NOT TO BE PRINTED_Draft Final TAAP comments duly

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Mr Neil Stott Keystone Development Trust Thetford 30 30.08 Comment Mr Neil Stott Keystone Development Trust Thetford 30 30.08 Comment Breckland Council has recently completed an Infrastructure project prioritisation process through a document known as the Breckland Integrated Delivery Document (BIDD). This process meets the requirements of the HCA and EEDA and identifies those projects critical to the successful and sustainable delivery of the growth and regeneration agenda. A specific package of projects was assessed for Thetford as part of this process. The BIDD was referential to the existing Breckland Infrastructure Study (2009) which idenitified infrastructure as being critical, essential or desirable. There has to be a realism that development is unlikely to fund everything and this will require two steps to be taken (as already identifed in the TAAP at While we are encouraged by the apparent intent set out in the paragraph 30.9). Firstly, it requires agreement/understanding of (TAAP), we have concerns that the above principles could be lost as what is critical and essential infrastructure in a Thetford context individual projects and pieces of development are taken forwards. and negotiating these with developers. . With the inevitable pressure from developers to minimise their contributions through S106 or a CIL, we see a risk that the total The key infrastructure necessary to make the development money raised being lower than anticipated, and that the community happen (transport, water, energy) is non-negotiable but there will infrastructure projects will be relegated to ‘nice-to-haves' in favour of be many policy requirements of the Council and local priorities grander scale infrastructure projects such as A11 junction that will need to be negotiated. The second step is to identify improvements. The following is an excerpt from our publication those mechanism which will deliver desirable and additional Learning From The Past? Building community in new towns, growth infrastructure. The TAAP identifies Tax Incremental Financing areas and new communities. (Keystone Development Trust, and Local Asset Backed Vehicles as two examples from the Thetford, 2009) Developing appropriate community infrastructure is Government's Local Growth White Paper (2010) which could be perceived as an essential ingredient in achieving vibrant, cohesive used by the public sector to bridge infrastructure funding gaps. and sustainable communities. Community infrastructure combines It would be inappropriate for the TAAP to provide detail on which people, places and property. Place and property provide the physical mechanisms and how they will be implemented but it can opportunities/limitations to community activity, people (community provide the outline of alternative funding sources to developer champions, activists, dedicated staff) provide the initiative, leadership contributions and expertise; No change Place has an important impact on community infrastructure as it physically provides/ constrains community activity through available space to develop community building etc. The socio-economics of place also influences the availability of time & resources, emergence of community champions & the levels of inter community cooperation or conflict. Although community activity can exist without community ‘property', there is a symbiotic relationship between the amount of dedicated community space & the ability of communities to develop & deliver appropriate services. We believe that this document, plus the recent Joseph Rowntree Foundation Briefing Paper have useful contributions to make to the future of Thetford with regard to the key points mentioned. The motivation and empowerment of local people to engage & develop community infrastructure is integral to any successful place. This can be enhanced/ constrained by the above & the actions of public, private & third sector organisations. Supportive frameworks include access to expertise such as community development staff, access to resources for example in kind or grant & a participatory approach to civic governance. Comments noted. It is likely that further reforms to the Planning System as a consequence of the Localism Act will result in greater empowerment of local people. This could be through the Community Infrastructure Levy and possible proportions of the Levy going to Neighbourhood funds or through future Neighbourhood Plans or Development Orders to deliver specific parts of the TAAP. No change
Mr Stephen Faulkner Mr Neil Stott Norfolk County Council Norwich 30 30.08 Comment Keystone Development Trust Thetford 30 30.09 Comment Chisman Gary Highways Agency Bedford 30 30.15 Comment Chisman Gary Highways Agency Bedford 30 30.16 Comment Ian Poole Mr Neil Stott St Edmundsbury Borough Council Bury St Edmunds 30 Delivery Comment Keystone Development Trust Thetford 30 Table 30.1 Comment NCC comments made in Nov2010 suggested the need for a specific planning obligations and/or Community Infrastructure Levy (CIL) policy to be included in the TAAP. While the latest version of the TAAP does not include such a policy, it is recognised that the "Delivery" section of the Plan refers, not only to the Integrated Delivery Programme (IDP) and Local Investment Plan (LIP), but also to developer funding as a means of bringing forward necessary infrastructure. This section specifically refers to the