPPS.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. This terminology in relation to site sharing was taken from paragraph 6.243 of the SPPS, as well as Policy TEL1 of Planning Policy Statement 10: Telecommunications (PPS10).

The reference to ‘Mast Sharing' in Policy TOC1 is clarified at paragraph 9.4.12 of justification and amplification which states "Telecommunications Operators are encouraged to site share".

Council also consider the relevant policy for 'renewable energy development' is found under Policy RE1, which does not reference site sharing.

Question evidence base for height restrictions in Countryside Designations policy.

The evidence base for the height restrictions is addressed under Policy CS3.

Policy wording unclear in relation to exceptional and 'not spots'.

Council note the issue and consider the draft Plan Strategy wording to be clear that the exceptional circumstances are to either serve a recognised telecommunication ‘not spot’ or for essential electricity transmission or supply.

However, in light of the comments made by numerous respondents, for clarity, Council propose to remove this paragraph of the policy box which part cross-refer to CS3, and instead just rely on the ‘other provisions of the LDP’ line within the policy.

Reference to exceptions to serve a recognised telecommunication ‘not spot’ or for essential electricity transmission or supply is now addressed in Policy CS3 justification and amplification – see Schedule of Proposed Modifications - Reference Numbers PM-032 and PM-135.

Policy wording 'regional significance' needs defined.

Council propose amending wording from 'regional significance' to 'regional importance'. This is addressed under Policy CS3.

207

Telecommunications and Overhead Cables – Suggested New Policies Responses received Reference

Respondent

MEA-DPS-026

Gravis Planning on behalf of EP UK Investments

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

New policy for Strategic Energy Infrastructure and Gas Infrastructure to ensure security and reliability of future gas supply.

Council consider the proposed amendments to Policy TOC1 will help address some of these concerns. In addition, a proposal for any such infrastructure falling outside a specific operational policy is adequately covered by General Policy GP1.

Policy needed to ensure the protection of Kilroot and Ballylumford Power Stations as Strategic Energy Locations to help promote a more diverse energy mix on the above sites in the drive to provide adequate security of supply.

Council consider the assessment of a proposal in the vicinity of such locations is covered by General Policy GP1 and Policy RE1 and will help ensure the sites are adequately protected from inappropriate or incompatible development.

Miscellaneous comments on Telecommunications and Overhead Cables Response received Reference

Respondent

MEA-DPS-009

Department for the Economy

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

As Mid and East Antrim Council is a partner in the Belfast Region City Deal, it would be expected that the LDP should reference it and its associated economic impacts.

Whilst Council recognise the various initiatives outlined within the Belfast Region City Deal, as these are still at an early stage, they have not been referenced in detail in the draft Plan Strategy.

Reference to (Belfast Region) City Deal is already made in paragraph 5.4.7 of Section 5.4 Economic Development Strategy in the draft Plan Strategy. However, in light of the comment made and to clarify what is being referenced, Council propose to add the wording ‘Belfast Region’ to paragraph 5.4.7 - see Schedule of Proposed Modifications - Reference Number PM-010.

208

9.5 Water and Wastewater Infrastructure Policy WWI1 Development Relying on Non-Mains Wastewater Infrastructure Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-051

Northern Ireland Water

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach and collaborative working with statutory partners.

Support is welcomed.

209

9.6 Waste Management Policy WMT1 Environmental Impact of a Waste Management Facility Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-026

Gravis Planning on behalf of EP UK Investments

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach.

Support for the proposed policy approach is welcomed.

Supportive of the policy and would encourage policy promotion of waste management facilities with renewable credentials.

Support for the proposed policy approach is welcomed. Section 9.6 has referenced the renewable credentials of waste recovery for energy purposes and the waste hierarchy which promotes this rather than disposal.

210

Policy WMT2 Waste Collection and Treatment Facilities Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-026

Gravis Planning on behalf of EP UK Investments

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach.

Support for the proposed policy approach is welcomed.

Question how this policy sits with anaerobic digestion plants as it is mentioned in paragraph 9.6.16.

This terminology was taken from Planning Policy Statement 11: Planning and Waste Management, Policy WM2 and paragraph 7.3 of WM2 justification and amplification and remains a matter for professional judgement during the assessment of a proposal.

211

Policy WMT3 Waste Disposal Sites Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-008

Department for Communities - Historic Environment Division

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach in relation to waste disposal sites.

Support for the proposed policy approach is welcomed.

The term ‘Derelict’ in paragraph 9.6.24 of justification and amplification needs defined to make it 'more sound'.

This terminology was taken from Planning Policy Statement 11: Planning and Waste Management, Policy WM3 and paragraph 8.14 of WM3 justification and amplification, and the term 'derelict' remains a matter for professional judgement during the assessment of a proposal.

The term ‘Environmental heritage assets' should be reworded to 'natural environment and heritage assets' in paragraph 9.6.25 of justification and amplification to make it ‘more sound’.

Council consider that this does not affect the soundness of the Plan and therefore suggests no changes are necessary to make the policy 'more sound'. However, in light of the comment made, for clarity, Council propose to amend the wording in paragraph 9.6.25 of justification and amplification – see Schedule of Proposed Modifications - Reference Number PM-138.

212

Policy WMT4 Development in the vicinity of a Waste Management Facility Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-051

Northern Ireland Water (NI Water)

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach.

Support for the proposed policy approach is welcomed.

Reference should be made to ‘NI Water Development Encroachment - Odour Assessment Policy and Procedure’.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan. However, in light of the comment made, for clarity, Council propose to add the suggested reference to the end of paragraph 9.6.30 of justification and amplification – see Schedule of Proposed Modifications - Reference Number PM-139.

213

Policy WMT5 Land Improvement Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-008

Department for Communities - Historic Environment Division

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for policy approach.

Support for the proposed policy approach is welcomed.

Question term 'Land Improvement' which implies positive outcomes whereas this type of activity could have negative impacts on the historic environment and landscape character. This terminology is not used in the SPPS.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Although the SPPS is silent on this issue, terminology was taken from Planning Policy Statement 11: Planning and Waste Management, Policy WM4 entitled 'Land Improvement'.

While Council acknowledge concerns surrounding this issue, it is considered this policy can offer positive outcomes. The policy criteria will help ensure that no unacceptable adverse environmental impacts are caused by this type of development.

Miscellaneous comments on Waste Management Responses received Reference

Respondent

MEA-DPS-056

Quarry Plan

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Request new policy to address Secondary Aggregates and promotion of the Secondary Aggregates Protocol.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change. Paragraph 9.6.16 of justification and amplification states that proposals for the recycling of construction and demolition waste are to be considered under Policy WMT2. Council consider this policy is sufficient to enable assessment of such proposals.

214

Management Facility

10.0 Stewardship of our Built Environment and Creating Places 215

10.1 Historic Environment Policy HE1 Archaeological Remains and their Settings Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department for Communities - Historic Environment Division (HED)

MEA-DPS-025

Gravis Planning on behalf of Individual

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-069

Turley on behalf of ABO Wind (NI) Ltd

MEA-DPS-076

Turley on behalf of RES

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy approach which adopts a positive approach to the protection of our historic built environment and heritage.

Support for the proposed policy approach is welcomed.

Additional policy text to distinguish each of the four paragraphs in the policy box.

Notwithstanding the appropriateness or otherwise of this suggested change, Council consider that this does not go to the soundness of the Plan and therefore suggests no change. It is considered that the policy subtitles in bold provides sufficient clarity between each of the four separate policy paragraphs.

Amend policy to include provisions for sympathetic and appropriate new development where it will ensure the protection, preservation and promotion of archaeological remains.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council is satisfied that the Policy HE1 is fully aligned to the core principles and aims of the SPPS and Planning Policy Statement 6, Archaeology and Built Heritage, and allows for development proposals impacting on archaeological remains and their settings where the policy is met. Each application will be assessed on its individual merits, taking into account the intrinsic importance of the archaeological remains in question.

216

Amend justification and amplification at 10.1.21 to include a paragraph highlighting to developers what they need to do if they discover archaeological remains when a development commences.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest that a new paragraph should be inserted after 10.1.21 - see Schedule of Proposed Modifications - Reference Number PM-141.

Amend justification and amplification text at paragraph 10.1.15, by removing 'are likely' and replacing with 'could have'. The use of the word ‘likely’ within the draft policy wording suggests that there is evidence that any of these forms of development will result in an adverse impact and no evidence of this is provided.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The policy intent of the SPPS in relation to Areas of Significant Archaeological Interest (ASAI) is clear, in that, development which would adversely affect such sites, or the integrity of their settings must only be permitted in exceptional circumstances and that a cautious approach for renewable energy development proposals will apply within designated landscapes which are of significant value. Council considers that the use of the wording 'are likely' in the context of the policy is justified due to the exceptional landscape qualities associated with the ASAI. HED provided Council with ‘A Statement of Significance’ in relation to the existing ASAI and the proposed extension, which outlines the distinctive qualities of the ASAI and considers what types of development may have the potential to adversely impact on its distinctive characteristics.

Policy approach proposed is based on the opinion that the visual appearance of a turbine or other high structure is adverse. Sensitivity to change does not correlate directly with no capacity for development or adverse impacts.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The policy intent of the SPPS in relation to ASAIs is clear in that, ‘development which would adversely affect such sites, or the integrity of their settings must only be permitted in exceptional circumstances’ and that ‘a cautious approach for renewable energy development proposals will apply within designated landscapes which are of significant value. It further states that, ‘In such sensitive landscapes, it may be difficult to accommodate renewable energy proposals, including wind turbines, without detriment to the region’s cultural and natural heritage assets’.

Under the exception test of this policy, a renewable energy development may be considered acceptable in principle, where the proposal is of such overriding regional importance that it outweighs any potential adverse impact on the ASAI.

Importance of considering proposals on a case by case basis.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. In a plan-led system there is an expectation for developers and other interested parties to be made aware of what development is acceptable in principle and what development is not likely to be permitted. Therefore, assessing proposals on a case-by-case basis alone is not considered appropriate in designated areas. Where the principle of development is considered acceptable, each proposal will be assessed on its own merits.

Under the exception test of this policy, a renewable energy development may be considered acceptable in principle, where the proposal is of such overriding regional importance that it outweighs any potential adverse impact on the ASAI.

217

Fails to identify the particular features of the ASAI and the proposed extension to be protected and does not provide evidence of the harmful effects of wind turbines and high structures on the ASAI.

Council is satisfied that Policy HE1 is in compliance with the SPPS, in particular paragraph section 6.29, bullet point two which refers to the rationale for designation of an ASAI. The ASAI was carried forward from the Larne Area Plan 2010.

HED consulted with the Historic Monuments Council with regard to the identification of the extended ASAI at Knockdhu and supplied Council with a Statement of Significance which was included in Appendix C, of Technical Supplement 13: Built Heritage which outlines the distinctive qualities of the ASAI. This statement relates to the entirety of the ASAI and also considers types of development which would have the potential to adversely impact on its distinctive characteristics and includes a selection of imagery and tables displaying a list of the archaeological monuments currently recorded in the area of landscape concerned.

Policy HE2 Historic Parks, Gardens and Demesnes Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which adopts a positive approach to the protection of the historic environment and heritage assets.

Support for the proposed policy approach is welcomed.

Reservations about how much more development can be sensitively integrated at Carnfunnock, without compromising the integrity of its distinctive historic environment characteristics, Gardens and Demesnes.

Council note the issue and confirms that any development proposal located in or adjacent to Carnfunnock Country Park will have to adhere to the policy provisions of Policy HE2 and other provisions of the LDP.

218

Policy HE3 Listed Buildings – Change of Use or Extension/Alteration or Conversion of a Listed Building Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which adopts a positive approach to the protection of the historic environment and heritage assets.

Support for the proposed policy approach is welcomed.

Amend policy text under criterion (b) to replace the word 'details' with 'techniques'.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change.

Recommends additional justification and amplification text at paragraph 10.1.32 to make to reference BS 7913:2013 - Guide to the Conservation of Historic Buildings.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change.

As the guidance document suggested is out with the remit of Planning it is not considered necessary to refer to it in this policy.

Amend policy text to include additional wording to ensure that any extensions, alterations or adaptions to a listed building will not result in a net loss of biodiversity, and where possible enhance it.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The draft Plan Strategy is intended to be read in the round. High quality design that takes account of its surrounding context including biodiversity is promoted through Policy GP1 e) Criteria relating to Sustainable Development point iv. and is supported by additional policies and guidance within the draft Plan Strategy and as such will provide sufficient safeguarding to ensure that development will conserve wildlife and vegetation and promote further diversity.

219

Policy HE4 Listed Buildings - Demolition of a Listed Building Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which adopts a positive approach to the protection of the historic environment and heritage assets.

Support for the proposed policy approach is welcomed.

Amend policy text to include the word ‘considered’ to the third sentence of the first paragraph.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council is satisfied that the Policy HE4 wording offers sufficient protection to listed buildings from demolition in that the policy wording specifically requires the submission of comprehensive evidence to demonstrate that every effort has been made to retain the listed building.

220

Policy HE5 Development affecting the Setting of a Listed Building Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which adopts a positive approach to the protection of the historic environment and heritage assets.

