Mendip Local Plan Part II: Sites & Policies – Pre-Submission Consultation

Consultation Response Form

Please use this form to respond or make representations on Local Plan Part II and

associated consultation documents. For information or advice, please contact the Planning Policy Team by email at [email protected] or phone (0300) 303 8588.

Contact Details If you have appointed somebody to act as your agent, please give their contact details. All correspondence will be sent to the agent Name: Agent Name: Andrew Cockett

Organisation (if applicable): Company Name: Lichfields Redrow Homes

Address: Address: The Quorum, Bond Street, c/o Agent Postcode: Postcode: BS1 3AE Email: Email: Tel: Tel: Date completed Date completed

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We will contact you by e-mail only unless you confirm here (tick box)

Data protection – please read - The information collected as part this consultation will be processed by the Council in accordance with the Data Protection Act 1998. The purposes for collecting this data are: to assist in plan making; and to contact you, if necessary, regarding the planning consultation process. Please note that representations must be attributable to named individuals or organisations at a postal address. Representations and contact names will be published on the Mendip website but no other personal information Copies of this form are available from Council Offices and Access Points or can be downloaded from www.mendip.gov.uk/localplanpart2 . If you require this document in another format such as Braille, large print or another language then please contact us.

Please use a separate form for each site or main issue you wish to make. You can also attach one contact form to a group of representations. Please make sure any separate documents include your name –so they can be clearly identified.

Please return your response by 5pm Monday 12th February 2018. By post to: Planning Policy, Council, Cannards Grave Road, , , BA4 5BT By email to: [email protected] By hand to: The Council offices in Shepton Mallet (address above).

For office use

Details of Objection/ Comment./Representation

Name /Organisation

Please indicate the document to which your representation relates (e.g. policy, paragraph See Attached Representations number, HELAA site reference )

Do you consider the Local Plan is Legally Do you consider the Local Plan is Sound 1 ? Compliant? See Attached Representations See Attached Representations

Do you consider it necessary to participate at examination hearings? (eg present oral Yes evidence)

Please provide details below of why you consider the Local Plan is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance and soundness of the plan, please also use this box to set out your comments.

SEE ATTACHED REPRESENTATIONS

2

MENDIP LOCAL PLAN PART 2 – REGULATION 19 CONSULTATION

SITE NAME: LAND AT BATH ROAD,

REPRESENTATIONS PREPARED BY LICHFIELDS ON BEHALF OF REDROW HOMES LTD

1.0 Introduction 1.1 Redrow Homes (Redrow) own the site known as ‘land at Bath Road’ in the village of Beckington. The site is not currently proposed for allocation within either the adopted Mendip Local Plan Part I or in the emerging Mendip Local Plan Part II.

1.2 Redrow has concerns regarding the soundness of the Local Plan Part II as currently drafted which is explored further within these representations.

1.3 In addition, Redrow consider the village of Beckington to offer a sustainable and appropriate location for growth and do not support Mendip District Council’s (MDC) decision not to allocate any sites within the village over the plan period to 2026.

2.0 Housing Land Supply and Requirement 2.1 These representations refer to the Local Plan Part II (Section 3 – paragraphs 3.1 – 3.36), Background Housing Paper (December 2017) and the SHMA (October 2016).

Housing Requirement 2.2 The housing requirement for MDC between 2006 and 2029 was set out in Local Plan Part I (LPPI) as 420 dwellings per annum (dpa). It is acknowledged that the purpose of the Local Plan Part II (LPPII) is to set out detailed policies and site allocations, drawing upon the strategy contained within the LPPI.

2.3 As such, the LPPII is not intended to revisit the overall need for housing growth, and it is agreed that this is not the role of such a plan at paragraph 3.7 of the Written Statement. Instead, the Council has indicated that it proposes to undertake a single Local Plan Review (LPR), commencing in 2018. This will take account of the changes to the NPPF and will address housing requirements from a new base date. 2.4 A joint Strategic Housing Market Assessment (SHMA) was produced in October 2016 for the authority areas of Mendip, Sedgemoor, South Somerset and Taunton Deane. For MDC, this document identified a full objective assessment of housing need (FOAN) of 490dpa which is approximately 16.5% higher than the Local Plan requirement figure of 420dpa.

