Meeting:	Executive Member for Housing, Planning and Safer Neighbourhoods Decision Session
Meeting date:	23/09/2024
Report of:	Claire Foale, Interim Director for City Development
Portfolio of:	Cllr. M Pavlovic, Executive member for Housing, Planning and Safer Neighbourhoods.

Decision Report: Proposed reforms to the National Planning Policy Framework Consultation

Subject of Report

1. City of York Council is a Local Planning Authority and has responsibility for planning within the authority area. The Government are consulting on reforms of the National Planning Policy Framework, which sets the overarching planning framework for plan-making and decision-making. Although a consultation at this stage, should the proposals be implemented there would be implications for planning in York.

2. This report sets out the key matters outlined in the consultation for consideration and discussion with members of the Local Plan Working Group to inform the Council’s response to the consultation.

Benefits and Challenges

3. This national consultation on proposed reforms to the National Planning Policy Framework (NPPF) is open to responses until 24 September 2024. This approach allows all interested parties to submit a response to inform the national approach to planning.

4. The outcomes of this consultation, including the proposed housing numbers, are subject to change following the Government’s consideration of all consultation responses received. However, the Government are keen to enact changes quickly to align the framework with their manifesto objectives; it is therefore anticipated that changes will be enacted by the end of 2024.

5. There a number of other challenges associated with consultation and implementation of a reformed planning framework:

6. The timing of the revised NPPF and other proposed changes in relation to the adoption of York’s emerging new Local Plan, currently in the final stages of independent Examination. The transitional arrangements set out for implementing policy changes and when these take effect will be an important consideration for planning across both plan-making and decision-taking. Currently, proposed transitional arrangements are clear that the Council will be able to continue to progress positively with the ongoing Examination of the Local Plan, and subject to any issues identified through this process, will be able to move to adopt the Local Plan;

i) The documentation released includes a tracked change version of NPPF text. However, it is anticipated that further text modifications may be enacted to align with questions asked and their answers, where wording is not currently suggested. These further changes and whether they are to be consulted on is unknown.

ii) The changes may have significant resourcing impacts on planning policy and development services in York should they be implemented. Whilst the government have committed to the provision of more planning officers, the funding and the scope of this on service areas will need to be considered in further detail to inform service planning, when known.

7. There remains a commitment from Government to implement further planning reforms aligned to the Levelling Up and Regeneration Act (2023) regarding examination of Local Plans, supplementary planning documents and environmental assessment for example. We await the detail of this, including the relevant timescales for implementation and how this will dovetail with updates in the NPPF.

8. Providing a Council response to the consultation is to help the government understand the impact the proposed policy changes might have on planning and development services in York together with the impact on the emerging new Local Plan which remains in examination.

Policy Basis for Decision

9. The National Planning Policy Framework sets out the government’s planning policies for England and how these are expected to be applied. This is the principal guidance for planning authorities in planning for future development and decision-making. It is supported by a suite of Planning Practice Guidance [1], which adds further details to the requirements set out therein. It is also supported by the delivery of other development plan documents, such as Neighbourhood Plans, which have their own legislative requirements.

10. The National Planning Policy Framework was revised in response to the Levelling-up and Regeneration Bill: reforms to national planning policy consultation on 19 December 2023; this was the fifth update since it was first introduced in 2012.

11. The Government has made clear that sustained economic growth is the only route to improving the prosperity of our country and the living standards of working people. Their approach to delivering this growth focuses on three pillars: stability, investment and reform. The Chancellor’s speech on 8 July committed to consulting on reforms to the NPPF to take a different, growth-focused approach and this consultation seeks views on their proposed approach to revising the National Planning Policy Framework in order to achieve sustainable growth in the planning system. They consider that this will help to deliver their economic ambitions and their overall housing target of 1.5 million new homes.

12. The contents of this consultation supports the Council Plan and 10 year strategies where delivery is reliant on plan making and decision-taking as part of delivery. This is particularly relevant for the Economic and Climate Change Strategies.

13. It also relates to all of the administration’s key manifesto pledges regarding Affordability, Environment, Equalities and Human Rights, and Health Inequalities in so far as the consultation is consulting on all aspects of the NPPF, which covers these policy areas in varying degrees of detail. The significance of this will be determined by the enacted changes resulting from this consultation.