Support for the proposed policy approach is welcomed.

221

Policy HE6 Conservation Areas Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which adopts a positive approach to the protection of the historic environment and heritage assets.

Support for the proposed policy approach is welcomed.

Amend policy wording under subtitle ‘New Build and Replacement Buildings’ to ensure that the policy test is consistent throughout with regards to preservation and enhancement.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comment made, for clarity, Council suggest a minor change to the policy wording of Policy HE6 - New Build and Replacement Building should be made - see Schedule of Proposed Modifications - Reference Number PM-145.

To avoid ambiguity, it is suggested that criterion a) of ‘New Build or Replacement Buildings’ is repeated in the list of policy requirements under the subtitle ‘Alteration, Extensions and Change of Use’.

Council note the issue and consider the draft Plan Strategy to be sound. Council is satisfied that the intent of the policy wording under Alteration, Extensions and Change of Use, criterion a) is unambiguous in that it clearly states that, 'Planning permission will only be granted for alterations and extensions and/or change of use applications within conservation areas where criterion a) above is met.'

Amend policy criterion a) under the policy subtitle ‘Alteration, Extensions and Change of Use’ and remove the words ‘materials and finishes’ as these issues are more aligned with criterion c).

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the policy wording of Policy HE6 - Alteration, Extensions and Change of Use should be made - see Schedule of Proposed Modifications - Reference Number PM-142.

Amend policy as it affords greater weight to the protection of buildings within a conservation area, than that required by the SPPS paragraph 6.18, the hierarchy of the demolition policy test should align with the significance of the heritage asset.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the policy wording of Policy HE6 - Demolition within a Conservation Area should be made - see Schedule of Proposed Modifications - Reference Number PM-143.

222

Policy HE7 Areas of Townscape Character Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which adopts a positive approach to the protection of the historic environment and heritage assets.

Support for the proposed policy approach is welcomed.

223

Policy HE8 Non-listed Locally Important Building or Vernacular Building Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which adopts a positive approach to the protection of the historic environment and heritage assets.

Support for the proposed policy approach is welcomed.

Amend the policy headnote to read HE8 - ‘Historic Buildings of Local Importance or Vernacular Buildings’ to adhere to the definitions applied in the SPPS policy 6.24.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for consistency of terminology, Council suggest a minor change to the policy headnote should be made - see Schedule of Proposed Modifications - Reference Number PM-146.

To align with the policy remit of SPPS paragraph 6.24 suggests that the first sentence of the policy box is amended, to read: All development proposals impacting on a historic building of local importance and/or vernacular building should involve the minimum intervention and should maintain or enhance the existing character of the building and its setting.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change. Similar wording is used in the opening paragraph of BH15 of Planning Policy Statement 6: Planning, Archaeology and Built Heritage (PPS6).

Amend policy text to include additional wording to ensure that any extensions, alterations or adaptions will not result in a net loss of biodiversity, and where possible enhance it.

Council note the issue and consider the draft Plan Strategy to be sound. Council have stated in paragraphs 1.7.4, 1.7.5 and 1.7.8 of the draft Plan Strategy that the LDP should be read in its entirety with no one policy read in isolation. High quality design that takes account of its surrounding context including biodiversity is promoted through Policy GP1 e) Criteria relating to Sustainable Development point iv. and is supported by additional policies and guidance within the draft Plan Strategy. This will provide sufficient safeguarding to ensure that development will conserve wildlife and vegetation and promote further diversity.

224

Recommends additional justification and amplification text at paragraph 10.1.57 and 10.1.58 to make to reference to the following guidance documents: ‘Historic Buildings of Local Importance- A guide to their identification and protection’ and ‘A Sense of Loss – The Survival of Rural Traditional Buildings in Northern Ireland’.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change.

Policy HE9 Enabling Development for the Conservation of Heritage Assets Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy which adopts a positive approach to the protection of the historic environment and heritage assets.

Support for the proposed policy approach is welcomed.

Amend justification and amplification text at paragraph 10.1.64 if retaining the term ‘Heritage Assets’ in the policy headnote, in lieu of ‘Significant Places’.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for consistency of terminology, Council suggest a minor change to the wording at paragraph 10.1.64 should be made - see Schedule of Proposed Modifications - Reference Number PM-148.

Amend justification and amplification text at paragraph 10.1.66 to include the following additional wording in the first sentence, ‘setting out the significance of the heritage asset’ and in the second sentence, ‘conservation statement or plans’.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the wording at paragraph 10.1.66 should be made - see Schedule of Proposed Modifications - Reference Number PM-149.

Insert additional text at the end of paragraph 10.1.66 to include reference to Planning Policy Statement 23: Assessing Enabling Development for the Conservation of Significant Places Best Practice Guidance.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change. Council may consider producing Supplementary Planning Guidance (SPG) relating to Best Practice Guidance for Enabling Development as part of the ongoing LDP process.

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Amend Footnote 58 - definition of Heritage Assets.

Council note the issue and consider the draft Plan Strategy to be sound and are satisfied that the wording contained within Footnote 58 sufficiently defines what constitutes a Heritage Assets for the purposes of the draft Plan Strategy.

Miscellaneous comments on Historic Environment Responses received Reference

Respondent

MEA-DPS-007

Individual

MEA-DPS-008

Department for Communities - Historic Environment Division (DfC HED)

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

In the three main town’s heritage, history and activities are main areas of economic growth. Propose to protect assets of quality and diversity of the natural and historical environment and identify all assets and map their boundaries.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The draft Plan Strategy contains specific policies for the natural and historic environment. A range of datasets are available to view on the DfC Historic Map Viewer and Northern Ireland Environment Agency Map Viewer.

Consistent terminology across the draft Plan Strategy document in relation the use of the term 'non-listed' and ‘unlisted’.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for consistency of terminology, Council suggest minor changes to the policy and justification text - see Schedule of Proposed Modifications - Reference Numbers PM-046, PM-065, PM-066, PM-068, PM-099, PM-105, PM-140, PM-144, PM-147.

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10.2 Advertisements Policy AD1 The Control of Advertisements Responses received Reference

Respondent

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-072

Turley on behalf of Clear Channel

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Council’s Consideration of Issue

Main Issue and the Historic

Notwithstanding the appropriateness or otherwise of this suggested change, Council consider that this does not affect the soundness of the Plan and therefore suggests no change. Council is satisfied that the subtitle '‘Advertisements and Heritage Assets' as proposed provides sufficient scope for the assessment of applications for advertisement consent in relation to the historic environment as the opening line under the sub-heading refers to 'heritage assets and their settings'.

Additional policy text - assessment criteria listed as a) to f) should apply to the two policy sub-sections.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest that a minor change to the policy wording should be made – see Schedule of Proposed Modifications - Reference Number PM-150.

Additional policy and justification and amplification text to include a definition of what constitutes a ‘digital advertisement screen’

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change.

The term ‘digital advertisement screen’ is a widely used standardised term and as such does not require a specific definition in relation to this policy.

Policy provisions across all advertisements and heritage assets provide ample protection of sensitive areas and assets and there is no requirement for the Council to introduce a blanket presumption against digital signs.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change.

The policy criteria contained in AD1 is considered to appropriately and proportionally address the impact of digital signage on amenity, safety and the historic environment through criteria a) - p) and is considered to provide sufficient scope to allow for digital signage.

Alternative policy subtitle Environment.

-

‘Advertisements

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Digital signage provides benefit to the local economy, further restrictions may have a detrimental impact on the transport network.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change.

Policy AD1 allows for the placement of digital signage on bus shelters in circumstances where all criteria a) - p) are met. Translink made no reference to the potential economic impact of AD1 in their submission to the draft Plan Strategy.

There are several conflicts between Policy AD1 and Appendix K, in relation to the illumination of signs and that ‘overly bright’ signage will be resisted if it harms amenity or safety. There is no test or benchmark for this.

Council note the issue and consider the draft Plan Strategy to be sound. Council considers that there is no conflict between the policy and Appendix K of the draft Plan Strategy. The wording in both the policy and guidance text explicitly refer to 'internally illuminated'. In certain cases the use of appropriate and subtle external illumination may be considered acceptable if it is well related to the building and causes no visual or physical harm. Council would direct the respondent to sub-heading, Lighting under appendix K of the draft Plan Strategy which includes text which refers and signposts to the following guidance document - Lighting Professionals’ guidance PLG05, ‘The Brightness of Illuminated Advertisements’.

Appendix K subtitle The Number and Location of Advertisements notes that proposals above ground level will be resisted as a ‘general rule’, not a definitive refusal.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity and to avoid conflict, Council suggest removing the last line under, The Number and Location of Advertisements of Appendix K of the draft Plan Strategy – see Schedule of Proposed Modifications - Reference Number PM-151.

Unclear why the draft Plan Strategy is not reflective of the content of the existing policy contained within the SPPS, PPS6 and Addendum to PPS6: Areas of Townscape Character.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

The draft Plan Strategy is fully aligned to the aims of the RDS and SPPS and in the case of the draft Advertisement Policy, the principle aims and objectives of PPS6 and its Addendum have been carried forward. The role of the draft Plan Strategy is not to duplicate or replicate precise wording of policy in the SPPS or PPS6, rather it should align to its core principles and aims and ensure they can be achieved at local level through the planning process. Where the opportunity exists to strengthen policy or identify specific needs that are bespoke to the Borough, the Council will do so where it is considered appropriate and justified.

Lack of evidence - does not provide ample justification in respect of digital signs.

The Preferred Options Paper (POP), (June 2017) had sought to gauge opinion on the principle of including specific policy wording relating to the control of flashing, scrolling, animated, intermittent or moving digital signage. Comments raised as part of the POP consultation were analysed and helped inform the development of the Policy AD1 with the majority of statutory consultees and public respondents supportive of the introduction of specific policy wording.

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10.3 Place-Making Policy SFA1 Strategic Focus Areas Responses received Reference

Respondent

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Supports the place-making approach.

Support for the proposed policy approach is welcomed.

Policy is not capable of being implemented upon adoption of the draft Plan Strategy as it relies on identification of Strategic Focus Areas (SFAs) at Local Policies Plan stage.

The draft Plan Strategy does not outline site specific zonings therefore detailed analysis has not been carried out to enable the identification of specific areas for consideration as a SFA. Under the new two tier LDP process, the intent has always been to develop the selection criteria and identify and undertake comprehensive analysis associated with potential SFA's at the Local Policies Plan Stage.

Amend policy wording to include reference to the need to take account of ‘Living Places’ Design Guide.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Specific policy wording and design criteria for each SFA will be developed at the Local Policies Plan Stage.

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11.0 Safeguarding our Natural Environment

230

11.1 Natural Heritage Policy NAT1 European and Ramsar Sites – International Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-007

Individual

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy that will protect natural heritage assets.

Support for the proposed policy is welcomed.

Amend justification and amplification text at paragraph 11.1.7 to include reference to European Sites.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the wording of paragraph 11.1.7 should be made – see Schedule of Proposed Modifications - Reference Number PM152.

Amend justification and amplification text at paragraph 11.1.8 as it wrongly implies that Ramsar sites are designated under European law, under the auspices of the Birds Directive.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the wording of paragraph 11.1.8 should be made – see Schedule of Proposed Modifications - Reference Number PM153.

Fails to identify priority species lists and species of concern.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Information relating to Protected Areas can be found at https://www.daerani.gov.uk/protected-areas. Identifying 'species of concern' is outside of the remit of the LDP and is a Departmental matter. Further information can be found in the Departments publication, ‘An Invasive Alien Species Strategy for Northern Ireland’.

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Policy NAT2 Species Protected by Law Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-058

Royal Society for the Protection of Birds

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy that will protect natural heritage assets.

Support for the proposed policy is welcomed.

Clarification on what the Council considers to be ‘associated public benefits’, may aid the application of this policy.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed and considers that the interpretation of the term ‘public benefit’, remains with the Council in the exercise of its statutory planning functions.

Additional justification and amplification at paragraph 11.1.11 to include a link to the full list of species of animals and plants and clarify that all fish are protected, no lists have been produced.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the wording of paragraph 11.1.11 should be made – see Schedule of Proposed Modifications - Reference Number PM154.

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Policy NAT3 Sites of Nature Conservation Importance – National Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy that will protect natural heritage assets.

Support for the proposed policy is welcomed.

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Policy NAT4 Sites of Nature Conservation Importance - Local Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy that will protect natural heritage assets.

Support for the proposed policy is welcomed.

Amend justification and amplification to remove reference to Ulster Wildlife Trust from paragraph 11.1.13 as it wrongly implies that they could establish a Local Nature Reserve.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the wording of paragraph 11.1.13 should be made – see Schedule of Proposed Modifications - Reference Number PM155.

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Policy NAT5 Habitats, Species or Features of Natural Heritage Importance Responses received Reference

Respondent

MEA-DPS-002

Belfast City Council

MEA-DPS-003

Causeway Coast and Glens Borough Council

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-056

Quarry Plan

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Support for this policy that will protect natural heritage assets.

Support for the proposed policy is welcomed.

