Consultation Draft (February 2017)

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Consultation Draft (February 2017)

Introduction

Representation ID: 5593

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

We support the general aims of the Local Plan Strategy but in its present form it does not deliver a sustainable form of development.

Please see attached statement for further details

Full text:

We support the general aims of the Local Plan Strategy but in its present form it does not deliver a sustainable form of development.

Please see attached statement for further details

Object

Consultation Draft (February 2017)

Housing Provision

Representation ID: 5594

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

We have concerns regarding the SHMA 2013 and Sensitivity Update. The housing requirement is not based on the full OAN. Additional provision should be made to take account of unmet need from Sheffield, the economic needs of the area, the need for significant affordable housing and the latest population and household projections. A figure of between 390-42- dwellings per annum or 8,580 - 9,240 dwellings over the plan period should be provided.

Please see attached statement for further details

Full text:

The Approach to Objectively Assessed Need for Housing
5.01 The Framework and the Planning Practice Guidance (PPG) provides detailed guidance in respect to the approach that should be taken in determining Objectively Assessed Need (OAN). The context in which OAN is determined is as follows:
a. The objective is to provide a supply of housing to meet the needs of both this and future generations (paragraph 7 of the Framework);
b. There is also the requirement to increase the opportunity for home ownership based not just on current but also future demographic trends, market trends and the needs of different groups in the community (paragraph 50 of the Framework);
c. Planning should encourage, not act as an impediment to sustainable growth and as such significant weight should be placed on the need to support economic growth through the planning system (paragraph 19 of the Framework;
d. Plans should also be positively prepared.
5.02 These principles should be used to inform the assumptions as part of the process of assessing OAN and the consequences of using this approach are as follows:
a. Where there is a choice of reasonable alternatives regarding the future propensity of persons to form households, then the requirement to increase the opportunity for home ownership and plan positively requires one to choose the more favourable assumption that would allow more rather than less persons to form their own households and achieve home ownership (paragraphs 7 and 50 of the Framework);
b. Where there are a number of reasonable projections of future employment growth, then one should plan to accommodate the highest of these projections in order to support sustainable economic growth in accordance with paragraph 19 of the Framework;
c. No constraints should be applied to the calculation of the overall assessment of need.
d. Once an objectively assessed need has been confirmed, then the housing requirement may be set at less than the need only if:
i. Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole; or specific policies in the Framework indicate development should be restricted; and
ii. The council has engaged in the Duty to Co-operate so that these needs are met elsewhere, so as to fulfil the core principle of delivering the homes the country needs (paragraph 17 of the Framework)
The Approach taken in the SHMA (2013)
5.03 In paragraph 11.42 of the SHMA it is concluded that 'an objective assessment of need for housing in North East Derbyshire would equate to delivery of between 270-310 homes per annum'. This was further amended following the sensitivity testing to 268-285 new homes per year. Paragraph 11.42 of the SHMA goes onto conclude that 'The higher end of this projection range is based on seeking to more positively support economic growth and deliver affordable housing. The economic-driven projections provide a further upside and higher housing provision still could be justified on the basis of supporting economic growth. High housing provision relative to the range suggested would also support stronger affordable housing'.
5.04 In respect to affordable housing the SHMA concludes in paragraph 11.50 that 482 affordable homes per annum would be needed in North East Derbyshire, which is clearly a significant level of need and following the approach in Government Guidance, 'provides a strong basis for seeking to maximise delivery of new affordable housing'.
5.05 A number of concerns are raised regarding the 2013 SHMA, and these are as follows:
