Wainhomes (South West) Holdings Ltd (ID: 407809), Sir Hugh Stucley (ID 852212) and Cavanna Homes (NOR7 Only) (ID 854147

Matter 6: Town Strategies

North Devon and Torridge Local Plan

On behalf of Wainhomes (South West) Holdings Ltd (ID: 407809), Sir Hugh Stucley (ID 852212) and Cavanna Homes (NOR7 only) (ID 854147 – plp2272-2277 only)

Emery Planning 2-4 South Park Court, Hobson Street Macclesfield, SK11 8BS Tel: 01625 433 881 www.emeryplanning.com

Project : 8032 Site address : North Devon and Torridge Local Plan Client : various clients

Date : November 2016 Author : Stephen Harris

This report has been prepared for the client by Emery Planning with all reasonable skill, care and diligence.

No part of this document may be reproduced without the prior written approval of Emery Planning.

Emery Planning Partnership Limited trading as Emery Planning.

Contents:

1. Introduction 1 2. Barnstaple 2 3. Bideford 3 4. Northam 4 5. South Molton 4 6. Ilfracombe 4

Matter 2 Housing North Devon and Torridge Local Plan November 2016

1. Introduction

1.1 The Inspector has invited comments on Matter 6 (Town Strategies) Housing in advance of the hearing sessions to be held on the w/c 29th November 2016.

1.2 We are representing Wainhomes (South West) Holdings Ltd, Sir Hugh Stucley and Cavanna Homes (on Site NOR7 only). We have been asked to represent Sir Hugh Stucley and Cavanna Homes (Site NOR7 only) due to Wainhomes having an interest in these sites and seeking to take them forward in the plan period for residential development.

1.3 We are fully aware that the Inspector is not seeking to examine omission sites as part of the forthcoming hearing sessions unless through the Examination there appears to be the need for additional sites and this would then be raised with the Councils to ascertain how that need would be addressed. However to provide context to our representations only we set out our main interests.

1.4 By way of introduction, Wainhomes is an active housebuilder based in Devon who have invested and continue to invest in both Torridge and North Devon. They have 4 active development sites at present, these being:

 Goodleigh Road, Barnstaple;

 Mead Park, Bickington;

 SM01(c), South Molton; and,

 Cornborough Road, Westward Ho!

1.5 At the Publication Draft, we submitted sites as omission sites. As a result of subsequent permissions on these sites, both Cornborough Road and South Molton no longer need to be progressed as omission sites. However whilst permissions have also been achieved on both Goodleigh Road and Mead Park, there remains residual land that we are promoting as omission sites should the need arise following these Examination sessions.

1.6 In addition to the sites being promoted by Wainhomes, since the Publication Local Plan and the Proposed Changes, they have obtained in interest in two further sites, these being:

 Site NOR7 – Representations made by Cavanna Homes (plp2272-2277 only). Since these representations were submitted Cavanna Homes no longer have an interest in

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the site. That interest is now with Wainhomes but we appear with the agreement of Cavanna Homes on their submitted representations.

 Land south of Clovelly Road – Representations made by John Blaney on behalf of Sir Hugh Stucley (Comment ID plp279). The land south of Clovelly Road is part allocated for employment and part is unallocated (SHLAA BID/026). Whilst we support the allocation of the employment land, the remaining land is being pursued as an omission site for residential development in order to bring forward a comprehensive mixed use development as illustrated on the General Arrangement Plan submitted to the Publication Local Plan.

1.7 We fully recognise that the forthcoming Examination sessions will not debate the merits of any omission site. Therefore following the Examination sessions should the Inspector conclude that additional sites are required to meet any identified shortfall that there are deliverable sites that can be brought forward by the Councils which importantly are in the control of an active local developer.

1.8 For each of the Town Strategies a number of questions have been set out by the Inspector. We set out our response.

2. Barnstaple

2.1 We agree that Barnstaple is located correctly in the settlement hierarchy as a Sub Regional Centre. Our concern in our representations was that Bideford was designated as a Strategic Centre yet had a greater level of development than the Sub Regional Centre of Barnstaple. Question 6.1(iv) of the agenda asks whether all housing figures set out in the town strategies should represent a minimum provision. We would agree that the plan should be clear that they are minimum requirements and this would assist in addressing our concerns.

2.2 There are two major housing sites allocated in Barnstaple, these being:

 Westacott Urban Extension (BAR01); and

 Larkbear Urban Extension (BAR02).

2.3 With regard to BAR01, we consider that the lead in time would be sufficient to obtain the necessary permissions and commence development. However we have significant reservations on the proposed build rate. We consider that it should be reduced to 75 dwellings per annum assuming that there would be 3 developers. This would result in 246 dwellings being delivered after the plan period.

