ALP21

North Warwickshire Borough Council Forward Planning Team

The Council House South Street Atherstone CV9 1DE

6 October 2020

Our Ref: MBA/2003/231432/41/MB

By Email

Dear Sirs

NORTH WARWICKSHIRE LOCAL PLAN – ADDITIONAL DOCUMENTS CONSULTATION

We act on behalf of Hallam Land Management Ltd (“HLM”) and write to submit comments on the additional documents consultation in respect of the examination of the North Warwickshire Local Plan. Our comments specifically relate to the current schedule of potential Main Modifications (NWBC20E).

MM25: LP5 – Strategic Gap. Whilst HLM maintain their objection regarding the methodology and evidence on which the boundaries of the gap have been formulated (see Regulation 19 submissions and Matter Statement 6), specifically on the amendments proposed under MM25, these are considered positive. The text of the policy within the Submission version of the Plan is overly restrictive, even more so than Green Belt policy, and the suggested paragraph 3 allows for a more site specific and balanced approach, which accords with national policy.

However, the supporting text to Policy LP5 will also need to be amended to reflect the policy wording change through MM25. We would suggest the final sentence of paragraph 7.31 is deleted to reflect the more flexible approach of the revised policy wording. This states:

“Its purpose is clear in that it is to maintain the gap, both visually and in landscape terms between the urban areas of Polesworth, Dordon and Tamworth.”

We also suggest the wording of para 7.32 is either changed to the below, again to be consistent with the policy amendments, or deleted altogether, as it will effectively repeat the wording of the policy.

7.32 In order to retain the separate identity of these settlements, new development should not visually or physically reduce the size of the gap significantly reduce the visual separation between Polesworth with Dordon and Tamworth

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MM34: LP6 – Amount of Development. The suggested amendments to Policy LP6 are supported. HLM had previously objected to the ‘further 3790 dwellings’ accommodated from the Greater Birmingham Housing Market Area being expressed as ‘aspirational’ as this was not sufficiently clear and failed all four tests of paragraph 182 of the NPPF (2012 version). The revision to provide the total minimum number of dwellings as 9,598 largely resolves this issue.

However, we also suggest that the final sentence is deleted. This reads “The actual amount of development delivered over the plan period will be governed by the provision of infrastructure to ensure developments are sustainable.” This is a ‘hangover’ from the previous approach of the 3,790 dwellings being ‘aspirational’. It still leaves ambiguity and is unnecessary wording. If there is specific infrastructure required for development this should be identified on a site by site basis.

MM89: H13 – Land west of Robey’s Lane, adjacent Tamworth. This site is promoted by HLM. Whilst HLM maintain that the allocation should be extended to the east, for the reasons set out in their Regulation 19 representations/Hearing Statement and as reflected in their current planning application (ref: PAP/2018/0755), in isolation the amendments to Policy H13 are supported. In particular the removal of the requirement for the primary vehicular access to be achieved via the adjacent former Tamworth Golf Course site is welcomed and reflects that such an access is not deliverable.

To reflect the above policy wording change it is also recommended that paragraph 14.52 be amended as follows:

“The land to the west of Robey’s Lane was not considered to be part of the Meaningful Gap due to its relationship to Tamworth and is seen as an opportunity to develop a site directly adjacent to the site of the former Golf course which is currently under construction in Tamworth. The opportunity exists to provide pedestrian and cycle access with this site to ensure that the developments are undertaken comprehensively.”

Yours faithfully

This letter is approved but unsigned as it is sent electronically.

Mark Bassett Principal Manager Please respond by e-mail where possible

ALP22 October 2020 | NCO | BIR.5373

NORTH WARWICKSHIRE LOCAL PLAN EXAMINATION

LOCAL PLAN – ADDITIONAL DOCUMENTS CONSULTATION RESPONSE

LAND OFF PACKINGTON LANE & BLYTHE ROAD, COLESHILL

ON BEHALF OF RICHBOROUGH ESTATES (SLP430)

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Richborough Estates Additional Documents Response

Contents Page No.

1. INTRODUCTION 1 2. HOUSING REQUIREMENTS 1 3. INFRASTRUCTURE REQUIREMENTS 2 4. STEPPED TRAJECTORY 3 5. LEAD IN TIMES 4 6. DELIVERY RATES 5 7. BUFFER & FLEXIBILITY 6 8. TRAJECTORY 7 9. SAFEGUARDED LAND 8 10. CONCLUSION 9

APPENDIX 1: Lichfields Start to Finish (Second Edition) Feb 2020

APPENDIX 2: Pegasus Changes to NWBC24C Trajectory

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Richborough Estates Additional Documents Response

1. INTRODUCTION

1.1 This representation has been prepared by Pegasus Group on behalf of Richborough Estates who has land interests within North Warwickshire Borough. This statement provides a response to the ‘Local Plan- Additional Documents’ in respect of Richborough Estates’ interest relates to land off Packington Lane, Coleshill and land off Blythe Road, Coleshill.

1.2 These representations relate specifically to the schedule of potential main modifications (NWBC20E) and further evidence that has been produced in respect of housing need and supply, including NWBC26A, NWBC26B and NWBC26C.

2. HOUSING REQUIREMENTS

2.1 In respect of OAHN the LP is based primarily upon evidence contained within the Strategic Housing Market Assessment Update (CD8/10) published in September 2015, over 5 years ago, which utilised the 2012 SNHP. The Inspector identifies within INSP21 that the 2018-based SNHP indicate a likely uplift in household formation in coming years relative to previous, data series.

2.2 Utilisation of the 2018 SNHP would result in the minimum housing requirement rising to 10,015. As set out in NWBC27, this is an increase of 417 dwellings over the plan period. Richborough Estates consider the 2018 SNHP should now be utilised to determine the OAHN for the purposes of this Local Plan on the basis the SHMA is out of date. Therefore, the housing requirement should be amended to a minimum of 10,015 over the proposed 22 year plan period. The required flexibility in supply should also be provided to ensure this OAHN can be delivered within the Plan period.

2.3 At present, the flexibility in the proposed supply contained within the emerging Local Plan would be insufficient to deliver a minimum of 10,015 homes, even if all identified sources of supply were realised within the plan period.

2.4 It is noted that the Council contends, through NWBC27, that there is no effective potential for additional supply to be brought forward in North Warwickshire, however this cannot be the case when there is currently no meaningful proposed housing development focused to Coleshill; a Category 1 Market Town, where the only constraint to development is a tightly drawn Green Belt boundary. Richborough Estates provided representations through Matter 3 in respect of reliance on the conclusions contained within the SGS which are not repeated here.

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Richborough Estates Additional Documents Response

2.5 In addition, representations submitted by Richborough Estates highlighted there is significant potential to increase supply within a number of settlements within North Warwickshire Borough. Examples include settlements such as Coleshill and Water Orton, where development is artificially constrained by Green Belt. In these settlements it can be demonstrated that locally derived housing needs will not be met through the implementation of the emerging strategy resulting in increased house prices, which are already significantly above the Borough average. In addition, as these settlements have strong functional links with the conurbation, including train stations with direct services to Birmingham and good access to existing and planned employment provision such as UK Central and Hams Hall, market attractiveness of these settlements will only increase.

2.6 MM34 should be amended accordingly.

3. INFRASTRUCTURE REQUIREMENTS

3.1 The Inspector, within INSP18, recognises that a significant element of the development proposed relies upon the improvements to the A5. The following three options were set out by the Inspector to overcome fundamental issues of soundness:

a) await the outcome of the HIF bid and unambiguously identify the likely source(s) of funding for the dualling of the A5; or

b) put forward alternative sites that do not rely on highways improvements for which funding is not certain or unknown; or

c) withdraw the plan.

3.2 Whilst it is agreed that MHCLG funds have been identified for the improvements to the A5 corridor as part of the RIS process, it is clear from the ‘Additional Documents’ subject to this consultation, including NWBC26 written in July 2020, there is still no agreement between Homes England, Highways England, Warwickshire County Council, the Department for Transport and the MHCLG on the delivery of such a scheme or indeed the timescales for delivery. NWBC26 highlights that such agreement is required prior to determining the ‘actual stepped trajectory.’

3.3 In light of the above lack of clarity in respect of the delivery of the A5 improvements, Richborough Estates considers it necessary for alternative sites to be put forward that do not rely on such improvements. If an alternative strategy

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Richborough Estates Additional Documents Response

is not pursued the Local Plan should at the very least identify further allocations, that are not reliant upon the A5 improvements. Such allocations should be consistent with the settlement hierarchy set out in LP2, including within Coleshill as a Category 1 Market Town, recognising that LP2 requires development within the Borough to be ‘proportionately distributed and be of a scale that is in accordance with the Borough’s settlement hierarchy.

4. STEPPED TRAJECTORY

4.1 INSP20 requests the establishment of a stepped housing trajectory which aligns to the overarching requirement of the Plan period with an appropriate degree of flexibility, justified by revisited evidence of lead-in-times and delivery rates.

4.2 The Council has prepared a number of stepped trajectories and it is understood from NWBC27 that the Option 2 trajectory is the Council’s preferred option. This stepped trajectory assumes a continuation of 203 dpa until 2018 and rising incrementally to 775 dpa in the final eight years of the plan period.

4.3 Richborough Estates does not support the introduction of the stepped trajectory; one that has been contrived to respond to an unsound distribution of proposed housing growth where delivery is predicated on the as yet uncommitted A5 improvements.

4.4 In addition, no clear evidence has been provided by the Borough Council in devising this stepped trajectory, the effect of which will be to result in identified housing need, both market and affordable, not being met within the Borough in the short to medium term. This is particularly pertinent in respect of affordable housing where need remains high and is identified by the Borough Council as being between 149 and 267 dwellings per annum which, at the top end of that range, is significantly higher than the annual housing requirement until 2024.

4.5 In line with INSP21 the stepped trajectory should not unnecessarily delay meeting identified development needs and it is therefore questioned whether it is appropriate that the Local Plan will fail to boost supply until 2024/25, some 13 years into a 21 year plan period.

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Richborough Estates Additional Documents Response

5. LEAD IN TIMES

5.1 The Council’s evidence of lead in times and delivery rates published within NWBC24B, Annex 1 is not supported by Richborough Estates.

5.2 In light of the lack of evidence in respect of lead-in times for development of the scale of proposed allocations within the emerging Local Plan it is considered necessary to rely on national trends.

5.3 Evidence was submitted By Richborough Estates in respect of lead-in times as part of Matter 9 discussions and therefore is not repeated here. However, it should be noted that Lichfield’s ‘Start to Finish’ Second Edition (Appendix 1) was published in February 2020 and provides more up to date evidence. This concludes the following average lead-in times nationally for a range of sites:

Site Size Average Average Average Validation of 1st Planning Planning to Application to 1st Approval Delivery Completion Period Period

50-99 1.4 2.0 3.3 years

100-499 2.1 1.9 4.0 years

500-999 3.3 1.7 5.0 years

1,000-1,499 4.6 2.3 6.9 years

1,500-1,999 5.3 1.7 7.0 years

Source: Lichfields Start to Finish ‘Second Edition’ 2020

5.4 In respect of H2 and H7 the supply trajectory assumes first deliveries on both sites in April 2025, some 4.5 years from today's date. Applications have not been submitted in respect of either site and therefore first completions should be pushed back to April 2028 at the very earliest in line with national trends evidence set out above.

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Richborough Estates Additional Documents Response

6. DELIVERY RATES

6.1 The delivery rates assumed in respect of a number of proposed allocations are considered completely unrealistic. The Inspector’s view contained within INSP20, that there is no compelling justification for anticipated build-out rates significantly above national trends is supported by Richborough Estates. The Council’s approach to the delivery trajectory, of applying either 50 dwellings per annum per sales outlet, or accepting trajectories provided by developers without significant scrutiny, is not a robust approach.

6.2 Evidence was submitted By Richborough Estates in respect of build out rates as part of the Matter 9 discussions and therefore is not repeated here. However, it should again be noted that Lichfield’s ‘Start to Finish’ Second Edition, published in February 2020 (Appendix 1), concludes the following average rates nationally at which new homes are built on sites:

Site Size Start to Finish 2016 Start to Finish 2020 Difference ‘First Edition’ build-out ‘Second Edition’ rates build-out rates

50-99 27 22 -5 (-19%)

100-499 60 55 -5 (-8%)

500-999 70 68 -2 (-3%)

1,000-1,499 117 107 -10 (-9%)

1,500-1,999 129 120 -9 (-7%)

Source: Lichfields Start to Finish ‘Second Edition’ 2020

6.3 The maximum annual delivery rates assumed by the Council on a number of the proposed allocations should be amended as overall, it is considered that the application of the above delivery rates is a realistic and justified approach which takes account of market absorption. The table below sets out the difference between the average delivery rates contained within NWBC26C and national trends contained within the recently published Start to Finish Report.

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Richborough Estates Additional Documents Response

Site Number of Start to Finish NWBC average Difference Allocation proposed 2020 average build-out rates Dwellings build-out rates

H1 499 55 55 0 (0%)

H2 1,282 107 160 +53 (+50%)

H7 1,969 120 209 +89 (+74%)

H13 1,270 107 127 +20 (+19%)

H20 450 55 56 +1 (+2%)

6.4 In light of the above, the supply trajectory should be amended in respect of H2, H7 and H13 in line with the national trends evidence identified in the tables above. The assumed delivery rates for H2 and H7 are significantly in excess of what can realistically be expected even with multiple sales outlets and is therefore not justified.

7. BUFFER & FLEXIBILITY

7.1 INSP18 highlighted that a phased trajectory with a 5% five year land supply buffer ‘may be appropriate.’ INSP20 again requests the establishment of a stepped trajectory with ‘an appropriate degree of flexibility, justified by revisited evidence of lead-in times and delivery rates.’

7.2 NWBC26 provides the Council’s approach to the issue of flexibility within the housing trajectory. It is clear that a 5% five year housing land supply buffer has not been included within the trajectory as a 5% buffer has only been applied to the forward supply minus any sites that benefit from planning permission. A 3% lapse rate has then been applied to the committed supply. This approach is incorrect and unsound and does not provide the necessary buffer or an appropriate degree of flexibility required.

7.3 A non-implementation rate is very different to a buffer. The buffer performs a totally different role. It is not a tool to ensure the local plan requirement can be met, but simply seeks to allow supply to be moved forward in the plan period, endeavouring to bring forward additional capacity now to ensure housing is

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boosted significantly and ensure that in the immediate future shortfalls do not occur. In essence it is there to enable housing supply to have a fighting chance of being boosted significantly. Therefore, the buffer should be applied to the committed supply not yet delivered irrespective of the non-implementation rate. To overcome this issue of unsoundness further supply needs to be identified within the emerging Local Plan. This is particularly important within a stepped trajectory as such an approach would clearly result in a delay in meeting identified development needs.

7.4 A 5% buffer alone does not constitute the necessary flexibility required for the proposed housing strategy. Whilst it is recognised that a 3% non-implementation rate has been applied to the committed supply, the housing trajectory is predicated on the A5 improvements being delivered within specific date milestones. Richborough Estates considers that reliance on the A5 improvements being delivered, and delivered in line with the assumed milestones, represents a significant risk to the strategy and the ability of the housing requirement of 9,598 homes being delivered within the Plan period. This is particularly true as the A5 improvement project remains uncommitted as it is still subject to further clarification and detail.

7.5 It is accepted that the Local Plan seeks to provide limited flexibility through the identification of reserve sites. However, one of these reserve sites (RH1) is also predicated upon the delivery of the A5 improvements. Richborough Estates consider that the identified reserve sites do not provide the necessary flexibility within the housing trajectory to provide any certainty that the identified housing needs can be met within the Plan period. To address this unsoundness further reserve sites should be identified, that are not reliant upon the A5 improvements, to provide the necessary flexibility to ensure certainty of delivery.

8. TRAJECTORY

8.1 Having regard to national trends evidence and the requirement to provide a 5% buffer, further allocations are required to ensure the delivery of the OAHN within the plan period.

8.2 A revised trajectory has been prepared and is attached at Appendix 2 to these representations. This demonstrates the need to allocate additional land necessary to deliver a minimum of a further 1,967 homes to 2033 to meet an OAHN of 9,598 homes or a minimum of a further 2,445 homes to 2033 to meet an increased OAHN of 10,015 homes in line with the 2018 SNHP.

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Richborough Estates Additional Documents Response

9. SAFEGUARDED LAND

9.1 Richborough Estates objects to the principle of removing Policy LP4 Safeguard Land for Potential Future Development (MM24). INSP18 paragraph 16 sought justification from the Council for release or safeguarding for potential development of land in the Green Belt, recognising the evidence did not justify the only area of safeguarded land being adjacent to Kingsbury via Policy LP4.

9.2 At paragraph 17 of INSP18 identifies the ambiguity in the Plan in respect of Coleshill, recognising that land at Coleshill was previously recommended for safeguarding [AD20A], a higher order settlement to Kingsbury. The Inspector suggests that for ‘consistency’ with national policy ‘either the plan’s approach to safeguarding Green Belt land at Kingsbury should be revised, or additional land should be safeguarded at other settlements in line with the plan’s settlement hierarchy.’

9.3 Richborough Estates considers the removal of land at Kingsbury as a safeguarded site is not the correct response and fails to provide consistency with national guidance. Paragraph 85 of the NPPF 2012 is clear that LPAs should “where necessary, identify in their plans areas of ‘safeguarded land’ between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period” and “satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.”

9.4 The submitted Local Plan justified the need for ‘safeguarded land’ for potential future development and this position has not changed. The Council’s justification for Green Belt release related to (i) pressures for growth, (ii) the role of different settlements, and (iii) site specific circumstances. The Inspector agreed these were ‘reasonable considerations.’ Whilst these considerations did not support a single area of safeguarded land at Kingsbury, the solution to this issue of soundness cannot simply be the removal of this site from the Plan.

9.5 The Local Plan is required to consider whether the existing Green Belt boundary remains appropriate when considering needs within the current Plan period and the longer-term development needs of the Borough beyond the Plan period. Richborough Estates supports the Council’s position that there are exceptional circumstances for Green Belt release within the plan period and the previously contended position that there is a need to support the longer-term development needs of the Borough.