a. The SHMA fails to correctly define the housing market area - it does not include relevant part of the wider Sheffield City Region;
b. Objectively assess the need for housing;
c. Meet unmet housing demand from Sheffield;
d. Take into account employment trends and policies;
e. Take into account the demand for labour in other locations (particularly Doncaster and Sheffield)
5.06 The Market Area identified in the SHMA only covers the local authority areas of Bassetlaw, Bolsover, Chesterfield and North East Derbyshire, however the evidence suggests that NEDDC is part of a wider Strategic Housing Market Area that includes Doncaster, Rotherham and Sheffield.
5.07 We do not consider that the Council has established a sufficiently robust evidence base to suggest that there are not strategic links in respect to housing and employment which obviates them from not fulfilling the Duty to Co-operate with the wider Strategic HMA, including Sheffield and Doncaster.
5.08 It is clear that there is a need for areas within the Sheffield City Region to accommodate additional housing that cannot be accommodated within Sheffield's boundaries. In order to be consistent with the guidance in the Framework and the PPG, this should be determined through a joint SHMA and Strategic Housing Land Availability Assessment, followed by effective co-operation. Where there is no such agreement, plans should be prepared on the basis of the latest joint evidence. In respect to Sheffield and NEDDC, there is clear evidence that there are migration flows out of Sheffield to NEDDC of the order of 20% and NEDDC should be accommodating this unmet need.
5.09 Given that the northern boundary of NEDDC abuts Sheffield and many locations within NEDDC share the same public transport infrastructure, such as ease of access to stations at Dore, Dronfield and Chesterfield, there is a policy argument that NEDDC should be accommodating more than a pro rata level of unmet housing need from Sheffield.
5.010 The DCLG 2012 Household Projections suggest that Sheffield requires on average 1900 dwellings per annum in the period 2012-2031 but completions recently have averaged 1300 dwelling per year , resulting in a shortfall of some 600 dwellings per year.
5.011 This unmet need is likely to result in migration pressures to other parts of the HMA and thus it is reasonable to assume that this will occur in a similar manner to past migration patterns. As such it is reasonable to assume that approximately 20% of this unmet need would be accommodated in NEDDC, which is approximately 120 additional dwellings per annum.
5.012 In conclusion therefore, if one takes the 2012 Household Projections of 245 dwellings a year as a starting point and then account is taken of the unmet need from Sheffield, the annual requirement for NEDDC would be 365 dwellings per annum. However in addition to this account should be taken of the economic needs of the area, which would provide a further uplift to the housing requirement for NEDDC and it is suggested that an additional 5 - 10% uplift should be including resulting in a housing provision in the range of 380-400 dwellings per annum.
5.013 The housing requirement for North East Derbyshire District council is set out in Chapter 4 Spatial Strategy of the North East Derbyshire Local Plan (2011 - 2033) Consultation Draft and Policy SS2 Scale of Development requires that a minimum of 300 dwellings per annum should be provided over the plan period, which based on the above evidence is clearly insufficient to meet the full OAN for housing. We Object to this policy in its current form.
5.014 The Council acknowledge that they have not taken account of the most recent 2014 based population figures and household projections. The 2014 population figures show that over a 10 year period to 2024 the UK population is set to increase to 69m, by 249,000 people more than that set out in the 2012 population projections with a projected increase in households over and above provided by the 2012 household projections.
5.015 On the basis of these higher population and household projections it is considered that the Council should increase the overall housing requirement by an additional 3-5% and that a figure of between 390-420 dwellings per annum or 8,580 - 9,240 over the plan period. This will ensure that the Council's Growth Strategy can be delivered and that there is a sufficient level of planned housing to accommodate the anticipated levels of economic growth. Further, setting a higher housing target will help to deliver the significant need for affordable housing across the District.
5.016 Policy SS2 Scale of Development should be amended to:
'For the period 2011-2033 the Local Plan will make sufficient housing and employment land to accommodate a minimum of:
* 8,580 dwellings; and
* 50ha of new employment land