Amend justification and amplification text at paragraph 11.1.15 strengthen policy to reflect NH5 of Planning Policy Statement 2: Natural Heritage, draft wording reads as if such material considerations are simply a desire of the policy, rather than higher level responsibilities and environmental consideration.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider the intent of the wording is clear and that the conservation, protection and where possible the enhancement of local biodiversity is a material consideration in the determining of planning applications.

Respondent notes the absence of a policy for Sites of Local Nature Conservation Importance (SLNCIs).

Draft BMAP 2015 designated SLNCIs within the former Carrickfergus Borough. There are no designated SLNCIs within the former Ballymena and Larne Boroughs due to the age of their plans. Council is satisfied that the features of nature conservation interest within existing SLNCIs can be sufficiently protected under Policy NAT5.

Encourage Council to take a balanced approach to mineral development, weighing up the need to protect the environment against the need for the mineral.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The policy aims fully embrace the regional strategic objectives and guidelines in the SPPS to facilitate a sustainable approach to mineral development.

The ‘Implementation’ section advises that when a robust evidence base is in place to inform supply and demand for mineral products across Northern Ireland, anticipated at Plan Review stage, Council will be in a position to designate Mineral Reserve Areas in order to safeguard important resources from development likely to prejudice their exploitation and review Areas of Constraint on Minerals Development, giving a more comprehensive plan led approach. In the

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meantime, the minerals policies seek to ensure a fit for purpose planning policy framework for the assessment of proposals on a case by case basis.

Natural Heritage - Suggested New Policy Responses received Reference

Respondent

MEA-DPS-004

Causeway Coast and Glens Heritage Trust

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Areas of Outstanding Natural Beauty (AONB) are not explicitly incorporated into any of the Natural Heritage policies within the draft Plan Strategy and there should be a specific policy for the AONB.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Paragraphs 1.7.4, 1.7.5 and 1.7.8 of the draft Plan Strategy state that the LDP should be read in its entirety with no one policy read in isolation. Policy CS5 clearly states in the second sentence of the policy box that, 'All new development proposals within the AONB or its setting must meet the General Policy' and 'accord with other provisions of the LDP’, including Policies NAT1 – NAT5.

Recommend the inclusion of a specific policy relating to trees and development.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Whilst there is no specific policy relating to trees and development, it should be noted that the draft Plan Strategy is intended to be read in the round. The importance of retaining existing and planting new trees is directly referred to throughout the document. Council may consider producing Supplementary Planning Guidance relating to Trees and Development as part of the ongoing LDP process.

236

Miscellaneous comments on Natural Heritage Responses received Reference

Respondent

MEA-DPS-007

Individual

MEA-DPS-047

Individual

MEA-DPS-049

Northern Ireland Housing Executive

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Expressed disappointment that Safeguarding of the Natural Environment chapter is relegated to Topic 11 instead of Topic 1.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council is satisfied that the plan was developed in the context of the three pillars of sustainability with consideration given to the impact policies will have, not only to the environment but also on social and economic considerations. Paragraph 4.22 of the draft Plan Strategy affirms that 'no one objective or theme is regarded as having priority over any other' and there is no compelling evidence to justify reordering chapters to ensure the soundness of the draft Plan Strategy.

There is an opportunity within the draft Plan Strategy to proactively promote biodiversity through the development management process.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change.

The draft Plan Strategy is intended to be read in the round. High quality design that takes account of its surrounding context including biodiversity is promoted through Policy GP1 (e) and the criteria relating to Sustainable Development point (iv) and is supported by additional policies and guidance within the draft Plan Strategy and as such will provide sufficient safeguarding to ensure that development will conserve wildlife and vegetation and promote further diversity.

Identify areas that contribute highly towards fighting climate change and areas of high biodiversity and create buffers to prevent development.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council consider that the protection of biodiversity interests is sufficient and note that these interests are protected by the policies contained within the Natural Heritage section of the draft Plan Strategy (Policies NAT1 - NAT5). Northern Ireland Environment Agency (NIEA) map viewer provides spatial information on the location of natural environment areas of interest including, protected areas and NIEA surveyed priority habitats and species.

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Identify species that have declined significantly over the last 25 years.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The identification of species is out with the remit of the LDP process. The Northern Ireland Priority Species list is produced by the Northern Ireland Environment Agency.

Climate crisis – introduce mitigation measures, e.g. ban single use plastics by 2030, announce renewable energy incentives.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The issue raised is out with the remit of the LDP process.

Safeguard the Natural Environment - smallest section in the LDP document and the need to protect natural environment assets.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. Council is satisfied that the draft Plan Strategy was developed in the context of the three pillars of sustainability with consideration given to the impact policies will have, not only to the environment but also on social and economic considerations. Council considers that safeguarding and the protection of natural environment interests is sufficiently addressed under polices NAT1 - NAT5.

Lack of Biodiversity Officer - how will our natural environment be safeguarded?

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed. The issue raised relating to a Biodiversity Officer is out with the remit of the LDP process. Council does however consider that safeguarding and the protection of natural environment interests through planning policy is sufficiently addressed under polices NAT1 NAT5.

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Miscellaneous Comments on the draft Plan Strategy

239

Miscellaneous comments on the draft Plan Strategy Responses received Reference

Respondent

MEA-DPS-005

Co-Ownership Housing Association Limited

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-008

Department for Communities - Historic Environment Division

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-038

Invest NI

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-063

Translink

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Prematurity Would like more information on how prematurity will be applied.

Council would refer to paragraph 5.73 of the SPPS which provides a full explanation of the concept of ‘Prematurity’. In addition, Council would refer to pages 22 and 23 of the draft Plan Strategy which sets out how the Plan Strategy will be used.

Developer Contributions Support for a developer contributions framework or planning agreements as a delivery mechanism for affordable housing/ infrastructure/public transport services.

Where necessary, Council have the mechanism to deliver agreements through the existing draft Plan Strategy policies. This includes affordable housing and infrastructure. Policy TR3 covers New Transport Schemes (or connectivity to an existing transportation facility in the locality). The developer contributions framework will be considered at some stage in the future and would be consulted on.

Extant planning guidance Question reference to out of date guidance documents.

The draft Plan Strategy was published in September 2019. Following this, on the 18 October 2019, DfI issued an update to clarify its position with respect to the future of extant planning 240

guidance. It is the Council's intention to publish replacement Supplementary Planning Guidance in due course.

Consistency of terminology Amend draft Plan Strategy text to ensure consistency of terminology, omit the term ‘historic asset’ and replace with ‘heritage asset’

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not go to the soundness of the Plan and therefore suggests no change.

The use of the term 'historic assets' in the context of the specific paragraphs within the draft Plan Strategy is considered acceptable.

Abbreviations and Glossary Use of term 'seascape' should be used explicitly throughout the document where a coastal element is acknowledged or exists.

Council note the issue and consider the draft Plan Strategy to be sound and does not need changed in relation to this issue as protection of the seascape is covered by other wording e.g. landscape character, coastal setting or reference to the Marine Plan for NI. Council notes that landscape character is created by factors such as geology, landform, soils, vegetation, land use and human settlement. These elements, which contribute to seascape, would all be considered under an assessment of landscape character.

Paragraph 2.6.5.1 of the UK Marine Policy Statement (MPS) (2011) states that there is no legal definition for seascape in the UK. Paragraph 2.6.5.1 goes on to state that in the context of the UK MPS 2011, 'seascape should be taken as meaning landscapes with views of the coast or seas, and coasts and the adjacent marine environment with cultural, historical and archaeological links with each other.' Council notes that its remit for carrying out its planning function only extends to the low mean tide water mark. Therefore, Council considers that the terms 'landscape' and 'coastal setting' are appropriate and sufficient for LDP policies that seek to protect the landscape character and setting of the coast, and key views of, and from the coast.

Amend definition of Heritage Assets.

Council note the issue and consider the draft Plan Strategy to be sound and are satisfied that the wording contained within the Abbreviations and Glossary sufficiently defines what constitutes a Heritage Assets for the purposes of the draft Plan Strategy.

Amend, for clarity, the definition of Historic Park, Garden of Specific Historic Interest.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the definition should be made – see Schedule of Proposed Modifications - Reference Number PM-157.

Amend for factual correction, the definition of a listed building.

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest a minor change to the definition should be made – see Schedule of Proposed Modifications - Reference Number PM-159.

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Appendices Set out appendices as supplementary guidance and give weight in determination of planning applications.

Policy HOU1 explicitly states that Appendix D of the draft Plan Strategy will be taken into account when assessing proposals for new residential development in settlements.

Appendix K - Digital Advertising Screens, states that ‘overly bright’ signage will be resisted if it harms amenity or safety. There is no test or benchmark for this and accepts that they are ‘highly controllable’.

Council note the issue and consider the draft Plan Strategy to be sound, and does not need changed. Sub-heading, ‘Lighting’ under Appendix K of the draft Plan Strategy refers to and signposts to the Institute of Lighting Professionals Guidance Documents - PLG05, the aim of which is to provide guidance on illuminated advertisements. The policy criteria contained in policy AD1 in the draft Plan Strategy is considered to appropriately and proportionally address the impact of digital signage on amenity, safety and our historic environment through criteria a) - p) and is considered to provide sufficient scope to allow for digital signage.

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Technical Supplement 1: Monitor and Review

243

Technical Supplement 1: Monitor and Review Responses received Reference

Respondent

MEA-DPS-008

Department for Communities - Historic Environment Division (HED)

MEA-DPS-010

Department for Infrastructure

MEA-DPS-023

Gravis Planning on behalf of Conway Estates Ltd

MEA-DPS-024

Gravis Planning on behalf of Conway Estates Ltd and Individuals

MEA-DPS-025

Gravis Planning on behalf of Individual

MEA-DPS-027

Gravis Planning on behalf of Individual

MEA-DPS-028

Gravis Planning on behalf of Individual

MEA-DPS-029

Gravis Planning on behalf of Individual

MEA-DPS-030

Gravis Planning on behalf of Individual

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-063

Translink

MEA-DPS-066

TSA Planning on behalf of Lotus Homes

MEA-DPS-067

TSA Planning on behalf of Rosemount Homes

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Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Broad support for the monitoring indicators set out in the technical supplement, which are to be used to measure how well the plan is performing in terms of achieving its strategic objectives, including ensuring an adequate supply of housing for the district over the plan period. The focus on identifying targets and triggers in respect of the indicators presented was welcomed.

Support for the monitoring indicators is welcomed.

Social Objective a) Indicator Reference 1

SGS3 sets out a notional housing allocation for each of the villages. Therefore, if the number of new dwellings approved exceeded 5% of the individual allocation to a particular village this would trigger a review. Similarly, a notional housing allocation figure has been allocated to all small settlements collectively. If the number of new dwellings approved in small settlements were to exceed this figure by 5% then a review would be triggered. Finally, a notional allocation figure has been attributed to the countryside i.e. lands outside of designated settlement limits.

Should the number of new dwellings in the countryside exceed this figure by 5% this would trigger a review.

Question if when the number of new dwellings in a village/small settlement/countryside exceeds 5% of the target set in the Strategic Housing Allocation – does the 5% refer to the total Strategic Housing Allocation or is it 5% of the tier?

Social Objective c) Indicator Reference 4 Five year land review should be in relation to strategic housing growth for the Borough in the first instance then for individual settlements at a secondary stage.

Indicator References for Social Objective c) Council should give consideration to a measure in relation to the proportion of residential development approved within the urban footprint of the largest towns. This would assist in evaluating success in achieving the policy aim of SGS5.

Indicator Reference for Social Objective d) Add additional indicator reference to monitor loss of open space to deliver quality residential environments (including associated public open space and linkages to green infrastructure networks). Suggested the Indicator Reference could include the restriction of existing areas of open space, where the target is no loss of existing open space, and the Review Trigger is more than one application permitted in any one year.

Social Objective f) Indicator Reference 10

Council are content that Indicator 4 will assist when determining the release of phase 2 land in main towns.

What is suggested would be to establish when the release of phase 2 lands is required. This is already monitored under Indicator 4. Council are content that Indicator 4 will assist when determining when phase 2 land will be released in main towns.

Council acknowledge the point raised and agree that it would be appropriate to include the loss of open space within the Monitoring and Review Framework – see Schedule of Proposed Modifications - Reference Number PM-160.

Greenways are not always associated with heritage assessments and these occasions would not merit review.

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Opportunity to relate indicator to other policies e.g. Policy OSL2. In this case a heritage led approach to the reuse of a heritage asset as a greenway (e.g. the old mineral railway) will ensure its safeguarding.

Environmental Objective a) Indicator Reference 22 Objective is lacking in detail for monitoring and review and Indicator Reference 22 and suggest an indicator for furthering sustainable development, a target to halt biodiversity loss, and a Review Trigger on ‘more than one application permitted per year contrary to DAERA advice’.

Environmental Objective e) Indicator Reference 26 Propose a trigger which relates only to listed buildings which appear on the Built Heritage at Risk Northern Ireland Register (BHARNI). To capture the impact of proposals involving demolition of all listed buildings and to ensure appropriate monitoring of the objective, it may be more applicable for monitoring to include:

Council would reiterate that generally indicators and targets have been included where the outputs can be delivered and targets measured through the planning system. Technical Supplement 1 also outlines that where possible the indicators and targets are specific, measurable, achievable, realistic and where appropriate, time bound. Council consider the suggestion too onerous for the monitoring of Indicator Reference 22.