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2.4 With regard to BAR02, there is an outline application awaiting a Section 106. The outline application was submitted in October 2012 which is 4 years ago. The application was then considered by committee on 23rd October 2013 and yet no Section 106 has been signed. Should a S106 be signed, the site needs to be progressed by a developer or developers, reserved matters applications prepared, submitted and approved and then the necessary pre- commencement approvals before development can start. We consider that whilst the site is available and suitable, we consider that it will not deliver until 2018 at the earliest. With two developers a build rate of 50 dwellings per annum should be applied.

2.5 In our Matter 2 statement we have assessed the deliverability of sites in the housing trajectory and there are no sites that are allocated which if maintained would cause the Local Plan to fail the test of soundness. However our assessment does demonstrate that sites will not come forward as expected in the trajectory due to unrealistic lead in time, optimistic build rates or other factors. Those points go the soundness (effective and consistent with national policy) of the trajectory rather than specific sites.

3. Bideford

3.1 We agree that Bideford is located correctly in the settlement hierarchy as a Strategic Centre. As noted above our concern in our representations was that Bideford was designated as a Strategic Centre yet had a greater level of development than the Sub Regional Centre of Barnstaple. Question 6.1(iv) of the agenda asks whether all housing figures set out in the town strategies should represent a minimum provision. We would agree that the plan should be clear that they are minimum requirements and this would assist in addressing our concerns.

3.2 As we also note above the reason for this change may be due to Bideford being less constrained by environmental and technical constraints than Barnstaple. As we have no in principle concerns with the allocations at the town then Bideford could accommodate the proposed level of development in a sustainable location.

3.3 In our Matter 2 statement we have assessed the deliverability of sites in the housing trajectory for Bideford and there are no sites that are allocated which if maintained would cause the Local Plan to fail the test of soundness. However our assessment does demonstrate that sites will not come forward as expected in the trajectory which do impact on soundness as the trajectory needs to be effective and in accordance with national policy.

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3.4 With regard to our client’s specific interest, part of their land is allocated for employment land (BID05). We support this allocation which the Councils will address as part of their evidence to the Examination.

4. Northam

4.1 We are attending to speak to the representations to the Publication Local Plan submitted by Cavanna Homes in August 2014 (plp2272 to plp2277) and they are not repeated here.

4.2 We endorse and support their comments that Policy NOR7 will make a positive contribution towards the spatial vision and that the policy should be worded more flexibly on the site specific matters. Overall the site will: Provide a mix of housing types and size to reflect local need; Include affordable housing provision; Minimise any loss of landscape character on the surrounding area; Include improvements to the existing infrastructure; and Provide areas of green infrastructure. It would also provide for the open market and affordable needs of Appledore and Northam on a site that is accessible and sustainable. As noted in our introduction, the site is being promoted by Wainhomes and they would intend to submit an application promptly and they would deliver 25 dwellings per annum.

5. South Molton

5.1 Wainhomes is currently building on Site SM01(c). This follows an approval for 172 dwellings. We support the recognition that the site is delivering and will continue to deliver going forward. However, the annual rate of delivery for years 17/18 and 18/19 are high for this site as it is only Wainhomes developing the site. The annual rate would be 25 dwellings per annum. This rate of delivery should apply to all sites at South Molton.

6. Ilfracombe

6.1 Site ILF01 is a site that has deliverability issues. It is a site that we discounted in our evidence for the Mead Park appeal which assessed housing supply at an April 2014 base date. Our evidence at that time was as follows:

Outline planning application submitted for 750 dwellings and a mixed use centre on 26/11/2013 (56675). Application has not yet been determined. LPA’s website states that report to planning committee is being prepared. However, the application was presented to the 30th July 2014 planning committee and

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it was resolved that the application be approved in principle. It was then presented to committee again on the 5th November 2014 to approve matters relating to conditions and S106 Heads of Terms. Officers recommended that the application be approved subject to conditions and the signing of a S106 agreement. The minutes for the 05/11/2014 committee meeting confirm that it was resolved that the application be approved subject to the signing of a S106 agreement. The LPA’s website does not provide any details of whether a S106 agreement has been signed. However, no S106 agreement is shown on the website and it is therefore considered that one has not been signed. It is therefore assumed that the site does not have planning permission. 6.2 This evidence was prepared nearly 2 years ago yet neither CE5 nor EC06 provide any update on this site and its delivery in the plan period. Therefore whilst the site may be suitable from the history to date it is neither available nor achievable.