Object

Consultation Draft (February 2017)

Balancing Housing and Economic Growth

Representation ID: 5595

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

Please see previous summary in relation to 'Housing Provision' and attached statement.

Full text:

The Approach to Objectively Assessed Need for Housing
5.01 The Framework and the Planning Practice Guidance (PPG) provides detailed guidance in respect to the approach that should be taken in determining Objectively Assessed Need (OAN). The context in which OAN is determined is as follows:
a. The objective is to provide a supply of housing to meet the needs of both this and future generations (paragraph 7 of the Framework);
b. There is also the requirement to increase the opportunity for home ownership based not just on current but also future demographic trends, market trends and the needs of different groups in the community (paragraph 50 of the Framework);
c. Planning should encourage, not act as an impediment to sustainable growth and as such significant weight should be placed on the need to support economic growth through the planning system (paragraph 19 of the Framework;
d. Plans should also be positively prepared.
5.02 These principles should be used to inform the assumptions as part of the process of assessing OAN and the consequences of using this approach are as follows:
a. Where there is a choice of reasonable alternatives regarding the future propensity of persons to form households, then the requirement to increase the opportunity for home ownership and plan positively requires one to choose the more favourable assumption that would allow more rather than less persons to form their own households and achieve home ownership (paragraphs 7 and 50 of the Framework);
b. Where there are a number of reasonable projections of future employment growth, then one should plan to accommodate the highest of these projections in order to support sustainable economic growth in accordance with paragraph 19 of the Framework;
c. No constraints should be applied to the calculation of the overall assessment of need.
d. Once an objectively assessed need has been confirmed, then the housing requirement may be set at less than the need only if:
i. Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole; or specific policies in the Framework indicate development should be restricted; and
ii. The council has engaged in the Duty to Co-operate so that these needs are met elsewhere, so as to fulfil the core principle of delivering the homes the country needs (paragraph 17 of the Framework)
The Approach taken in the SHMA (2013)
5.03 In paragraph 11.42 of the SHMA it is concluded that 'an objective assessment of need for housing in North East Derbyshire would equate to delivery of between 270-310 homes per annum'. This was further amended following the sensitivity testing to 268-285 new homes per year. Paragraph 11.42 of the SHMA goes onto conclude that 'The higher end of this projection range is based on seeking to more positively support economic growth and deliver affordable housing. The economic-driven projections provide a further upside and higher housing provision still could be justified on the basis of supporting economic growth. High housing provision relative to the range suggested would also support stronger affordable housing'.
5.04 In respect to affordable housing the SHMA concludes in paragraph 11.50 that 482 affordable homes per annum would be needed in North East Derbyshire, which is clearly a significant level of need and following the approach in Government Guidance, 'provides a strong basis for seeking to maximise delivery of new affordable housing'.
5.05 A number of concerns are raised regarding the 2013 SHMA, and these are as follows:
a. The SHMA fails to correctly define the housing market area - it does not include relevant part of the wider Sheffield City Region;
b. Objectively assess the need for housing;
c. Meet unmet housing demand from Sheffield;
d. Take into account employment trends and policies;
e. Take into account the demand for labour in other locations (particularly Doncaster and Sheffield)
5.06 The Market Area identified in the SHMA only covers the local authority areas of Bassetlaw, Bolsover, Chesterfield and North East Derbyshire, however the evidence suggests that NEDDC is part of a wider Strategic Housing Market Area that includes Doncaster, Rotherham and Sheffield.
5.07 We do not consider that the Council has established a sufficiently robust evidence base to suggest that there are not strategic links in respect to housing and employment which obviates them from not fulfilling the Duty to Co-operate with the wider Strategic HMA, including Sheffield and Doncaster.
5.08 It is clear that there is a need for areas within the Sheffield City Region to accommodate additional housing that cannot be accommodated within Sheffield's boundaries. In order to be consistent with the guidance in the Framework and the PPG, this should be determined through a joint SHMA and Strategic Housing Land Availability Assessment, followed by effective co-operation. Where there is no such agreement, plans should be prepared on the basis of the latest joint evidence. In respect to Sheffield and NEDDC, there is clear evidence that there are migration flows out of Sheffield to NEDDC of the order of 20% and NEDDC should be accommodating this unmet need.
5.09 Given that the northern boundary of NEDDC abuts Sheffield and many locations within NEDDC share the same public transport infrastructure, such as ease of access to stations at Dore, Dronfield and Chesterfield, there is a policy argument that NEDDC should be accommodating more than a pro rata level of unmet housing need from Sheffield.
5.010 The DCLG 2012 Household Projections suggest that Sheffield requires on average 1900 dwellings per annum in the period 2012-2031 but completions recently have averaged 1300 dwelling per year , resulting in a shortfall of some 600 dwellings per year.
5.011 This unmet need is likely to result in migration pressures to other parts of the HMA and thus it is reasonable to assume that this will occur in a similar manner to past migration patterns. As such it is reasonable to assume that approximately 20% of this unmet need would be accommodated in NEDDC, which is approximately 120 additional dwellings per annum.
5.012 In conclusion therefore, if one takes the 2012 Household Projections of 245 dwellings a year as a starting point and then account is taken of the unmet need from Sheffield, the annual requirement for NEDDC would be 365 dwellings per annum. However in addition to this account should be taken of the economic needs of the area, which would provide a further uplift to the housing requirement for NEDDC and it is suggested that an additional 5 - 10% uplift should be including resulting in a housing provision in the range of 380-400 dwellings per annum.
5.013 The housing requirement for North East Derbyshire District council is set out in Chapter 4 Spatial Strategy of the North East Derbyshire Local Plan (2011 - 2033) Consultation Draft and Policy SS2 Scale of Development requires that a minimum of 300 dwellings per annum should be provided over the plan period, which based on the above evidence is clearly insufficient to meet the full OAN for housing. We Object to this policy in its current form.
5.014 The Council acknowledge that they have not taken account of the most recent 2014 based population figures and household projections. The 2014 population figures show that over a 10 year period to 2024 the UK population is set to increase to 69m, by 249,000 people more than that set out in the 2012 population projections with a projected increase in households over and above provided by the 2012 household projections.
5.015 On the basis of these higher population and household projections it is considered that the Council should increase the overall housing requirement by an additional 3-5% and that a figure of between 390-420 dwellings per annum or 8,580 - 9,240 over the plan period. This will ensure that the Council's Growth Strategy can be delivered and that there is a sufficient level of planned housing to accommodate the anticipated levels of economic growth. Further, setting a higher housing target will help to deliver the significant need for affordable housing across the District.
5.016 Policy SS2 Scale of Development should be amended to:
'For the period 2011-2033 the Local Plan will make sufficient housing and employment land to accommodate a minimum of:
* 8,580 dwellings; and
* 50ha of new employment land