Council acknowledge the point raised and agree that it would be appropriate in this case to widen the scope of both the target and trigger to capture the impact of proposals involving demolition of all listed buildings – see Schedule of Proposed Modifications - Reference Number PM-161.

(a) Number of listed buildings demolished To monitor the impacts of development and change to the historic environment it would also be pertinent to monitor: (b) Planning decisions determined against statutory consultee advice and/or recommendations throughout the Plan period Environmental Objective e) Indicator Reference 27 Suggest the following indicators can provide more appropriate monitoring of development impacts on Conservation Areas and/or Areas of Townscape Character (ATC). (c) The number of Conservation Area Consents granted (d) The number of Conservation Areas and/or ATCs designated or removed; and (e) The number of non-designated heritage assets (in Conservation Areas, ATCs or the countryside) reused/enhanced, demolished or replaced.

Council notes the comments in relation to Indicator 27 and considers that both the target and trigger are sufficient to monitor change within Conservation Areas and ATCs. It would be difficult to assign both meaningful targets and triggers as the policy aim is to positively manage change to ensure that the overall character and appearance of the conservation area is enhanced or preserved where an opportunity to enhance does not exist and that the overall distinct character displayed within an ATC is maintained or where possible enhanced.

Council does not intend to de-designate any conservation areas during the plan period. The Planning Act (Northern Ireland) 2011 subsection (5) requires Council before making, varying or cancelling a designation must give notice to the Department and consult with the Historic Buildings Council and such other persons or bodies as may be prescribed. The designation of any new ATCs will be considered at the Local Policies Plan stage.

Council considers that it would be administratively difficult to achieve the level of monitoring of non-designated heritage assets as suggested as they have not been sufficiently identified or mapped.

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Environmental Objective e) Indicator Reference 28 Should expand beyond Area of Significant Archaeological Interest (ASAI), and one application per year against HED advice ought in itself to be a trigger and considers it may be appropriate for monitoring to also include; (f) The number of Scheduled Monument Consents related to planning applications;

Council are satisfied that Indicator 28 is sufficiently robust in respect of the ASAI and considers that it would be administratively difficult to achieve the level of monitoring as suggested in point f), g) and h). In addition, Scheduled Monument Consents are outside the remit of the Council, therefore monitoring of these goes beyond the LDP monitoring and review process. Points g) and h) are not meaningful indicators as they do not measure the success or otherwise of draft Plan Strategy.

(g) Monitoring of number of decisions with archaeological conditions across the district, and (h) Monitoring of applications in the Area of Archaeological Potential (AAP) to which archaeological conditions are applied.

Environmental Objective g): Indicator Reference 31 The LDP monitoring framework should be measuring what contribution the LDP is making to climate change and mitigation measures needed in order to ascertain whether these are sufficient to address the climate and ecological emergencies faced and help inform Mid and East Antrim Council’s all-party working group on climate change.

Council note the comment and see merit in including additional indicators to demonstrate the contribution of the planning system to climate change mitigation, both in terms of the amount of energy (MW) by technology type produced from renewable sources and the presumption against commercial peat extraction - see Schedule of Proposed Modifications - Reference Number PM-162.

Suggest an Indicator Reference could include, for example, the restriction of further commercial peat extraction, where the target is no new approvals for peat extraction (either new sites or extension of existing), and the Review Trigger is more than one application permitted in any one year.

Council may also wish to consider alternative measures in relation to the MW of renewable energy development as this may help to demonstrate the contribution of the planning system to climate change mitigation.

Council should identify more meaningful indicators and targets to assist monitoring and impact of land use on transport network.

Council are satisfied that the monitoring framework is sufficiently robust in this respect and addressed under existing Indicator 11 against Social Objective g), and Indicators 15 and 16 against Economic Objective c).

Projected housing figures and other relevant policies specified (SGS3, Policies HOU5, HOU7) should be amended as required in order to enable accurate monitoring of the plan.

Council are satisfied that the monitoring framework is sufficiently robust in this respect.

Provide information on how the draft Plan Strategy will be monitored to ensure the Council's vision and objectives are met.

The vision and objectives will be borne out through the successfulness of the various policies and their monitoring.

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Chapter 5 Draft Habitats Regulations Assessment

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Draft Habitats Regulations Assessment Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-010

Department for Infrastructure

MEA-DPS-080

Department of Agriculture Environment and Rural Affairs - Natural Environment Division - SEA Team

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

Note the criteria used to screen European sites for likely significant effects and test of likely significance is sound.

Support for the approach is welcomed.

All text changes recommended in draft Habitats Regulations Assessment Report (dHRA) of the draft Plan Strategy, September 2019, pages 16-20, must be accepted in full to achieve conformity and meet the legal requirements of the Conservation (Natural Habitats, etc.)

Regulations (NI) 1995 (as amended).

Council note the issue and consider the draft Plan Strategy to be sound. However, in light of the comments made, for clarity, Council suggest the minor additions to the policy and justification and amplification wording should be made to the policies referred to in the dHRA – see Schedule of Proposed Modifications - Reference Numbers PM-012, PM-060, PM-061, PM-062, PM-063, PM-079, PM-080, PM-086, PM-087, PM-108, PM-109, PM-110, PM-113 and PM-116.

Whilst the dHRA has screened out housing from the possibility of having likely significant effect, it cannot be assumed that the 'quality checks' imposed on a discharge from housing development to ensure a certain water quality meet the same test for the satisfaction of the integrity of a European site.

Council remains of the view that, for the reasons set out under Section 3 of the dHRA - Potential Impacts of Development: Waste Water Treatment, and that development cannot proceed unless there is adequate wastewater treatment, therefore phasing is not essential for this purpose.

Suggested SGS5 should clearly require 'phasing of housing' until wastewater treatment works (WwTW) infrastructure capacity is sufficient to meet projected discharge.

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Chapter 6 Sustainability Appraisal of the draft Plan Strategy (incorporating Strategic Environmental Assessment)

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Sustainability Appraisal of the draft Plan Strategy (incorporating Strategic Environmental Assessment) Responses received Reference

Respondent

MEA-DPS-006

Department of Agriculture Environment and Rural Affairs - Natural Environment Division

MEA-DPS-008

Department for Communities - Historic Environment Division (HED)

MEA-DPS-010

Department for Infrastructure (DfI)

MEA-DPS-012

Donaldson Planning on behalf of Ballymena Development Consortium

MEA-DPS-056

Quarry Plan

MEA-DPS-069

Turley on behalf of ABO Wind (NI) Ltd

MEA-DPS-070

Turley on behalf of Antrim Construction Company

MEA-DPS-076

Turley on behalf of RES

MEA-DPS-077

Turley on behalf of Vaughan Homes

MEA-DPS-080

Department of Agriculture Environment and Rural Affairs - Natural Environment Division - SEA Team

Main Issue(s) raised by respondent(s) and Mid and East Antrim Borough Council’s response Main Issue

Council’s Consideration of Issue

The updating of the scoping report is welcomed.

Comment welcomed.

SGS1 Spatial Growth Strategy Given the strong description of Ballymena as an economically active retail destination, the consideration of Carrickfergus within the Belfast Metropolitan Urban Area and the view that Larne is a potential tourist hub, it is believed there is ample justification to consider reasonable alternatives to the distribution of housing between the three main towns and that majority should go to Ballymena and Carrickfergus.

SGS1 is required to uphold the Regional Development Strategy (RDS) Spatial Framework and this has been appraised through the Preferred Options Paper (POP) in Key Issue 3 and again in the draft Plan Strategy Sustainability Appraisal Report. It is considered that the allocation of housing to individual settlements is dealt with under SGS3 Strategic Allocation of Housing to Settlements. Change to the allocation of housing between tiers was considered in the Interim Sustainability Appraisal for the POP in Key Issue 4. No reasonable alternatives are being brought forward in the draft Plan Strategy for the tiers, as the principle of directing greatest proportion of population to main towns is set by DfI and was tested in the Interim Sustainability Appraisal for the POP and found to be sustainable. Three options were appraised at draft Plan 251

Strategy stage in relation to the allocation of housing within the same tier. It is considered that the allocation of housing to settlements has been considered under SGS3 and that two reasonable alternatives were considered as part of this process.

Sustainability Objective 5 (economic growth): The assessment of a minor positive impact lacks ambition.

In the full appraisal matrix for SGS1 in Appendix 4 of the Sustainability Appraisal Report, the comments under Sustainability Objective 5 are a reflection of the appraisal of the policy as a whole i.e. the focus of major population growth and economic development in the three main towns, facilitate appropriate growth in the small towns, sustain rural communities living in and around villages and small settlements and facilitate sustainable development in the open countryside. The comments and scoring acknowledge the benefits the policy will contribute to the economy but notes issues with treatment capacity at Wastewater Treatment Works (WwTW) which may influence permissions for new economic development requiring mains infrastructure. The minor positive score awarded reflects this.

Sustainability Objective 8 (sustainable travel): By only directing 63% of housing to main towns means major positive score unwarranted.

SGS1 is required to uphold the RDS Spatial Framework and this has been appraised through the POP in Key Issue 3 and again in the draft Plan Strategy Sustainability Appraisal Report. It is considered that the allocation of housing to individual settlements is dealt with under SGS3 Strategic Allocation of Housing to Settlements. Change to the allocation of housing between tiers was considered in the Interim Sustainability Appraisal for the POP in Key Issue 4. No reasonable alternatives are being brought forward at draft Plan Strategy for the tiers, as the principle of directing greatest proportion of population to main towns is set by DfI and was tested in the Interim Sustainability Appraisal for the POP and found to be sustainable.

Three options were appraised at draft Plan Strategy stage in relation to the allocation of housing within the same tier. It is considered that the allocation of housing to settlements has been considered under SGS3 and that two reasonable alternatives were considered as part of this process. The full appraisal matrix for SGS1 in Appendix 4 of the Sustainability Appraisal Report includes comments for Sustainability Objective 8 which acknowledge that all the main towns have both train and bus links and that focusing growth and populations to urban areas enables people to conveniently access public transport and focus on the provision of active travel for the majority of people. The comments acknowledge that the hierarchy of scale approach (SGS2) to direct growth helps to focus adequate facilities and services to meet local need. The comments note that rural areas are not excluded and part of their sustainability is ensuring adequate public transport and where possible, active travel connections are in place.

Behavioural change was also considered. It is considered the comments justify the score awarded.

Sustainability Objective 10 (climate change): Disappointed with uncertain effect score and more should be allocated to Ballymena and Carrickfergus.

In the full appraisal matrix for SGS1 in Appendix 4 of the Sustainability Appraisal Report, the comments under Sustainability Objective 10 note that focused population growth and development in settlements requires new housing and heating, and usually increased levels of traffic. This general development may lead to increases in greenhouse gas emissions, however focusing growth in main towns may enable more efficient housing and allow greater access to 252

active and sustainable travel options. New housing and buildings could be constructed using recycled materials. Building standards will require energy efficient construction and other measures are available to reduce energy needs, reuse water and integrate adaptation measures to local infrastructure such as Sustainable Drainage Systems (SuDS). The overall impact on this objective is uncertain as it is dependent to a large extent on behavioural change.

Indirect effects of spatial growth on marine, coastal and transitional waters has not been acknowledged.

It is acknowledged that the comments under Sustainability Objective 11 for SGS1 do not specifically relate to marine, coastal and transitional waters. However, this is more a reflection of the language used in the appraisals themselves rather than an absence of consideration of how the Spatial Growth Strategy may affect or impact these areas. The Sustainability Appraisal Scoping Report examined a wide range of marine and coastal aspects in its evidence base reported in Chapter 5, which also informed the discussions occurring during the appraisal of options. For the Local Policies Plan the Key Sustainability Issues and Appraisal Prompts will be reviewed to ensure that they adequately direct the appraisal discussions for relevant policies or policy options. This may aid in ensuring that the reporting of effects on the marine, coastal and transitional waters uses appropriate terminology and is more clearly identifiable in the Sustainability Appraisal Report.

SGS2 Settlement Hierarchy Support identification of Ballymena as one of three main towns, but the sustainability performance of three main towns should have been further considered in relation to individual allocations.

As part of the housing allocation process the six RDS Housing Evaluation Framework tests were applied to the top three tiers of the settlement hierarchy using a broad scoring system and a series of indicators tailored for the different tiers (see Technical Supplement 3: Housing).

It is considered that allocations (housing and economic land) will not restrict growth as there is an oversupply of both within main towns.

Sustainability Objective 5 (sustainable economic growth): Major positive score unwarranted as Ballymena and Carrickfergus have not secured significant allocation above the base increase allocated to main towns.

As outlined in the comments under Section 3.2.2 SGS2 Settlement Hierarchy of the Sustainability Appraisal Report the three main towns have been retained at the top tier of the hierarchy based on their regional status set out in the RDS and as highlighted in the Spatial Growth Strategy they will be the focus for major population growth and economic development.

The score awarded for Sustainability Objective 5 takes into account the fact that settlements are identified in accordance with their available land, facilities and infrastructure, which in turn informs their ability to accommodate types and scales of economic development sustainably.