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Richborough Estates Additional Documents Response

9.6 Richborough Estates maintains the position that in the longer-term, settlements including Coleshill will need to retain a role in providing new homes to meet the objectively assessed housing needs of the Borough, including identified local needs for affordable homes. With the existing Green Belt drawn tightly around the existing settlement boundaries, it is necessary to release land from the Green Belt to ensure future needs can be met and the vitality of services and facilities can be maximised in the longer term. In addition, the pressures to identify further land to accommodate housing in the future will only be exacerbated by the likely continuation of pressures being placed on North Warwickshire from beyond the Borough boundaries.

9.7 By removing all safeguarded land the Local Plan is ineffective in ensuring long term development needs can be met and the Green Belt boundaries will endure well beyond the Plan Period. There is a need for land to be allocated outside the current settlement boundary of Coleshill to meet both market and affordable housing needs in the short term, but there will be a continued need to meet housing needs within Coleshill and other sustainable settlements well beyond the current plan period. Due to the constrained nature of Coleshill, its position within the settlement hierarchy and identified local housing needs emanating from within the settlement and it’s hinterland there is a requirement to remove land from the Green Belt and identify safeguarded land to allow for longer term development beyond the Plan period. Safeguarded land in other local services centres should also be identified having regard to the Council’s identified considerations.

10. CONCLUSION

10.1 The Main Modifications fail to address Richborough Estates significant concerns raised with regards to the fundamental mismatch between the identified settlement hierarchy and the spatial distribution of housing that would result from the identified housing allocations. The proposed housing allocations and committed development would result in the delivery of a spatial strategy which would not constitute sustainable development, resulting in: a significant imbalance in jobs and homes within a number of settlements, including Coleshill; failure in local housing needs (both market and affordable) being met; and, the promotion of unsustainable travel patterns, placing greater strain on infrastructure. To resolve this unsoundness, it is necessary to direct significantly more development to the Category 1 Market Town of Coleshill.

10.2 It is recognised that focusing a greater proportion of housing growth to Coleshill would require the removal of land from the Green Belt, however, this is the only

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option that would allow for a sustainable distribution of growth across the Borough over the Plan Period. There are a number of clear exceptional circumstances to support the removal of land from the Green Belt around this Category 1 Market Town, including:

• Coleshill is the second most sustainable standalone settlement within the Borough and Green Belt release is the only option to allow it to accommodate growth in line with the identified settlement hierarchy;

• Further development at Coleshill is the only reasonable option available to ensure the Spatial Objective 1 of securing a sustainable pattern of development can be met;

• Additional growth is required to support the maintenance of the working age population within Coleshill. This is important to ensure a relative balance between jobs and workers that can assist in meeting the Council’s vision of reducing out commuting and unsustainable travel patterns; and

• Additional growth is required to allow local housing needs (market and affordable) to be met within Coleshill, to ensure existing issues of affordability are not perpetuated and exacerbated.

10.3 In relation to neighbouring need, it is noted that North Warwickshire has agreed to accommodate the unmet need from Neighbouring LPAs and the housing requirement, including cross boundary provision, is now expressed as a minimum (MM34). This approach is supported by Richborough Estates. However, the 2018 SNHP should now be utilised to determine the OAHN for the purposes of this Local Plan. Therefore, a revised housing requirement should be identified of a minimum of 10,015 over the 22 year plan period.

10.4 Richborough Estates has identified significant concerns in respect of the housing trajectory which is not based on robust trends. The housing trajectory contained within NWBC26C does not identify a 5% buffer and fails to have regard to national trends evidence on lead-in times and build out rates. It has been demonstrated that additional land is required to be allocated to ensure the OAHN can be delivered within the Borough to 2033.

10.5 Richborough Estates considers the removal of a safeguarded land policy through MM24 is not the correct response to address the Inspector’s concerns and fails to provide consistency with national guidance. It is considered necessary to release

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Richborough Estates Additional Documents Response

additional land from the Green Belt in appropriate settlements to allow for longer term development needs to be met and for Green Belt boundaries to endure well beyond the plan period. This is necessary to ensure consistency with paragraph 85 of the NPPF 2012. Safeguarded land will be required at Coleshill to support the development needs of a Category 1 settlement constrained by Green Belt.

10.6 A lack of housing development within Coleshill within the plan period and beyond will result in local housing needs not being met. In addition, the lack of proposed housing will result in a significant imbalance between the jobs available and the economically active local population to support sustainable economic growth. This mismatch between the provision of jobs and homes will inevitably lead to unsustainable commuting patterns, placing increasing strain on local infrastructure. The proposed Main Modifications do not address this.

10.7 Land off Packington Lane, Coleshill and Land off Blythe Road, Coleshill are suitable and sustainable locations for residential development and represents deliverable and developable propositions, with both locations being available now and providing every prospect that a significant number of homes can be delivered within the next five years. The suitability of these sites for residential development are fully detailed within previous submissions.

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APPENDIX 1 INSIGHT FEBRUARY 2020 Start to Finish What factors affect the build-out rates of large scale housing sites? SECOND EDITION Lichfields is the pre-eminent planning and development consultancy in the UK We’ve been helping create great places for over 50 years.

lichfields.uk Executive summary

Lichfields published the first edition of Start to Finish in November In too many local plans and five-year land supply cases, 2016. In undertaking the research, our purpose was to help inform there is insufficient evidence for how large sites are the production of realistic housing trajectories for plan making and treated in housing trajectories. Our research seeks to fill decision taking. The empirical evidence we produced has informed the gap by providing some benchmark figures - which numerous local plan examinations, S.78 inquiries and five-year land can be of some assistance where there is limited or supply position statements. no local evidence - but the averages derived from our analysis are not intended to be definitive and are no Meanwhile, planning for housing has continued to evolve: with alternative to having a robust, bottom-up justification for a revised NPPF and PPG; the Housing Delivery Test and Homes the delivery trajectory of any given site. England upscaling resources to support implementation of large sites. Net housing completions are also at 240,000 dwellings per annum. With this in mind, it is timely to refresh and revisit the evidence on the speed and rate of delivery of large scale housing sites, now looking at 97 sites over 500 dwellings. We consider a wide range of factors which might affect lead-in times and build-out rates and have drawn four key conclusions.

We have drawn four key conclusions:

1 Large schemes can take 5+ years to start 2 Lead-in times jumped post recession

Our research shows that if a scheme of more than 500 dwellings has Our research shows that the planning to delivery period for large an outline permission, then on average it delivers its first home in sites completed since 2007/08 has jumped compared to those where c.3 years. However, from the date at which an outline application is the first completion came before 2007/08. This is a key area where validated, the average figures can be 5.0-8.4 years for the first home improvements could be sought on timeliness and in streamlining pre- to be delivered; such sites would make no contribution to completions commencement conditions, but is also likely impacted by a number of in the first five years. macro factors.

3 Large greenfield sites deliver quicker 4 Outlets and tenure matter

Large sites seem to ramp up delivery beyond year five of the Our analysis suggests that having additional outlets on site has a positive development on sites of 2,000+ units. Furthermore, large scale impact on build-out rates. Interestingly, we also found that schemes with brownfield sites deliver at a slower rate than their greenfield more affordable housing (more than 30%) built out at close to twice the equivalents: the average rate of build out for greenfield sites in our rate as those with lower levels of affordable housing as a percentage of all sample is 34% greater than the equivalent brownfield. units on site. Local plans should reflect that – where viable – higher rates of affordable housing supports greater rates of delivery. This principle is also likely to apply to other sectors that complement market housing for sale. Key sites assessed, with combined yield of 213k+ dwellings; 97 sites figures 180 had 500+ homes

average time taken from outline decision notice to first dwelling completions on c.3yrs sites of 500+ homes

the average time from validation of the first planning application to the first dwelling being 8.4yrs completed on schemes of 2,000+ dwellings

the average annual build-out rate for a scheme of 2,000+ 160 dpa dwellings (median: 137)

the average annual build rate of a scheme 68 dpa of 500-999 dwellings (median: 73)

higher average annual build-out rate on +34% greenfield sites compared with brownfield sites

average completions per outlet on sites with one outlet, dropping to 51 for sites of two 61 dpa outlets, and 45 for sites with three outlets INSIGHT START TO FINISH

01 Introduction

This is the second edition of our review on the speed of delivery on large-scale housing development sites. The first edition was published in November 2016 and has provided the sector with an authoritative evidence base to inform discussions on housing trajectories and land supply at planning appeals, local plan examinations and wider public policy debates. Over this period, housing delivery has remained at or near the top, of the domestic political agenda: the publication of the Housing White Paper, the new NPPF, an emboldened Homes England, a raft of consultations on measures intended to improve the effectiveness of the planning system and speed up delivery of housing. Of particular relevance to Start to Finish was the completion of Sir Oliver Letwin’s independent review of build out (“the Letwin Review”), the inclusion within the revised NPPF of a tighter definition of ‘deliverable’ for the purposes of five-year housing land supply (5YHLS) assessment, and the new Housing Delivery Test which provides a backward Our research complements, rather than supplants, looking measure of performance. The policy aim is to focus more the analysis undertaken by Sir Oliver Letwin in his attention on how to accelerate the rate of housing build out, in Review. The most important differentiation is that the context of the NPPF (para 72) message that the delivery of a we focus exclusively on what has been built, whereas large numbers of new homes can often be best achieved through each of the sites in the Letwin Review included larger scale development such as new settlements or significant forecasts of future delivery. Additionally, the Letwin extensions to existing villages and towns, but that these need a Review looked at 15 sites of 1,500+ homes, of which realistic assessment of build-out rates and lead in times of large-scale many (including the three largest) were in London. By development. contrast, the examples in this research sample include 46 examples of sites over 1,500 homes across England This second edition of Start to Finish is our response to the latest and Wales, the majority of which are currently active. policy emphasis. It provides the planning sector with real-world As with the first edition of our research, we have benchmarks to help assess the realism of housing trajectory excluded London because of the distinct market and assumptions, particularly for locations where there have been few delivery factors in the capital. contemporary examples of strategic-scale development. The first edition looked in detail at how the size of the site affected build-out rates and lead in times, as well as other factors such as the value of the land and whether land was greenfield or brownfield. We have Contents updated these findings, as well as considering additional issues such 01 Introduction 1 as how the affordability of an area and the number of outlets on a site impacts on annual build-out rates. 02 Methodology 2 5 We have also expanded the sample size (with an extra 27 large 03 Timing is everything sites, taking our total to 97 large sites, equivalent to over 195,000 04 How quickly do sites build out? 9 dwellings) and updated with more recent data to the latest 05 What factors influence build-out rates? 14 monitoring year (all data was obtained at or before the 1st April 2019). 06 Conclusions 18

1 INSIGHT START TO FINISH 02 Methodology 180 sites The evidence presented in this report analyses by significant amounts of pre-application how large-scale housing sites emerge through engagement and work, plus the timescale of the the planning system, how quickly they build local plan process. out, and identifies the factors which lead to 97 The ‘planning to delivery’ period follows faster or slower rates of delivery. large sites of 500 immediately after the planning approval period units or more We look at the full extent of the planning and measures the period from the approval and delivery period. To help structure the of the first detailed application to permit research and provide a basis for standardised development of dwellings and the completion measurement and comparison, the various of the first dwelling. 27 stages of development have been codified. additional sites Figure 1 sets out the stages and the milestones Development and data compared with our used, which remain unchanged from the first Whilst our analysis focuses on larger sites, we 2016 research edition of this research. The overall ‘lead-in have also considered data from the smaller time’ covers stages associated with gaining sites for comparison and to identify trends. The an allocation, going through the ‘planning geographic distribution of the 97 large sites and approval period’ and ‘planning to delivery comparator small sites is shown in Figure 2 8 period’, finishing when the first dwelling is and a full list can be found in Appendix 2 (large sites also included completed. The ‘build period’ commences when sites) and Appendix 3 (small sites). in Sir Oliver Letwin’s the first dwelling is completed, denoting the Efforts were made to secure a range of locations review end of the lead-in time. The annualised build- and site sizes in the sample, but there is no way out rates are also recorded for the development of ensuring it is representative of the housing up until the latest year where data was available market in England and Wales as a whole, and at April 2019 (2017/18 in most cases). Detailed thus our conclusions may not be applicable definitions of each of these stages can be found in all areas or on all sites. In augmenting our in Appendix 1. Not every site assessed will sample with 27 additional large sites, new necessarily have gone through each component to this edition of our research, we sought to of the identified stages as many of the sites include examples in the Letwin Review that we considered had not delivered all dwellings were outside of London, only excluding them permitted at the time of assessment, some have not delivered any dwellings. Information on the process of securing a Box 1: Letwin Review sites development plan allocation (often the most significant step in the planning process for 1. Arborfield Green (also known as large-scale schemes, and which – due to the Arborfield Garrison), Wokingham nature of the local plan process - can take decades) is not easy to obtain on a consistent 2. Ledsham Garden Village, Cheshire West basis across all examples, so is not a significant & Chester focus of our analysis. Therefore, for the 3. Great Kneighton (also known as Clay purposes of this research the lead-in time Farm), Cambridge (included in the first reflects the start of the planning approval edition of this research) period up to the first housing completion. 4. Trumpington Meadows, Cambridge The ‘planning approval period’ measures the 5. Graven Hill, Cherwell validation date of the first planning application 6. South West Bicester, Cherwell on the site (usually an outline application but sometimes hybrid), to the decision date of the 7. Great Western Park, South Oxfordshire first detailed application to permit dwellings 8. Ebbsfleet, Gravesham and Dartford in the scheme (either full, hybrid or reserved (included in the first edition of this matters applications). It is worth noting that research) planning applications are typically preceded

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when it was difficult to obtain reliable data. The The sources on which we have relied to secure study therefore includes the Letwin Review’s delivery data on the relevant sites include: case studies listed in Box 1. 1. Annual Monitoring Reports (AMRs) and In most instances, we were unable to secure other planning evidence base documents1 the precise completion figures for these sites produced by local authorities; that matched those cited in the Letwin Review. 2. By contacting the relevant local planning Sources for data Lichfields has obtained on authority, and in some instances the completions for those sites that also appear in relevant County Council, to confirm the the Letwin Review are included at the end of data or receive the most up to date figures Appendix 2. from monitoring officers or planners; and 3. In a handful of instances obtaining/ confirming the information from the relevant house builders.

Figure 1: Timeline for the delivery of strategic housing sites

Securing an allocation

Submission to Site Promotion and Local Secretary of Plan Consultations State (SoS) Suspension of Examination in Public (EIP) Inspector finds ! examination or Local Plan sound withdrawal of Adoption of Local Plan Local Plan Local Planning Authority adopts Local Plan Securing planning permission

Pre-Application Work EIA Screening Planning approval period* Local Planning ! and Scoping Lead-in time* Authority Outline Application minded to Full Planning approve Application S106 Judicial SoS call in/ S106 ! Review application Reserved matters (potential refused/ Planning for) appeal lodged

permission period * Planning to delivery granted Discharge pre-commencement conditions

On site completions Start on site Delivery of infrastructure ‘Opening up works’ ! (e.g. roads) and 1 First housing mitigation (e.g. ecology, completion flooding etc) period* Build

Delivery of dwellings Scheme complete 1 Monitoring documents, five-year land supply reports, housing trajectories (some in land availability Data obtained only for some sites Data obtained for all sites *Definition for research purposes assessments), housing development reports and newsletters Source: Lichfields analysis

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Figure 2: Map of site sample by size of site (total dwellings)

196,714 Large housing sites units on large sites Number of Units of 500 or more 2,000+ homes 1,500-1,999

1,000–1,499 16,467 500–999 units on small sites Small housing sites Number of Units under 500 homes 100–499 35 <100 sites of 2,000 homes or more

Source: Lichfields analysis

4 INSIGHT 03 START TO FINISH Timing is everything: how long does it take to get started?

In this section we look at lead in times, the considered deliverable where there is clear evidence time it takes for large sites to get the necessary that housing completions will begin on site within planning approvals. Firstly, the changing five years”. (emphasis added) c.3 years context of what ‘deliverable’ means for What constitutes ‘clear evidence’ was clarified development. Secondly, the ‘planning approval average time from in a number of early appeal decisions and in the obtaining outline period’ (the time it takes for large sites to get Planning Practice Guidance2 and can include permission to first the necessary planning approvals). And thirdly, information on progress being made towards dwelling completion the ‘planning to delivery period’ (the time submission of a reserved matters application, on sites of 500+ from approval of the first detailed application any progress on site assessment work and homes to permit development of dwellings to the any relevant information about site viability, completion of the first dwelling). ownership constraints or infrastructure provision. In this context, it is relevant to look The new definition of ‘Deliverable’ at how long it takes, on average, for a strategic The question of how quickly and how much housing site to progress from obtaining outline housing a site can begin delivering once it permission to delivering the first home (or how has planning permission, or an allocation, has long it takes to obtain the first reserved matters become more relevant since the publication approval, discharge pre-commencement of the new NPPF with its new definition conditions and open up the site), and then how of deliverable. Only sites which match the much housing could be realistically expected to deliverability criteria (i.e. suitable now, be completed in that same five-year period. available now and achievable with a realistic prospect that housing will be delivered on Based on our sample of large sites, the the site within five years) can be included in a research shows that, upon granting of outline calculation of a 5YHLS by a local authority. This permission, the time taken to achieve the first definition was tightened in the revised NPPF dwelling is – on average c.3 years, regardless of which states that: site size. After this period an appropriate build- out rate based on the size of the site should “sites with outline planning permission, permission also be considered as part of the assessment of in principle, allocated in the development plan or deliverability (see Section 4). Outline planning identified on a brownfield register should only be permissions for strategic development are not

Figure 3: Average time taken from gaining outline permission to completion of the first dwelling on site (years), compared to site size

3.5 3.1 3.2 3.1 3.0 2.9 3.0 2.8

2.5 2.5 2.5

2.0

1.5

1.0

0.5

Outline permission to first dwelling completed (years) 0.0 500-999 1,000-1,499 1,500-1,999 2,000+

Site size (dwellings) Mean Median 2 Planning Practice Guidance Reference ID: 68- Source: Lichfeilds analysis 007-20190722