Financial Strategy Implications

14. There are no financial implications as result of considering or responding to this consultation.

15. Subject to the implementation of the revised NPPF following the consultation, there may be financial implications on York Council planning services. Work to scope the impact of a revised NPPF following the outcomes of this consultation will be considered in due course when these are understood.

Recommendation and Reasons

16. Recommendations for the Executive Member are:

i. To note the discussion and recommendations arising from Local Plan Working Group;

ii. To agree to submit a comprehensive response to the consultation (Annex A);

iii. To delegate authority to the Director for City Development, in conjunction with the Executive Member for Housing, Planning and Safer Neighbourhoods, for any changes and approval the final response for submission.

Reason: To allow a Council response to the Government’s consultation on Proposed Modifications to the National Planning Policy Framework by the deadline of 24 September 2024.

Background

17. The Government are seeking views on a reformed approach to the planning system. This consultation seeks to modify the National Planning Policy Framework to achieve sustainable growth in our planning system. They are also seeking views on a series of wider policy proposals in relation to increasing planning fees, local plan intervention criteria and appropriate thresholds for certain Nationally Significant Infrastructure Projects. This aligns with their drive for sustained economic growth and are stated to be vital to delivering the Government’s commitment to achieve economic growth and build 1.5 million new homes.

18. The proposed changes to the NPPF fall within several topic areas, which are detailed below. In summary, these are:

· Reverse other changes to the NPPF made in December 2023 which are considered to be detrimental to housing supply. This includes the reintroduction of mandatory standard method for assessing housing need to ensure local plans are ambitious enough to support the Government’s manifesto commitment of 1.5 million new homes during this Parliament;

· Broaden the existing definition of brownfield land, setting a strengthened expectation that applications on brownfield land will be approved and that plans should promote an uplift in density in urban areas;

· Identify grey belt land within the Green Belt, to be brought forward into the planning system through both plan and decision-making to meet development needs;

· Improve the operation of ‘the presumption’ in favour of sustainable development, including safeguards to make sure its application cannot justify poor quality development;

· Deliver affordable, well-designed homes, with new “golden rules” for land released in the Green Belt to ensure it delivers in the public interest;

· Ensure that local planning authorities are able to prioritise the types of affordable homes their communities need;

· Support economic growth in key sectors, aligned with the Government’s industrial strategy and future local growth plans

· Deliver community needs to support society and the creation of healthy places.

· Support clean energy and the environment, including through support for onshore wind and renewables.

19. It should be noted that the consultation does not cover revisions to the Neighbourhood Planning process.

Assessing housing needs

20. The Ministerial Statement[2] and proposed modifications seek to reverse changes to the NPPF made in December 2023 regarding housing land supply. This means that mandatory housing targets are reintroduced and that there remains necessary a need to show a 5 year housing supply (as opposed to a 4 years supply in specific circumstances).

21. The standard method for assessing the level of local housing need was originally introduced in 2018 and uses a formula to identify the minimum number of homes expected to be planned for based on household projections (produced by the Office for National Statistics), which are then adjusted to take account of affordability.

22. The current standard method housing need for York based on the existing formula equates to 1020 net additional homes per year.

23. This consultation proposes a new standard method that uses a baseline set at a percentage of existing housing stock levels and using a stronger affordability multiplier. The result of this new standard method would result in the requirement for 1251 net additional homes per year (see Annex B for a breakdown of this calculation).

24. This compared to the new Local Plan, currently in Examination, wherein policy requires at least 822 net additional homes per year over the Plan period.

25. The proposed new standard method for housing results in an increased housing requirement of 429 net additional homes compared to the Local Plan requirement of 822 homes, or an increase of 52.19%.

26. In the context of the new Local Plan, it should be noted that planned delivery of our site allocations will currently result in an oversupply of housing against our average housing target given we have identified strategic sites which will continue to deliver post plan period. This may lessen the overall uplift required to be implemented.

27. Additionally, the requirement for a 5% buffer to be added to 5 year housing land supply (YHLS) is required for plan-making and decision-taking. This rises to 20% should an authority not meet 75% of its requirement as demonstrated in the Housing Delivery Test. For York, currently, a 20% buffer would be required raising the annual target to 1501 dwellings.

28. The proposals also remove the ability to ‘fix’ the 5 YHLS for a year through the release of an annual position statement. The implication being that authorities’ will need to continually demonstrate a 5 YHLS of specific, deliverable sites for housing.