2.5 The conclusions of the SHMA are disputed, and it is likely that the FOAN is actually higher than indicated within this document (discussed in further detail below). In Lichfields’ view, the implication of this is that the purported FOAN of 490dpa is insufficient to reflect actual needs in Mendip, and that it will perpetuate, rather than address, the housing shortage that exists in the District.

2.6 The single Local Plan Review (discussed in paragraphs 2.10-2.11 of the Written Statement) which is due to commence in 2018, will inevitably be subject to the MHCLG standard

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methodology for calculating OAN which is due for publication in summer 2018 which essentially means that the SHMA will be superseded and ultimately should have no bearing upon the future strategic housing requirement for Mendip District. 2.7 By way of context, the draft standard methodology identifies a FOAN of 588dpa – 40% above the LPPI requirement, and 20% above the SHMA FOAN. This provides evidence of upward pressure on the housing requirement. It is expected that the standard methodology will be introduced in summer 2018, although it is noted that the precise FOAN figures may differ to those set out in the draft. 2.8 In the light of the current housing need context, a pragmatic solution would therefore be to move directly to the single Local Plan review, although it is acknowledged that the Council is committed to the preparation of the LPPII.

2.9 The LPPII responds to the findings of the SHMA by increasing the housing target to 10,685 dwellings over the plan period (2006-2026). This is described as being 11% above the LPPI supply and is based upon an application of the SHMA requirement of 490dpa over the period between 2014 and 2029. Table 3 of the draft Part 2 Plan then identifies a total supply of 11,200 dwellings.

2.10 The rationale for this response is to ensure that an adequate supply of housing can be delivered over the remainder of the Plan period to reflect the latest assessment of housing need. This approach is understood but in light of our concerns regarding the SHMA, it is not considered that the supply response is sufficient to address emerging need in full.

2.11 In addition, although implied through its response to supply, the Council needs to formally acknowledge that the latest SHMA and the proposed amendment to the revised plan target constitutes “significant new evidence” for the purposes of PPG (id 3-030-20140306) and that the 5 year supply should be assessed against a FOAN of (at least) 490dpa, or preferably a figure that responds to the shortcomings of the SHMA (discussed below) and not the LPPI figure of 420dpa. Following the introduction of the standard methodology, that figure (the draft figure being 588 dpa) should be used for the purposes of assessing the five year land supply and this position should be reflected in the Council’s five year land supply statements.

2.12 Currently, the application of an increased supply in light of the ‘significant new evidence’ provided by the SHMA coupled with the use of the much lower LPPI requirement for calculating five year supply is completely self-serving and only seeks to falsely inflate the 5 year supply figures.

Five Year Housing Land Supply 2.13 The ability to maintain a five year supply and achieve the Local Plan housing requirement depends upon the deliverability of sites and the proposed allocations should thus be subject to careful scrutiny to ensure that they can come forward. For the purposes of the representations, Lichfields has not sought to interrogate the supply which is provided by the accompanying housing trajectory. 2.14 The total supply of 11,200 provides a flexibility of just 515 units above the revised target of 10,685 (4.8%) which Lichfields consider insufficient to address and militate against any unforeseen barriers to delivery.

2.15 Between 2006 and 2017, a total of 4,831 dwellings were completed (according to the Council’s Housing Supply Background Paper of December 2017). This represents an over-supply of 211

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dwellings against the LPPI prescribed requirement of 4,620 over this period. Following the conclusions of two planning inspectors (at Land adjacent to “The Navigator”, off Swanwick Lane, Lower Swanwick, Hampshire (APP/A1720/A/14/2220031) 20 January 2015, and land north of Aylesbury Road, Wendover, Buckinghamshire (APP/J0405/W/16/3158833) 9 October 2017), it would be inappropriate to discount any such past over-provision from the future supply because: 1 Such an approach would effectively “mirror” the Sedgefield methodology and, whilst there would be a clear imperative to increase delivery in cases of past under-supply, the reverse is not the case in situations of past over-supply; 2 The effect of such an approach would be a sharp reduction in future housing delivery, which would be at odds with the objective of the NPPF to boost the supply of housing; 3 Any suggestion that an oversupply in the early years could be “banked” so as to reduce the annualised targets later on in the plan period would depend upon taking the requirement figure as a precise target, rather than a “minimum”, which is how Core Policy 2 of LPPI described it; and, 4 There is no evidence that the past oversupply of housing has resulted in vacant houses that are available to meet future needs. Consequently, a future undersupply would create a problem in that it would result in the housing needs of the future population not being met.

