Former Phoenix Works
Total Page：16
File Type：pdf, Size：1020Kb
South Derbyshire Local Plan Part 1 Examination Matter 2: The Spatial Strategy and Housing Policy Hearing Statement for The Chamberlain Family and Central Land Holdings Ltd (106) November 2014 South Derbyshire Local Plan Part 1 Examination Matter 2: The Spatial Strategy and Housing Policy Statement for The Chamberlain Family and Central Land Holdings Ltd (106) Project Ref: 6748/P43/A5 6748/P43a/A5 Status: Draft Final Issue/Rev: A Date: 5th November, 2014 6th November, 2014 Prepared by: Michael Knott Michael Knott Checked by: Michael Knott Michael Knott The Blade, Abbey Square, Reading, Berkshire. RG1 3BE Tel: 0118 943 0000 Ref: 6748/P43a/A5/MK/dw Fax: 0118 943 0001 Email: [email protected] Date: 6th November, 2014 COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP. All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks. South Derbyshire Local Plan Part 1 EiP Matter 2: Chamberlain Family/Central Land Holdings (106) 1.0 RESPONSE TO INSPECTOR’S ISSUES AND QUESTIONS Q4: Is the Key Diagram simply describing the existing situation? Should it illustrate the proposed spatial strategy for the District? 1.1 We would support a proposed modification to the Key Diagram which would include the identification of the Boulton Moor allocation proposed through Policy H13 of the Local Plan. Q10: E.77 also shows developable sites which could be delivered in years 6-10 years and in years 11-13 (Appendix 1). Are these in suitable locations and likely to be available at the appropriate time. Is there a reasonable expectation that they could be viably developed at the time envisaged? 1.2 As we explain below, the proposed allocation of Boulton Moor is a suitable location for new (housing) development. 1.3 Development of the Phase 1 site, which benefits from outline planning permission and approval of first phase reserved matters, has commenced and first completions are expected within this current monitoring year (2014/15). It is anticipated that the projected completion figures as set out in Appendix 1 of Document E77 are achievable with completion of the Phase 1 site by 2025/26, or within the plan period. 1.4 On behalf of our clients Barton Willmore is about to commence the preparation of an outline planning application for the Phase 2 site. An EIA Scoping Report is due to be submitted to the Council shortly and it is anticipated that the application will be submitted in early 2015. The anticipated delivery of first completions from the Phase 2 site in 2020/21 is considered reasonable. 1.5 We note that E77 anticipates first completions from the Boulton Moor Phase 3 site in 2017/18. Work has yet to commence on preparing an application for this site, awaiting its removal from the extent of the Green Belt as proposed through Policy S8 (see our separate submission to Matter 4). Upon adoption of the Local Plan Part 1, our clients confirm that a planning application for Phase 3 will be forthcoming and that the forecast completions set out in E77 are broadly realistic. 6748/P43a/A5/MK/dw Page 1 November, 2014 South Derbyshire Local Plan Part 1 EiP Matter 2: Chamberlain Family/Central Land Holdings (106) 1.6 Overall, the delivery rates shown in E77 for the Boulton Moor sites are considered to be broadly realistic. Whilst there could be some variation in annual delivery compared with the figures shown in E77, and that the peak rates identified through the trajectory will be challenging, the anticipated overall completion of the Boulton Moor allocation by 2028 is considered achievable. Q11: The housing trajectory in Appendix 3 of the Local Plan shows a marked uplift in housing delivery from 2014/15 onwards. The Housing Position Papers show different trajectories, but with a step up in 2015/16. The schedule of minor modifications, C.32, includes M177 which would ensure that the most recent trajectory was included in the Plan. However, are the trajectories consistent with being aspirational but realistic, in line with the NPPF, or are they too ambitious? 1.7 As set above, we consider the assessment of deliverability of development from the Boulton Moor allocation to achieve an appropriate balance between aspiration and realism, albeit we recognise that achieving the peak rates presented in the trajectory will be challenging. Q17: Are the sites listed in Table 4 (Derby Urban Edge) likely to deliver the numbers of new homes expected over the plan period, given the difficulties associated with large development sites, the slow progress made on sites which already have planning permission, and any outstanding constraints? 1.8 Clearly, an impact of the recent economic recession has been to stall housing delivery in the UK, particularly from large development sites. As stated above, construction has commenced at Boulton Moor Phase 1 with first completions due within the current monitoring year (2014/15). 