29. Additionally, the proposals seek to remove the wording on past oversupply in paragraph 77, which was introduced to set out that previous over-supply could be set against upcoming supply. Given the chronic need for housing the government consider that strong delivery records should be celebrated without diluting future ambitions.

Brownfield land, grey belt and the Green Belt

30. The revisions to the NPPF will require a local planning authority undertakes a Green Belt review where they cannot meet their identified housing, commercial or other need without altering Green Belt boundaries.

31. A sequential approach is proposed to the release of Green Belt land for development. This starts with the consideration of Previously Developed Land (PDL) and to assist in this para.154 of the NPPF is to be amended to allow for the redevelopment of PDL with the only restriction being that it should not cause substantial harm to the openness of the Green Belt. The consultation further asks whether the definition of PDL in the glossary of the NPPF should be revised to include hardstanding and glasshouses.

32. Following the consideration of PDL in the Green Belt, attention would turn to land defined as grey belt. The proposed definition of grey belt[3] is:

‘For the purposes of Plan-making and decision-making, grey belt is defined as land in the Green Belt comprising Previously Developed Land and any other parcels and/or areas of Green Belt land that make a limited contribution to the five Green Belt purposes (as defined in para 140 of this Framework) but excluding those areas or assets of particular importance listed in footnote 7 of this Framework (other than land designated as Green Belt).’

33. The consultation goes on to explain that land which makes a limited contribution to Green Belt purposes will:

a) Not strongly perform against any Green Belt purpose; and

b) Have at least one of the following features:

i. Land containing substantial built development or which is fully enclosed by built form

ii. Land which makes no or very little contribution to preventing neighbouring towns from merging into one another

iii. Land which is dominated by urban land uses, including physical developments

34. Land which contributes little to preserving the setting and special character of historic towns

35. Finally, once PDL and grey belt land have been considered, higher performing Green Belt sites, where these can be made sustainable, should be assessed.

36. The aim of the approach is to ensure that low quality Green Belt is identified first, while not restricting development of specific opportunities which could be made more sustainable. While it is made clear that local planning authorities should meet their development needs in full, the release of land should not be supported where doing so would fundamentally undermine the function of the Green Belt across the area of the plan.

37. While it is intended that Green Belt release takes place through the plan making process, the consultation recognises this will take time. In the short term, to support housing delivery, changes are proposed to support the release of Green Belt land through development management. This is detailed in a new paragraph 152 which identifies that housing and other development in the Green Belt is not inappropriate where it utilises grey belt in sustainable locations; and the authority cannot demonstrate a five year housing land supply, or failed the housing delivery test over the previous 3 years, or where there was a demonstrable need for land to be released for development of local, regional or national importance.

38. Where land is released from the Green Belt, either as PDL, grey belt or Green Belt, then development will have to comply with the golden rules as set out in new paragraph 155. These apply only to major development and require that:

· Housing schemes provide at least 50% affordable housing with an appropriate proportion being Social Rent, and subject to viability;

· Necessary improvements to local or national infrastructure are made; and

· The provision of new, or improvements to existing, local green spaces that are accessible to the public.

39. Implications for York of this approach include reviewing the entirety of the York Green Belt to evaluate it based on the proposed sequential approach criteria. Our response highlights this and the importance of transitional arrangements for authorities who have recently set their Green Belt boundaries to provide a degree of permanence (as expected through our emerging Local Plan for primarily the purpose of ‘preserving the setting and special character of historic towns’). It is suggested that these transitional arrangements should be made more clear.

Gypsies and Travellers

40. Proposed changes to support the release of Green Belt land are intended to address unmet needs for traveller sites. The exceptional circumstances under which Green Belt boundaries can be altered during the preparation or review of plans are now defined and include instances where an authority cannot meet its identified need for housing through other means, unless such alterations would undermine the function of the Green Belt across the plan area.

41. The sequential approach to Green Belt release, explained above, would apply and would allow for housing in the Green Belt to be not inappropriate where it utilised grey belt in sustainable locations; and the authority could not demonstrate a five year housing land supply, or failed the housing delivery test over the previous 3 years, or where there was a demonstrable need for land to be released for development of local, regional or national importance. The ‘golden rules’ would apply. The consultation asks for views on how the assessment of need for traveller sites should be approached to determine whether a Green Belt review is required.