potential use of both planning obligations and CIL, which is welcomed. There are, however, some detailed amendments needed to this section on Core Policies 4 and 5 of the adopted Core Strategy set out the Delivery, particularly in relation to paragraph 30.8 and reference to policy framework for delivering strategic infrastructure and CIL. This paragraph should be amended in light of the Government's developer obligations. As the Core Strategy applies to Thetford commitment to continue with CIL (i.e. delete reference to successor it seems unnecessary to repeat adopted policy in another DPD. tariff arrangements). Notwithstanding the above comments it is felt However, Breckland Council is keen to work with the County that an over-arching Policy on Infrastructure Provision delivery Council on the Infrastructure Delivery Programme for the TAAP through developer-funding would give the TAAP more weight in and ensuring that the best potential for CIL is reflected in the Amend paragraph 30.8 to remove terms of any future CIL Charging Schedule, or negotiation on any subsequent document. S106 agreements. reference to successor tariffs. There is reference in paragraph 30.9 (p115) to creation of Local Asset Backed Vehicle when Keystone is already in place as just that form of organisation which was established by key partners, Breckland and Norfolk County Councils, and has demonstrated its capacity to deliver projects from earned income built on strategic investment and revenue from core assets. It is noted that the Infrastructure Delivery Programme document is awaited. The Highways Agency should be fully engaged in this process to ensure the document meets with the Highways Agency's requirements. A Local Asset Backed Vehicle in the context of paragraph 30.9 of the TAAP is envisaged as public-private partnership between local authorities and an investment/construction company who will match publicly owned assets with private equity to bring forward key development and regeneration opportunities. Profits from the Vehicle would be divided 50/50 between the public sector and the private sector with public sector profit then capable of being reinvested. No change Comments noted. A draft of the Infrastructure Delivery Programme will be circulated in advance of the next iteration of the TAAP and this process will include the Highways Agency Circulate draft Infrastructure Delivery Programme to the Highways Agency. The HA should be consulted on the scheme costs to ensure that these are DfT WebTAG compliant and meet all of the HA's requirements including optimism bias & future maintenance costs. The costs outlined in the TAAP for transport schemes seem quite low.Clarification is required about whether the approximate third of £64.3million (circa £21 million), as per paragraphs 30.16 & 30.17, is expected to cover all the A11 junction improvements & sustainable transport measures. The Breckland Infrastructure Study, EDAW 2009, identified a series of transport improvements totalling £22.6 million.This included £1 million for ‘A11 access improvements from Comments noted. Revisions to costs will be addressed as part Croxton Road' & £4.1 million for ‘A11Norwich Road & A11Munford of finalising the Infrastructure Delivery Programme to which the Road widening & signalisation' (Table 15.1 p.117). The study Highways Agency will be a consultee. This will ensure estimated acknowledges the uncertainties with deriving accurate costs at an transport costs are as realistic as possible at the time of Plan early stage. The HA considers these costs to be low. The HA submission. Breckland Council recognises that base transport Circulate draft Infrastructure Delivery suggests that consideration be given to removing monetary sums costs have been explored and refined as part of the Thetford Programme to the Highways from paragraphs 30.16-30.18 until, with regard to transport schemes, Transport Study (2010). The TAAP will include a suitable caveat Agency. And add caveat about the further work is carried out & more accurate costs have been derived in about consultation these being with the indicative HA. costs. The council has infrastructure study evidence that has considered impacts on higher order infrastructure no available in St Edmundsbury Borough Council is concerned that the wider impact Thetford. The principle of growth and its wider impact on on infrastructure resulting from the planned growth of Thetford is not transport, educaiton, health and water was fully examined as costs being indicative. being addressed by Draft AAP. The AAP should be amended to part of the Regional Spatial Strategy. Where cross-boundary enable developer contributions to be spent on projects wherever impacts are understood (e.e. recreational impacts on the SPA) there is a demonstrated adverse impact on existing infrastructure the council identified that mitigation will be required and that CIL that is directly attributable to the growth in the Area Action Plan, provides a robust mechanism too collect appropriate Late representation. Comments whether or not it is in the area covered by the Plan. contributions. noted. As a result we are disappointed that Keystone is not included in the list of delivery partners (p114). While we accept that the list is not exhaustive, we believe we can contribute a considerable amount to the aspirations of this action plan. Comments noted Add 'Keystone' to list of delivery partners and agencies.
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