2.16 As stated above, Lichfields are of the view that the application of an increased supply against the LPPI figure is falsely inflating the 5 year supply.

2.17 By means of comparison, taking the emerging (SHMA) target of 490 dpa and applying a 5% buffer (but no adjustment for over or undersupply), results in a 5 year target of 2,572 dwellings. The Council’s Housing Supply Background Paper identifies a supply of 3,013 units between 2017/18 and 2021/22. This equates to a supply of 5.85 years. Applying the draft standard methodology figure of 588 dpa (plus 5% buffer but no adjustment), this would reduce the 5 year supply figure further over this period to 4.88 years.

Housing Trajectory (Autumn 2017)

2.18 Lichfields has not sought to interrogate the housing trajectory in significant detail. However, initial comments on this document and the sources which sit behind it are as follows: 1 The cover sheet for the trajectory includes details of the base dates for the various information sources. This shows that dates for completions has been updated to 31 March 2017 and commitments to 31 September 2017. It is considered that a consistent base date should be applied across all components of supply to limited errors of double counting. 2 The Council’s evidence base states two different figures for completions. The Housing Background Paper puts completions 2006-2017 at 4,831 dwellings yet the Housing Completions 2017 document has completions at 4,911 dwellings for the same period. The correct figure should be clarified. 3 There appear to be basic counting errors throughout the housing trajectory. For example, the summary table on page 2 of the trajectory puts supply in Street in the period 2024/25 as 105 units yet the trajectory (page 10) implies this figure is actually 55 units.

2.19 Taking into account the above and some additional scrutiny, Lichfields believe that the supply position has been overstated.

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Review of the Strategic Housing Market Assessment (SHMA) 2.20 As stated above, Lichfields dispute the conclusions of the SHMA and consider that the FOAN is actually much higher than indicated within this document. While in many ways this dispute is academic given the MHCLG standard OAN methodology is due for publication this summer, Lichfields key comments are summarised as follows: 1 Failure to fully consider jobs-housing alignment, including inadequate analysis of past employment trends which are shown to have been higher than the forecasts that were used by JGC. 2 Application of "national level" economic activity data which "should be treated as indicative" without any consideration of local factors (including differences between the various Somerset authorities), and no information regarding the unemployment rates that have been applied. 3 Failure to fully determine the impact of Hinckley Point C upon future housing need in Mendip (and elsewhere). 4 Failure to apply any meaningful adjustment in response to concealed households and suppressed household formation, particularly amongst the 25-34 cohort, which the SHMA recognises to be suppressed. Reliance upon the 2014-based rates will maintain the trend towards suppressed household formation which occurred both during and immediately prior to the recession, and which is demonstrated through the delivery statistics for Mendip. It is noted that the SHMA makes an uplift of 8no. dwellings in response to concealed households, but this is viewed as being wholly inadequate. The only acceptable response would be to apply an adjustment directly to the household formation rates assumed within the 2014-based SNHP. 5 Failure to recognise the signs of market pressure that exists by making an appropriate upward adjustment, in spite of clear evidence of pressure, including: i Average house prices in Mendip in 2016 £235,000, compared to Somerset average of £205,000 and national average of £219,000; ii 343% increase in average house prices between 1995 and 2016, compared to a 290% increase in Somerset and 298% increase nationally; and, iii Affordability ratio (median earnings to median house prices) of 8.61 in 2016, compared to 8.11 in Somerset and 6.95 nationally. 6 Although there is no official guidance on the current approach that should be taken to market signal uplift, it is noteworthy that the LPEG approach would support a 20% uplift whilst the standard methodology is based upon a 40% adjustment. 7 Failure to consider the implications of affordable housing need upon FOAN, contrary to the approach taken in a number of recent HCJs, including Satnam Millennium v Warrington Borough Council (2015), Borough Councils of Kings Lynn and West Norfolk v SoSCLG and Elm Park Holdings (2015) and Jelson v SoS and Hinckley and Bosworth Borough Council (2016). 8 The SHMA concludes a significantly reduced net annual affordable housing need to that suggested in the earlier 2011 Housing Need Assessment (at 838 per annum) despite both being prepared by the same author and there being no obvious explanation (i.e. there has not been a significant boost in affordable housing supply based on the Council’s affordable