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always obtained by the company that builds Comparison with our 2016 the houses, indeed master developers and other land promoters play a significant role in findings bringing forward large scale sites for housing Planning Approval Period Only sites of fewer development3. As such, some of these examples Our latest research reveals little difference than 499 dwellings will include schemes where the land promoter are on average likely between the average planning approval period or master developer will have to sell the site to deliver any homes by site size compared to the same analysis in the (or phases/parcels) to a housebuilder before within an immediate first edition (see Table 1). However, it is important five year period. the detailed planning application stage can to remember that these are average figures commence, adding a step to the planning to which come from a selection of large sites. There delivery period. are significant variations within this average, Figure 4 considers the average timescales with some sites progressing very slowly or for delivery of the first dwelling from the quickly compared to the other examples. This is validation of an outline planning application. unsurprising as planning circumstances will vary This demonstrates that only sites comprising between places and over time. fewer than 499 dwellings are – on average - likely to deliver anything within an immediate Table 1: Average planning approval period by size of site (years) five year period. The average time from 1st edition This research 4 Site Size validation of an outline application to the research (years) (years) delivery of the first dwelling for large sites 50-99 1.1 1.4 ranges from 5.0 to 8.4 years dependent on the size of the site, i.e. beyond an immediate five- 100-499 2.4 2.1 year period for land supply calculations. 500-999 4.2 3.3

1,000-1,499 4.8 4.6

1,500-1,999 5.4 5.3

2,000+ 6.1 6.1

Source: Lichfields analysis

Figure 4: Average timeframes from validation of first application to completion of the first dwelling

9 8.4

8 6.9 7.0 2.3 7

6 1.7 5.0 2.3 5 3 Realising Potential - our 4.0 research for the Land 4 1.7 Promoters and Developers 3.3* Federation in 2017 - found (years)Duration 3 1.9 6.1 that 41% of homes with 5.3 2.0 4.6 outline planning permission 2 3.3 were promoted by specialist land promoter and 1 2.1 development companies, 1.4 compared to 32% for volume 0 house builders. 50-99 100-499 500-999 1,000-1,499 1,500-1,999 2,000+ 4 The planning approval Site size (dwellings) period could also include a hybrid or full application, Average planning approval period Average planning to delivery period *does not sum due to rounding but on the basis of our examples this only impacts a small number of sites Source: Lichfields analysis

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Planning to Delivery Period A similar trend is apparent considering the 55 sites that delivered their first completions after Although there is little difference between the 2007/08. These have significantly longer planning average planning approval periods identified to delivery periods than those where completions in this research compared to our first edition began prior to the recession. The precise reasons Sites that delivered findings, the average lead-in time after securing are not clear, but is perhaps to be expected given their first completion planning permission is higher (Figure 5). It is during or after the the slowdown in housing delivery during the 2007/08 recession this period during which pre-commencement recession, and the significant reductions in local have significantly planning conditions have to be discharged as authority planning resources which are necessary longer planning to well as other technical approvals and associated to support discharge of pre-commencement delivery periods than commercial agreements put in place. sites which began conditions. However, delays may lie outside the before. planning system; for example, delays in securing This is likely due to the inclusion of more recent necessary technical approvals from other bodies proposed developments in this edition. Of the and agencies, or market conditions. 27 new sites considered, 17 (63%) completed their first dwelling during or after 2012; this compares to just 14 (20%) out of 70 sites in the first edition of this research (albeit at the time of publication 8 of these sites had not delivered their first home but have subsequently). This implies that the introduction of more recent examples into the research, including existing examples which have now commenced delivery5, has seen the average for planning to delivery periods lengthening.

Figure 5: Planning to delivery period, total average, pre and post-2008

4.5 4.0 4.0 3.5 3.5

3.0 2.6 2.7 2.6 2.5 2.4 1.9 2.0 1.9 1.9 1.4 1.5 1.1 1.0 1.0

0.5 Average planning to delivery period (years) Figure 5: Five of the large 0.0 sites examples do not have 500-999 1,000-1,499 1,500-1,999 2,000+ a first dwelling completion Site size (dwellings) recorded in this research

5 Completions begun pre-2008 Completions begun post-2008 All years Priors Hall has been (37 sites) (55 sites) (92 sites) amended since the first edition based on more Source: Lichfeilds analysis recent data

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In demand: how quickly do high pressure areas determine strategic applications for housing? Using industry-standard affordability ratios, we found that areas with the least affordable places to purchase a home (i.e. the highest affordability ratios) tended to have longer planning to delivery times than areas that were more affordable. This is shown in Figure 6, which splits the large site sample into national affordability quartiles, with the national average equating to 8.72.

The above analysis coincides with the fact (Table 2) that sites in the most affordable locations (lowest quartile) tend to be smaller than those in less affordable locations (an average site size of c.1,150 compared to in excess of 2,000 dwellings for the three other quartiles). Even the least affordable LPAs (with the greatest gap between workplace earnings Table 2: Site size by 2018 affordability ratio and house prices) have examples of large schemes Affordability ratio Average site size with an average site size of 2,000+ dwellings. It may (workplace based) be that the more affordable markets do not support the scale of up-front infrastructure investment that 2.5 – 6.4 1,149

is required for larger-scale developments and which 6.5 – 8.7 2,215 lead to longer periods before new homes can be built. However, looking at the other three quartiles, 8.8 – 11.0 2,170 the analysis does also suggest that planning and 11.1 – 44.5 2,079 implementation becomes more challenging in less affordable locations. Source: Lichfields analysis

Figure 6: Planning approval period (years) by 2018 affordability ratio

8

6.8 7

6 5.6 5.4 2.9 5 4.4 1.8 2.0 4 1.5 3

2 3.9 3.4 3.8 2.9 1 Average planning approval period (years) period approval planning Average

0

More affordable 2018 affordability ratio (national quartiles) Less affordable

1st: 2.5 to 6.4 2nd: 6.5 to 8.7 3rd: 8.8 to 11.0 4th: 11.1 to 44.5

Planning approval period Planning to delivery period

Source: Lichfields analysis

8 INSIGHT 04 START TO FINISH How quickly do sites build out?

The rate at which new homes are built on sites Average Annual Build-out rates is still one of the most contested matters at local Figure 7 presents our updated results, with plan examinations and planning inquiries which our additional 27 sites and the latest data for 160 dpa address 5YHLS and housing supply trajectories. all sites considered. The analysis compares the the average annual The first edition of this research provided a size of site to its average annual build-out rate. build rate for schemes range of ‘real world’ examples to illustrate what Perhaps unsurprisingly, larger sites deliver on of 2,000+ dwellings a typical large-scale site delivers annually. The average more dwellings per year than smaller research showed that even when some schemes sites. The largest sites in our sample of over were able to achieve very high annual build-out 2,000 dwellings, delivered on average more than rates in a particular year (the top five annual twice as many dwellings per year than sites of figures were between 419-620 dwellings per 500-999 dwellings, which in turn delivered an annum), this rate of delivery was not always average of three times as many units as sites sustained. Indeed, for schemes of 2,000 or more of 1-99 units. To ensure the build-out rates dwellings the average annual completion rate averages are not unduly skewed, our analysis across the delivery period was 160 dwellings excludes any sites which have only just started per annum. delivering and have less than three years of data. This is because it is highly unlikely that the first annual completion figure would actually cover a whole monitoring year, and as such could distort the average when compared to only one other full year of delivery data.

Figure 7: Build-out rate by size of site (dpa)

180 35% 160 160 29% 30% 140 120 25% 120 21% 107

100 20%

80 68 15%

60 55 9% 9% 10% 7% 40

22 4% as % of total dwellings on site) 5%

Housing delivery (dwellings per annum) per deliveryHousing (dwellings 20 Housing delivery (dwellings per annum

0 0 50-99 100-499 500-999 1,000-1,499 1,500-1,999 2,000+

Site Size (dwellings)

Housing delivery (dwellings per annum) Housing delivery (dwellings per annum as % of total dwellings on site) Source: Lichfields analysis

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We include the relevant percentage growth rates in this edition’s analysis; this shows that the proportion of a site’s total size that is build out each year reduces as site size increases. In most cases the median annual Our use of averages refers to the arithmetic mean delivery rate is lower across the sample sites. In most cases the median than the mean for of the rates seen on the larger sample sites is larger sites. lower, as shown in Figure 8; this reflects the small number of sites which have higher delivery rates (the distribution is not equal around the average). The use of mean average in the analysis therefore already builds in a degree of optimism compared with the median or ‘mid-point scheme’.

Figure 8: Minimum, mean, median and maximum build-out rates by size of site (dpa)

350

Mean 300 Median

250

200

150

100

Housing delivery (dwellings per annum) per deliveryHousing (dwellings 50

0 50-99 100-499 500-999 1,000-1,499 1,500-1,999 2,000+

Source: Lichfields analysis Site Size (dwellings)

Table 3: Median and mean delivery rates by site size

Median housing Mean annual Mean annual Median delivery as Site Size Number of sites delivery (dwellings delivery (dwellings delivery as % of % of total on site per annum) per annum) total units on site

50-99 29 27 33% 22 29%

100-499 54 54 24% 55 21%

500-999 24 73 9% 68 9%

1,000-1,499 17 88 8% 107 9%

1,500-1,999 9 104 7% 120 7%

2,000+ 27 137 4% 160 4%

Source: Lichfields analysis

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Comparison with our 2016 Variations for individual schemes can be findings marked. For example, the 2,605 unit scheme South of the M4 in Wokingham delivered Comparing these findings to those in the first 419 homes in 2017/18, but this was more than edition of this research, there is very little double the completions in 2016/17 (174) and the Site build-out rates difference between the averages observed average over all six years of delivery so far was for individual years (median was not presented) for different site are highly variable. just 147 dwellings per annum. sizes, as set out below. The largest difference is For example, one Even when sites have seen very high peak years scheme in Wokingham a decrease in average annual build-out rates for delivered more than sites of 1,000-1,499 dwellings, but even then, of delivery, as Table 5 shows, no sites have been twice as many homes this is only a reduction of 10 dpa or 9%. able to consistently delivery 300 dpa. in 2017/18 as it did in the year before. As with the first edition of the research, these are averages and there are examples of sites which deliver significantly higher and lower than these averages, both overall and in individual years. Figure 8 shows the divergence from the average for different site size categories. This shows that whilst the average for the largest sites is 160 dpa and the median equivalent 137 dpa, the highest site average was 286 dpa and the lowest site average was 50 dpa for sites of 2,000+ dwellings. This shows the need for care in interpreting the findings of the research, there may well be specific factors that mean a specific site will build faster or slower than the average. We explore some of the factors later in this report.

Table 4: Mean delivery rates by site sizes, a comparison with first Table 5: Peak annual build-out rates compared against average edition findings annual delivery rates on those sites

Average 2016 edition 2020 edition Peak annual Site size Site size annual research research Difference Site build-out (dwellings) build-out rate (dwellings) rate (dpa) (dpa) (dpa) (dpa)

Cambourne, South 50-99 27 22 -5 (-19%) 4,343 620 223 Cambridgeshire Table 5: Please note The Oakley Vale, Hamptons was included as 100-499 60 55 -5 (-8%) 3,100 520 180 Corby an example of peak annual delivery in the first edition Eastern Expansion 500-999 70 68 -2 (-3%) 4,000 473 268 Area, Milton Keynes with one year reaching 520 completions. However, Clay Farm, evidence for this figure 1,000-1,499 117 107 -10 (-9%) 2,169 467 260 Cambridge is no longer available and as it was not possible to South of M4, 1,500-1,999 129 120 -9 (-7%) 2,605 419 147 Wokingham corroborate the figure it has been removed. The analysis Cranbrook, East has been updated to reflect 2,000+ 161 160 -1 (-0.62%) 2,900 419 286 Devon the latest monitoring data from Peterborough City Source: Lichfields analysis Source: Lichfields analysis Council.

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Longer term trends The impact of the recession on This section considers the average build-out build-out rates rates of sites which have been delivering over It is also helpful to consider the impact of a long period of time. This is useful in terms of market conditions on the build-out rate of large planning for housing trajectories in local plans scale housing sites. Figure 10 overleaf shows when such trajectories may span an economic the average delivery rate of sites of 2,000 or cycle. more dwellings in five-year tranches back to In theory, sites of more than 2,000 dwellings 1995/96. This shows that although annual will have the longest delivery periods. build-out rates have improved slightly since Therefore, to test long term averages we have the first half of the 2010’s, they remain 37% calculated an average build-out rate for sites of below the rates of the early 2000’s. The reasons 2,000+ dwellings that have ten years or more of for the difference are not clear and are worthy completions data available. of further exploration – there could be wider market, industry structure, financial, planning For these sites, the average annual build-out or other factors at play. rate is slightly higher than the average of all sites of that size (i.e. including those only part In using evidence on rates of delivery for way through build out), at 165 dwellings per current/historic schemes, some planning annum6. The median for these sites was also 165 authorities have suggested that one should dwellings per annum. adjust for the fact that rates of build out may have been affected by the impact of the This indicates that higher rates of annual recession. We have therefore considered how housing delivery on sites of this size are more the average rates change with and without likely to occur between years five and ten, i.e. including the period of economic downturn after these sites have had time to ‘ramp up’. (2008/09 – 2012/13). This is shown in Table 6 It might even relate to stages in delivery when and it reveals that average build-out rates are multiple phases and therefore multiple outlets only slightly depressed when one includes this (including affordable housing) are operating at period, but may not have fully recovered to the same time. These factors are explored later their pre-recession peaks. We know that whilst in the report. the recession – with the crunch on mortgage

Figure 9: Average build-out rate for sites over 2,000 homes by length of delivery period (dpa)

180 165 160 160 155

140

120

100

80

60

40 Housing delivery (dwellings per annum) per deliveryHousing (dwellings 6 This is based on the 20 completions of seven examples, Chapelford 0 Urban Village, Broadlands, Kings Hill, Oakley Vale, Sites with 10+ years of delivery (7) Sites with 5+ years of delivery (24) All sites (27) Cambourne, The Hamptons and Wixhams Source: Lichfields analysis

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availability – did have a big impact and led to the flow of new sites slowing, there were mechanisms put in place to help sustain the build out of existing sites. However, setting aside that stripping out the recession has a modest impact on the statistical averages for the sites in our sample, the more significant point is that – because of economic cycles - larger sites which build out over five or more years are inherently likely to coincide with a period of economic slowdown at some point during their build out. It therefore makes sense for housing trajectories for such sites to include an allowance for the prospect that, at some point, the rate of build out may slow due to a market downturn, albeit the effect may be smaller than one might suspect.

Table 6: Impact of recession on build-out rates

Build-out rates excluding Build-out rates in all years Build-out rates pre-recession recession years (2008/9-2012/13)

Average rate Sample size Average rate Sample size Average rate Sample size

All large sites 115 77 126 68 130 21 500+

All large sites 160 27 171 25 242 6 2,000+

Greenfield sites 181 14 198 12 257 3 2,000+

Source: Lichfields analysis

Figure 10: Average build-out rate by five year period for sites over 2,000 dwellings (dpa)

250 235

200 190 181

147 150 136

100

50 Housing delivery (dwellings per annum) per deliveryHousing (dwellings

0 1995/96-1999/00 2000/01-2004/05 2005/06-2009/10 2010/11-2014/15 2015/16-2017/18*

Delivery period Source: Lichfields analysis

13 INSIGHT START TO FINISH 05 What factors can influence build-out rates?

Having established some broad averages and how delivered for three years or more. This analysis these have changed over time, we turn now to shows that sites in areas of higher demand +34% look at what factors might influence the speed (i.e. less affordable) deliver on average more at which individual sites build out. How does dwellings per annum. higher average annual build-out housing demand influence site build out? What is Our analysis also coincides with the fact that rates on greenfield the impact of affordable housing? Does it matter sites in less affordable areas are on average land compared with whether the site is greenfield or brownfield? c.17% larger than those in more affordable brownfield What about location and site configuration? areas. The average site size for schemes in In demand: do homes get delivered areas where affordability is below the national faster in high pressure areas? average is 1,834 dwellings. For those delivered in areas where the affordability is greater than One theory regarding annual build-out rates is the national average, average site size is 2,145 that the rate at which homes can be sold (the dwellings. So, it is possible that the size of site – ‘absorption rate’) determines the build-out rate. rather than affordability per se – is a factor here. This is likely to be driven by levels of market demand relative to supply for the product being Do sites on greenfield land deliver supplied. more quickly? This analysis considers whether demand for The first edition of this research showed that housing at the local authority level affects greenfield sites on average delivered quicker delivery rates by using (industry-standard) than their brownfield counterparts. In our affordability ratios. Higher demand areas are updated analysis this remains the case; large indicated by a higher ratio of house prices greenfield sites in our sample built out a third to earnings i.e. less affordable. Whilst this faster than large brownfield sites. is a broad-brush measure, the affordability In the life cycle of a site, our data also shows ratio is a key metric in the assessment of that greenfield sites had shorter planning to local housing need under the Government’s delivery periods (2.0 years compared to 2.3 for standard methodology. Figure 11 shows the brownfield sites), although on average, longer sample of 500+ unit schemes divided into those planning approval periods (5.1 years compared where the local authority in which they are to 4.6 for brownfield sites). located is above or below the national median affordability ratio (8.72) for sites which have

Figure 11: Build-out rates by level of demand using national Figure 12: Build-out rates on brownfield and greenfield sites median 2018 workplace based affordability ratio (dpa) (dpa)

140 140

120 120

100 100

80 80 131 60 126 60 99 98 40 40

20 20 Housing delivery (dwellings per annum) per deliveryHousing (dwellings Housing delivery (dwellings per annum) per deliveryHousing (dwellings 0 0 More affordable than Less affordable than Brownfield Greenfield national average (<8.72) national average (>8.72)

Source: Lichfields analysis Source: Lichfields analysis

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Housing mix and variety not be. On this basis, we use the outlets metric as Among the more topical issues surrounding a proxy for variation. Based on the limited data delivery rates on large-scale sites is the variety available for this analysis, if two phases are being of housing on offer. The Letwin Review posited built out at the same time by the same housebuilder Having more outtlets that increasing the diversity of dwellings on large (e.g. two concurrent parcels by Bovis) this has been counted as one outlet with the assumption there is operating at the same sites in areas of high housing demand would help time will on average achieve a greater rate of build out. The report little variety (although it is clear that some builders quicken build-out concluded that a variety of housing is likely may in reality differentiate their products on the rates. to appeal to a wider, complementary range of same site). This data was derived from sites in a potential customers which in turn would mean relatively small number of local planning authorities a greater absorption rate of housing by the local who publish information relating to outlets on site. market. It therefore represents a small sample of just 12 sites, albeit over many different years in which the number Consistent data on the mix of sizes, types and prices of outlets varied on the same site, giving a total of 80 of homes built out on any given site is difficult to data points i.e. individual delivery rates and number of source, so we have used the number of sales outlets outlets to compare. on a site as a proxy for variety of product. This gives the prospect of multiple house builders each Our analysis confirms that having more outlets seeking to build and sell homes for which there operating at the same time will on average have a is demand in the face of ‘competing’ supply from positive impact on build-out rates, as shown in Figure other outlets (as revealed by the case study of Land 13. However, there are limits to this, likely to be due South of the M4 in Wokingham). Letwin stated to additional capacity from the outlets themselves as that “…it seems extraordinarily likely that the presence well as competition for buyers. of more variety in these aesthetic characteristics would On a site-by-site basis, the average number of create more, separate markets”7. Clearly, it is likely that outlets open over the site’s entire delivery lifetime on many sites, competing builders may focus on a had a fairly strong correlation with annual delivery, similar type of product, for example three or four both as a percentage of total dwellings and in absolute bed family housing, but even across similar types of terms, with a greater number of outlets contributing dwelling, there will be differences (in configuration, to higher levels of delivery. However, the completions design, specification) that mean one product may be per outlet did reduce with every additional outlet attractive to a purchaser in the way another might operating in that year.8

Figure 13: Build-out rates by number of outlets present (dpa)

450

400

350

300

250

200

150

100 7 Letwin Review draft analysis report (June 2018) Housing delivery (dwellings per annum) per deliveryHousing (dwellings 50 - final bullet of para 4.25 8 Average completions per 0 outlet on site with one outlet 0 1 2 3 4 5 6 7 8 9 10 was 61dpa, dropping to Outlets 51dpa for two outlets and Source: Lichfields analysis 45dpa for three outlets.

