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Background

Green infrastructure is a network of multifunctional green space, which is capable of delivering a wide range of environmental and quality of life benefits for local communities. It is widely acknowledged that high quality environs with high quality green infrastructure promotes economic growth and health and wellbeing as well as increasing biodiversity and helping to mitigate against climate change.

However, a shortage of green infrastructure, particularly in the inner area and town centre compounds the public health deficit in the town. Nine out of the 21 wards in Blackpool fall significantly short of the 4 hectares per 1,000 population standard, where the open space assessment confirms that there are few opportunities for providing additional open space in the Inner Area due to the high density of development. It is important that green infrastructure is considered early on in the design process and is central to the design and layout of a development.

The Greening Blackpool SPD provides direction on the importance for new development to fully consider landscaping and green infrastructure, including open space, sports and play facilities, amenity greenspace, public art, biodiversity and trees. This document is a material consideration when assessing relevant planning applications.

Statement to support consultation on a new draft SPD

1.0 Reasons for amending the existing Greening Blackpool Supplementary Planning Document adopted May 2022

  • The council’s current Greening Blackpool SPD was adopted in May 2022
  • However, since adoption, the council has experienced a number of challenges in implementation. Regular planning agents working on behalf of developers have repeatedly commented that the requirements compromise the financial viability of development schemes. Numerous viability appraisals have been submitted to demonstrate this in respect of specific proposals. These have been considered either by independent consultants working on behalf of the council, or by experienced valuation surveyors employed within the council. In the majority of cases, it has been confirmed that the Greening Blackpool SPD requirements would either make the scheme unviable or marginally viable at best
  • Both the preparation of financial viability assessments and their review on behalf of the council incur costs, place further strain on resources and delay the determination of planning applications
  • In response to these issues, the council has undertaken a review of the implementation of the Greening Blackpool SPD to date. This review has found that some 54 applications have been liable for Greening Blackpool obligations in the two year period from 1 June 2022 to 31 May 2024. In total, these applications should have delivered around £960,000. However, between these dates only £58,000 was secured and, of this, only £16,000 has been paid. This clearly shows that the requirements of the SPD are compromising development deliverability
  • Parallel to these issues, Blackpool has seen a significant increase in the population of serviced self-contained holiday accommodation, both in the form of holiday flats and holiday houses. The Greening Blackpool SPD requirements for holiday and permanent accommodation are different, and this has also been a point of comment and concern for regular applicants and agents
  • The overwhelming need to green Blackpool and the multiple benefits that green infrastructure can provide are not disputed. However, there is an equally pressing need to ensure that Blackpool continues to attract growth and investment to deliver the town’s regeneration objectives and address long-standing issues relating to deprivation and poor-quality built form, particularly in our inner areas
  • As a result, the council has judged it appropriate to revise the Greening Blackpool SPD in order to strike a more workable balance to secure green infrastructure from development

2.0 Summary of main changes

2.1 Those familiar with the existing Greening Blackpool SPD will note that the proposed Greening Blackpool SPD is a much shorter document. The sections of supporting text have all been slimmed down to make the document as a whole more accessible and to focus on the most salient points. Biodiversity Net Gain, for example, is now a matter of national statute, and so a lengthy explanation of its merits is considered to be unnecessary. Discussion of protected species and protected landscapes has also been removed because these matters are not directly relevant to the requirements of the SPD, and because the relevant safeguards are well established in other legislation and policy. To further reduce the length of the document, and to reflect the way in which information is now presented on the council website, text duplicating relevant planning policies and sections of the national planning policy has been replaced by links to those documents.

2.2 As with the main body of the document, the appendices have also been rationalised. Appendix A of the existing SPD relates to supporting evidence which is available elsewhere on the council website as part of the evidence base to the local plan. Appendices B and D relate to national policy and legislation and biological heritage sites respectively. This information is also easily available elsewhere. Appendix E relates to submission requirements, but it is considered that this is adequately and more appropriately covered by the council’s published validation checklist.

2.3 Appendix C details trees and shrubs considered appropriate to the Blackpool area. This is useful information and the council recognises that it is used by applicants and agents. However, as our climate changes, this list is likewise likely to change. It is therefore considered more appropriate that this list be provided alongside rather than within the SPD, to enable it to be updated more easily and more frequently to reflect prevailing environmental conditions.