Object

Consultation Draft (February 2017)

Policy SS2: Scale of Development

Representation ID: 5596

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

we propose the following new wording for Policy SS2 Scale of Development

5.016 Policy SS2 Scale of Development should be amended to:
'For the period 2011-2033 the Local Plan will make sufficient housing and employment land to accommodate a minimum of:
* 8,580 dwellings; and
* 50ha of new employment land

Please see attached statement

Full text:

we propose the following new wording for Policy SS2 Scale of Development

5.016 Policy SS2 Scale of Development should be amended to:
'For the period 2011-2033 the Local Plan will make sufficient housing and employment land to accommodate a minimum of:
* 8,580 dwellings; and
* 50ha of new employment land

Please see attached statement

Object

Consultation Draft (February 2017)

Distribution of Growth & the Settlement Hierarchy

Representation ID: 5597

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

The Settlement Hierarchy is broadly in line with the fundamental principles of sustainability set out in the Framework.
As already set out in Section 5, it is considered that the housing requirement for the plan period of 300 dwellings per annum or 6,600 for the plan period is insufficient to meet the full OAN.
There are opportunities for some of the Level 2 Settlements to support higher levels of housing provision.
See Attached Statement

Full text:

6.01 The distribution of housing allocations across the District has been underpinned by the Council's Settlement Hierarchy Study, December 2016. Level 1 Settlements include the Principal Towns of Clay Cross and Dronfield and the Secondary Towns of Eckington and Killamarsh. Below this are level 2 Settlements, which are those with good levels of sustainability followed by level 3 Settlements with limited sustainability and level 4 Very small villages and hamlets with limited sustainability. The Settlement Hierarchy is broadly in line with the fundamental principles of sustainability set out in the Framework.
6.02 Level 1 Settlements contain 48% of the District's population and will provide for a significant proportion of the District's housing growth requirements, alongside retail and employment growth over the plan period.
6.03 Paragraph 4.33 of the supporting text of the draft plan confirms that outside the principal and secondary towns (and identified strategic sites); Level 2 Settlements will provide much of the remaining planned housing growth, which is expected to be in the region of 1,950 dwellings.
6.04 As already set out in Section 5, it is considered that the housing requirement for the plan period of 300 dwellings per annum or 6,600 for the plan period is insufficient to meet the full OAN. The Council identify overall housing allocations that will provide 5,740 dwellings over the plan period and consider that when combined with 1,016 dwellings already built this is more than sufficient to meet the housing requirement of the District. This however only provides a margin of 2.4% provision over and above the Council's minimum requirement of 6,600 dwellings, which is considered not to give sufficient flexibility should any of the identified site allocations fail to deliver the expected number of homes within the plan period. The housing provision set out in paragraph 5.015 of 390-420 dwellings per annum would ensure that there was sufficient headroom to take account of the economic growth strategy, reductions in and/or delays in delivery and the significant need for affordable housing provision. It is considered that this approach is compliant with the policies of the Framework which requires plans to be:
'positively prepared ....and based on a strategy that seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development' (paragraph 182 of the Framework).
6.05 There are opportunities for some of the Level 2 Settlements to support higher levels of housing provision. For example an extension to LC1ao) Land to the rear of 10-52 Ashover Road, Old Tupton would provide a further 60 dwellings and would provide a sustainable form of development in this location. The Sustainability Appraisal scores Tupton as a sustainable settlement with good access to services, facilities and public transport, which supports its inclusion as a Level 2 Settlement.
6.06 The inclusion of the site at Tupton would increase the provision of housing over the plan period. It is considered that the Council are at risk of submitting a plan that will be found unsound, unless they can identify further sources of housing land and extend where appropriate identified housing allocations, such as LC1ao).