15 INSIGHT START TO FINISH

Geography and Site Configuration Keynes Council suggesting an average of c.12 parcels were active across the build period. In this An under-explored aspect of large-scale site second edition of this research the Milton Keynes delivery is the physical opportunity on site. examples remain some of the sites with the For example, some schemes lend themselves to highest annual build-out rates. simultaneous build out of phases which can have the impact of boosting delivery rates in that year,

for example, by having access points from two Table 7: Parcels at Land South of M4, Wokingham alternative ends of the site. Other sites may be reliant on one key piece of infrastructure which Parcel Developers Completions make this opportunity less likely or impractical. reference (active outlets) in 2017/18

In the first edition of this research we touched SP1 Bellway (1) 59 on this point in relation to Eastern Expansion None - parcel SP2w Bellway and Bovis (-) Area (Broughton Gate & Brooklands) of Milton completed Keynes. As is widely recognised, the planning SP3 Crest Nicholson (1) 47 and delivery of housing in Milton Keynes is Taylor Wimpey and David distinct from almost all the sites considered in SP4 140 Wilson Homes (2) this research as serviced parcels with the roads already provided were delivered as part of the SP9_1 Bloor, Bovis and Linden (3) 169

Milton Keynes delivery model. Multiple house None - parcel SP10 Darcliffe Homes (-) builders were able to proceed straight onto the completed

site and commence delivery on different serviced SP11 Taylor Wimpey (1) 4 parcels, with monitoring data from Milton Source: Lichfields analysis

Figure 14: Map of parcels at Land South of M4, Wokingham

Source: © Google Earth 2020/ Wokingham Local Plan

16 INSIGHT START TO FINISH

In this edition we look at the case study of Land Affordable choices: do different South of the M4 in Wokingham. In 2017/18 tenures provide more demand? the site achieved a significant 419 completions. Our findings on tenure, another form of Using the local authority’s granular recording of ‘variety’ in terms of house building products, delivery on the site to date, we have been able to Schemes with more are informed by data that is available on about consider where these completions were coming affordable housing half the sites in our large site sample. From built out at close to forward from within the wider 2,605 dwelling this the analysis shows schemes with more twice the rates as scheme. As shown in Figure 14, in that year those with lower affordable housing built out at close to twice new homes were completed on five separate levels. the rate as those with lower levels of affordable parcels with completions ranging from 4 to housing as a percentage of all dwellings on site. 169 dwellings. On some of these parcels (SP9_1 However this is not always the case. Schemes and SP4) there were two or three separate with 20-29% affordable housing had the lowest housebuilders building out, and in total on the build-out rates, both in terms of dwellings and site there were seven different house building proportionate to their size. companies active (the impact of multiple outlets on build-out rates is explored later in this report). The parcels are located in separate parts of the site and each had their own road frontages and access arrangements which meant they are able to come forward in parallel. This can enable an increased build rate.

Source: Lichfields analysis

Figure 15: Build-out rates by level of affordable housing (dpa and percentage)

160 16%

142 140 135 14%

12% 12.1% 120 12% 107 104 10.0% 100 98 10%

80 8% 6.5% 5.9% 60 6%

40 4% Housing delivery (dwellings per annum) per deliveryHousing (dwellings

20 2% Housing delivery (dwellings per annum as % of total dwellings on site)

0 0 0-9% 10-19% 20-29% 30-39% 40%+ Level of affordable housing on site (% of total dwellings)

Housing delivery (dwellings per annum) Housing delivery (dwellings per annum as % of total dwellings on site) Source: Lichfields analysis

17 INSIGHT START TO FINISH 06 Conclusions

Recent changes to national planning policy helpful in locations where there is little recent emphasise the importance of having a realistic experience of such strategic developments. Whilst expectation of delivery on large-scale housing we present some statistical averages, the real sites, whilst local authorities now find themselves relevance of our findings is that there are likely subject to both forward and backward-looking to be many factors which affect lead-in times housing delivery performance measures. A and build-out rates, and that these - alongside number of local plans have hit troubles because the characteristics of individual sites - need to be they over-estimated the yield from some of considered carefully by local authorities relying their proposed allocations. Meanwhile, it is no on large sites to deliver planned housing. longer sufficient for a 5YHLS to look good on In too many local plans and 5YHLS cases, there paper; the Housing Delivery Test means there are is insufficient evidence for how large sites are consequences if it fails to convert into homes built. treated in housing trajectories. This research To ensure local authorities are prepared for these seeks to fill the gap with some benchmark figures tests, plan making and the work involved in - which can be of some assistance where there maintaining housing land supply must be driven is limited or no local evidence. But the average by realistic and flexible housing trajectories, derived from our analysis are not intended to based on evidence and the specific characteristics be definitive and are no alternative to having a of individual sites and local markets. For local robust, bottom-up justification for the delivery authorities to deliver housing in a manner which trajectory of any given site. It is clear from is truly plan-led, this is likely to mean allocating our analysis that some sites start and deliver more sites rather than less, with a good mix of more quickly than the average, whilst others types and sizes, and being realistic about how have delivered much more slowly. Every site is fast they will deliver so supply is maintained different. Therefore, whilst the averages observed throughout the plan period. Equally, recognising in this research may be a good starting point, the ambition and benefits of more rapid build out there are a number of key questions to consider on large sites, it may mean a greater focus on how when estimating delivery on large housing sites, such sites are developed. based around the three key elements in the three- tier analytical framework at Figure 16. Our research provides those in the public and private sector with a series of real-world benchmarks in this complex area of planning for large scale housing, which can be particularly

18 INSIGHT START TO FINISH

Key findings:

1 Large schemes can take 2 Lead-in times jumped 5+ years to start post-recession

In developing a local plan, but especially Whilst attention and evidence gathering in calculating a 5YHLS position, it is is often focused on how long it takes to important to factor in a realistic planning get planning permission, the planning to approval period dependent on the size delivery period from gaining permission of the site. Our research shows that if a to building the first house has also been scheme of more than 500 dwellings has increasing. Our research shows that the an outline permission, then the average planning to delivery period for large sites time to deliver its first home is two or completed since 2007/08 has jumped three years. However, from the date at compared to those where the first which an outline application is validated completion came before 2007/08. This is it can be 5.0 - 8.4 years for the first home a key area where improvements could be to be delivered dependent on the size of sought on timeliness and in streamlining the site. In these circumstances, such pre-commencement conditions, but is also sites would make no contribution to likely impacted by a number of macro factors completions in the first five years. including the recession and reductions in local authority planning resources.

3 Large greenfield sites 4 Outlets and tenure deliver quicker matter

Large sites can deliver more homes per Our analysis suggests that having year over a longer time period, with this additional outlets on site has a positive seeming to ramp up beyond year five impact on build 0ut rates, although there of the development on sites of 2,000+ is not a linear relationship. Interestingly, units. However, on average these longer- we also found that schemes with more term sites also have longer lead-in times. affordable housing (more than 30%) built Therefore, short term boosts in supply, out at close to twice the rate as those with where needed, are likely to also require a lower levels of affordable housing as a good mix of smaller sites. Furthermore, percentage of all units on site, but those large scale greenfield sites deliver at with 20-29% had the lowest rates of all. a quicker rate than their brownfield Local plans should reflect that – where equivalents: the average rate of build out viable – higher rates of affordable housing for greenfield sites in our sample was supports greater rates of delivery. This 34% greater than the equivalent figure principle is also likely to apply to other for those on brownfield land. In most sectors that complement market housing locations, a good mix of types of site will for sale, such as build to rent and self-build therefore be required. (where there is demand).

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Figure 16: Key questions for assessing large site build-out rates and delivery timelines

Planning Approval

• Is the site already allocated for development? If it is in an emerging Plan, does it need to be adopted before the site can be brought forward? • Is an SPD, masterplan or development brief required and will it help resolve key planning issues? • Is there an extant planning permission or live planning application submitted? • If outline permission is granted, when will reserved matters be submitted? • Is the proposal of the promoter consistent with local policy and/or SPD/Masterplan? • Are there significant objections to the proposal from local residents? • Are there material objections to the proposal from statutory bodies? • If planning permission is secured, is reserved matters approval required?

Lead In

• Does the scheme have pre-commencement conditions? • Is the land in existing use? • Has the land been fully assembled? • Are there any known technical constraints that need to be resolved? • If in multiple ownership/control, are the interests of all parties aligned? • Is there up-front infrastructure required before new homes can be built? • Has the viability of the proposal been established and is the feasibility consistent with known infrastructure costs and the likely rate of development? • Does the proposal rely on access to public resources and what evidence is there on when those will be available? • Is the scheme led by a promoter or master developer who will need to dispose of phases to a house builder before completions begin?

Build Out

• How large is the site? • How strong is the local market? • Does the site tap into local demand from one or more existing neighbourhoods? • Will delivery be affected by competing sites? • How many sales outlets will be supported by the scale, configuration and delivery model for the site? • What is the track record of the promoter/master developer in delivery of comparable sites? • How active are different housebuilders in the local market? • What proportion of affordable housing is being delivered? • Are there policy requirements for a specific mix of housing types and are there other forms of housing – such as build to rent? • When will new infrastructure – such as schools – be provided to support the new community? • Are there trigger points or phasing issues that may affect the build-out rate achievable in different phases?

Source: Lichfeilds analysis

20 INSIGHT START TO FINISH Appendices

Contents

Appendix 1: Definitions and notes 22 Appendix 2: Large sites tables and sources for sites also found in the Letwin Review 23 Appendix 3: Small sites tables 28

21 INSIGHT START TO FINISH Appendix 1: Definitions and notes

The ‘lead in’

Measures the period up to first completion of a house on site from the validation date of the first planning application made for the scheme. The lead-in time covers both the planning approval period and planning to delivery periods set out below. The lead-in time does also include the date of the first formal identification of the site as a potential housing allocation (e.g. in a LPA policy document), but consistent data on this for the sample is not available.

The ‘planning period’

Measured from the validation date of the first application for the proposed development (be that an outline, full or hybrid application). The end date is the decision date of the first detailed application which permits the development of dwellings on site (this may be a full or hybrid application or the first reserved matters approval which includes details for housing). A measurement based on a detailed ‘consent’ was considered reasonable and proportionate milestone for ‘planning’ in the context of this research.

The ‘planning to delivery period’

Includes the discharge of any pre-commencement and any opening up works required to deliver the site. It finishes on completion of the first dwelling.

The date of the ‘first housing completion’

On site (the month and year) is used where the data is available. However, in most instances the monitoring year of the first completion is all that is available and in these cases a mid- point of the monitoring period (1st October, falling halfway between 1st April and the Due to the varying ages following 31st March) is used. of the assessed sites, the implementation of some schemes was more advanced than others and, as a function of the desk-based nature of the The ‘annual build-out rate’ research and the age of some of the sites assessed, there have been some data Each site is taken or inferred from a number of sources. This includes Annual Monitoring limitations, which means Reports (AMR’s) and other planning evidence base documents produced by local authorities there is not a complete data set for every assessed (see footnote 1), contacting the local planning authority monitoring officers or planners and in site. For example, lead-in a handful of instances obtaining the information from housebuilders. time information prior to submission of planning applications is not available for the vast majority of sites. And because not all of the sites assessed have commenced housing delivery, build-out rate information is not universal. The results are presented

accordingly. tables sites Large 2: Appendix

22 Appendix 2: Large sites tables

Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Ebbsfleet Gravesham/ 15,000 2009/10 127 79 55 50 44 40 60 141 312 Dartford The Hamptons Peterborough 6,320 1997/98 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 224 224 154 157 71 67 101 34 54 100

Rugby Radio Station Rugby 6,200 N/A

East of Kettering Kettering 5,500 2016/17 43 93

Sherford Plymouth 5,500 2016/17 7 106

Priors Hall Corby 5,200 2011/12 56 21 59 87 170 155 273

Wichelstowe Swindon 4,500 2008/09 158 93 195 64 100 61 44 60 57

Monkton Taunton Deane 4,500 2012/13 22 76 220 191 222 148 Heathfield The Wixams Bedford 4,500 2008/09 8 190 160 138 113 109 109 44 37 47

Cambourne South 4,343 1999/2000 42 361 213 337 620 151 377 267 219 190 162 206 154 151 129 239 201 95 126 Cambridgeshire Eastern Expansion Milton Keynes 4,000 2008/09 154 359 371 114 473 138 Area (Broughton Gate & Brooklands) Locking North Somerset 3,700 2011/12 23 45 97 75 10 21 86 Parklands Stanton Cross Wellingborough 3,650 N/A

Beaulieu Park Chelmsford 3,600 2015/16 40 110 262

Northampton North Daventry 3,500 2017/18 50 SUE Great Western Park South 3,300 2011/12 110 204 232 392 237 274 78 Oxfordshire Oakley Vale Corby 3,100 2001/02 35 89 289 258 346 487 520 233 174 159 107 96 103 51 40 9 70

Kings Hill Tonbridge and 3,024 1996/97 140 140 140 140 140 126 219 104 237 166 281 300 224 93 55 90 84 108 91 74 41 31 Malling North West Cam- Cambridge and 3,000 2016/17 73 bridge South Cambridgeshire West of Havant and Win- 3,000 2009/10 38 71 30 82 112 135 196 241 Waterloo chester Cranbrook East Devon 2,900 2012/13 187 419 356 299 214 241

West of Kempston Bedford 2,760 2010/11 52 102 144 167 124 175 103 93

South of the M4 Wokingham 2,605 2012/13 37 175 56 29 166 419

Winterstoke Village North 2,550 2014/15 132 185 242 161 Somerset Emersons Green East South 2,550 2014/15 274 197 318 280 Gloucestershire Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Land East Icknield Test Valley 2,500 2009/10 184 257 103 181 135 229 146 184 Way South Wokingham 2,490 2013/14 6 104 120 135 118 Wokingham North Wokingham 2,391 2010/11 28 99 23 0 95 112 66 154 Wokingham Broadlands Bridgend 2,309 1999/2000 288 331 307 193 204 156 64 104 91 28 81 50 147 11

Western Bath and North 2,281 2011/12 59 147 93 61 163 154 45 Riverside East Somerset Arborfield Wokingham 2,225 2016/17 57 114 Garrison Charlton Hayes, South 2,200 2010/11 83 87 163 333 281 193 301 168 Northfield Gloucestershire Clay Farm/ Cambridge 2,169 2012/13 16 265 399 153 467 Showground Site (Great Kneighton) Chapelford Urban Warrington 2,144 2004/05 211 214 166 262 224 141 180 183 247 60 160 66 30 Village Ledsham Cheshire West and 2,000 2016/17 41 90 Garden Village Chester Graven Hill Cherwell 1,900 2016/17 1 28

Elvetham Heath Hart 1,869 2000/01 192 300 297 307 287 238 103 139 6

Hunts Grove Stroud 1,750 2010/11 2 87 106 80 58 7 2 22

Dickens Heath Solihull 1,672 1997/98 2 179 196 191 207 88 124 64 249 174 16 96 110 4 0 0 13 10 26 12 96

Red Lodge Forest Heath 1,667 2004/05 65 93 181 79 57 79 61 101 213 101 78 23 75 111

South West Bicester Cherwell 1,631 2011/12 40 107 133 179 210 231 196 (Phase 1 Kingsmere)

Centenary Quay Southampton 1,620 2011/12 102 58 103 137 257 8

Northumberland Park North Tyneside 1,513 2003/04 54 194 171 93 179 100 69 117 96 53 82 64 86

Parc Derwen Bridgend 1,500 2010/11 8 103 134 201 199 197 157 186

Jennet’s Park Bracknell Forest 1,500 2007/08 153 154 145 168 136 179 235 93 37 0 28

Melton Road Rushcliffe 1,500 2016/17 40 126

Great Denham Bedford 1,450 data only 92 150 159 71 122 150 125 211 168 avalibale from 2009/10 Love’s Farm, Huntingdonshire 1,438 2007/08 34 186 336 302 216 60 108 59 85 St Neots South Maldon Garden Malden 1,428 2017/18 1 Suburb Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Bolnore Village Mid Sussex 1,358 2012/13 30 54 88 73 36 124

Park Prewett Hospital Basingstoke and 1,341 1998/99 58 82 37 102 0 0 0 0 0 307 214 219 146 33 34 56 7 30 16 Deane Ashford Ashford 1,300 2005/06 83 0 124 14 64 58 155 103 49 70 67 138 90 Barracks (Repton Park) Oxley Park (East & Milton Keynes 1,300 2004/05 52 166 295 202 115 91 75 163 West) Kempshott Park Basingstoke and 1,252 2000/01 78 310 229 213 281 84 33 24 Deane Holborough Quarry Tonbridge and 1,211 2006/07 85 137 91 47 18 100 59 12 43 64 60 101 Malling Staynor Hall Selby 1,200 2005/06 12 141 115 10 43 62 46 59 79 162 79 34 50