The comments justify the score awarded.

Sustainability Objective 8 (sustainable travel): Minor positive score is disappointing.

In the full appraisal matrix for SGS2 in Appendix 4 of the Sustainability Appraisal Report the comments for Sustainability Objective 8 acknowledge that the assessments which have informed the hierarchy considered existing settlements and that one of the indicators included public transport. It was considered that the strategic policy reflects the most suitable hierarchy for sustainable travel and ability to encourage active travel. It is considered that SGS2 is in keeping with Regional Policy and the score awarded is justified.

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Sustainability Objective 10 (climate change): Uncertain score is disappointing given the critical role that housing allocations can have with respect to reducing carbon emissions through private vehicle use.

The awarded scores and associated commentary for SGS2 is provided in Appendix 4 of the Sustainability Appraisal Report. The comments associated with Sustainability Objective 10 note that the principle of hierarchy supports the objective as it may help to reduce the need to travel by car and the most efficient hierarchy has been chosen based on recent assessments that looked at existing facilities and population. It was also acknowledged that new development usually produces greenhouse gas emissions i.e. construction etc. but that these may be balanced by encouraging the incorporation of renewables etc. An uncertain score was awarded for Sustainability Objective 10 as it is dependent to a large extent on the rate of uptake on measures to reduce Greehouse Gas Emissions including behavioural change. The comments justify the score awarded.

SGS3 Strategic Allocation of Housing to Settlements Scoring flawed as three options have scored exactly the same but Option 1 appears to be the most sustainable.

Preferred Option 1 is for ‘a proportionate allocation of housing for settlements within the same tier, according to population at Census 2011, but with some tailoring to reflect the capacity of a settlement and existing facilities as assessed in the Housing Evaluation Framework’.

Preferred Option 2 is ‘for the proportionate allocation of housing for settlements within the same tier, according to population at Census 2011’. It is considered that Preferred Option 1 clearly states in the description that tailoring which reflects the capacity of a settlement is based on the Housing Evaluation Framework on which information can be found in Appendix A of the draft Plan Strategy and Technical Supplement 3: Housing. The difference in housing numbers between each option is considered to be clear and is contained within Appendix A of the draft Plan Strategy and Technical Supplement 3: Housing. It is acknowledged that all three options received the same score in the appraisal, as the main influence on the Sustainability Objectives is the distribution of housing growth to each tier. However, the comments reflected the subtle differences that would have been generated through each approach.

Wastewater infrastructure to allocate growth taken into account in Sustainability Appraisal matrices but insufficient WwTW capacity not addressed by policy.

Council do not consider additional wording in the SGS3 policy box is necessary given the changing nature of WwTW capacity. If there is not adequate WwTW capacity the development will still have to meet Policy WWI1 'Development relying on non-mains wastewater infrastructure'.

Sustainability Objective 12, page 153 recognises the potential to use brownfield sites and apply mitigation to avoid impacts on biodiversity, but this is neither mentioned in measures to reduce negative effects and promote positive effects on page 28 of the Sustainability Appraisal report or in the draft Plan Strategy Section 5.3.

The scoring for Sustainability Objective 12 in relation to SGS3 is positive therefore no mitigation measures are required. It is anticipated that as sites are zoned through the Local Policies Plan process that any loss of biodiversity will be mitigated through other relevant policies or through Key Site Requirements (KSRs).

SGS5 Management of Housing Supply Welcome for the recognition of the impact that Key Site Requirements can have with regard to archaeological remains. Suggested however

In the full appraisal matrix for SGS5 in Appendix 4 of the Sustainability Appraisal Report, the comments under Sustainability Objective 14 have acknowledged that construction activities 254

that the scoring on impact could be uncertain i.e. when remains protected this can be positive, when excavated can be negative.

may conflict with the preservation of the historic environment. While an uncertain score could also be justified with the comments recorded, it was considered in the appraisal that relevant operational policies would provide adequate safeguarding against negative impacts and a neutral score was awarded.

Wastewater infrastructure to allocate growth taken into account in Sustainability Appraisal matrices but insufficient WwTW capacity not addressed by policy. Amend policy to require phasing of housing until WwTW infrastructure capacity is sufficient to meet discharge.

Council do not consider additional wording in the SGS5 policy box is necessary given the changing nature of WwTW capacity. If there is not adequate WwTW capacity the development will still have to meet Policy WWI1 'Development relying on non-mains wastewater infrastructure'.

Use of the word ‘may’ in paragraph 5.3.25 of the draft Plan Strategy in relation to capacity in Larne has associations of possibility.

The comments about Larne were added as capacity issues with WwTWs were raised just before the draft Plan Strategy was published to make potential developers aware but given the changing nature of WwTW capacity this was only included for information. The word 'may' was used because if there is not adequate WwTW capacity the development will still have to meet Policy WWI1 Development relying on non-mains waste water infrastructure. Temporary WwTW solutions may therefore allow development to proceed and this will be considered on a site by site basis taking into account the most up-to-date data on WwTW capacity.

Review score of ‘no overall effect’ for Options 1 and 2 against Sustainability Objective 11.

The comments associated with Sustainability Objective 11 consider that it is unlikely that either option will have an impact on the objective to protect, manage and use water resources sustainably. This is because the principle of zoned land is already established and the policy options are considering the merits of a phased approach.

SGS6 Strategic Allocation of Land for Economic Development The 'measures to reduce negative effects and promote positive effects' in paragraph 3.2.6 are not reproduced in the draft Plan Strategy in SGS6 or in any of the Policy Boxes ECD1-ECD4.

The Sustainability Appraisal (SA) Scoping Report (section 3.1) notes that during the appraisal ideas were discussed for measures to reduce negative effects and promote positive effects, and these are as reported. There is not a legal requirement to implement these, however they are recorded so that, where appropriate, they can be incorporated to further the overall sustainability of the LDP. SGS6 relates only to the gross supply of economic land required. It is only through the Local Policies Plan process that individual sites are zoned so measures to reduce specific negative effects and promote positive effect on those sites can be considered as part of Key Site Requirements, if considered appropriate. In addition, as these sites will also be assessed against Policies ECD1-4 as applicable and Policy GP1, Council consider these policies already do include mitigation measures through policy requirements and criteria to be met.

SGS8 Tourism Strategy Regarding paragraph 3.2.8 concern about the level of development that the identified Tourism Opportunity Zone at Carnfunnock can accommodate and advise development should be heritage led.

In the detailed appraisal matrix for SGSG8 in Appendix 4 of the SA report the comments under Sustainability Objective 14 recognise that many historic and cultural features such as Carnfunnock are also key tourism assets.

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Through the Local Policies Plan process, the tourism opportunity zone at Carnfunnock Country Park will be considered in detail. The areas of the site suitable for development will be identified in consultation with DAERA/HED/Council Tourism Team, ensuring that the setting and assets of the site are protected.

Identifying Carnfunnock as a Tourism Opportunity Zone, does not mean that inappropriate development will be allowed at the site and a balance will need to be met between development and respecting the historical features within/adjacent to the site. This approach is reflected in Policy TOU2 paragraph 7.3.11 which specifically states proposals within Carnfunnock Country Park should be sensitive to its coastal location and historic and natural features and also comply with Policy HE2.

Sustainability Objective 9 (improve air quality): May be better reflected with a minor negative score.

The commentary in the detailed appraisal included in Appendix 4 of the SA Report explains the scoring approach taken. It is considered that this strategy will help to promote sustainable tourism and part of this will be directing tourism within settlements. Where this is not possible it is acknowledged that access to tourism facilities may not always align with sustainable travel options. It is considered that overall air quality is unlikely to be affected by the strategy and that any related facilities are unlikely to be big air polluters. Council therefore consider no change to the draft Plan Strategy Sustainability Appraisal is required.

SGS9 Open Space Strategy Welcome articulation of historic environment concerns in relation to cemeteries in OSL7.

The comments are noted but Council consider that this does not affect the soundness of the Plan, as Council are satisfied that the policy as proposed ensures that the historic environment will be considered as part of any proposal.

CS1 Sustainable Development in the Countryside CS1 was scoped out of the Sustainability Appraisal review on the basis that it is in effect a signpost to spatial policies so it is unsound as it relies upon Policies such as RE1 which is in itself considered unsound. Policy CS1 will be amended through amendments to supporting policies such as RE1 so should be re-screened for appraisal within the Sustainability Appraisal.

Policies will only be reviewed again if it is considered that there will be any likely significant effects as a result of changes to draft Plan Strategy. Council consider CS1 to remain a signpost policy with any issues relating to individual operational policies considered under that relevant policy appraisal within the Sustainability Appraisal.

CS2 Special Countryside Areas Methodology within the Landscape Character Assessment (LCA) is flawed and the designations are not justified from a planning perspective. There is no criteria for a project to demonstrate regional significance and to justify an application.

The reference to the LCA being flawed and the lack of clarity on regional significance is considered in the CS2 policy consideration.

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No other reasonable alternatives to the Preferred Option (Policy CS2) appear to have been considered. A reasonable alternative should be to retain Area of Outstanding Natural Beauty (AONB) and not introduce a further landscape based upon flawed evidence.

The principle of spatially defining areas that should be afforded specific protection for their landscape quality has been established through the legacy Larne Plan. Removing the existing spatial designation for landscape character is therefore not considered to be a reasonable alternative. In the case of the Larne Coast, Gobbins Coast, Lough Beg and Slemish Special Countryside Areas (SCAs), these landscapes and their associated environment and heritage assets are considered so special, that they warrant a strong level of policy protection from the potential adverse impacts of development. Further explanation why the AONB does not offer sufficient enough protection in these areas, is addressed in CS2 policy consideration.

Given the presumption against any development within the SCA, the policy cannot achieve a minor positive impact upon the local economy.

Without new buildings and infrastructure to support economic growth there can only be a significant negative impact upon the local economy in the SCAs.

The commentary in the detailed appraisal of CS2 included in Appendix 4 of the SA Report justifies the awarded scores. Council therefore consider there is no change required to the appraisal.

Several significant positive environmental effects are noted against Sustainability Objectives 7, 10, 11, 12 & 13 because the policy prevents any new development in the SCA, which is not in the pursuit of sustainable development and contrary to paragraph 6.65 of the SPPS.

The awarded scores and associated commentary for CS2 is provided in Appendix 4 of the SA Scoping Report. Significant positive outcomes were predicted for Sustainability Objective 7 on the basis that the policy would further protect earth science sites and semi natural land. The comments acknowledge that the approach of the policy may restrict aggregate mineral excavation if they are located in the areas protected under the policy but valuable minerals of regional significance could still be sought and there would still be the opportunity for mineral excavation outside of these areas. Significant positive scores were also awarded for Sustainability Objective 10, 11, 12 and 13 based on the location of the areas protected under the policy and the multiple functions they provide including climate change adaptation.

The habitats act as carbon/water stores and help to maintain natural resilience in the environment that can combat erosion, reduce flood risk, conserve local biodiversity as part of the green/blue infrastructure network as well as provide areas that provide significant landscape value and visual amenity. The most distinctive landscapes within the Borough, which are particularly sensitive to change, will be protected. The scores are justified are in line with the SPPS. Council therefore consider there is no change required to the appraisal.

CS3 Areas of Constraint on High Structures By failing to identify alternatives to height restrictions within CS3 the Sustainability Appraisal has failed to meet the legal requirements of the Strategic Environmental Assessment (SEA) Regulations.

The reference to Council not considering alternatives to height restrictions is addressed in CS3 policy consideration. Comments in the SA Report note that no alternatives were considered as the designated areas and their associated environment and heritage assets are considered so sensitive to the adverse impacts of visually prominent development, that they warrant a strong level of policy protection that seeks to exclude such development from these areas, except in exceptional circumstances.

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Queries if the 'carbon release' associated with loss of natural habitat has been compared to 'carbon gain' associated with high structures.

Consider what area of Borough needs to be left available for high structures to ensure no adverse effects for Objective 10. An uncertain score may be more appropriate in this case.

It is considered that a proportionate appraisal of CS3 has been carried out against Sustainability Objective 10 and that the comments justify the score awarded.

CS5 Antrim Coast and Glens Area of Outstanding Natural Beauty Policy is flawed as it presumes no development is acceptable in the AONB, contrary to the SPPS. A positive score is recorded against Sustainability Objective 5 despite a presumption against development in the AONB. Under this presumption a significant negative impact is the only reasonable conclusion as new services, facilities and jobs will be severely restricted.

The reference to the policy being flawed is considered in the CS5 policy consideration. The full appraisal matrix for CS5 in Appendix 4 of the SA Scoping Report provides the commentary for the scoring of Sustainability Objective 5. A positive score was awarded for this policy as it acknowledges that the policy will secure the area as a specific destination and should help to make the area more attractive for visitors and investors with associated spin offs for tourism and ventures linked to the AONB as a destination. Restrictions on economic ventures are unlikely and diversification will remain feasible. Local design and sustainable tourism would be expected to be of high quality. The score is justified and the policy is in keeping with the regional policy direction of the SPPS.

ECD1 Economic Development in Settlements In section 3.4.1. on page 46 of the SA, the appraisal of Policy ECD1 identified negative effects for Objective 12, however no mitigation measures have been identified to reduce negative effects and promote positive effects.