Object

Consultation Draft (February 2017)

Policy SS3 : Spatial Strategy and the Distribution of Development

Representation ID: 5598

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

Amend the housing provision in line with our comments made in respect to Policy SS2 Scale of Development

Please see attached statement

Full text:

Amend the housing provision in line with our comments made in respect to Policy SS2 Scale of Development

Please see attached statement

Object

Consultation Draft (February 2017)

Housing Provision by Settlement

Representation ID: 5599

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

Please see our comments/objections in relation to overall requirement for housing.

See attached statement

Full text:

Please see our comments/objections in relation to overall requirement for housing.

See attached statement

Object

Consultation Draft (February 2017)

Table 4.2: Housing Provision by Level 1 and Level 2 Settlement

Representation ID: 5600

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

Please see attached statement

Full text:

6.05 There are opportunities for some of the Level 2 Settlements to support higher levels of housing provision. For example an extension to LC1ao) Land to the rear of 10-52 Ashover Road, Old Tupton would provide a further 60 dwellings and would provide a sustainable form of development in this location. The Sustainability Appraisal scores Tupton as a sustainable settlement with good access to services, facilities and public transport, which supports its inclusion as a Level 2 Settlement.
6.06 The inclusion of the site at Tupton would increase the provision of housing over the plan period. It is considered that the Council are at risk of submitting a plan that will be found unsound, unless they can identify further sources of housing land and extend where appropriate identified housing allocations, such as LC1ao).

6.015 It is considered that given the need for housing in the District over the plan period, particularly the significant amount of affordable housing, it is considered that the exceptional circumstances exist to make further green belt releases, where it has been demonstrated appropriate to do so, around settlements only partially constrained by the Green Belt.
6.016 Release of Green Belt land on sites that abut Level 1 and 2 settlements are considered to promote sustainable patterns of development and such settlements will be able to accommodate the housing needs of smaller less sustainable settlements in neighbouring areas.
6.017 Even if the Inspector is of the view that the housing requirement identified in Policy SS2 Scale of Development provides for the full OAN, a view not supported by Gleeson Regeneration Ltd, the Council has failed to give any consideration to the longer term development needs of the District. Given the constrained supply of housing land in NEDDC, this is likely to result in the need for a further review of Green Belt boundaries at the end of the plan period, contrary to the policies in the Framework.

Additional comment from duplicated rep:

Further Table 4.2 that sets out the Housing Provision by Level 1 and Level 2 settlements should be amended to include additional housing provision in Tupton with an overall uplift of 10%

There is capacity to increase the overall housing provision in Level 1 and 2 Settlements through increased capacity on identified sites and the identification of additional sites.

Please see attached statement

Object

Consultation Draft (February 2017)

Green Belt Review

Representation ID: 5603

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

Please see attached statement

Full text:

6.07 Although the representation site at Tupton is outwith the Green Belt, we consider that it is pertinent to discuss the matter of Green Belt in general terms as it goes to the heart of the Council's housing land position.
6.08 The Council acknowledges that in order to deliver the spatial strategy set out in the plan, particularly given the location of three out of four of its Level 1 Settlements located in the north of the District and tightly constrained by Green Belt there is a need to release Green Belt land.
6.09 A Strategic Green Belt Functionality Study was published in November 2015 and subsequently a Green Belt Review has been undertaken by Nathaniel Lichfield and Partners (in two parts), February 2017.
6.010 The Nathaniel Lichfield Part 1 report identifies three alternative Green Belt growth scenarios, which are as follows:
a. Scenario A: Restricted Growth - up to 1,000 dwellings; below the level of housing growth required to meet the District's objectively assessed housing need but would address affordable housing needs;
b. Scenario B: Medium Level Growth between 1,000 and 2,000 dwellings; a level of housing growth which is sufficient to meet the District's objectively assessed housing needs; and
c. Scenario C: High Level Growth up to 4,000 dwellings; Growth above and beyond Objectively Assessed Needs, in line with the Council's Growth Strategy, capitalising on the economic benefits.
6.011 As the Council's spatial strategy requires a significant proportion of its housing requirement to be delivered in the north of the District, which includes three out of four of the District's main towns, and those housing needs cannot be met from existing land outside of the Green Belt, the main focus for the Green Belt review is in towns and settlements in the north of the District. The Green Belt review however does confirm that the settlements of Wingerworth, Grassmoor and Temple Normanton, which are only partially constrained by Green Belt, have not been excluded from the assessment.
6.012 Paragraph 83 of the Framework advises that:
'Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period'.
6.013 Paragraph 84 further advises that:
'...local planning authorities should take account of the need to promote sustainable patterns of development......channelling development towards urban area inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary'.
6.014 Paragraph 85 states, inter alia that local planning authorities should:
* Not include land which it is unnecessary to keep permanently open;
* Where necessary identify in their plans areas of 'safeguarded land'...to meet longer term development needs stretching well beyond the plan period
* Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
6.015 It is considered that given the need for housing in the District over the plan period, particularly the significant amount of affordable housing, it is considered that the exceptional circumstances exist to make further green belt releases, where it has been demonstrated appropriate to do so, around settlements only partially constrained by the Green Belt.
6.016 Release of Green Belt land on sites that abut Level 1 and 2 settlements are considered to promote sustainable patterns of development and such settlements will be able to accommodate the housing needs of smaller less sustainable settlements in neighbouring areas.
6.017 Even if the Inspector is of the view that the housing requirement identified in Policy SS2 Scale of Development provides for the full OAN, a view not supported by Gleeson Regeneration Ltd, the Council has failed to give any consideration to the longer term development needs of the District. Given the constrained supply of housing land in NEDDC, this is likely to result in the need for a further review of Green Belt boundaries at the end of the plan period, contrary to the policies in the Framework.

Object

Consultation Draft (February 2017)

Housing Allocations

Representation ID: 5604

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

Please see attached statement

Full text:

6.01 The distribution of housing allocations across the District has been underpinned by the Council's Settlement Hierarchy Study, December 2016. Level 1 Settlements include the Principal Towns of Clay Cross and Dronfield and the Secondary Towns of Eckington and Killamarsh. Below this are level 2 Settlements, which are those with good levels of sustainability followed by level 3 Settlements with limited sustainability and level 4 Very small villages and hamlets with limited sustainability. The Settlement Hierarchy is broadly in line with the fundamental principles of sustainability set out in the Framework.
6.02 Level 1 Settlements contain 48% of the District's population and will provide for a significant proportion of the District's housing growth requirements, alongside retail and employment growth over the plan period.
6.03 Paragraph 4.33 of the supporting text of the draft plan confirms that outside the principal and secondary towns (and identified strategic sites); Level 2 Settlements will provide much of the remaining planned housing growth, which is expected to be in the region of 1,950 dwellings.
6.04 As already set out in Section 5, it is considered that the housing requirement for the plan period of 300 dwellings per annum or 6,600 for the plan period is insufficient to meet the full OAN. The Council identify overall housing allocations that will provide 5,740 dwellings over the plan period and consider that when combined with 1,016 dwellings already built this is more than sufficient to meet the housing requirement of the District. This however only provides a margin of 2.4% provision over and above the Council's minimum requirement of 6,600 dwellings, which is considered not to give sufficient flexibility should any of the identified site allocations fail to deliver the expected number of homes within the plan period. The housing provision set out in paragraph 5.015 of 390-420 dwellings per annum would ensure that there was sufficient headroom to take account of the economic growth strategy, reductions in and/or delays in delivery and the significant need for affordable housing provision. It is considered that this approach is compliant with the policies of the Framework which requires plans to be:
'positively prepared ....and based on a strategy that seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development' (paragraph 182 of the Framework).
6.05 There are opportunities for some of the Level 2 Settlements to support higher levels of housing provision. For example an extension to LC1ao) Land to the rear of 10-52 Ashover Road, Old Tupton would provide a further 60 dwellings and would provide a sustainable form of development in this location. The Sustainability Appraisal scores Tupton as a sustainable settlement with good access to services, facilities and public transport, which supports its inclusion as a Level 2 Settlement.
6.06 The inclusion of the site at Tupton would increase the provision of housing over the plan period. It is considered that the Council are at risk of submitting a plan that will be found unsound, unless they can identify further sources of housing land and extend where appropriate identified housing allocations, such as LC1ao).
Green Belt Review
6.07 Although the representation site at Tupton is outwith the Green Belt, we consider that it is pertinent to discuss the matter of Green Belt in general terms as it goes to the heart of the Council's housing land position.
6.08 The Council acknowledges that in order to deliver the spatial strategy set out in the plan, particularly given the location of three out of four of its Level 1 Settlements located in the north of the District and tightly constrained by Green Belt there is a need to release Green Belt land.
6.09 A Strategic Green Belt Functionality Study was published in November 2015 and subsequently a Green Belt Review has been undertaken by Nathaniel Lichfield and Partners (in two parts), February 2017.
6.010 The Nathaniel Lichfield Part 1 report identifies three alternative Green Belt growth scenarios, which are as follows:
a. Scenario A: Restricted Growth - up to 1,000 dwellings; below the level of housing growth required to meet the District's objectively assessed housing need but would address affordable housing needs;
b. Scenario B: Medium Level Growth between 1,000 and 2,000 dwellings; a level of housing growth which is sufficient to meet the District's objectively assessed housing needs; and
c. Scenario C: High Level Growth up to 4,000 dwellings; Growth above and beyond Objectively Assessed Needs, in line with the Council's Growth Strategy, capitalising on the economic benefits.
6.011 As the Council's spatial strategy requires a significant proportion of its housing requirement to be delivered in the north of the District, which includes three out of four of the District's main towns, and those housing needs cannot be met from existing land outside of the Green Belt, the main focus for the Green Belt review is in towns and settlements in the north of the District. The Green Belt review however does confirm that the settlements of Wingerworth, Grassmoor and Temple Normanton, which are only partially constrained by Green Belt, have not been excluded from the assessment.
6.012 Paragraph 83 of the Framework advises that:
'Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period'.
6.013 Paragraph 84 further advises that:
'...local planning authorities should take account of the need to promote sustainable patterns of development......channelling development towards urban area inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary'.
6.014 Paragraph 85 states, inter alia that local planning authorities should:
* Not include land which it is unnecessary to keep permanently open;
* Where necessary identify in their plans areas of 'safeguarded land'...to meet longer term development needs stretching well beyond the plan period
* Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
6.015 It is considered that given the need for housing in the District over the plan period, particularly the significant amount of affordable housing, it is considered that the exceptional circumstances exist to make further green belt releases, where it has been demonstrated appropriate to do so, around settlements only partially constrained by the Green Belt.
6.016 Release of Green Belt land on sites that abut Level 1 and 2 settlements are considered to promote sustainable patterns of development and such settlements will be able to accommodate the housing needs of smaller less sustainable settlements in neighbouring areas.
6.017 Even if the Inspector is of the view that the housing requirement identified in Policy SS2 Scale of Development provides for the full OAN, a view not supported by Gleeson Regeneration Ltd, the Council has failed to give any consideration to the longer term development needs of the District. Given the constrained supply of housing land in NEDDC, this is likely to result in the need for a further review of Green Belt boundaries at the end of the plan period, contrary to the policies in the Framework.
Summary
6.018 Policy SS3: Spatial Strategy and the Distribution of Development, is objected to in its current form and the overall housing requirement should be amended to reflect our comments on Policy SS2. Further Table 4.2 that sets out the Housing Provision by Level 1 and Level 2 Settlements should be amended to include additional housing provision figures in Grassmoor and Tupton plus a 10% uplift overall.
6.019 Policy LC1: Housing Allocations sets out the proposed housing to deliver the housing land requirement set out in Policy SS3. In its current form we object to the policy. The allocation of Land to the rear of 10-52 Ashover Road, Tupton is supported, however this allocation should be extended to include the land to the north, which has the capacity to provide an additional 60 dwellings.

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