Picket Twenty Test Valley 1,200 2011/12 147 178 180 176 164 145 175

Trumpington Cambridge and 1,200 2012/13 141 143 67 100 94 Meadows South Cambridgeshire Broughton Milton Keynes 1,200 2003/04 114 105 170 409 204 180 18 (Broughton & At- terbury) Orchard Park Cambridge 1,120 2006/07 100 290 148 103 95 56 34 15 75 39 30 2

Velmead Farm Hart 1,112 1989/90 1 104 193 89 101 52 101 113 130 74 102 48 4

Cheeseman’s Green Ashford 1,100 2014/15 59 47 102 157 (Finberry) Zones 3 to 6, Omega Warrington 1,100 2017/18 15 South Boulton moor South 1,058 2014/15 22 96 96 116 Derbyshire Highfields Farm South 1,056 2016/17 141 204 Derbyshire Monksmoor Farm Daventry 1,000 2013/14 6 65 98 128 122

Northampton North of Daventry 1,000 2016/17 108 100 Whitehills SUE Taylors Farm/Sher- Basingstoke and 991 2004/05 56 79 81 86 88 51 143 141 88 91 75 0 12 field Park Deane Queen Elizabeth II Hart 972 2012/13 56 165 110 228 213 96 Barracks Little Staniton Corby 970 2009/10 106 116 74 121 102 93 89 86 26

North of Popley Basingstoke and 951 2007/08 65 57 16 28 0 0 15 118 84 60 Deane Ingress Park Dartford 950 2002/03 184 275 100 74 0 119 0 0

Nar Ouse Millenium Kings Lynn and 900 2007/08 32 77 0 0 0 0 30 22.5 22.5 68 0 Commuity West Norfolk West Park Darlington 893 2004/05 60 104 98 66 69 19 35 10 16 51 35 28 14 42

South Bradwell Great Yarmouth 850 2015/16 60.3 60.3 60.3 Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Prospect Place Cardiff 826 2007/08 185 48 0 0 0 0 0 76 170

Abbotswood Test Valley 800 2011/12 30 190 157 114 152 90 20

Dowds Farm Eastleigh 795 2006/07 54 189 187 44 102 47 66 76 30

Land at Popley Fields/ Basingstoke and 751 2006/07 105 172 118 186 126 44 Marnell Park Deane Hungate York 720 2009/10 90 52 11 9 7 187 8

Northside Gateshead 718 1999/2000 46.8 46.8 46.8 46.8 46.8 56 46.8 46.8 46.8 46.8 46.8 16 30 31 33 25 43

Land at West Blyth Northumbeland 705 2008/09 6.25 6.25 6.25 6.25 32 66 51 127 78 90

Rowner Renewal Gosport 700 2010/11 4 100 70 45 89 101 79 97 Project Channels - North Chelmsford 700 2015/16 31 172 110 Chelmsford The Parks, formally Bracknell Forest 697 2006/07 -94 104 88 101 54 47 72 59 94 78 Staff College Staiths South Bank Gateshead 667 2003/04 24 58 44 48

Land south of Northumberland 644 2005/06 18.7 18.7 18.7 18.7 18.7 18.7 18.7 17 24 37 60 57 54 Wansbeck General Hospital Former Pontins Lancaster 626 2006/07 16 22 4 5 Holiday Camp

Ochre Yards Gateshead 606 2004/05 83 68.2 68.2 68.2 68.2 68.2 46 4 52 2

Former Runwell Chelmsford 575 2016/17 91 90 Hospital Land adjoining Man- Trafford 550 N/A chester Ship Canal Pamona Docks Trafford 546 N/A

Thingwall Lane Knowlsey 525 2013/14 79

St. James Village Gateshead 518 2000/01 41.4 41.4 41.4 41.4 41.4 41.4 41.4 41.4 41.4 41.4 14 13 18 15

University Chelmsford 507 2014/15 216 3 Campus Chelmsford Land at Siston Hill South 504 2006/07 77 211 96 63 57 Gloucestershire Land West of Mid Sussex 500 N/A Copthorne Sources for sites also found in the Letwin Review

Arborfield Green (Arborfield Five Year Housing Land Supply Statement and appendix on Strategic Development Locations at 31st March 2018 published 9th October 2018 Garrison) http://www.wokingham.gov.uk/planning-policy/planning-policy-information/evidence-topics/

Ledsham Garden Village Various Housing Land Monitor Reports https://consult.cheshirewestandchester.gov.uk/portal/cwc_ldf/mon/

Great Kneighton (Clay Farm) Partly provided by Cambridgeshire County Council and included in numerous AMR’s https://www.cambridge.gov.uk/annual-monitoring-reports

Trumpington Meadows Included in numerous AMR’s for Cambridge and South Cambridgeshire (site crosses boundaries) https://www.cambridge.gov.uk/annual-monitoring-reports and https://www.scambs.gov.uk/planning/local-plan-and-neighbourhood-planning/ annual-monitoring-report/ Graven Hill Various Annual monitoring reports https://www.cherwell.gov.uk/info/33/planning-policy/370/monitoring-reports South West Bicester Various Annual monitoring reports (Kingsmere Phase 1) https://www.cherwell.gov.uk/info/33/planning-policy/370/monitoring-reports Great Western Park Housing Land Supply Statement April 2018 http://www.southoxon.gov.uk/sites/default/files/30.04.2018%20Housing%20Land%20Supply%20Statement%20FINAL%20(2)%20combined. pdf Ebbsfleet: First phase at Springhead Park and Northfleet South from Gravesham AMR’s 2009/10 to 2012/13

2009-10: 127 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0010/69823/AMR2010.pdf 2010-11: 79 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0010/69814/AMR2011.pdf 2011-12: 55 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0009/92448/Gravesham-Authority-Monitoring-Report-2011-12-May-2013.pdf 2012-13: 50 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0010/92449/Gravesham-Authority-Monitoring-Report-2012-13-interim-May-2013.pdf 2013/14: 87 dwellings, based on total completions form Gravesham to 2012/13 of 311 and total completions to the start of 2014/15 in the Ebbsfleet Garden City Latest Starts and Completion Figures totalling 398.

2014/15 to Ebbsfleet Garden City Latest Starts and Completion Figures: https://ebbsfleetdc.org.uk/tracking-our-performance/ 2017/18: Appendix 3: Small sites tables

Site Name Local Planning Size Site Name Local Planning Size Site Name Local Planning Size Authority Authority Authority Cookridge Hospital Leeds 495 GCHQ Oakley - Phase 1 Cheltenham 262 Auction Mart South Lakeland 94

Stenson Fields South Derbyshire 487 Hewlett Packard (Land Adjacent Bristol, City of 242 Parcel 4 Gloucester Business Tewkesbury 94 To Romney House) Park Horfield Estate Phase 1 Bristol City 485 128-134 Bridge Road And Nos Windsor and 242 York Road Hambleton 93 Council 1 - 4 Oldfield Road Maidenhead Farnborough Business Park Rushmoor 476 Hoval Ltd North Gate Newark and 196 Land At Green Road - Reading Reading 93 Sherwood College Bickershaw Colliery Wigan 471 Notcutts Nursery, 150 - 152 Cherwell 182 Caistor Road West Lindsey 89 London Road Farington Park, east of Wheelton South Ribble 468 Sellars Farm Stroud 176 The Kylins Northumberland 88 Lane Bleach Green Gateshead 456 Land South of Inervet Campus Off Milton Keynes 176 North East Area Professional Crawley 76 Brickhill Street, Walton, Milton Keynes Centre, Furnace Drive Kingsmead South Milton Keynes 450 Queen Mary School Fylde 169 Land at Willoughbys Bank Northumberland 76 Council New Central Woking Borough 445 London Road/ Adj. St Francis East Hertford- 149 Watermead, Land At Kennel Lane Tewkesbury 72 Council Close shire Land at former Battle Hospital Reading Borough 434 Land off Gallamore Lane West Lindsey 149 Land to the North of Walk Mill Wychavon 71 Council Drive New World House Warrington 426 Doxey Road Stafford 145 Hawthorn Croft (Off Hawthorn West Lindsey 69 Avenue Old Slaughterhouse Site) Radyr Sidings Cardiff 421 Former York Trailers (two schemes Hambleton 145 Land off Crown Lane Wychavon 68 - one Barratt, one DWH) Luneside West Lancaster 403 Bracken Park, Land At Cor- West Lindsey 141 Former Wensleydale School Northumberland 68 ringham Road Woolley Edge Park Wakefield 375 Land at Farnham Hospital Waverley 134 Land at Lintham Drive South Glouces- 68 tershire Former Masons Cerement Works and Mid Suffolk 365 North of Douglas Road South Glouces- 131 Springfield Road South Kesteven 67 Adjoining Ministry of Defence Land tershire Former NCB Workshops (Port- Northumberland 357 Land to the east of Efflinch Lane East Staffordshire 130 Land off Cirencester Rd Stroud 66 land Park) Chatham Street Car Park Reading 307 Land to the rear of Mount Cheshire West 127 Land south of Pinchington Lane West Berkshire 64 Complex Pleasant and Chester Kennet Island Phase 1 - H, M, Reading 303 Primrose Mill Site Ribble Valley 126 Land at Prudhoe Hospital Northumberland 60 T, U1, U2 Land at Dorian Road Bristol, City of 300 Kennet Island Phase 1B - E, F, Reading 125 Oxfordshire County Council Cherwell 60 O & Q Highways Depot Land at Fire Service College, Cotswold 299 Land between Godsey Lane and South Kesteven 120 Clewborough House School Cherwell 60 London Road Towngate East Land at Badsey Road Wychavon 298 Bibby Scientific Ltd Stafford 120 Land at the Beacon, Tilford Road Waverley 59

Land at Brookwood Farm Woking 297 Land west of Birchwood Road Bristol, City of 119 Land to Rear Of 28 - 34 Bedale Hambleton 59 Road Long Marston Storage Depot Stratford-on- 284 Former Bewbush Leisure Centre Crawley 112 Hanwell Fields Development Cherwell 59 Phase 1 Avon Site M & G Sports Ground, Golden Tewkesbury 273 Land south of Station Road East Hertford- 111 Fenton Grange Northumberland 54 Yolk and Middle Farm shire Land at Canons Marsh Bristol, City of 272 Poppy Meadow Stratford-on- 106 Former Downend Lower School South Glouces- 52 Avon tershire Land off Henthorn Road Ribble Valley 270 Weeton Road/Fleetwood Road Fylde 106 Holme Farm, Carleton Road Wakefield 50

Land Between A419 And A417 Cotswold 270 Former York Trailers (two schemes Hambleton 96 Land off Elizabeth Close West Lindsey 50 - one Barratt, one DWH) Hortham Hospital South 270 North East Sandylands South Lakeland 94 Gloucestershire The Lichfields perspective

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Disclaimer This publication has been written in general terms and cannot be relied on to cover specific situations. We recommend that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. Lichfields accepts no duty of care or liability for any loss occasioned to any person acting or refraining from acting as a result of any material in this publication. Lichfields is the trading name of Nathaniel Lichfield & Partners Limited. Registered in England, no.2778116. © Nathaniel Lichfield & Partners Ltd 2020. All rights reserved. lichfields.uk @LichfieldsTT APPENDIX 2 Latest Planning Dwelling Site Application (No. 1) capacity 18/19 19/20 20/21 21/22 22/23 23/24 24/25 25/26 26/27 27/28 28/29 29/30 30/31 31/32 32/33 H22 Land at Village Farm, Birmingham Road 12 066

H20 Land south of Coleshill Road, Ansley Common 450 05050606065605550

H1 - Land at Holly Lane, Atherstone PAP/2014/0542 499 25 25 50 75 75 75 60 60 54

Part of H1 - Durnos Nursery, Holly Lane, Atherstone PAP/2014/0540 121 28 28 28 37

H2 Land to north west of Atherstone off Whittington 1282 107 107 107 107 107 107

H3 Land off Sheepy Road, Atherstone 46 20 26

H15 Land at Church Farm, Baddesley Ensor 47 0101010107 H6 Allotments adjacent to Memorial Park, Coleshill 30 0101010 H16 Land south of Grendon Community Hall 7 7 H17 - Former Sparrowdale School site NEW APPLICATION and Recycling centre Spon Lane GRANTED ON THIS Grendon SITE (PAP/2018/0287 and PAP/2019/0396 - 56units approved 56 25 31 H19 Land between Church Road & Nuneaton Road, Hartshill 400 25 25 50 50 50 50 50 50 50 H24 Land at Manor Farm, Austrey Lane, Newton Regis PAP/2016/0266 30 16

H7 Land to east of Polesworth & Dordon 1969 120 120 120 120 120 120 H13 Land west of Robey's Lane PAP/2018/0755 1270 50 107 107 107 107 107 107 107 107 107 PAP/2019/0022 H25 - Land south of Shuttington Outline Granted - Village Hall 27/05/2020 24 12 12 PAP/2017/0202 (22/11/2018) and H26 - land north of Orton Road, PAP/2016/0280 Warton (28/06/2019) 128 0404444 H21 Former School redevelopment site, Attleborough Lane/Vicarage Lane, Water Orton 48 24 24 H14 Site at Lindridge Road adj Langley SUE 141 41 50 50 H28 - Land south of Islington Farm, Wood End 28 028 TOTALS 6588 0 53 59 65 165 222 355 359 539 553 540 545 513 460 4428 1st Phase 2nd A5 Phase A5

Pegasus Options 2 Housing Supply Table as follows;

Year - Plan Period 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 Sub Total Totals Completions (net) 75 38 119 223 251 363 203 298 1570 1570 Windfall Allowance 60 60 60 60 60 60 60 60 60 60 60 660 660 Planning Permissions 0 132 328 414 282 105 60 20 1341 1301 -3% minus lapse rate (excluding 2020/21) New Options 2 Allocations Trajectory - Annual Totals Within Plan Period 0 535965165222 355 359 539 553 540 545 513 460 4428 4428

Annual Totals Within Plan Period 75 38 119 223 251 363 203 298 132 381 473 407 330 342 435 419 599 613 600 605 573 520 7999 7959 1st Phase 2nd A5 Phase A5 RED TEXT HIGHLIGHTS PEGASUS CHANGES TO NWBC26C TRAJECTORY ALP22 October 2020 | NCO | BIR.3048

NORTH WARWICKSHIRE LOCAL PLAN EXAMINATION

LOCAL PLAN – ADDITIONAL DOCUMENTS CONSULTATION RESPONSE

LAND OFF BIRMINGHAM ROAD & LAND SOUTH OF WATER ORTON PRIMARY SCHOOL, WATER ORTON

ON BEHALF OF RICHBOROUGH ESTATES (SLP430)

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Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester

©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited Richborough Estates Additional Documents Response

Contents Page No.

1. NTRODUCTION 1 2. HOUSING REQUIREMENTS 1 3. INFRASTRUCTURE REQUIREMENTS 2 4. STEPPED TRAJECTORY 3 5. LEAD IN TIMES 4 6. DELIVERY RATES 5 7. BUFFER & FLEXIBILITY 6 8. TRAJECTORY 7 9. SAFEGUARDED LAND 8 10. CONCLUSION 9

APPENDIX 1: Lichfields Start to Finish (Second Edition) Feb 2020

APPENDIX 2: Pegasus Changes to NWBC24C Traject

October 2020 | NCO | BIR.5373

Richborough Estates Additional Documents Response

1. NTRODUCTION

1.1 This representation has been prepared by Pegasus Group on behalf of Richborough Estates who has land interests within North Warwickshire Borough. This statement provides a response to the ‘Local Plan- Additional Documents’ in respect of Richborough Estates’ interest relates to land off Birmingham Road, Water Orton and land south of Water Orton Primary School.

1.2 These representations relate specifically to the schedule of potential main modifications (NWBC20E) and further evidence that has been produced in respect of housing need and supply, including NWBC26A, NWBC26B and NWBC26C.

2. HOUSING REQUIREMENTS

2.1 In respect of OAHN the LP is based primarily upon evidence contained within the Strategic Housing Market Assessment Update (CD8/10) published in September 2015, over 5 years ago, which utilised the 2012 SNHP. The Inspector identifies within INSP21 that the 2018-based SNHP indicate a likely uplift in household formation in coming years relative to previous, data series.

2.2 Utilisation of the 2018 SNHP would result in the minimum housing requirement rising to 10,015. As set out in NWBC27, this is an increase of 417 dwellings over the plan period. Richborough Estates consider the 2018 SNHP should now be utilised to determine the OAHN for the purposes of this Local Plan on the basis the SHMA is out of date. Therefore, the housing requirement should be amended to a minimum of 10,015 over the proposed 22 year plan period. The required flexibility in supply should also be provided to ensure this OAHN can be delivered within the Plan period.

2.3 At present, the flexibility in the proposed supply contained within the emerging Local Plan would be insufficient to deliver a minimum of 10,015 homes, even if all identified sources of supply were realised within the plan period.

2.4 It is noted that the Council contends, through NWBC27, that there is no effective potential for additional supply to be brought forward in North Warwickshire, however this cannot be the case when there is currently no meaningful proposed housing development focused to Water Orton; a Category 3 Local Service Centre, where the only constraint to development is a tightly drawn Green Belt boundary.

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Richborough Estates Additional Documents Response

Richborough Estates provided representations through Matter 3 in respect of reliance on the conclusions contained within the SGS which are not repeated here.

2.5 In addition, representations submitted by Richborough Estates highlighted there is significant potential to increase supply within a number of settlements within North Warwickshire Borough. Examples include settlements such as Coleshill and Water Orton, where development is artificially constrained by Green Belt. In these settlements it can be demonstrated that locally derived housing needs will not be met through the implementation of the emerging strategy resulting in increased house prices, which are already significantly above the Borough average. In addition, as these settlements have strong functional links with the conurbation, including train stations with direct services to Birmingham and good access to existing and planned employment provision such as UK Central and Hams Hall, market attractiveness of these settlements will only increase.