2.4 The key features of the requirements of the new SPD can be summarised as follows:

  • Biodiversity hierarchy – no substantive change from existing SPD - all development will be expected to demonstrate that the biodiversity hierarchy has been followed
  • Biodiversity net gain – no substantive change from existing SPD - all development must either comply with statutory biodiversity net gain requirements where they apply, or take full advantage of any opportunities to provide biodiversity net gain
  • Tree protection - no substantive change from existing SPD - it is expected that existing trees will be protected, and that any necessary loss of tree planting would be compensated for through replacement planting or payment of a tree contribution
  • New green infrastructure – new requirement - this is a new requirement that expects all developments to take the opportunities available to provide green infrastructure
  • New tree planting for residential uses – substantive change from existing SPD - this section stipulates the number of trees that different types of development would generate a requirement for. However, the requirement for new tree planting would no longer apply to change of use proposals
  • New tree planting for non-residential uses – substantive change from existing SPD - this section stipulates the number of trees that different types of development would generate a requirement for. However, the requirement for new tree planting would no longer apply to change of use proposals
  • Public open space (POS) – minor but no substantive change from existing SPD - this section now clarifies that POS contributions would only be required from developments for permanent residential uses. The amounts payable for the different sizes of dwelling have also been updated to reflect the information recorded by the 2021 Census

3.0 Justification for main changes

3.1 As set out in section 1, financial viability has proven to be a consistent challenge for developments liable for Greening Blackpool SPD obligations. In officer experience, this has most particularly been the case for change of use proposals and major scale schemes proposing a significant amount of floorspace.

3.2 Change of use applications may represent a relatively minor form of development, but they can have a very significant positive impact on the character and appearance of an area. This is certainly true within the defined Inner Area of the town where the redevelopment of a long-vacant property in a state of disrepair can lift the quality of a street, and often improve the quality of life for immediate neighbours who may have had to deal with issues of anti-social behaviour or structural decay.

3.3 The council wishes to encourage and support the redevelopment and regeneration of existing properties, and so considers it appropriate to remove the requirement for Greening Blackpool SPD obligations from change of use schemes. To help compensate for any loss of tree planting that would result, the proposed SPD would place greater emphasis on the provision of on-site greening. For example, within the densely developed inner areas of the town, the planting of a shrub or hedgerow at the front of a property would likely have a far more beneficial visual and greening impact than a tree planted off-site outside of the immediate streetscene.

3.4 It is proposed that new-build holiday accommodation continue to be liable for tree planting. This reflects the fact that holiday makers to the town benefit from the greening of the environment and also leave an environmental footprint that can be mitigated in part through provision of green infrastructure.

3.5 Holiday accommodation is not liable for public open space provision because, whilst some visitors may use local parks whilst in Blackpool, it is unlikely to be a main feature of their stay. Instead, public open space within the borough is considered to be most used and of most benefit to permanent residents.

3.6 It is recognised that financial viability may continue to be a challenge in some cases. However, the provision of financial viability appraisals as part of larger application submissions is anticipated to be less of a disproportionate burden for developers.

4.0 Next steps

4.1 The council will now consult on the proposed SPD for a period of 6 weeks. Once the consultation period has ended, the council will consider any comments made and may make amendments to the SPD if appropriate.

4.2 If no substantive objections are received to the proposed SPD, the council’s director of communications and regeneration has delegated authority to approve the SPD for adoption. If substantive objections are received, the SPD would have to be referred to the council’s executive committee for adoption.

4.2 The document will be available to view in the following locations:

  • Customer First reception, Corporation Street
  • Blackpool Central Library, Queen Street
  • Anchorsholme Library, Luton Road
  • Moor Park Library, Bristol Avenue
  • Boundary Library, Bathurst Avenue
  • Layton Library, Talbot Road
  • Revoe Library, Revoe Street
  • Palatine Library, St. Anne’s Road
  • Mereside Library, Langdale Place

4.3 The document will be available to view online

4.4 You can make comments by emailing planning@blackpool.gov.uk or via post to:

Planning department
PO Box 17
Corporation Street
Blackpool
FY1 1LZ

4.5 Comments can only be accepted in writing but, if you have any queries, you can call the development management duty line on 01253 476193.

4.6 Comments must be received by: 28 January 2025