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housing completions data and affordability is unlikely to have improved during the intervening period). 9 Lack of justification relating to assumptions made regarding current affordable housing need which appears to suppress this need. For example, 7.8% of remaining 450 current need households in Mendip are removed on the basis that they are expected to be able to afford market housing leaving a backlog of 415 households in affordable housing need in the District. This deduction is made despite these households already having been categorised as being in affordable housing need and banded accordingly in an emergency, gold or silver band. 10 The methodology applied to calculate backlog affordable housing need appears to rely solely on housing waiting list data, whereas the earlier Housing Need Assessment (HNA) (2011) referred to household survey data on overcrowded, concealed and unsuitably housed households. The 2011 approach is more consistent with the guidance provided in the NPPG (ID: 2a-024-20140306) and the reason behind this change in methodology is unclear. 11 Census data (2011) relating to overcrowding and the previous HNA 2011 implies that the SHMA significantly underestimates the level of current affordable housing need. Indeed, HNA considered there were 692 households in unsuitable housing whereas the SHMA is stating just 415 households with no clear understanding provided for this reduction. Concern is raised that the SHMA not does reflect all households in the District that are in affordable housing need. 12 The SHMA’s approach to annualising backlog need over a 25 year period rather than the more standard 5 years (as was adopted by the HNA 2011 and has been tested at appeal) seeks to greatly underestimate affordable need. If, alternatively, the backlog need is annualised on a 5 year basis the net need for additional affordable housing increases to 308 homes per annum. Based on a 308 annual affordable housing need and assuming an overall average delivery of affordable housing being achieved at c.32% of all homes being provided; delivering this level of affordable housing would require a minimum overall housing requirement of c.963 new homes (market and affordable) per annum.

Conclusions 2.21 The approach in the LPPII which essentially seeks to ignore latest evidence on housing requirement yet increase the supply seeks only to inflate the five year housing supply and in the light of our concerns regarding the SHMA, it is not considered that the supply response is sufficient to address emerging need in full. 2.22 Redrow Homes therefore strongly object to the Council’s self-serving use of this new (and flawed) evidence and consider that the Council should consider the outcomes of amendments to NPPF and the standard OAN methodology before making any significant amendments to housing requirement and supply matters particularly given there may be significant implications for the spatial strategy. 2.23 It is considered that in line with the Council’s own statement at paragraph 3.7, the role of re- examining housing requirements is best considered through a single Local Plan Review rather than through the LPPII. The Council should proceed straight into the new local plan review now given the rapidly changing picture on housing need. Other South West authorities have followed this route and omitted housing sites from its Part II in favour of positively expediting a new Local Plan e.g. South Gloucestershire and Mendip should do the same.

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3.0 Beckington (LPPII, Section 11.2) 3.1 Redrow own a site within Beckington known as ‘Land at Bath Road, Beckington’. Redrow submitted a planning application at the site in February 2017 for 28no. dwellings (ref: 2017/0278/FUL) but consent was refused on 21 April 2017 by MDC.

3.2 The site essentially forms ‘Phase 2’ of land at Bath Road, Beckington. Phase 1, which comprised development of 43 dwellings, had reserved matters approved in October 2014. Marketed as ‘The Ridings’, this development sold extremely well. 3.3 Redrow has subsequently appealed the refusal with an Inquiry scheduled to be held in July 2018. 3.4 Beckington is identified in the LPPI as a Primary Village and under Policy CP2, housing numbers in the village were limited to 55 dwellings. In the period 2006-2017, the Council’s development monitoring figures suggest that, 108 houses have been delivered in the village and within the LPPII the Council considers that the village has filled its requirement and is therefore not seeking to deliver any further development.