Council consider the commentary in the detailed appraisal (included in Appendix 4 of the SA Report) explains the scoring approach taken. Council also note that as the scoring reflects a minor negative as opposed to significant negative, mitigation measures are not required.

Council therefore consider no change to the draft Plan Strategy Sustainability Appraisal is required.

ECD4 Economic Development in the Countryside The 'measures to reduce negative effects and promote positive effects' identified on page 50 are not reproduced in the draft Plan Strategy in Policy ECD4.

The SA Scoping Report (section 3.1) notes that during the appraisal ideas were discussed for measures to reduce negative effects and promote positive effects, and these are as reported.

There is not a legal requirement to implement these, however they are recorded so that, where appropriate, they can be incorporated to further the overall sustainability of the LDP. In addition, these measures are already taken into account as Policy ECD4 cross refers to Policy GP1 which includes criteria relating to design quality, appropriate landscaping, as well as ensuring no unacceptable adverse impact on the quality and integrity of the environment and particularly upon local biodiversity.

The impact of Policy ECD4 (page 49) in relation to the historic environment should be uncertain rather than a minor positive scoring.

While there is a potential positive in the reuse of older buildings and

In the full appraisal matrix for Policy ECD4 in Appendix 4 of the SA Report, the comments for Sustainability Objective 14 recognise that there could be greater potential to find new evidence of the historic environment by enabling new developments/proposals. The policy appraisal comments recognise that other operational policies such as Policy HE8 which is signposted by 258

historic structures and the discovery of new remains might be a positive, their destruction, albeit through scientific recording can be negative.

Policy ECD4 will apply and there is confidence that operational policy will reduce the risk of negative or uncertain effects. The score has been influenced by the policy inclusions encouraging the retention and renovation/refurbishment of existing buildings (including Irish vernacular) which would help to conserve the built environment. Council consider that these comments support the positive score and no change to the draft Plan Strategy SA is required.

Policy TOU2 Tourism Development in Settlements and Tourism Opportunity Zones In regard to the Tourism Opportunity Zones, concern about the level of development that Carnfunnock Country Park can accommodate and advise development should be heritage led.

At Local Policies Plan stage, the tourism opportunity zone at Carnfunnock Country Park will be considered in detail. The areas of the site suitable for development will be identified in consultation with DAERA/HED/Council Tourism Team, ensuring that the setting and assets of the site are protected.

Identifying Carnfunnock as a Tourism Opportunity Zone, does not mean that inappropriate development will be allowed at the site and a balance will need to be met between development and respecting the historical features within/adjacent to the site. This approach is reflected in Policy TOU2 paragraph 7.3.11 which specifically states proposals within Carnfunnock Country Park should be sensitive to its coastal location and historic and natural features and also comply with Policy HE2.

Mineral Development – Introduction Baseline and evidence on which minerals policies are based, is not considered accurate. Socio-economic and environmental profile of plan area is inaccurate. Data provided is only a snapshot of the economic importance of the industry in Mid and East Antrim. Data previously supplied not seen in evidence base. Other data misinterpreted, resulting in base line upon which SA has been based, being incorrect, providing an erroneous SA/SEA, conclusion and assessment of draft Plan Strategy and ultimately a strategy that is not sound.

Section 4.4 Baseline Evidence in the SA Report notes that baseline evidence has been taken from LDP Preparatory Position Papers and the SA Report acknowledges that ‘a series of Technical Supplements have been published alongside the LDP draft Plan Strategy’ and that as they were ‘published simultaneously to the Scoping Report consequently some of the updated information presented within the Technical Supplements was not available at the time the Scoping Report was finalised.’ The Scoping Report was prepared with the only published evidence base available. It is considered that the Scoping Report acknowledges the economic importance of the industry with reference to the Borough’s ‘regional importance to the minerals industry’, the creation of employment particularly in rural areas and recognition that the Borough is the second most important Council area in Northern Ireland for minerals in monetary terms and the third biggest employer within the minerals industry.

Policy MIN1 Mineral Development – Extraction and Processing of Hard Rock and Aggregates There is a paucity of information in the evidence base regarding economic impacts associated with the industry or future development aspirations, so SA conclusions cannot be adequately assessed.

It is noted in section 4.4 Baseline evidence, that the Scoping Report was finalised before the completion of the updated technical supplements. However, any new research or findings associated with Technical Supplement 8 would have informed discussions during the SA process. It is considered that the evidence base has utilised the most up to date published data available. In the full appraisal matrix for Policy MIN1 in Appendix 4 of the SA Report the significant positive scoring and associated comments for Sustainability Objective 5 259

acknowledge the minerals industry as an important contributor to the economy. The appraisal recognises that the industry supports the creation of a range of job types, that quarried minerals are a high value product and that the industry also supports complementary businesses and provides locally sourced materials for roads. This score recognises the significant impact that the minerals industry has on the Borough’s economy but this must be considered within the wider framework of the remaining Sustainability Objectives and regional policy direction.

Given that mineral resources in the district are of regional importance, the SA has not considered that an alternative approach may be where Council would designate Mineral Reserve Areas to protect such resources, in line with SPPS paragraph 6.156.

The SPPS states that in preparing their LDP councils 'may' also identify areas most suitable for minerals development within the plan area. Identifying suitable areas for minerals development is not a requirement of the SPPS. In the full appraisal matrix for MIN1 in Appendix 4 of the SA Report it is recognised in the Reasonable Alternatives section that the POP Option 12a proposed designating Mineral Reserves Area in the Preferred Option for Key Issue 12. It was considered that there is a current lack of robust evidence on supply and demand to identify new Mineral Reserve Areas within the Borough. It was proposed that this aspect is postponed until the first review stage when it is hoped that the information will be gathered through the newly formed minerals working group. Council therefore consider no change to the draft Plan Strategy SA is required.

The SA is not considered to have assessed all reasonable alternatives to the proposed policy, rendering it inadequate.

Alternatives to extraction and processing of hard rock and aggregates were appraised in the POP SA Interim Report, (POP Option 12). Three options were presented as part of this process. Option 12a (Preferred Option) proposed defining areas where there would be a presumption for and against minerals development. Option 12b proposed removing existing Areas of Constraint on Mineral Development (ACMD) with the facilitation of minerals development entirely through application of existing or amended policies. Option 12c proposed the safeguarding of mineral resources of economic or conservation value by allowing for expansion of existing quarries and retention of existing designated Area of Salt Reserve with a presumption in favour of minerals development within such areas. Elsewhere existing/amended policy would apply with applications being decided on a case by case basis The proposed options put forward at the POP stage are considered to have covered a proportionate range of policy options. Option 12a was found to be the most sustainable option.

Policy MIN4 Areas of Constraint on Mineral Development Accurate SA is not possible as industries contribution to the economy is based on production figures from the Annual Minerals Statement which does not report value-added processes which significantly affect turnover of operators.

The importance of the minerals industry to the Borough economy is recognised through Section 5.71 of the Scoping Report and is reflected in the appraisal of the MIN policies in the SA Report.

The full appraisal matrix for MIN4 in Appendix 4 of the SA Report has been awarded a minor positive in respect of Sustainability Objective 5 as it recognises that there will be some constraint on minerals development in certain areas but also highlights the benefit of the policy to other economic uses such as tourism and recreation. The comments also acknowledge that designation allows existing mineral development to expand and that valuable minerals can still be extracted, subject to evidence. It is noted in the reasonable alternatives commentary that 260

new ACMDs in the Borough were not identified due to a lack of a 'robust evidence base on supply and demand,' with this aspect of the Preferred Option delayed until new information is gathered through the newly formed minerals working group. It is considered that the Scoping Report and information utilised through the appraisal process has utilised the best published information available and that the score awarded is justified.

The evidence base is void of information, with regards to the vulnerability of the landscapes to minerals development or the effectiveness of the designations.

In line with the SPPS, ACMDs have been identified because of their 'intrinsic landscape, amenity, scientific or heritage value (including natural, built and archaeological heritage). It is considered that sections 5.12 Natural Resources, 5.13 Landscape and 5.14 Historic Environment and Cultural heritage of the Scoping Report provide information relevant to the policy. Discussion during the SA process would also have influenced comments and scoring of Sustainability Objectives. The draft Plan Strategy SA has reported that there is no reasonable alternative, as the policy option is consistent with regional policy contained in the SPPS.

SA assessment appears to be based on POP options, which included retaining or expanding ACMDs (Key Issue 12a) or removing them (Key Issue 12b). However, there was no option to review or reduce the existing ACMDS, to reflect only the area’s most sensitive/vulnerable to mineral development, so therefore the SA is not considered to have assessed all reasonable options.

The draft Plan Strategy SA as reported is that there is no reasonable alternative, as the policy option is consistent with regional policy contained in the SPPS. The Minerals section of this report sets out that in response to the issues raised it is suggested that the introduction text should be amended to clarify that it is envisaged that there may be a need to review the existing ACMDs and to consider the designation of additional ACMDs. This along with potentially designating Mineral Reserve Areas will be considered when sufficient evidence is provided by the Minerals Working Group

Policy MIN7 Peat Extraction In relation to paragraph 3.4.16 in the SA report, the impact of MIN7 in relation to the historic environment should be a positive rather than neutral or negative score. Peat bogs contain rare and important archaeological remains as the bog preserves the organic materials.

Policy MIN7 operates a presumption against commercial peat extraction. In the full appraisal matrix for Policy MIN7 it is recognised that the draining of bogs can result in damage to/ loss of archaeological artefacts and that peat areas can be linked with landscape and history. The negligible score awarded for the objective reflects the fact that the policy is being considered from a strategic Borough wide perspective.

Policy HOU5 Affordable Housing in Settlements The SA should have identified alternatives to the affordable housing provision (lower and higher than the preferred option) and tested these against the SA framework to identify the most sustainable option.

The draft Plan Strategy SA has reported that there is no reasonable alternative, as the policy option is consistent with regional policy contained in the SPPS. Under the section reasonable alternatives it is noted that none were identified and that the SPPS outlines that the LDP process is the primary vehicle to facilitate and identify affordable housing need by zoning land or indicating through KSRs, where a proportion of a site may be required for social/affordable housing. Previously through the POP under Key Issue 14 the principle of zoning sites solely for affordable housing was discounted as such an approach would lead to single tenure developments, contrary to the SPPS. The principle of providing affordable housing via KSRs and through a bespoke policy was also assessed at POP under Key Issue 14. The comments 261

also note that thresholds were established by carrying out an initial indication of potential yield within settlements and through consultations with statutory consultee NIHE. Thresholds were then tailored to find those which would deliver an appropriate level of provision in line with the identified need. The comments also acknowledge that thresholds will not meet 100% of the social housing rented need and NIHE acknowledge that this would not be expected as this would be supplemented by existing mechanisms delivered by housing associations.

Policy HOU16 Affordable Housing in the Countryside Council to consider historic environment beyond the recorded assets.

Comments noted.

Policy RE1 Renewable Energy Development Clearer reference to concerns around the historic environment in the Policy text would enable more positive outcomes for Sustainability Objective 14 ‘historic environment’ in the SA scoring for Policy RE1 more likely.

The wording amendments suggested to address concerns around the historic environment are addressed in Policy RE1 policy consideration.

In relation to 3.6.11 in the SA report, the impact of Policy RE1 on Sustainability Objective 10 on Climate Change should be a significant negative impact rather than significant positive.

In the full appraisal matrix for Policy RE1 in Appendix 4 of the SA Report, the comments under Sustainability Objective 10 have acknowledged that the policy option would enable a reduction in the use of fossil fuels by promoting and facilitating the delivery of renewables, which emit less greenhouse gas emissions than traditional sources of energy i.e. fossil fuels. The comments also acknowledge that the policy approach aims for appropriate technologies which does not halt development but encourages consideration of more sustainable options.

Additionally, the comments also refer to the policy approach of avoidance of active peatlands, which are an important store for carbon and water. It is considered that the comments justify the score awarded and that the policy approach is in keeping with regional policy. Council therefore consider no change to the draft Plan Strategy SA is required.

In relation to paragraph 3.6.11 in the SA report, the impact of Policy RE1 on Sustainability Objective 6 on managing material assets sustainably should be a significant negative impact rather than minor positive.

In the full appraisal matrix for Policy RE1 in Appendix 4 of the SA Report the comments under Sustainability Objective 6- manage material assets sustainably, acknowledge that that there may be some restrictions because the type of renewable may be inappropriate for that location.

However, a minor positive score was awarded because the policy option enables the most appropriate renewable energy technologies to be located within the Borough and supports delivery of renewables including small scale projects. The policy approach may also help with the upgrading of local infrastructure. It is considered that the comments justify the score

In the full appraisal matrix for Policy RE1 in Appendix 4 of the SA Report, the comments and scoring for Sustainability Objective 14 reflect the positive outcomes for this policy associated with the historic environment. It acknowledged that the policy could help to enable the protection of historic/cultural features and their settings with reference to specific sites and cross reference of other relevant policies. Council therefore consider no change to the draft Plan Strategy SA is required.

262

awarded and that the policy approach will not 'remove' large scale solar and wind. Council therefore consider no change to the draft Plan Strategy SA is required.