1.9 Delivery of Boulton Moor Phases 2 and 3 will be brought forward within the broad timescales set out in E77 and are expected to achieve the approximate numbers allocated. 6748/P43a/A5/MK/dw Page 2 November, 2014 South Derbyshire Local Plan Part 1 EiP Matter 2: Chamberlain Family/Central Land Holdings (106) Q21: Representations on the Local Plan show that there are objections to several of the allocations in Policies H2-18, with suggestions for alternative sites elsewhere or, in some cases suggested extensions to the allocations. In view of these representations and the comparative merits of sites, is it necessary to delete, amend or add to the allocations for housing? 1.10 The proposed allocation of Boulton Moor, comprising 3 phases located within South Derbyshire District and further land located within Derby City’s administrative area (’Snelsmoor Grange’), immediately adjacent to the Phase 2 site, is ‘sound’. The merits of the allocation are in large part established through the grant of planning permission for the Phase 1 site which is now being brought forward for development. The additional land forming the Boulton Moor allocation is a logical extension to Phase 1. 1.11 A draft Development Framework Document has been prepared jointly with the promoters of the Snelsmoor Grange site to provide further detail relating to the proposed allocation of Boulton Moor. It presents a analysis of the proposed allocation area and a comprehensive masterplan for the future development of Boulton Moor Phases 1, 2 and 3 alongside Snelsmoor Grange with Derby City’s administrative area. A copy of the draft Development Framework Document (dated October 2014) is provided as Appendix 1. 1.12 In respect of the proposed requirements as set out in Policy H13, we draw the Inspector’s attention to the representations submitted at the Regulation 19 stage by Barton Willmore on behalf of The Chamberlain Family and Central Land Holdings (dated 22nd April 2014). We have proposed a number of modifications to Policy H13 we do not repeat in full. In summary, these are: - The need for the proposed requirement for a “cross boundary approach” being taken towards affordable housing set out in part iv) to be clarified and for the level to be adequately justified by viability evidence; - Deletion of the requirement in part viii) for cross boundary flood mitigation measures, to address fluvial and surface water issues relating to the Thulston Brook and ground water levels; - Deletion of the requirement in part ix) for a cross boundary flood risk assessment; - Modification of part xiii) to require the district centre to be anchored by a “supermarket” (as opposed to a “small/medium sized supermarket”). Alternatively the word “small” should be omitted given that this represents the scale of retail already approved to support the Phase 1 development alone; and 6748/P43a/A5/MK/dw Page 3 November, 2014 South Derbyshire Local Plan Part 1 EiP Matter 2: Chamberlain Family/Central Land Holdings (106) - Modification to part xviii), as set out in our April 2014 representations, making specific reference to contributions to be made in accordance with the Highway Agency’s SRN Contributions Formula. 1.13 In conclusion, the proposed strategic allocation of Boulton Moor as set out in Policy H13 is entirely justified and considered sound, having been assessed against other alternatives. The inclusion of the allocation is sound and therefore any new sites should only be considered if additional land is necessary which cannot be addressed through the Local Plan: Part process. 1.14 Turning to other representations submitted to the Regulation 19 consultation, we have reviewed responses to Policy H13 of the Pre-submission Draft Local Plan Part 1, as documented on the Council’s website. Officers have confirmed that only the following organisations responded to Policy H13 of the plan relating to the proposed Boulton Moor allocation (in addition to our own submission): • The Highways Agency; • Derbyshire County Council; • English Heritage; and • The National Trust. 1.15 None of the above, or any other parties as far as we are aware, is proposing the removal of the Boulton Moor allocation in place of any alternative site. In response to the submissions made by those organisations listed under paragraph 2.10 above we comments as follows: 1.16 The Inspector will note that the Highways Agency’s comments are in support of the plan and the approach envisaged towards the Strategic Road Network (SRN). There is no objection to Policy H13 and the proposed Boulton Moor allocation. 1.17 We note that Derbyshire County Council has not objected to the Policy H13 and the allocation of Boulton Moor. Indeed, they provide support for the proposed review of Green Belt boundaries set out in Policy S8 which is associated with the proposed allocation at Boulton Moor (as discussed in our separate response to Matter 4: Green Belt).