2.6 MM34 should be amended accordingly.

3. INFRASTRUCTURE REQUIREMENTS

3.1 The Inspector, within INSP18, recognises that a significant element of the development proposed relies upon the improvements to the A5. The following three options were set out by the Inspector to overcome fundamental issues of soundness:

a) await the outcome of the HIF bid and unambiguously identify the likely source(s) of funding for the dualling of the A5; or

b) put forward alternative sites that do not rely on highways improvements for which funding is not certain or unknown; or

c) withdraw the plan.

3.2 Whilst it is agreed that MHCLG funds have been identified for the improvements to the A5 corridor as part of the RIS process, it is clear from the ‘Additional Documents’ subject to this consultation, including NWBC26 written in July 2020, there is still no agreement between Homes England, Highways England, Warwickshire County Council, the Department for Transport and the MHCLG on the delivery of such a scheme or indeed the timescales for delivery. NWBC26 highlights that such agreement is required prior to determining the ‘actual stepped trajectory.’

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Richborough Estates Additional Documents Response

3.3 In light of the above lack of clarity in respect of the delivery of the A5 improvements, Richborough Estates considers it necessary for alternative sites to be put forward that do not rely on such improvements. If an alternative strategy is not pursued the Local Plan should at the very least identify further allocations, that are not reliant upon the A5 improvements. Such allocations should be consistent with the settlement hierarchy set out in LP2, including within Water Orton as a Category 3 Local Service Centre, recognising that LP2 requires development within the Borough to be ‘proportionately distributed and be of a scale that is in accordance with the Borough’s settlement hierarchy.

4. STEPPED TRAJECTORY

4.1 INSP20 requests the establishment of a stepped housing trajectory which aligns to the overarching requirement of the Plan period with an appropriate degree of flexibility, justified by revisited evidence of lead-in-times and delivery rates.

4.2 The Council has prepared a number of stepped trajectories and it is understood from NWBC27 that the Option 2 trajectory is the Council’s preferred option. This stepped trajectory assumes a continuation of 203 dpa until 2018 and rising incrementally to 775 dpa in the final eight years of the plan period.

4.3 Richborough Estates does not support the introduction of the stepped trajectory; one that has been contrived to respond to an unsound distribution of proposed housing growth where delivery is predicated on the as yet uncommitted A5 improvements.

4.4 In addition, no clear evidence has been provided by the Borough Council in devising this stepped trajectory, the effect of which will be to result in identified housing need, both market and affordable, not being met within the Borough in the short to medium term. This is particularly pertinent in respect of affordable housing where need remains high and is identified by the Borough Council as being between 149 and 267 dwellings per annum which, at the top end of that range, is significantly higher than the annual housing requirement until 2024.

4.5 In line with INSP21 the stepped trajectory should not unnecessarily delay meeting identified development needs and it is therefore questioned whether it is appropriate that the Local Plan will fail to boost supply until 2024/25, some 13 years into a 21 year plan period.

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Richborough Estates Additional Documents Response

5. LEAD IN TIMES

5.1 The Council’s evidence of lead in times and delivery rates published within NWBC24B, Annex 1 is not supported by Richborough Estates.

5.2 In light of the lack of evidence in respect of lead-in times for development of the scale of proposed allocations within the emerging Local Plan it is considered necessary to rely on national trends.

5.3 Evidence was submitted By Richborough Estates in respect of lead-in times as part of Matter 9 discussions and therefore is not repeated here. However, it should be noted that Lichfield’s ‘Start to Finish’ Second Edition (Appendix 1) was published in February 2020 and provides more up to date evidence. This concludes the following average lead-in times nationally for a range of sites:

Site Size Average Average Average Validation of 1st Planning Planning to Application to 1st Approval Delivery Completion Period Period

50-99 1.4 2.0 3.3 years

100-499 2.1 1.9 4.0 years

500-999 3.3 1.7 5.0 years

1,000-1,499 4.6 2.3 6.9 years

1,500-1,999 5.3 1.7 7.0 years

Source: Lichfields Start to Finish ‘Second Edition’ 2020

5.4 In respect of H2 and H7 the supply trajectory assumes first deliveries on both sites in April 2025, some 4.5 years from today's date. Applications have not been submitted in respect of either site and therefore first completions should be pushed back to April 2028 at the very earliest in line with national trends evidence set out above.

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Richborough Estates Additional Documents Response

6. DELIVERY RATES

6.1 The delivery rates assumed in respect of a number of proposed allocations are considered completely unrealistic. The Inspector’s view contained within INSP20, that there is no compelling justification for anticipated build-out rates significantly above national trends is supported by Richborough Estates. The Council’s approach to the delivery trajectory, of applying either 50 dwellings per annum per sales outlet, or accepting trajectories provided by developers without significant scrutiny, is not a robust approach.

6.2 Evidence was submitted By Richborough Estates in respect of build out rates as part of the Matter 9 discussions and therefore is not repeated here. However, it should again be noted that Lichfield’s ‘Start to Finish’ Second Edition, published in February 2020 (Appendix 1), concludes the following average rates nationally at which new homes are built on sites:

Site Size Start to Finish 2016 Start to Finish 2020 Difference ‘First Edition’ build-out ‘Second Edition’ rates build-out rates

50-99 27 22 -5 (-19%)

100-499 60 55 -5 (-8%)

500-999 70 68 -2 (-3%)

1,000-1,499 117 107 -10 (-9%)

1,500-1,999 129 120 -9 (-7%)

Source: Lichfields Start to Finish ‘Second Edition’ 2020

6.3 The maximum annual delivery rates assumed by the Council on a number of the proposed allocations should be amended as overall, it is considered that the application of the above delivery rates is a realistic and justified approach which takes account of market absorption. The table below sets out the difference between the average delivery rates contained within NWBC26C and national trends contained within the recently published Start to Finish Report.

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Richborough Estates Additional Documents Response

Site Number of Start to Finish NWBC average Difference Allocation proposed 2020 average build-out rates Dwellings build-out rates

H1 499 55 55 0 (0%)

H2 1,282 107 160 +53 (+50%)

H7 1,969 120 209 +89 (+74%)

H13 1,270 107 127 +20 (+19%)

H20 450 55 56 +1 (+2%)

6.4 In light of the above, the supply trajectory should be amended in respect of H2, H7 and H13 in line with the national trends evidence identified in the tables above. The assumed delivery rates for H2 and H7 are significantly in excess of what can realistically be expected even with multiple sales outlets and is therefore not justified.

7. BUFFER & FLEXIBILITY

7.1 INSP18 highlighted that a phased trajectory with a 5% five year land supply buffer ‘may be appropriate.’ INSP20 again requests the establishment of a stepped trajectory with ‘an appropriate degree of flexibility, justified by revisited evidence of lead-in times and delivery rates.’

7.2 NWBC26 provides the Council’s approach to the issue of flexibility within the housing trajectory. It is clear that a 5% five year housing land supply buffer has not been included within the trajectory as a 5% buffer has only been applied to the forward supply minus any sites that benefit from planning permission. A 3% lapse rate has then been applied to the committed supply. This approach is incorrect and unsound and does not provide the necessary buffer or an appropriate degree of flexibility required.

7.3 A non-implementation rate is very different to a buffer. The buffer performs a totally different role. It is not a tool to ensure the local plan requirement can be met, but simply seeks to allow supply to be moved forward in the plan period, endeavouring to bring forward additional capacity now to ensure housing is

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Richborough Estates Additional Documents Response

boosted significantly and ensure that in the immediate future shortfalls do not occur. In essence it is there to enable housing supply to have a fighting chance of being boosted significantly. Therefore, the buffer should be applied to the committed supply not yet delivered irrespective of the non-implementation rate. To overcome this issue of unsoundness further supply needs to be identified within the emerging Local Plan. This is particularly important within a stepped trajectory as such an approach would clearly result in a delay in meeting identified development needs.

7.4 A 5% buffer alone does not constitute the necessary flexibility required for the proposed housing strategy. Whilst it is recognised that a 3% non-implementation rate has been applied to the committed supply, the housing trajectory is predicated on the A5 improvements being delivered within specific date milestones. Richborough Estates considers that reliance on the A5 improvements being delivered, and delivered in line with the assumed milestones, represents a significant risk to the strategy and the ability of the housing requirement of 9,598 homes being delivered within the Plan period. This is particularly true as the A5 improvement project remains uncommitted as it is still subject to further clarification and detail.

7.5 It is accepted that the Local Plan seeks to provide limited flexibility through the identification of reserve sites. However, one of these reserve sites (RH1) is also predicated upon the delivery of the A5 improvements. Richborough Estates consider that the identified reserve sites do not provide the necessary flexibility within the housing trajectory to provide any certainty that the identified housing needs can be met within the Plan period. To address this unsoundness further reserve sites should be identified, that are not reliant upon the A5 improvements, to provide the necessary flexibility to ensure certainty of delivery.

8. TRAJECTORY

8.1 Having regard to national trends evidence and the requirement to provide a 5% buffer, further allocations are required to ensure the delivery of the OAHN within the plan period.

8.2 A revised trajectory has been prepared and is attached at Appendix 2 to these representations. This demonstrates the need to allocate additional land necessary to deliver a minimum of a further 1,967 homes to 2033 to meet an OAHN of 9,598 homes or a minimum of a further 2,445 homes to 2033 to meet an increased OAHN of 10,015 homes in line with the 2018 SNHP.

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Richborough Estates Additional Documents Response

9. SAFEGUARDED LAND

9.1 Richborough Estates objects to the principle of removing Policy LP4 Safeguard Land for Potential Future Development (MM24). INSP18 paragraph 16 sought justification from the Council for release or safeguarding for potential development of land in the Green Belt, recognising the evidence did not justify the only area of safeguarded land being adjacent to Kingsbury via Policy LP4.

9.2 At paragraph 17 of INSP18 identifies the ambiguity in the Plan in respect of Coleshill, recognising that land at Coleshill was previously recommended for safeguarding [AD20A], a higher order settlement to Kingsbury. The Inspector suggests that for ‘consistency’ with national policy ‘either the plan’s approach to safeguarding Green Belt land at Kingsbury should be revised, or additional land should be safeguarded at other settlements in line with the plan’s settlement hierarchy.’ This ambiguity also relates to Water Orton, a similar Category 3 settlement to Kingsbury.

9.3 Richborough Estates considers the removal of land at Kingsbury as a safeguarded site is not the correct response and fails to provide consistency with national guidance. Paragraph 85 of the NPPF 2012 is clear that LPAs should “where necessary, identify in their plans areas of ‘safeguarded land’ between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period” and “satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.”

9.4 The submitted Local Plan justified the need for ‘safeguarded land’ for potential future development and this position has not changed. The Council’s justification for Green Belt release related to (i) pressures for growth, (ii) the role of different settlements, and (iii) site specific circumstances. The Inspector agreed these were ‘reasonable considerations.’ Whilst these considerations did not support a single area of safeguarded land at Kingsbury, the solution to this issue of soundness cannot simply be the removal of this site from the Plan.

9.5 The Local Plan is required to consider whether the existing Green Belt boundary remains appropriate when considering needs within the current Plan period and the longer-term development needs of the Borough beyond the Plan period. Richborough Estates supports the Council’s position that there are exceptional circumstances for Green Belt release within the plan period and the previously contended position that there is a need to support the longer-term development needs of the Borough.

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Richborough Estates Additional Documents Response

9.6 Richborough Estates maintains the position that in the longer-term, settlements including Water Orton will need to retain a role in providing new homes to meet the objectively assessed housing needs of the Borough, including identified local needs for affordable homes. With the existing Green Belt drawn tightly around the existing settlement boundaries, it is necessary to release land from the Green Belt to ensure future needs can be met and the vitality of services and facilities can be maximised in the longer term. In addition, the pressures to identify further land to accommodate housing in the future will only be exacerbated by the likely continuation of pressures being placed on North Warwickshire from beyond the Borough boundaries.

9.7 By removing all safeguarded land the Local Plan is ineffective in ensuring long term development needs can be met and the Green Belt boundaries will endure well beyond the Plan Period. There is a need for land to be allocated outside the current settlement boundary of Water Orton to meet both market and affordable housing needs in the short term, but there will be a continued need to meet housing needs within Water Orton and other sustainable settlements well beyond the current plan period. Due to the constrained nature of Water Orton, its position within the settlement hierarchy and identified local housing needs emanating from within the settlement and it’s hinterland there is a requirement to remove land from the Green Belt and identify safeguarded land to allow for longer term development beyond the Plan period. Safeguarded land in other local services centres should also be identified having regard to the Council’s identified considerations.

10. CONCLUSION

10.1 The Main Modifications fail to address Richborough Estates significant concerns raised with regards to the fundamental mismatch between the identified settlement hierarchy and the spatial distribution of housing that would result from the identified housing allocations. The proposed housing allocations and committed development would result in the delivery of a spatial strategy which would not constitute sustainable development, resulting in: a significant imbalance in jobs and homes within a number of settlements, including Water Orton; failure in local housing needs (both market and affordable) being met; and, the promotion of unsustainable travel patterns, placing greater strain on infrastructure. To resolve this unsoundness, it is necessary to direct significantly more development to the Category 3 Local Service Centre of Water Orton.

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Richborough Estates Additional Documents Response

10.2 It is recognised that focusing a greater proportion of housing growth to Water Orton would require the removal of land from the Green Belt, however, this is the only option that would allow for a sustainable distribution of growth across the Borough over the Plan Period. There are a number of clear exceptional circumstances to support the removal of land from the Green Belt around this Category 3 Local Service Centre, including:

• Water Orton is a sustainable standalone settlement within the Borough and Green Belt release is the only option to allow it to accommodate growth in line with the identified settlement hierarchy;

• Additional growth is required to support the maintenance of the working age population within Water Orton. This is important to ensure a relative balance between jobs and workers that can assist in meeting the Council’s vision of reducing out commuting and unsustainable travel patterns; and

• Additional growth is required to allow local housing needs (market and affordable) to be met within Water Orton, to ensure existing issues of affordability are not perpetuated and exacerbated.

10.3 In relation to neighbouring need, it is noted that North Warwickshire has agreed to accommodate the unmet need from Neighbouring LPAs and the housing requirement, including cross boundary provision, is now expressed as a minimum (MM34). This approach is supported by Richborough Estates. However, the 2018 SNHP should now be utilised to determine the OAHN for the purposes of this Local Plan. Therefore, a revised housing requirement should be identified of a minimum of 10,015 over the 22 year plan period.

10.4 Richborough Estates has identified significant concerns in respect of the housing trajectory which is not based on robust trends. The housing trajectory contained within NWBC26C does not identify a 5% buffer and fails to have regard to national trends evidence on lead-in times and build out rates. It has been demonstrated that additional land is required to be allocated to ensure the OAHN can be delivered within the Borough to 2033.

10.5 Richborough Estates considers the removal of a safeguarded land policy through MM24 is not the correct response to address the Inspector’s concerns and fails to provide consistency with national guidance. It is considered necessary to release additional land from the Green Belt in appropriate settlements to allow for longer term development needs to be met and for Green Belt boundaries to endure well

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Richborough Estates Additional Documents Response

beyond the plan period. This is necessary to ensure consistency with paragraph 85 of the NPPF 2012. Safeguarded land will be required at Water Orton to support the development needs of a Category 3 settlement constrained by Green Belt.

10.6 A lack of housing development within Water Orton within the plan period and beyond will result in local housing needs not being met. In addition, the lack of proposed housing will result in a significant imbalance between the jobs available and the economically active local population to support sustainable economic growth. This mismatch between the provision of jobs and homes will inevitably lead to unsustainable commuting patterns, placing increasing strain on local infrastructure. The proposed Main Modifications do not address this.

10.7 Land off Birmingham Road, Water Orton and Land south of Water Orton Primary School are suitable and sustainable locations for residential development and represents deliverable and developable propositions, with both locations being available now and providing every prospect that a significant number of homes can be delivered within the next five years. The suitability of these sites for residential development are fully detailed within previous submissions.

October 2020 | NCO | BIR.3048 Page | 11

APPENDIX 1 INSIGHT FEBRUARY 2020 Start to Finish What factors affect the build-out rates of large scale housing sites? SECOND EDITION Lichfields is the pre-eminent planning and development consultancy in the UK We’ve been helping create great places for over 50 years.

lichfields.uk Executive summary

Lichfields published the first edition of Start to Finish in November In too many local plans and five-year land supply cases, 2016. In undertaking the research, our purpose was to help inform there is insufficient evidence for how large sites are the production of realistic housing trajectories for plan making and treated in housing trajectories. Our research seeks to fill decision taking. The empirical evidence we produced has informed the gap by providing some benchmark figures - which numerous local plan examinations, S.78 inquiries and five-year land can be of some assistance where there is limited or supply position statements. no local evidence - but the averages derived from our analysis are not intended to be definitive and are no Meanwhile, planning for housing has continued to evolve: with alternative to having a robust, bottom-up justification for a revised NPPF and PPG; the Housing Delivery Test and Homes the delivery trajectory of any given site. England upscaling resources to support implementation of large sites. Net housing completions are also at 240,000 dwellings per annum. With this in mind, it is timely to refresh and revisit the evidence on the speed and rate of delivery of large scale housing sites, now looking at 97 sites over 500 dwellings. We consider a wide range of factors which might affect lead-in times and build-out rates and have drawn four key conclusions.

We have drawn four key conclusions:

1 Large schemes can take 5+ years to start 2 Lead-in times jumped post recession

Our research shows that if a scheme of more than 500 dwellings has Our research shows that the planning to delivery period for large an outline permission, then on average it delivers its first home in sites completed since 2007/08 has jumped compared to those where c.3 years. However, from the date at which an outline application is the first completion came before 2007/08. This is a key area where validated, the average figures can be 5.0-8.4 years for the first home improvements could be sought on timeliness and in streamlining pre- to be delivered; such sites would make no contribution to completions commencement conditions, but is also likely impacted by a number of in the first five years. macro factors.