In relation to paragraph 3.6.11 in the SA report, Sustainability Objective 13 on landscape character is unsound on the basis that negative landscape impacts from wind turbines cannot automatically be assumed and must be judged on a case by case basis.

In the full appraisal matrix for Policy RE1 in Appendix 4 of the SA Report the comments under Sustainability Objective 13 note that the most appropriate technologies would be sought for specific areas across the Borough, with the most sensitive landscapes avoided. This is in keeping with regional policy direction and the score awarded is considered to be justified.

Council therefore consider no change to the draft Plan Strategy SA is required.

Suggest Policy RE1 wording criteria l) does not conform with the SPPS and reasonable alternatives based on the SPPS wording should have been considered in the SA.

The concerns relating to criteria l) of Policy RE1 are addressed in RE1 policy consideration.

The draft Plan Strategy SA has reported that there is no reasonable alternative, as the policy option is consistent with regional policy approach, the SPPS, to promote renewables in a balanced way. Council therefore consider no change to the draft Plan Strategy SA is required.

Policy TOC1 Telecommunications Development and Overhead Cables In relation to 3.6.12 in the SA report, Policy TOC1 failed to meet the requirements of the SEA Regulations by considering alternatives to the height restrictions.

The concerns relating to the justification for the 25m height restriction are addressed in CS3 policy consideration.

In relation to paragraph 3.6.12 in the SA report, the impact of Policy TOC1 on Sustainability Objective 10 'Climate Change' should be a significant negative impact rather than a negligible score.

The full matrix for Policy TOC1 in Appendix 4 of the SA Report Sustainability Objective 10 scored a negligible score. Positive comments were noted as it was considered that this balanced policy could enable remote working, working from home through enhanced communications infrastructure and a reduction in transport requirements.

No reasonable alternatives were identified and the option was considered to be required to uphold the aims or policy approach of the SPPS. The SA found the option to be a sustainable option. Council therefore consider no change to the draft Plan Strategy SA is required.

Policies WMT1 Environmental Impact of a Waste Management Facility, WMT2 Waste Collection and Treatment Facilities and WMT3 Waste Disposal Sites In relation to the scoring of Policies WMT1-3 on page 92, the suggested wording amendments to Policy WMT3 could assist in reducing the likelihood that these policies will have adverse impacts in relation to historic environment interests.

The wording amendments suggested to address concerns around the historic environment are addressed in Policy WMT3 policy consideration.

There is no specified modification suggested to the SA reports. Council therefore consider no change to the draft Plan Strategy SA is required.

Policy WMT5 Land Improvement In relation to the scoring of Policy WMT5 on page 94, it is considered that an uncertain scoring rather than a negligible effect would be more appropriate in relation to potential impacts on the historic environment.

In the full appraisal matrix for Policy WM5 in Appendix 4 of the SA Report, the comments under Sustainability Objective 14 have acknowledged that land improvement activities may have an effect on the setting of certain types of heritage asset. The comments also acknowledge that topsoil stripping may damage or destroy unrecorded or buried archaeology. While an uncertain score could also be justified with the comments recorded, it was considered in the SA that relevant operational policies would provide adequate safeguarding against negative impacts 263

and a neutral score was awarded. Council therefore consider no change to the draft Plan Strategy SA is required.

Policy HE1 Archaeological Remains and their Settings Would be useful to articulate the proposed extension of the Areas of Significant Archaeological Interest (ASAI) on page 131 of scoping report, but recognise this is covered under Technical Supplement 13: Built Heritage.

The Scoping Report covers strategic themes and the concept of the ASAI is covered in the Scoping Report. As noted by HED this is covered under the Historic Environment Evidence Paper.

Page 132 of the SA scoping report says “The LDP will consider the designation of new ASAIs and Areas of Archaeological Potential (AAP)”.

It is emphasised that the new AAP would be identified in the plan based on HED records, rather than designated through it as the ASAI is.

The comments are noted but Council consider that this does not affect the soundness of the Plan. The wording will be amended in future reports to reflect the comments.

Page 190 of SA Scoping report says “Notes that historic Ordnance Survey (OS) mapping of sites may not yet be within HED records”.

There may be a misunderstanding of previous comments in relation to use of evidence. Historic OS maps may depict features such as ruins, historic farmsteads, or other features which although not named in the Historic Environment Record of Northern Ireland held and managed by HED, should nonetheless themselves, like townland and parish boundaries, also be considered as heritage assets and components of the historic landscape.

Notwithstanding the appropriateness or otherwise of this suggested change, the Council consider that this does not affect the soundness of the Plan and therefore suggests no change.

In relation to paragraph 3.7.1 the scoring for natural environment impacts should be considered positive, on the whole. Most extant archaeological sites are located on agricultural land and many form semi wild uncultivated islands in otherwise managed land, which provide important habitats and reservoirs for many plant and animal species.

The detailed appraisal in Appendix 4 of the SA Report recognises potential positives for the protection of natural resources and enhancement of biodiversity. However, a negligible score was awarded as the extent of the Council area was considered in relation to the number of areas which will be affected by this policy. Council therefore consider no change to the draft Plan Strategy SA is required.

Policy HE1 should have scored a minor negative effect against Sustainability Objective 10 on the basis that this policy will have a negative effect upon the deployment of wind energy although this would only occur if archaeological remains were present.

In the full appraisal matrix for Policy HE1 in Appendix 4 of the SA Report the comments under Sustainability Objective 3 acknowledge that the policy is likely to affect several urban areas where AAPs exist and as such house builders could incur additional costs. This would have a negative impact upon Sustainability Objective 3 to provide good quality, sustainable housing and as such a minor negative score was awarded. It was considered that the thrust of the policy would have a negligible effect upon Sustainability Objective 10 - reduce causes of and adapt to climate change although some positive comments were noted.

264

Miscellaneous Indicators 1 and 2 could be more targeted to reflect the impact of the out workings of the LDP. e.g. number/extent of developments approved/refused in relation to protected habitats/species and number/extent of developments approved/refused within or adjacent to designated sites (both marine & terrestrial).

It is considered that the monitoring approach is proportionate.

The effects on the marine environment could have been drawn out more. Consideration should have been given to Marine Strategy Framework Directive and Water Framework Directive. No reference to the consideration of marine policy documents as part of justifications within policy options or reasonable alternatives. Appears only terrestrial planning policy documents have been considered.

It is considered that the effects on the wider marine area have been considered and are outlined in the SA report and that the SA Scoping Report also examined a wide range of marine and coastal aspects in its evidence base reported in Chapter 5, which also informed the discussions occurring during the appraisal of options.

The SA provided in support of the draft Plan Strategy is fundamentally flawed.

Unable to provide comment as no clarification given as to which elements of the Sustainability Appraisal are fundamentally flawed. Appendix 1 of the Sustainability Appraisal Report records how the Environmental Assessment of Plans and Programmes (EAPP) Regulations (Northern Ireland) 2004 are being complied with.

HED would welcome if both they and Northern Ireland Environment Agency (NIEA) could be reflected in the list of abbreviations as both provide comment and advice in relation to matters of Cultural Heritage including archaeological and architectural heritage.

The comments are noted but Council consider that this does not affect the soundness of the Plan. The wording will be amended in future reports to reflect the comments.

265

Chapter 7 Draft Plan Strategy Counter Representations

Draft Plan Strategy - Counter Representations

266

a) Adding a site specific policy to the development plan document; or

Purpose of this chapter 7.1

This is a brief synopsis of the responses received in relation to the Mid and East Antrim Borough Council Local Development Plan (LDP) draft Plan Strategy counter representations stage, in accordance with the Statement of Community Involvement (SCI) and the Planning (Local Development Plan) Regulations (NI) 2015.

b) Altering or deleting any site specific policy in the development plan document.

7.5

The counter-representation process 7.2

7.3

7.4

The draft Plan Strategy and supporting evidence was published for public consultation over a period of eight weeks beginning on Wednesday 16 October 2019 and closing on Wednesday 11 December 2019.

Representations submitted in response to this public consultation were then subject to an eight week consultation period from 31 January 2020 to 27 March 2020 in accordance with Regulation 18 of the LDP Regulations.

Counter-representations are therefore required to relate to a site-specific policy representation and should not propose any change to the draft Plan Strategy document. This is also set out in paragraph 8.0 of the Department for Infrastructure’s Development Plan Practice Note 9.

Summary of responses received 7.6

A total of 10 counter representations were received, all but one of which had previously made representations to the draft Plan Strategy. These respondents are listed below:

Counter Representation Respondents

The Government lockdown in respect to Covid-19 was announced on 23 March taking effect from 24 March. As stated in the public notices and on the Council website, all representations were available for inspection online, with counter-representations then to be submitted online, posted or emailed. As there was no requirement to physically attend Council premises to submit a counter-representation, a decision was taken not to postpone or cancel the counter-representation consultation period as a result of the lockdown. Further, a notice was placed on the Councils website from April 2020 to December 2020 advising that where the pandemic prevented anyone making a counter-representation, they should contact the planning office.

Representation Reference Number

Name of Respondent

Submitted on behalf of

MEA-DPS-CR001

Francis Dinsmore Ltd

N/A

MEA-DPS-CR002

GM Design

Individual

MEA-DPS-CR003

Gravis Planning

Individual

MEA-DPS-CR004

Gravis Planning

Individual

In accordance with Regulation 18 of the LDP Regulations, counterrepresentations can only be made to any representation on a site-specific policy. Regulation 2 specifies that a “site specific policy” means a policy in a development plan document which identifies a site for a particular use or development. A “site specific policy representation” means any representation which seeks to change a development plan document by:

MEA-DPS-CR005

Gravis Planning

Don Rimes Pension Fund

MEA-DPS-CR006

Gravis Planning

Conway Estates Limited

MEA-DPS-CR007

Gravis Planning

Conway Estates Limited, Backus Brothers and Individuals

267

MEA-DPS-CR008

Gravis Planning

Individual

Summary of key issues raised MEA-DPS-CR009

MEA-DPS-CR010

7.7

Department for Communities – Historic Environment Division

N/A

Turley

ABO Wind Ltd

Strategic Policy SGS3 Strategic Allocation of Housing to Settlements 7.8

The 10 counter representations relate to 2 strategic policies and 5 subject policies. They cross-refer to 7 of the draft Plan Strategy representations.

All of the counter representations were received by email with 4 of them using the official Council response form. Of the 2 strategic policies and the 5 subject policies referred to in the counter representations, only strategic policy CS3 and subject policy HE1 have associated site specific designations and therefore Council consider that only Counter Representations CR009 and CR010 meet the definition of a counter representation. However, a summary of the key issues raised in all 10 counter representations is outlined below.

Figure 14 Representations

Policies/Strategies

Referenced

in

Counter

Counter representation MEA-DPS-CR002 supports comments made in representation MEA-DPS-016 with respect to there being an inadequate housing allocation for Broughshane. It also argues that site specific representations should only be considered at Local Policies Plan stage.

Counter representations MEA-DPS-CR003, MEA-DPS-CR004, MEADPS-CR005, MEA-DPS-CR006, MEA-DPS-CR007 and MEA-DPSCR008 broadly disagree with representations MEA-DPS-010, MEA-DPS049 and MEA-DPS-058 with respect to the housing allocation and are of the opinion that it is incorrect and is not in line with the Preferred Options Paper. It is stated that SGS3 is unsound as it is not flexible and not based on robust evidence.

Strategic Policy CS3 Areas of Constraint on High Structures 7.9

8 7

Counter representation MEA-DPS-CR010 in relation to this Strategic policy disagrees with representation MEA-DPS-058 that supports the introduction of any Area of Constraint on High Structures and any further extension of such areas. It is of the respondent’s opinion that suitable protection is already afforded to Special Protection Areas (SPAs) and Protected Species under existing Legislation.

6 5

Policies ECD2 Retention of Economic Development Land and ECD3 Development incompatible with Economic Development Uses

4 3 2

7.10

1 0 SGS3

ECD2

ECD3

HOU5

HOU7

HE1

CS3

Counter representation MEA-DPS-CR001 in relation to ECD2 and ECD3 disagrees with representation MEA-DPS-025 relating to a specific site in Kells and Connor used for industrial purposes could be re-used for housing. The counter representation argues that such re-use would go against Council’s Economic Policies. The assertion in the original representation that if an industrial/employment site does not sell within 6 268

months it is therefore deemed unsuitable for that use, is disputed by the respondent, with a period of 3 years suggested as more appropriate.

Policy HE1 Archaeological Remains and their Settings 7.13

Counter representation MEA-DPS-CR009 in relation to this policy disagrees with the argument made in representation MEA-DPS-076 that the extension to the Knockdhu Area of Significant Archaeological Interest (ASAI) has not been founded on sound evidence and explains the process of how it was designated and how the evidence was used in the determination to extend the existing ASAI.