42. Our proposed response draws upon our experience through the Local Plan process of identifying suitable sites and the ability this proposed amendment would make to site delivery.

Viability

43. A new Annex 4 is proposed to the NPPF to clarify issues around viability in relation to Green Belt release and the golden rules. It suggests a national policy basis for adopting an Existing Use Value of the land plus a ‘reasonable and proportionate premium’ for the landowner when calculating benchmark land values (BLV) as part of a viability assessment. Locally set BLVs would then be informed by Local Plan policies. Where land transacted at a price above the nationally set BLV, it should then be assumed to be viable.

Housing mix

44. Changes are proposed to ensure that development provides the most appropriate mix of housing. This includes specifically socially rented housing within the mix of affordable housing and in accordance with identified local needs. Sites should contain a mix of tenures including ownership and rental as well as housing for specific groups.

45. The removal of the requirement to deliver 10% of housing on major sites as affordable home ownership. LAs are advised that this should be seen as an expectation to deliver a locally specific mix. The consultation also asks why insufficient small sites are being allocated and how this issue might be solved.

46. Our proposed response draws upon our experience of affordable housing delivery and negotiations experienced through the planning process as well as our understanding of desired tenures.

Strategic and regional planning

47. Issues such as meeting housing needs (including neighbours’ unmet needs), strategic infrastructure and climate resilience are areas which are specifically identified to be addressed through the duty to cooperate. Para.24 is amended to address this and notes that effective strategic planning across boundaries will play a vital and increasing role in how sustainable growth is delivered.

48. New para.27 then makes clear that once the matters of collaboration have been identified, strategic policy makers should ensure that their plan policies are consistent with others where a strategic relationship exists unless there is a clear justification to the contrary.

49. The consultation notes that the Duty to Cooperate requirement is to be strengthened but also that short term measures to strengthen cross-boundary strategic planning will be introduced. New legislation will subsequently introduce formal strategic planning mechanisms with the intention to move to a model of universal strategic planning covering functional economic areas within this parliament. The model will support elected Mayors in overseeing the development and agreement of Spatial Development Strategies.

50. No further detail has been provided of the form of the Spatial Development Strategies but is expected to be released as part further guidance.

51. Consideration in the response has been given to the existing role of combined authority and geographical extent implications of this locally. It is considered that there may be opportunities associated with this approach to work with North Yorkshire Council and the MCA to ensure our planning approach and evidence based align.

Local Plan Production

52. Plans at examination will continue to be examined under the version of the NPPF they were submitted under. However, as is the case in York, if the revised Local Housing Need (LHN) figure is more than 200 dwellings per annum higher than the annual housing requirement set out in the adopted version of the plan, upon introduction of the new plan-making system, the local planning authority will be required to begin preparation of a plan under the new system as soon as possible, or in line with any subsequent arrangements set out to manage the roll-out of the new system.

53. It is the intention to implement the new plan-making system as set out in the Levelling- up and Regeneration Act from summer or autumn 2025.

Design and character

54. Chapter 12 maintains the primacy of the National Model Design Code and support for design codes, in areas that provide the greatest opportunities for change, such as allocated sites. Reflecting the wider aspiration to drive housing and economic growth, there is an acknowledgement that design codes should also consider where, and in what circumstances, higher density development could be encouraged.

55. Removal of the references to ‘beauty’ and ‘beautiful’ (which is considered subjective), instead focusing on well-designed buildings and places.

Building a modern economy

56. The proposed change to para 86b now mandates local plans to set criteria and identify strategic sites for local and inward investment, where previously they were only required to do one or the other. This includes for the first time a requirement to plan and provide land to accommodate a range of commercial development which meets the need of the ‘modern economy’ (also enacted in changes to para 87): Laboratories, Gigafactories, Data Centres, Digital Infrastructure and Freight/Logistics.

57. In our response we are drawing on our evidence and Economic Strategy to inform the response to ensure that the Government’s approach to the ‘modern economy’ is able to reflect our local ambitions.

Presumption in favour of sustainable development

58. Changes seek to strengthen the ‘presumption in favour of sustainable development’ to engage the tilted balance where the supply of housing has not been met, subject to existing protections or safeguarded areas. This changes the current focus which is to engage the presumption where plan policies are not up-to-date.