3.5 However, these representations demonstrate that the methodology for distributing growth across the primary and secondary villages was extremely arbitrary and does not take account of the relative sustainability of the individual settlements.

Sustainability of Beckington

3.6 The levels of growth within the Primary Villages (including Beckington) proposed under the LPPI was informed by the Housing Technical Paper (2012) which is now extremely dated. Para 6.10 of this document discusses the methodology and the need to determine ‘a consistent percentage’ which could be applied that balanced the concerns about overdevelopment in line with the premise accepted in Option B3 of the original Technical Paper.

3.7 The original 2010 version entitled ‘Housing Distribution Options for Mendip’ considered various housing distribution scenarios and describes at para 6.13 how a 15% growth rate was established through a ‘trial and error’ process.

3.8 Essentially, Primary Villages suitable for development were identified and then the dwelling stock for each was increased in increments of 5% until the number of homes discounted (from the starting point of a maximum of 80 in each village) was as close to 400 as could be achieved. 3.9 Therefore, Redrow argue that the 15% growth rate applied to Beckington under the LPP1 is arbitrary and does not relate to the actual sustainability credentials of the settlement itself. 3.10 It is also notable that Beckington (alongside , Coleford, and ) is recognised as one of the most sustainable Primary Villages within Mendip and thus arguably could take more development. Indeed, options were considered within the 2010 document to provide circa 300-350 units in each of these 5 villages.

3.11 The Council produced a Rural Settlement Role & Function Paper (October 2012) which scored the Primary and Secondary villages on their relative sustainability. Beckington (which supports 359 households) scored 15 out of a possible 17, second only to Evercreech (which supports 855 households) with a score of 16 and equal to .

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3.12 Redrow therefore consider that Beckington is a sustainable location for additional growth, which is supported by the Council’s own evidence base and as discussed above, it is clear that the Council needs to reconsider the spatial strategy for the district as part of the Local Plan Review which, on the basis of the emerging standard methodology for calculating OAN, will also require the need for a significant increase in housing requirement. 3.13 Beckington, as one of the most sustainable villages in the district, should therefore be considered as an appropriate location for additional growth, with this site providing a logical and completely contained development site.

3.14 As such, it is requested that the Council give further consideration to the allocation of Redrow’s site in Beckington for 28no. dwellings either through the Local Plan Part 2 or as part of the Local Plan Review. 3.15 Further details relating to the site are provided below.

The Site 3.16 The site has not been promoted through the LPPII previously and is not considered within the accompanying Sustainability Appraisal.

3.17 The site is located to the north of the village of Beckington and is well enclosed by existing development. The site adjoins the existing built form of the village on its southern and south western boundary. The western and north western boundaries of the site adjoins Redrow’s ‘The Ridings’ development which has now been built out. To the east of the site is a lightly wooded area, comprising gardens.

3.18 The site is currently undeveloped although has been used as a construction compound in association with the Phase 1 development. The site adjoins the Beckington Conservation Area on its southern boundary where there are a number of listed buildings located along Goose Street. To the north-east of the site there is a Texaco Garage with 24 hour convenience store and a Travelodge Hotel. Beyond the built form of the village to the east lies the A36 which provides a strong boundary to the wider countryside. The site is not identified as being at risk of flooding by the Environment Agency.

3.19 Beckington is identified within the MDC Local Plan Part 1 as a ‘Primary Village’ which is a second tier settlement in the hierarchy. There are 16 identified Primary Villages of which Beckington falls within the top 3 for sustainability. The site is therefore very sustainable, being within walking distance (11 minutes or less) of a number of services and facilities including but not limited to a 24 hour convenience store, primary school, coffee shop, two pubs, village hall and GP surgery.

3.20 The nearest bus stops to the site are located on either side of Bath Road directly adjacent to the site and within a short walk. There are hourly bus services from these stops Monday to Friday to Trowbridge (20 min journey), (30 min journey), Chippenham and Bath (both 40 min journeys).