7.14

A full copy of all the representations submitted as part of the counter representation process, alongside this summary report, will form part of the submission of the draft Plan Strategy to be considered appropriate as part of the future independent examination

Policy HOU5 Affordable Housing in Settlements 7.11

Counter representations MEA-DPS-CR003, MEA-DPS-CR004, MEADPS-CR005, MEA-DPS-CR006, MEA-DPS-CR007 and MEA-DPSCR008 in relation to HOU5 disagree with representation MEA-DPS-049 that supports a threshold approach and that a threshold for Affordable Housing should only be applied to major applications. These counter representations argue that the thresholds proposed through the representations are too low and would make a site unviable whilst reducing the number of smaller scale developments. Furthermore, there was disagreement with comments made on Planning Agreements as set out in Section 76 of the Planning Act (NI) 2011 and whether they are an appropriate means to secure Affordable Housing. These counter representations go on to argue that Section 76 Planning Agreements are onerous and time consuming and can increase the timelines for the delivery of housing and that planning conditions would be more appropriate for Affordable Housing. They also state that HOU5 is unsound as it is not flexible and not based on robust evidence.

Policy HOU7 Adaptable and Accessible Homes 7.12

Counter representations MEA-DPS-CR003, MEA-DPS-CR004, MEADPS-CR005, MEA-DPS-CR006, MEA-DPS-CR007 and MEA-DPSCR008 outlined how they agree with representations MEA-DPS-010 and MEA-DPS-049 that supported Lifetime Homes but stated they shouldn’t be a planning requirement especially in all homes. The counter representations noted that this has been abolished in England. These counter representations argue that the policy is somewhat different from the Preferred Options Paper and there is no evidence provided as to why it should be a requirement in all homes. The counter representations also made the point that the policy could restrict the regeneration of brownfield sites. They also state that HOU7 is unsound as it is not based on a robust evidence base, the mechanism for monitoring is not clear and the policy should be removed.

269

Appendices

270

Appendix 1 - Respondents to the Draft Plan Strategy

Reference

Respondent

MEA-DPS-001 MEA-DPS-002 MEA-DPS-003 MEA-DPS-004 MEA-DPS-005

MEA-DPS-006

On behalf of

Reference

Respondent

On behalf of

Antrim and Newtownabbey Borough Council

MEA-DPS-016

Ferguson Planning

Individual

Belfast City Council

MEA-DPS-017

FP McCann

Causeway Coast and Glens Borough Council Causeway Coast and Glens Heritage Trust Co-Ownership Housing Association Limited Department of Agriculture Environment and Rural Affairs Natural Environment Division

MEA-DPS-018 MEA-DPS-019 MEA-DPS-020

Jobling Planning and Environment Ltd Jobling Planning and Environment Ltd Jobling Planning and Environment Ltd

MEA-DPS-021

Glenarm Visitor Information Centre

Individual Individual Individual

MEA-DPS-007

Individual

MEA-DPS-022

GM Design Associates Ltd

Individual

MEA-DPS-008

Department for Communities Historic Environment Division

MEA-DPS-023

Gravis Planning

Conway Estates Ltd

MEA-DPS-009

Department for the Economy

MEA-DPS-024

Gravis Planning

Conway Estates Ltd and Individual

MEA-DPS-010

Department for Infrastructure

MEA-DPS-025

Gravis Planning

Individual

MEA-DPS-011

Department of Justice

MEA-DPS-026

Gravis Planning

EP UK Investments

MEA-DPS-012

Donaldson Planning

Ballymena Development Consortium

MEA-DPS-027

Gravis Planning

Individual

MEA-DPS-013

Donaldson Planning

Individual

MEA-DPS-028

Gravis Planning

Individual

MEA-DPS-014

Donaldson Planning

Individual

MEA-DPS-029

Gravis Planning

Individual

MEA-DPS-015

Farrans Construction Ltd

MEA-DPS-030

Gravis Planning

Don Rimes Pension Fund 271

Reference

Respondent

MEA-DPS-031

Individual

MEA-DPS-032

Inaltus

MEA-DPS-033

On behalf of

Reference

Respondent

MEA-DPS-046

Ministerial Advisory Group

Alexander Property Holdings

MEA-DPS-047

Individual

Inaltus

Bridge Park Development Ltd

MEA-DPS-048

Mineral Products Association Northern Ireland

MEA-DPS-034

Inaltus

Galgorm Group

MEA-DPS-049

Northern Ireland Housing Executive

MEA-DPS-035

Inaltus

Galgorm Properties

MEA-DPS-050

Northern Ireland Renewables Industry Group

MEA-DPS-036

Inaltus

Individual

MEA-DPS-051

Northern Ireland Water

MEA-DPS-037

Inaltus

N.K. Holdings Ltd

MEA-DPS-052

Northern Health and Social Care Trust

MEA-DPS-038

Invest NI

MEA-DPS-053

O'Connor Kennedy Turtle

Individual

MEA-DPS-039

Irish Salt Mining & Exploration Co. Ltd

MEA-DPS-054

O'Connor Kennedy Turtle

Individual

MEA-DPS-040

James Stevenson Quarries Ltd

MEA-DPS-055

Pragma Planning

Carnlough Dev Ltd

MEA-DPS-041

Lightsource BP

MEA-DPS-056

Quarry Plan

MEA-DPS-042

Individual

MEA-DPS-057

RPS Group

MEA-DPS-043

MBA Planning

MEA-DPS-058

Royal Society for the Protection of Birds

MEA-DPS-044

Individual

MEA-DPS-059

Scottish Power Renewables

MEA-DPS-045

Mid Ulster District Council

MEA-DPS-060

SONI

CYM Properties

On behalf of

Northern Ireland Electricity Networks

272

Reference

Respondent

MEA-DPS-061

Individual

MEA-DPS-062

TC Town Planning

MEA-DPS-063

Translink

MEA-DPS-064

TSA Planning

On behalf of

Individual

Individual

MEA-DPS-065

TSA Planning

Individual

MEA-DPS-066

TSA Planning

Lotus Homes

MEA-DPS-067

TSA Planning

Rosemount Homes

MEA-DPS-068

TSA Planning

Silverwood Business Park Ltd

MEA-DPS-069

Turley

ABO Wind (NI) Ltd

MEA-DPS-070

Turley

MEA-DPS-071

Turley

MEA-DPS-072

Turley

Clear Channel

MEA-DPS-073

Turley

Hagan Homes

MEA-DPS-074

Turley

Herron Bros

Turley

Northern Ireland Federation of Housing Associations

MEA-DPS-075

Reference

Respondent

On behalf of

MEA-DPS-076

Turley

RES

MEA-DPS-077

Turley

Vaughan Homes

MEA-DPS-078

Wardell Armstrong LLP

The Crown Estate

MEA-DPS-079

White Young Green

Individual

MEA-DPS-080

Department of Agriculture Environment and Rural Affairs Natural Environment Division - SEA Team

Antrim Construction Company Clanmil Housing Group

273

Appendix 2 - Draft Plan Strategy Events Event Types

Location

Date

Draft Plan Strategy Launch

The Braid, Ballymena Town Hall

17 September 2019

Public Event - Afternoon Session

The Braid, Ballymena Town Hall

25 September 2019

Public Event - Evening Session

The Braid, Ballymena Town Hall

25 September 2019

Public Event - Afternoon Session

Larne Town Hall

30 September 2019

Public Event - Evening Session

Larne Town Hall

30 September 2019

Public Event - Afternoon Session

Carrickfergus Town Hall

8 October 2019

Public Event - Evening Session

Carrickfergus Town Hall

8 October 2019

Public Drop-In

Portglenone Community Centre

16 October 2019

Public Drop-In

Gobbins Visitor Centre, Islandmagee

22 October 2019

Public Drop-In

Glenlough Community Centre, Carnlough

24 October 2019

Planning Agents Event

County Hall, Ballymena

21 October 2019

Development Plan Working Group Meeting

Belfast City Council Offices

28 October 2019

The Antrim Coast and Glens AONB Management Forum Meeting

Ballygalley Community Hall

5 November 2019

Mid and East Antrim Planning staff (Development Management and Enforcement) Department for Infrastructure

County Hall, Ballymena

14 November 2019

County Hall, Ballymena

26 November 2019

Minerals Operators Draft Plan Strategy Public Meeting

The Braid, Ballymena

29 November 2019

Mid and East Antrim Community Planning Strategic Alliance and Community Panel Metropolitan Area Spatial Working Group

Showgrounds, Ballymena

3 December 2019

The Braid, Ballymena

10 December 2019

274

Appendix 3 - Documents available during consultation period

Location Planning Office, County Hall Ballymena

Documents available during consultation period  

  

Draft Plan Strategy and district proposals maps Sustainability Appraisal of the draft Plan Strategy (incorporating Strategic Environmental Assessment Sustainability Appraisal Report) Sustainability Appraisal of the draft Plan Strategy Scoping Report Sustainability Appraisal of the draft Plan Strategy (incorporating Strategic Environmental Assessment) Nontechnical Summary Draft Habitats Regulations Assessment (dHRA) Report of the draft Plan Strategy Draft Equality (Section 75) Screening Report of the draft Plan Strategy Rural Needs Impact Assessment of the draft Plan Strategy 13 technical supplements and associated appendices Draft Plan Strategy and district proposals maps Sustainability Appraisal of the draft Plan Strategy (incorporating Strategic Environmental Assessment0 Sustainability Appraisal Report Sustainability Appraisal of the draft Plan Strategy Scoping Report Sustainability Appraisal of the draft Plan Strategy (incorporating Strategic Environmental Assessment) Nontechnical Summary Draft Habitats Regulations Assessment (dHRA) Report of the draft Plan Strategy Draft Equality (Section 75) Screening Report of the draft Plan Strategy Rural Needs Impact Assessment of the draft Plan Strategy

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Draft Plan Strategy and district proposals maps

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Draft Equality (Section 75) Screening Report of the draft Plan Strategy

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Draft Plan Strategy and district proposals maps

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The Braid, Ballymena Smiley Buildings, Larne Civic Buildings, Carrickfergus

Ardeevin, Ballymena Ballymena Library

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Kells/Connor Library Broughshane Library Carnlough Library Carrickfergus Library Greenisland Library Whitehead Library Portglenone Library Larne Library 275

Appendix 4 - Equality Monitoring of Attendees at Consultation Events In addition to the 96 people who attended the launch of the draft Plan Strategy, 49 people then attended the public consultation events. Of those 49 people, 32 submitted an Equality Monitoring Form.

Age This question was answered by 31 respondents (97%) 100 87%

90 80 70

Of the respondents who completed the equality monitoring form at the draft Plan Strategy Consultation events:

60

Note: Some figures are rounded and therefore may not add exactly.

40

50 27

30 20

Gender This question was answered by 32 respondents (100%)

10

13%

0

4

0

0

0 Under 16

70% 60% 50%

16-25

25-65 Number

59% 49%

51%

49%

51%

65+ %

Marital Status This question was answered by 31 respondents (97%)

41% 40%

Count

30% 20% 10% 0% Male Respondents

Female 2011 Census

Prefer not to say

2018 Mid Year*

Married or in registered civil partnership Co-habiting as if married or in registered civil partnership Single (never married or in registered civil partnership Separated, divorced or formerly in a registered civil partnership that is not dissolved Prefer not to say

22 1

Percentage % 71 3

5

16

2

6

1 31

3 100%

*Mid and East Antrim 2018 Mid-Year Population Estimates, NISRA

276

Sexual Orientation This question was answered by 32 respondents (100%)

Dependents This question was answered by 32 respondents (100%)

Is your sexual orientation towards someone of...?

Do you have dependants or caring responsibilities? If yes, which of the following caring responsibilities for family or other persons?

6% 3% A child or children 30%

An elderly person 50%

A person with a disability 20%

91% An elderly person

A different sex

Other

Same sex

A person with a disability

A child or children

*Note: of the 8 people who indicated that they have a dependent, 2 of these indicated that they had two types of dependents. This could either be two types of dependents or one person who falls within two types of dependents. The figures above take account of both answers for these 2 people

277

Disability This question was answered by 31 respondents (97%) Under the Disability Discrimination (NI) Act 1995 a disabled person is defined as a person with: “A physical or mental impairment, which has a substantial or long term adverse effect on their ability to carry out normal everyday activities”. Having read this definition, do you consider yourself to have a disability?

28%

Political Opinion This question was answered by 32 respondents (100%)

Other 6% Prefer not to say 12%

Unionist 44%

None 16%

72% Nationalist 22%

Yes

No

278

Religious Denomination

Community Background This question was answered by 32 respondents.

This question was answered by 30 respondents.

Not Protestant or Roman Catholic 9%

Sikh

Other Muslim Jewish

Prefer not to say 13%

Hindu Buddhist Prefer not to say No Religion Christian 0

10

20

30

40

50

60

70

Ethnicity

Roman Catholic Community 22%

This question was answered by 32 respondents.

Protestant Community 56%

Count White Chinese Irish Traveller Indian Pakistani Bangladeshi Black Caribbean Black African Black Other Mixed Ethnic group Other Prefer not to say

32 0 0 0 0 0 0 0 0 0 0 0 32

Percentage % 100% 0 0 0 0 0 0 0 0 0 0 0 100%

279

Local Development Plan Team Silverwood Business Park 190 Raceview Road Ballymena BT42 4HZ Tel: 028 2563 3500 planning@midandeastantrim.gov.uk www.midandeastantrim.gov.uk/planning 280