59. Changes to para 11d, which include clarification both of the policies relevant to decision taking and to those in the Framework, seek to ensure that planning permissions are only granted where high standards are met; these are safeguards to ensure only high-quality schemes benefit from the presumption.

Supporting Renewable Development

60. The changes give emphasis and support for all forms of renewable and low carbon development:

· New para 161 b) mandates Local Authorities to identify in their Local Plans suitable areas for renewable and low carbon energy sources, and supporting infrastructure where this would help secure the development (removing the prior ‘consider identifying’ phrase).

· Para 164 guides LPAs to support planning applications for all forms of renewable and low carbon development and, at part a) significant weight should be given to the proposal’s contribution to renewable energy generation and a net zero future.

Changes to Planning Fees

61. The proposals seek to address the funding shortfall experienced by many Local Authorities by:

· Proposing a fee increase for householder applications to £528 (from £258) to meet cost recovery levels (and seeking views on whether a smaller increase to the householder fee (e.g. 50% increase) would be more appropriate).

· Seeking views on increasing fees for other application types such as prior approval and S73 applications.

· Introducing fees for applications with no fee at the moment such as demolition consent in a conservation area and Listed Building Consent.

62. There is also the potential for a locally set fee and two different models are suggested for how this might be calculated.

63. The proposed response supports the uplift in fees for planning applications and the ability for cost recovery.

Sustainable Transport

64. The consultation proposes a move to set a vision for how we want places to be, and designing the transport and behavioural interventions to help achieve this vision. This approach is known as ‘vision-led’ transport planning and, unlike the existing ‘predict and provide’ approach, it focuses on the outcomes desired, and planning for achieving them. To support this, the consultation proposes to make amendments to paragraphs 114 and 115 of the existing NPPF. To support the implementation of this updated policy, further guidance alongside the policy coming into effect would be published.

65. Our response welcomes this approach as it is aligned with York’s emerging Local Transport Strategy.

Consultation Analysis

66. Given the NPPF covers different technical topic areas, an internal officer workshop was undertaken to inform a council response including officers from Strategic Planning Policy, Development Services, Design and Conservation, Housing, Health, Carbon reduction and Transport.

67. Consultation has also taken place with the Leader of the Council, the Executive Member for Housing, Planning and Safer Neighbourhoods and the Chief Operating Officer of the Council as required by Appendix 1 of the Constitution.

68. Officers are also attending a suite of national workshops run by the Planning Advisory Service and MHCLG (up to 18 September) wherein they are presenting on the proposed planning reforms and allowing discussion with colleagues from other authorities. This will help better understand and respond to the current consultation.

69. The consultation was also presented to Local Plan Working Group on 10 September 2024 under ‘urgent business’ for cross party discussion (Annex C). Members were invited to provide comments, both during the meeting, and separately by 12 September, to inform the council’s response to government. In summary these were:

· Planning fees should be uplifted to reflect cost recovery of the planning services;

· The green belt purposes should recognise additional criteria for enhancing nature and providing resilience, particularly for flooding

· As well as mixed tenure, housing should consider lifecycle tenures, for example, family homes, single homes, homes adapted for independent living etc.

· The scale of further development should be self-sustaining to ensure the delivery of necessary facilities and infrastructure, for example schools, health facilities, etc.

· Healthy communities should consider safety (such as make space for girls) as well as accessible and inclusive developments that encourage social connection and wellbeing

· Language should be defined to avoid value-judgments.

· Proposals put challenge back to Local Planning Authorities but it should be clear on the government responsibilities, for example who is funding the infrastructure, particularly health and transport connections

· Be clear on developer responsibilities, particularly timescales for fulfilling allocations and progressing developments to completion.

· When considering grey belt criteria, also consider the grey belt’s relationship to biodiversity and nature corridors

· Development should be plan-led; There is a risk between both the transition arrangements and and uplift in proposed housing requirements, including that there is no ceiling on housing numbers, that there will be unplanned and unsustainable growth

· More generally, a consultation held over the summer break is difficult to respond to and the government are asked to consider the best time to hold a consultation of this importance; this does not represent best practice for engagement.

70. One public speaker addressed LPWG regarding the NPPF reform, requesting that student blocks are not counted as ‘homes’ in the reporting of housing monitoring statistics. In their view, flats and rooms in student blocks counted as homes skews the reporting market housing delivery.

71. The government is inviting comment from all interested parties who can submit a response directly to government by 24 September 2024. Details of how to submit a response is set out in the Government’s consultation material[4].