3.21 A summary of the site’s location in relation to key facilities is provided as follows:

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3.22 In the course of its determination of the planning application, all technical matters were agreed with the Council and therefore it can be confirmed that there are no overriding technical constraints to development.

3.23 The Council has raised concern regarding heritage although it is noted that the proposed scheme looks to maintain exactly the same landscape buffer as the Phase 1 development and there would be no significant loss of public views into or out of the village which contribute to the setting of historic buildings, no open views from Goose Street (the CAA actually notes that the properties on Goose Street are tightly bounded) and no views from the north and west due to the site being almost fully screened by Phase 1 and boundary planting. It is therefore considered that heritage impacts will be limited and can be mitigated.

3.24 In addition, the Council raised concern regarding landscape but given that the Phase 1 development was determined to have limited visual impact due to the surrounding existing development at Bath Road and at the nearby service area, it is considered that logically the same view must be taken with regard to the Phase 2 scheme.

3.25 Redrow considers that it site known as ‘Land at Bath Road, Beckington’ offers an opportunity to allocate a logical and contained site within one of the most sustainable villages within Mendip. In addition, the scale of development proposed would be proportionate in scale to the Village. It is therefore requested that the Council give due consideration to the allocation of the site either through the Local Plan Part II or as part of the Local Plan Review.

3.26 Redrow would be pleased to discuss this site further with the Council and can provide additional information to support an allocation if required. In the meantime, the site layout plan has been appended to these representations to assist in the identification of the site.

Settlement Boundary Revision (Section 11.2, Development Limit Plan)

3.27 The proposed settlement boundary revision to include Redrow’s completed housing site at Bath Road is welcomed.

3.28 However, the omission of the area to the north of the village which includes a Travelodge, petrol filling station, convenience store and Starbucks appears at odds with the approach taken

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elsewhere within the settlement. These facilities which serve the village should be included within the settlement boundary. In addition the Council has adopted an inconsistent approach with regard to the inclusion / exclusion of residential gardens. These inconsistencies should be rectified.

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KEY

Site Boundary

Soft Landscape (Refer to detailed landscape proposals)

Existing Trees to be retained

04

Existing Trees to be removed

7

Highway Strip. Marshalls Mistral granite sett 8 3 5 Harvest Buff colour or similar approved

9 Fence 1.8 Closeboard

WAR H Knee Rail Fence

10 1.8m Stone Screen wall

11 Single Pedestrian Gate (1m) WAR H H 12 TAV 12 Plot Numbers

S/O TAV 13 8 Plot Parking DAR 14 S/O H 14

15 S/O 26 Social Rented Housing

16 11 17 11

17

R 12 Intermediate Housing 13

R DAR 28 13 H R TAV

V R H DAR V 14 V DAR 27 21 15

22 16

18 23 17 1 19

20 25 3 4 5

24 LEADONH 24 LUDL

V 24 23 Hedgerow trimmed 2 24 LUDL 3 4 23 back as shown 4 25 5 23 22 5 6 6

MAR H 22 21 SW attenuation10 11 10 9 22 tank under9 8 21 8 7 20 21 26 7

LEDB

20 H 19 Hedgerow trimmed 12 20 SUN H LEDB back as shown LEDB 19

LED3

19 H 18

27 13 10 BLEN SHAF 9 14 8 7 16

27

27 28 15

CAN H

28

MAR

29

Proposed footpath link to P.O.S Goose Street

RevisionDate Amendment Initials

Development Land East of Bath Road Location Beckington

Marketing Name - Drawing Title Planning Layout Drawing Number RHSW.5321.02.PL004 Revision Scale @ A2 - 1:500 Drawn By Date Started YW Nov 2016

Checked by Date

Redrow Homes SW 01020 50 Redrow House, Westpoint, Bristol, BS324GQ. Tel: 01454 62500 Fax: 01454 616033 Web: www.redrow.co.uk

Legal Disclaimer TBC SCALE BAR 1:500 This layout has been designed after due consideration of our Context & Constraints Plan