3 Large greenfield sites deliver quicker 4 Outlets and tenure matter

Large sites seem to ramp up delivery beyond year five of the Our analysis suggests that having additional outlets on site has a positive development on sites of 2,000+ units. Furthermore, large scale impact on build-out rates. Interestingly, we also found that schemes with brownfield sites deliver at a slower rate than their greenfield more affordable housing (more than 30%) built out at close to twice the equivalents: the average rate of build out for greenfield sites in our rate as those with lower levels of affordable housing as a percentage of all sample is 34% greater than the equivalent brownfield. units on site. Local plans should reflect that – where viable – higher rates of affordable housing supports greater rates of delivery. This principle is also likely to apply to other sectors that complement market housing for sale. Key sites assessed, with combined yield of 213k+ dwellings; 97 sites figures 180 had 500+ homes

average time taken from outline decision notice to first dwelling completions on c.3yrs sites of 500+ homes

the average time from validation of the first planning application to the first dwelling being 8.4yrs completed on schemes of 2,000+ dwellings

the average annual build-out rate for a scheme of 2,000+ 160 dpa dwellings (median: 137)

the average annual build rate of a scheme 68 dpa of 500-999 dwellings (median: 73)

higher average annual build-out rate on +34% greenfield sites compared with brownfield sites

average completions per outlet on sites with one outlet, dropping to 51 for sites of two 61 dpa outlets, and 45 for sites with three outlets INSIGHT START TO FINISH

01 Introduction

This is the second edition of our review on the speed of delivery on large-scale housing development sites. The first edition was published in November 2016 and has provided the sector with an authoritative evidence base to inform discussions on housing trajectories and land supply at planning appeals, local plan examinations and wider public policy debates. Over this period, housing delivery has remained at or near the top, of the domestic political agenda: the publication of the Housing White Paper, the new NPPF, an emboldened Homes England, a raft of consultations on measures intended to improve the effectiveness of the planning system and speed up delivery of housing. Of particular relevance to Start to Finish was the completion of Sir Oliver Letwin’s independent review of build out (“the Letwin Review”), the inclusion within the revised NPPF of a tighter definition of ‘deliverable’ for the purposes of five-year housing land supply (5YHLS) assessment, and the new Housing Delivery Test which provides a backward Our research complements, rather than supplants, looking measure of performance. The policy aim is to focus more the analysis undertaken by Sir Oliver Letwin in his attention on how to accelerate the rate of housing build out, in Review. The most important differentiation is that the context of the NPPF (para 72) message that the delivery of a we focus exclusively on what has been built, whereas large numbers of new homes can often be best achieved through each of the sites in the Letwin Review included larger scale development such as new settlements or significant forecasts of future delivery. Additionally, the Letwin extensions to existing villages and towns, but that these need a Review looked at 15 sites of 1,500+ homes, of which realistic assessment of build-out rates and lead in times of large-scale many (including the three largest) were in London. By development. contrast, the examples in this research sample include 46 examples of sites over 1,500 homes across England This second edition of Start to Finish is our response to the latest and Wales, the majority of which are currently active. policy emphasis. It provides the planning sector with real-world As with the first edition of our research, we have benchmarks to help assess the realism of housing trajectory excluded London because of the distinct market and assumptions, particularly for locations where there have been few delivery factors in the capital. contemporary examples of strategic-scale development. The first edition looked in detail at how the size of the site affected build-out rates and lead in times, as well as other factors such as the value of the land and whether land was greenfield or brownfield. We have Contents updated these findings, as well as considering additional issues such 01 Introduction 1 as how the affordability of an area and the number of outlets on a site impacts on annual build-out rates. 02 Methodology 2 5 We have also expanded the sample size (with an extra 27 large 03 Timing is everything sites, taking our total to 97 large sites, equivalent to over 195,000 04 How quickly do sites build out? 9 dwellings) and updated with more recent data to the latest 05 What factors influence build-out rates? 14 monitoring year (all data was obtained at or before the 1st April 2019). 06 Conclusions 18

1 INSIGHT START TO FINISH 02 Methodology 180 sites The evidence presented in this report analyses by significant amounts of pre-application how large-scale housing sites emerge through engagement and work, plus the timescale of the the planning system, how quickly they build local plan process. out, and identifies the factors which lead to 97 The ‘planning to delivery’ period follows faster or slower rates of delivery. large sites of 500 immediately after the planning approval period units or more We look at the full extent of the planning and measures the period from the approval and delivery period. To help structure the of the first detailed application to permit research and provide a basis for standardised development of dwellings and the completion measurement and comparison, the various of the first dwelling. 27 stages of development have been codified. additional sites Figure 1 sets out the stages and the milestones Development and data compared with our used, which remain unchanged from the first Whilst our analysis focuses on larger sites, we 2016 research edition of this research. The overall ‘lead-in have also considered data from the smaller time’ covers stages associated with gaining sites for comparison and to identify trends. The an allocation, going through the ‘planning geographic distribution of the 97 large sites and approval period’ and ‘planning to delivery comparator small sites is shown in Figure 2 8 period’, finishing when the first dwelling is and a full list can be found in Appendix 2 (large sites also included completed. The ‘build period’ commences when sites) and Appendix 3 (small sites). in Sir Oliver Letwin’s the first dwelling is completed, denoting the Efforts were made to secure a range of locations review end of the lead-in time. The annualised build- and site sizes in the sample, but there is no way out rates are also recorded for the development of ensuring it is representative of the housing up until the latest year where data was available market in England and Wales as a whole, and at April 2019 (2017/18 in most cases). Detailed thus our conclusions may not be applicable definitions of each of these stages can be found in all areas or on all sites. In augmenting our in Appendix 1. Not every site assessed will sample with 27 additional large sites, new necessarily have gone through each component to this edition of our research, we sought to of the identified stages as many of the sites include examples in the Letwin Review that we considered had not delivered all dwellings were outside of London, only excluding them permitted at the time of assessment, some have not delivered any dwellings. Information on the process of securing a Box 1: Letwin Review sites development plan allocation (often the most significant step in the planning process for 1. Arborfield Green (also known as large-scale schemes, and which – due to the Arborfield Garrison), Wokingham nature of the local plan process - can take decades) is not easy to obtain on a consistent 2. Ledsham Garden Village, Cheshire West basis across all examples, so is not a significant & Chester focus of our analysis. Therefore, for the 3. Great Kneighton (also known as Clay purposes of this research the lead-in time Farm), Cambridge (included in the first reflects the start of the planning approval edition of this research) period up to the first housing completion. 4. Trumpington Meadows, Cambridge The ‘planning approval period’ measures the 5. Graven Hill, Cherwell validation date of the first planning application 6. South West Bicester, Cherwell on the site (usually an outline application but sometimes hybrid), to the decision date of the 7. Great Western Park, South Oxfordshire first detailed application to permit dwellings 8. Ebbsfleet, Gravesham and Dartford in the scheme (either full, hybrid or reserved (included in the first edition of this matters applications). It is worth noting that research) planning applications are typically preceded

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when it was difficult to obtain reliable data. The The sources on which we have relied to secure study therefore includes the Letwin Review’s delivery data on the relevant sites include: case studies listed in Box 1. 1. Annual Monitoring Reports (AMRs) and In most instances, we were unable to secure other planning evidence base documents1 the precise completion figures for these sites produced by local authorities; that matched those cited in the Letwin Review. 2. By contacting the relevant local planning Sources for data Lichfields has obtained on authority, and in some instances the completions for those sites that also appear in relevant County Council, to confirm the the Letwin Review are included at the end of data or receive the most up to date figures Appendix 2. from monitoring officers or planners; and 3. In a handful of instances obtaining/ confirming the information from the relevant house builders.

Figure 1: Timeline for the delivery of strategic housing sites

Securing an allocation

Submission to Site Promotion and Local Secretary of Plan Consultations State (SoS) Suspension of Examination in Public (EIP) Inspector finds ! examination or Local Plan sound withdrawal of Adoption of Local Plan Local Plan Local Planning Authority adopts Local Plan Securing planning permission

Pre-Application Work EIA Screening Planning approval period* Local Planning ! and Scoping Lead-in time* Authority Outline Application minded to Full Planning approve Application S106 Judicial SoS call in/ S106 ! Review application Reserved matters (potential refused/ Planning for) appeal lodged

permission period * Planning to delivery granted Discharge pre-commencement conditions

On site completions Start on site Delivery of infrastructure ‘Opening up works’ ! (e.g. roads) and 1 First housing mitigation (e.g. ecology, completion flooding etc) period* Build

Delivery of dwellings Scheme complete 1 Monitoring documents, five-year land supply reports, housing trajectories (some in land availability Data obtained only for some sites Data obtained for all sites *Definition for research purposes assessments), housing development reports and newsletters Source: Lichfields analysis

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Figure 2: Map of site sample by size of site (total dwellings)

196,714 Large housing sites units on large sites Number of Units of 500 or more 2,000+ homes 1,500-1,999

1,000–1,499 16,467 500–999 units on small sites Small housing sites Number of Units under 500 homes 100–499 35 <100 sites of 2,000 homes or more

Source: Lichfields analysis

4 INSIGHT 03 START TO FINISH Timing is everything: how long does it take to get started?

In this section we look at lead in times, the considered deliverable where there is clear evidence time it takes for large sites to get the necessary that housing completions will begin on site within planning approvals. Firstly, the changing five years”. (emphasis added) c.3 years context of what ‘deliverable’ means for What constitutes ‘clear evidence’ was clarified development. Secondly, the ‘planning approval average time from in a number of early appeal decisions and in the obtaining outline period’ (the time it takes for large sites to get Planning Practice Guidance2 and can include permission to first the necessary planning approvals). And thirdly, information on progress being made towards dwelling completion the ‘planning to delivery period’ (the time submission of a reserved matters application, on sites of 500+ from approval of the first detailed application any progress on site assessment work and homes to permit development of dwellings to the any relevant information about site viability, completion of the first dwelling). ownership constraints or infrastructure provision. In this context, it is relevant to look The new definition of ‘Deliverable’ at how long it takes, on average, for a strategic The question of how quickly and how much housing site to progress from obtaining outline housing a site can begin delivering once it permission to delivering the first home (or how has planning permission, or an allocation, has long it takes to obtain the first reserved matters become more relevant since the publication approval, discharge pre-commencement of the new NPPF with its new definition conditions and open up the site), and then how of deliverable. Only sites which match the much housing could be realistically expected to deliverability criteria (i.e. suitable now, be completed in that same five-year period. available now and achievable with a realistic prospect that housing will be delivered on Based on our sample of large sites, the the site within five years) can be included in a research shows that, upon granting of outline calculation of a 5YHLS by a local authority. This permission, the time taken to achieve the first definition was tightened in the revised NPPF dwelling is – on average c.3 years, regardless of which states that: site size. After this period an appropriate build- out rate based on the size of the site should “sites with outline planning permission, permission also be considered as part of the assessment of in principle, allocated in the development plan or deliverability (see Section 4). Outline planning identified on a brownfield register should only be permissions for strategic development are not

Figure 3: Average time taken from gaining outline permission to completion of the first dwelling on site (years), compared to site size

3.5 3.1 3.2 3.1 3.0 2.9 3.0 2.8

2.5 2.5 2.5

2.0

1.5

1.0

0.5

Outline permission to first dwelling completed (years) 0.0 500-999 1,000-1,499 1,500-1,999 2,000+

Site size (dwellings) Mean Median 2 Planning Practice Guidance Reference ID: 68- Source: Lichfeilds analysis 007-20190722

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always obtained by the company that builds Comparison with our 2016 the houses, indeed master developers and other land promoters play a significant role in findings bringing forward large scale sites for housing Planning Approval Period Only sites of fewer development3. As such, some of these examples Our latest research reveals little difference than 499 dwellings will include schemes where the land promoter are on average likely between the average planning approval period or master developer will have to sell the site to deliver any homes by site size compared to the same analysis in the (or phases/parcels) to a housebuilder before within an immediate first edition (see Table 1). However, it is important five year period. the detailed planning application stage can to remember that these are average figures commence, adding a step to the planning to which come from a selection of large sites. There delivery period. are significant variations within this average, Figure 4 considers the average timescales with some sites progressing very slowly or for delivery of the first dwelling from the quickly compared to the other examples. This is validation of an outline planning application. unsurprising as planning circumstances will vary This demonstrates that only sites comprising between places and over time. fewer than 499 dwellings are – on average - likely to deliver anything within an immediate Table 1: Average planning approval period by size of site (years) five year period. The average time from 1st edition This research 4 Site Size validation of an outline application to the research (years) (years) delivery of the first dwelling for large sites 50-99 1.1 1.4 ranges from 5.0 to 8.4 years dependent on the size of the site, i.e. beyond an immediate five- 100-499 2.4 2.1 year period for land supply calculations. 500-999 4.2 3.3

1,000-1,499 4.8 4.6

1,500-1,999 5.4 5.3

2,000+ 6.1 6.1

Source: Lichfields analysis

Figure 4: Average timeframes from validation of first application to completion of the first dwelling

9 8.4

8 6.9 7.0 2.3 7

6 1.7 5.0 2.3 5 3 Realising Potential - our 4.0 research for the Land 4 1.7 Promoters and Developers 3.3* Federation in 2017 - found (years)Duration 3 1.9 6.1 that 41% of homes with 5.3 2.0 4.6 outline planning permission 2 3.3 were promoted by specialist land promoter and 1 2.1 development companies, 1.4 compared to 32% for volume 0 house builders. 50-99 100-499 500-999 1,000-1,499 1,500-1,999 2,000+ 4 The planning approval Site size (dwellings) period could also include a hybrid or full application, Average planning approval period Average planning to delivery period *does not sum due to rounding but on the basis of our examples this only impacts a small number of sites Source: Lichfields analysis

6 INSIGHT START TO FINISH

Planning to Delivery Period A similar trend is apparent considering the 55 sites that delivered their first completions after Although there is little difference between the 2007/08. These have significantly longer planning average planning approval periods identified to delivery periods than those where completions in this research compared to our first edition began prior to the recession. The precise reasons Sites that delivered findings, the average lead-in time after securing are not clear, but is perhaps to be expected given their first completion planning permission is higher (Figure 5). It is during or after the the slowdown in housing delivery during the 2007/08 recession this period during which pre-commencement recession, and the significant reductions in local have significantly planning conditions have to be discharged as authority planning resources which are necessary longer planning to well as other technical approvals and associated to support discharge of pre-commencement delivery periods than commercial agreements put in place. sites which began conditions. However, delays may lie outside the before. planning system; for example, delays in securing This is likely due to the inclusion of more recent necessary technical approvals from other bodies proposed developments in this edition. Of the and agencies, or market conditions. 27 new sites considered, 17 (63%) completed their first dwelling during or after 2012; this compares to just 14 (20%) out of 70 sites in the first edition of this research (albeit at the time of publication 8 of these sites had not delivered their first home but have subsequently). This implies that the introduction of more recent examples into the research, including existing examples which have now commenced delivery5, has seen the average for planning to delivery periods lengthening.

Figure 5: Planning to delivery period, total average, pre and post-2008

4.5 4.0 4.0 3.5 3.5

3.0 2.6 2.7 2.6 2.5 2.4 1.9 2.0 1.9 1.9 1.4 1.5 1.1 1.0 1.0

0.5 Average planning to delivery period (years) Figure 5: Five of the large 0.0 sites examples do not have 500-999 1,000-1,499 1,500-1,999 2,000+ a first dwelling completion Site size (dwellings) recorded in this research

5 Completions begun pre-2008 Completions begun post-2008 All years Priors Hall has been (37 sites) (55 sites) (92 sites) amended since the first edition based on more Source: Lichfeilds analysis recent data

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In demand: how quickly do high pressure areas determine strategic applications for housing? Using industry-standard affordability ratios, we found that areas with the least affordable places to purchase a home (i.e. the highest affordability ratios) tended to have longer planning to delivery times than areas that were more affordable. This is shown in Figure 6, which splits the large site sample into national affordability quartiles, with the national average equating to 8.72.

The above analysis coincides with the fact (Table 2) that sites in the most affordable locations (lowest quartile) tend to be smaller than those in less affordable locations (an average site size of c.1,150 compared to in excess of 2,000 dwellings for the three other quartiles). Even the least affordable LPAs (with the greatest gap between workplace earnings Table 2: Site size by 2018 affordability ratio and house prices) have examples of large schemes Affordability ratio Average site size with an average site size of 2,000+ dwellings. It may (workplace based) be that the more affordable markets do not support the scale of up-front infrastructure investment that 2.5 – 6.4 1,149

is required for larger-scale developments and which 6.5 – 8.7 2,215 lead to longer periods before new homes can be built. However, looking at the other three quartiles, 8.8 – 11.0 2,170 the analysis does also suggest that planning and 11.1 – 44.5 2,079 implementation becomes more challenging in less affordable locations. Source: Lichfields analysis

Figure 6: Planning approval period (years) by 2018 affordability ratio

8

6.8 7

6 5.6 5.4 2.9 5 4.4 1.8 2.0 4 1.5 3

2 3.9 3.4 3.8 2.9 1 Average planning approval period (years) period approval planning Average

0

More affordable 2018 affordability ratio (national quartiles) Less affordable

1st: 2.5 to 6.4 2nd: 6.5 to 8.7 3rd: 8.8 to 11.0 4th: 11.1 to 44.5

Planning approval period Planning to delivery period

Source: Lichfields analysis

8 INSIGHT 04 START TO FINISH How quickly do sites build out?

The rate at which new homes are built on sites Average Annual Build-out rates is still one of the most contested matters at local Figure 7 presents our updated results, with plan examinations and planning inquiries which our additional 27 sites and the latest data for 160 dpa address 5YHLS and housing supply trajectories. all sites considered. The analysis compares the the average annual The first edition of this research provided a size of site to its average annual build-out rate. build rate for schemes range of ‘real world’ examples to illustrate what Perhaps unsurprisingly, larger sites deliver on of 2,000+ dwellings a typical large-scale site delivers annually. The average more dwellings per year than smaller research showed that even when some schemes sites. The largest sites in our sample of over were able to achieve very high annual build-out 2,000 dwellings, delivered on average more than rates in a particular year (the top five annual twice as many dwellings per year than sites of figures were between 419-620 dwellings per 500-999 dwellings, which in turn delivered an annum), this rate of delivery was not always average of three times as many units as sites sustained. Indeed, for schemes of 2,000 or more of 1-99 units. To ensure the build-out rates dwellings the average annual completion rate averages are not unduly skewed, our analysis across the delivery period was 160 dwellings excludes any sites which have only just started per annum. delivering and have less than three years of data. This is because it is highly unlikely that the first annual completion figure would actually cover a whole monitoring year, and as such could distort the average when compared to only one other full year of delivery data.