Options Analysis and Evidential Basis

72. Option considered for this report were:

(i) To submit a Council response to the national consultation;

(ii) To not submit a Council response to the national consultation;

(iii) To submit the response proposed as drafted by officers without amendment at Annex A;

(iv) To amend the response proposed at Annex A.

73. Submitting a response to the consultation will help inform the Government’s approach to modifying the NPPF and sets out the Council’s understanding of the proposed changes, both in support and objection where necessary. Option (i) has therefore been recommended.

74. The government will review local responses in respect of changes to local housing need and growth expectation, and alongside this, multiple responses about wider issues. The Member is advised that their comments will not necessarily be included in the final NPPF.

75. Whilst technical officers from across the council have compiled a response to the consultation, there may be further considerations arising from discussion at the meeting. Option (iv) is therefore recommended to allow modifications as a result of the Executive Members consideration of any discussion.

Organisational Impact and Implications

76. It is important to note that the proposed reforms to the NPPF and associated reforms to the planning system, if implemented in their current form, will likely have a very significant impact on City of York Council’s Planning Services.

77. With regard to the Development Management service, the key issue is that proposals would likely to lead to an increase in the number and complexity of speculative planning applications and planning appeals, which has resource and cost implications as a result of the increased housing requirement and in advance of further Green Belt Assessment.

78. With regard to the Strategic Planning Policy Service, whilst it is considered unlikely that the proposals place a significant risk to the timeframe for the adoption of the current draft Local Plan (currently at examination), as a result of the proposed transitional arrangements there is a significant risk to the Council that it would need to progress a Local Plan review at the earliest opportunity, which has significant resource and cost implications.

79. Financial: There cost of submitting a response to the consultation can be funded from within current budgets.

80. Human Resources (HR): There are no direct implications arising from submitting a response. Scoping of potential resource impacts a result of implementation of the proposals is noted.

81. Legal: As this is a consultation, there are no direct legal implications arising from this report.

82. Procurement: There are no implications arising from submitting a consultation response.

83. Health and Wellbeing: Public health have been engaged with this process as part of the partnership response. There is a long term implication in planning policy which should have a positive impact on the health and wellbeing of residents via mitigation in the planning cycle. Submitting a response as a council is a positive and pragmatic approach.

84. Environment and Climate action: The environmental implications of the proposed changes to NPPF are considered within the body of the report.

85. Affordability: Subject to the outcomes of this consultation, there may be clear positive impacts on affordable housing delivery under the proposals.

86. Equalities and Human Rights: This is a consultation response only and therefore a full EIA has not been completed.

87. Data Protection and Privacy: The data protection impact assessment (DPIAs) screening questions were completed for the recommendations and options in this report and as there is no personal, special categories or criminal offence data being processed to set these out, there is no requirement to complete a DPIA at this time. However, this will be reviewed following the approved recommendations and options from this report and a DPIA completed if required.

88. Communications: We note that this could receive some press interest due to the broader issues related to this consultation, particularly around the size of York as a city and the potential growth expected by the government. We also note there is a suggested motion for full council, which would involve further interest.

89. Economy: The Local Plan and Government Planning Policy are fundamental to the city’s economy, and it is therefore vital that York responds to the consultation. While much of the focus will be on housing targets, the continued provision of employment land and the protection of existing employment sites are highlighted in the York Economic Strategy.

Risks and Mitigations

90. There are no risks anticipated with responding to this national consultation on proposed reform to planning.

91. There is the risk that by not responding, York’s views will not be taken into account in the government’s final considerations.

92. There are risks associated with the proposed revisions in the NPPF itself. Where appropriate, these will be highlighted in the consultation response to government.

Wards Impacted

93. All wards would be potentially impacted by revised requirements set out in the planning reforms.

Contact details

For further information please contact the authors of this Decision Report.

Author

Name:	Alison Cooke
Job Title:	Head of Strategic Planning Policy
Service Area:	Strategic Planning Policy, City Development
Telephone:	01904 551467
Report approved:	Yes
Date:	06/09/2024

Co-author

Name:	Becky Eades
Job Title:	Head of Planning and Development Services
Service Area:	Development Services, Directorate for Transport, Planning and Environment
Telephone:	01904 551627
Report approved:	Yes
Date:	06/09/2024