Figure 7: Build-out rate by size of site (dpa)

180 35% 160 160 29% 30% 140 120 25% 120 21% 107

100 20%

80 68 15%

60 55 9% 9% 10% 7% 40

22 4% as % of total dwellings on site) 5%

Housing delivery (dwellings per annum) per deliveryHousing (dwellings 20 Housing delivery (dwellings per annum

0 0 50-99 100-499 500-999 1,000-1,499 1,500-1,999 2,000+

Site Size (dwellings)

Housing delivery (dwellings per annum) Housing delivery (dwellings per annum as % of total dwellings on site) Source: Lichfields analysis

9 INSIGHT START TO FINISH

We include the relevant percentage growth rates in this edition’s analysis; this shows that the proportion of a site’s total size that is build out each year reduces as site size increases. In most cases the median annual Our use of averages refers to the arithmetic mean delivery rate is lower across the sample sites. In most cases the median than the mean for of the rates seen on the larger sample sites is larger sites. lower, as shown in Figure 8; this reflects the small number of sites which have higher delivery rates (the distribution is not equal around the average). The use of mean average in the analysis therefore already builds in a degree of optimism compared with the median or ‘mid-point scheme’.

Figure 8: Minimum, mean, median and maximum build-out rates by size of site (dpa)

350

Mean 300 Median

250

200

150

100

Housing delivery (dwellings per annum) per deliveryHousing (dwellings 50

0 50-99 100-499 500-999 1,000-1,499 1,500-1,999 2,000+

Source: Lichfields analysis Site Size (dwellings)

Table 3: Median and mean delivery rates by site size

Median housing Mean annual Mean annual Median delivery as Site Size Number of sites delivery (dwellings delivery (dwellings delivery as % of % of total on site per annum) per annum) total units on site

50-99 29 27 33% 22 29%

100-499 54 54 24% 55 21%

500-999 24 73 9% 68 9%

1,000-1,499 17 88 8% 107 9%

1,500-1,999 9 104 7% 120 7%

2,000+ 27 137 4% 160 4%

Source: Lichfields analysis

10 INSIGHT START TO FINISH

Comparison with our 2016 Variations for individual schemes can be findings marked. For example, the 2,605 unit scheme South of the M4 in Wokingham delivered Comparing these findings to those in the first 419 homes in 2017/18, but this was more than edition of this research, there is very little double the completions in 2016/17 (174) and the Site build-out rates difference between the averages observed average over all six years of delivery so far was for individual years (median was not presented) for different site are highly variable. just 147 dwellings per annum. sizes, as set out below. The largest difference is For example, one Even when sites have seen very high peak years scheme in Wokingham a decrease in average annual build-out rates for delivered more than sites of 1,000-1,499 dwellings, but even then, of delivery, as Table 5 shows, no sites have been twice as many homes this is only a reduction of 10 dpa or 9%. able to consistently delivery 300 dpa. in 2017/18 as it did in the year before. As with the first edition of the research, these are averages and there are examples of sites which deliver significantly higher and lower than these averages, both overall and in individual years. Figure 8 shows the divergence from the average for different site size categories. This shows that whilst the average for the largest sites is 160 dpa and the median equivalent 137 dpa, the highest site average was 286 dpa and the lowest site average was 50 dpa for sites of 2,000+ dwellings. This shows the need for care in interpreting the findings of the research, there may well be specific factors that mean a specific site will build faster or slower than the average. We explore some of the factors later in this report.

Table 4: Mean delivery rates by site sizes, a comparison with first Table 5: Peak annual build-out rates compared against average edition findings annual delivery rates on those sites

Average 2016 edition 2020 edition Peak annual Site size Site size annual research research Difference Site build-out (dwellings) build-out rate (dwellings) rate (dpa) (dpa) (dpa) (dpa)

Cambourne, South 50-99 27 22 -5 (-19%) 4,343 620 223 Cambridgeshire Table 5: Please note The Oakley Vale, Hamptons was included as 100-499 60 55 -5 (-8%) 3,100 520 180 Corby an example of peak annual delivery in the first edition Eastern Expansion 500-999 70 68 -2 (-3%) 4,000 473 268 Area, Milton Keynes with one year reaching 520 completions. However, Clay Farm, evidence for this figure 1,000-1,499 117 107 -10 (-9%) 2,169 467 260 Cambridge is no longer available and as it was not possible to South of M4, 1,500-1,999 129 120 -9 (-7%) 2,605 419 147 Wokingham corroborate the figure it has been removed. The analysis Cranbrook, East has been updated to reflect 2,000+ 161 160 -1 (-0.62%) 2,900 419 286 Devon the latest monitoring data from Peterborough City Source: Lichfields analysis Source: Lichfields analysis Council.

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Longer term trends The impact of the recession on This section considers the average build-out build-out rates rates of sites which have been delivering over It is also helpful to consider the impact of a long period of time. This is useful in terms of market conditions on the build-out rate of large planning for housing trajectories in local plans scale housing sites. Figure 10 overleaf shows when such trajectories may span an economic the average delivery rate of sites of 2,000 or cycle. more dwellings in five-year tranches back to In theory, sites of more than 2,000 dwellings 1995/96. This shows that although annual will have the longest delivery periods. build-out rates have improved slightly since Therefore, to test long term averages we have the first half of the 2010’s, they remain 37% calculated an average build-out rate for sites of below the rates of the early 2000’s. The reasons 2,000+ dwellings that have ten years or more of for the difference are not clear and are worthy completions data available. of further exploration – there could be wider market, industry structure, financial, planning For these sites, the average annual build-out or other factors at play. rate is slightly higher than the average of all sites of that size (i.e. including those only part In using evidence on rates of delivery for way through build out), at 165 dwellings per current/historic schemes, some planning annum6. The median for these sites was also 165 authorities have suggested that one should dwellings per annum. adjust for the fact that rates of build out may have been affected by the impact of the This indicates that higher rates of annual recession. We have therefore considered how housing delivery on sites of this size are more the average rates change with and without likely to occur between years five and ten, i.e. including the period of economic downturn after these sites have had time to ‘ramp up’. (2008/09 – 2012/13). This is shown in Table 6 It might even relate to stages in delivery when and it reveals that average build-out rates are multiple phases and therefore multiple outlets only slightly depressed when one includes this (including affordable housing) are operating at period, but may not have fully recovered to the same time. These factors are explored later their pre-recession peaks. We know that whilst in the report. the recession – with the crunch on mortgage

Figure 9: Average build-out rate for sites over 2,000 homes by length of delivery period (dpa)

180 165 160 160 155

140

120

100

80

60

40 Housing delivery (dwellings per annum) per deliveryHousing (dwellings 6 This is based on the 20 completions of seven examples, Chapelford 0 Urban Village, Broadlands, Kings Hill, Oakley Vale, Sites with 10+ years of delivery (7) Sites with 5+ years of delivery (24) All sites (27) Cambourne, The Hamptons and Wixhams Source: Lichfields analysis

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availability – did have a big impact and led to the flow of new sites slowing, there were mechanisms put in place to help sustain the build out of existing sites. However, setting aside that stripping out the recession has a modest impact on the statistical averages for the sites in our sample, the more significant point is that – because of economic cycles - larger sites which build out over five or more years are inherently likely to coincide with a period of economic slowdown at some point during their build out. It therefore makes sense for housing trajectories for such sites to include an allowance for the prospect that, at some point, the rate of build out may slow due to a market downturn, albeit the effect may be smaller than one might suspect.

Table 6: Impact of recession on build-out rates

Build-out rates excluding Build-out rates in all years Build-out rates pre-recession recession years (2008/9-2012/13)

Average rate Sample size Average rate Sample size Average rate Sample size

All large sites 115 77 126 68 130 21 500+

All large sites 160 27 171 25 242 6 2,000+

Greenfield sites 181 14 198 12 257 3 2,000+

Source: Lichfields analysis

Figure 10: Average build-out rate by five year period for sites over 2,000 dwellings (dpa)

250 235

200 190 181

147 150 136

100

50 Housing delivery (dwellings per annum) per deliveryHousing (dwellings

0 1995/96-1999/00 2000/01-2004/05 2005/06-2009/10 2010/11-2014/15 2015/16-2017/18*

Delivery period Source: Lichfields analysis

13 INSIGHT START TO FINISH 05 What factors can influence build-out rates?

Having established some broad averages and how delivered for three years or more. This analysis these have changed over time, we turn now to shows that sites in areas of higher demand +34% look at what factors might influence the speed (i.e. less affordable) deliver on average more at which individual sites build out. How does dwellings per annum. higher average annual build-out housing demand influence site build out? What is Our analysis also coincides with the fact that rates on greenfield the impact of affordable housing? Does it matter sites in less affordable areas are on average land compared with whether the site is greenfield or brownfield? c.17% larger than those in more affordable brownfield What about location and site configuration? areas. The average site size for schemes in In demand: do homes get delivered areas where affordability is below the national faster in high pressure areas? average is 1,834 dwellings. For those delivered in areas where the affordability is greater than One theory regarding annual build-out rates is the national average, average site size is 2,145 that the rate at which homes can be sold (the dwellings. So, it is possible that the size of site – ‘absorption rate’) determines the build-out rate. rather than affordability per se – is a factor here. This is likely to be driven by levels of market demand relative to supply for the product being Do sites on greenfield land deliver supplied. more quickly? This analysis considers whether demand for The first edition of this research showed that housing at the local authority level affects greenfield sites on average delivered quicker delivery rates by using (industry-standard) than their brownfield counterparts. In our affordability ratios. Higher demand areas are updated analysis this remains the case; large indicated by a higher ratio of house prices greenfield sites in our sample built out a third to earnings i.e. less affordable. Whilst this faster than large brownfield sites. is a broad-brush measure, the affordability In the life cycle of a site, our data also shows ratio is a key metric in the assessment of that greenfield sites had shorter planning to local housing need under the Government’s delivery periods (2.0 years compared to 2.3 for standard methodology. Figure 11 shows the brownfield sites), although on average, longer sample of 500+ unit schemes divided into those planning approval periods (5.1 years compared where the local authority in which they are to 4.6 for brownfield sites). located is above or below the national median affordability ratio (8.72) for sites which have

Figure 11: Build-out rates by level of demand using national Figure 12: Build-out rates on brownfield and greenfield sites median 2018 workplace based affordability ratio (dpa) (dpa)

140 140

120 120

100 100

80 80 131 60 126 60 99 98 40 40

20 20 Housing delivery (dwellings per annum) per deliveryHousing (dwellings Housing delivery (dwellings per annum) per deliveryHousing (dwellings 0 0 More affordable than Less affordable than Brownfield Greenfield national average (<8.72) national average (>8.72)

Source: Lichfields analysis Source: Lichfields analysis

14 INSIGHT START TO FINISH

Housing mix and variety not be. On this basis, we use the outlets metric as Among the more topical issues surrounding a proxy for variation. Based on the limited data delivery rates on large-scale sites is the variety available for this analysis, if two phases are being of housing on offer. The Letwin Review posited built out at the same time by the same housebuilder Having more outtlets that increasing the diversity of dwellings on large (e.g. two concurrent parcels by Bovis) this has been counted as one outlet with the assumption there is operating at the same sites in areas of high housing demand would help time will on average achieve a greater rate of build out. The report little variety (although it is clear that some builders quicken build-out concluded that a variety of housing is likely may in reality differentiate their products on the rates. to appeal to a wider, complementary range of same site). This data was derived from sites in a potential customers which in turn would mean relatively small number of local planning authorities a greater absorption rate of housing by the local who publish information relating to outlets on site. market. It therefore represents a small sample of just 12 sites, albeit over many different years in which the number Consistent data on the mix of sizes, types and prices of outlets varied on the same site, giving a total of 80 of homes built out on any given site is difficult to data points i.e. individual delivery rates and number of source, so we have used the number of sales outlets outlets to compare. on a site as a proxy for variety of product. This gives the prospect of multiple house builders each Our analysis confirms that having more outlets seeking to build and sell homes for which there operating at the same time will on average have a is demand in the face of ‘competing’ supply from positive impact on build-out rates, as shown in Figure other outlets (as revealed by the case study of Land 13. However, there are limits to this, likely to be due South of the M4 in Wokingham). Letwin stated to additional capacity from the outlets themselves as that “…it seems extraordinarily likely that the presence well as competition for buyers. of more variety in these aesthetic characteristics would On a site-by-site basis, the average number of create more, separate markets”7. Clearly, it is likely that outlets open over the site’s entire delivery lifetime on many sites, competing builders may focus on a had a fairly strong correlation with annual delivery, similar type of product, for example three or four both as a percentage of total dwellings and in absolute bed family housing, but even across similar types of terms, with a greater number of outlets contributing dwelling, there will be differences (in configuration, to higher levels of delivery. However, the completions design, specification) that mean one product may be per outlet did reduce with every additional outlet attractive to a purchaser in the way another might operating in that year.8

Figure 13: Build-out rates by number of outlets present (dpa)

450

400

350

300

250

200

150

100 7 Letwin Review draft analysis report (June 2018) Housing delivery (dwellings per annum) per deliveryHousing (dwellings 50 - final bullet of para 4.25 8 Average completions per 0 outlet on site with one outlet 0 1 2 3 4 5 6 7 8 9 10 was 61dpa, dropping to Outlets 51dpa for two outlets and Source: Lichfields analysis 45dpa for three outlets.

15 INSIGHT START TO FINISH

Geography and Site Configuration Keynes Council suggesting an average of c.12 parcels were active across the build period. In this An under-explored aspect of large-scale site second edition of this research the Milton Keynes delivery is the physical opportunity on site. examples remain some of the sites with the For example, some schemes lend themselves to highest annual build-out rates. simultaneous build out of phases which can have the impact of boosting delivery rates in that year,

for example, by having access points from two Table 7: Parcels at Land South of M4, Wokingham alternative ends of the site. Other sites may be reliant on one key piece of infrastructure which Parcel Developers Completions make this opportunity less likely or impractical. reference (active outlets) in 2017/18

In the first edition of this research we touched SP1 Bellway (1) 59 on this point in relation to Eastern Expansion None - parcel SP2w Bellway and Bovis (-) Area (Broughton Gate & Brooklands) of Milton completed Keynes. As is widely recognised, the planning SP3 Crest Nicholson (1) 47 and delivery of housing in Milton Keynes is Taylor Wimpey and David distinct from almost all the sites considered in SP4 140 Wilson Homes (2) this research as serviced parcels with the roads already provided were delivered as part of the SP9_1 Bloor, Bovis and Linden (3) 169

Milton Keynes delivery model. Multiple house None - parcel SP10 Darcliffe Homes (-) builders were able to proceed straight onto the completed

site and commence delivery on different serviced SP11 Taylor Wimpey (1) 4 parcels, with monitoring data from Milton Source: Lichfields analysis

Figure 14: Map of parcels at Land South of M4, Wokingham

Source: © Google Earth 2020/ Wokingham Local Plan

16 INSIGHT START TO FINISH

In this edition we look at the case study of Land Affordable choices: do different South of the M4 in Wokingham. In 2017/18 tenures provide more demand? the site achieved a significant 419 completions. Our findings on tenure, another form of Using the local authority’s granular recording of ‘variety’ in terms of house building products, delivery on the site to date, we have been able to Schemes with more are informed by data that is available on about consider where these completions were coming affordable housing half the sites in our large site sample. From built out at close to forward from within the wider 2,605 dwelling this the analysis shows schemes with more twice the rates as scheme. As shown in Figure 14, in that year those with lower affordable housing built out at close to twice new homes were completed on five separate levels. the rate as those with lower levels of affordable parcels with completions ranging from 4 to housing as a percentage of all dwellings on site. 169 dwellings. On some of these parcels (SP9_1 However this is not always the case. Schemes and SP4) there were two or three separate with 20-29% affordable housing had the lowest housebuilders building out, and in total on the build-out rates, both in terms of dwellings and site there were seven different house building proportionate to their size. companies active (the impact of multiple outlets on build-out rates is explored later in this report). The parcels are located in separate parts of the site and each had their own road frontages and access arrangements which meant they are able to come forward in parallel. This can enable an increased build rate.

Source: Lichfields analysis

Figure 15: Build-out rates by level of affordable housing (dpa and percentage)

160 16%

142 140 135 14%

12% 12.1% 120 12% 107 104 10.0% 100 98 10%

80 8% 6.5% 5.9% 60 6%

40 4% Housing delivery (dwellings per annum) per deliveryHousing (dwellings

20 2% Housing delivery (dwellings per annum as % of total dwellings on site)

0 0 0-9% 10-19% 20-29% 30-39% 40%+ Level of affordable housing on site (% of total dwellings)

Housing delivery (dwellings per annum) Housing delivery (dwellings per annum as % of total dwellings on site) Source: Lichfields analysis

17 INSIGHT START TO FINISH 06 Conclusions

Recent changes to national planning policy helpful in locations where there is little recent emphasise the importance of having a realistic experience of such strategic developments. Whilst expectation of delivery on large-scale housing we present some statistical averages, the real sites, whilst local authorities now find themselves relevance of our findings is that there are likely subject to both forward and backward-looking to be many factors which affect lead-in times housing delivery performance measures. A and build-out rates, and that these - alongside number of local plans have hit troubles because the characteristics of individual sites - need to be they over-estimated the yield from some of considered carefully by local authorities relying their proposed allocations. Meanwhile, it is no on large sites to deliver planned housing. longer sufficient for a 5YHLS to look good on In too many local plans and 5YHLS cases, there paper; the Housing Delivery Test means there are is insufficient evidence for how large sites are consequences if it fails to convert into homes built. treated in housing trajectories. This research To ensure local authorities are prepared for these seeks to fill the gap with some benchmark figures tests, plan making and the work involved in - which can be of some assistance where there maintaining housing land supply must be driven is limited or no local evidence. But the average by realistic and flexible housing trajectories, derived from our analysis are not intended to based on evidence and the specific characteristics be definitive and are no alternative to having a of individual sites and local markets. For local robust, bottom-up justification for the delivery authorities to deliver housing in a manner which trajectory of any given site. It is clear from is truly plan-led, this is likely to mean allocating our analysis that some sites start and deliver more sites rather than less, with a good mix of more quickly than the average, whilst others types and sizes, and being realistic about how have delivered much more slowly. Every site is fast they will deliver so supply is maintained different. Therefore, whilst the averages observed throughout the plan period. Equally, recognising in this research may be a good starting point, the ambition and benefits of more rapid build out there are a number of key questions to consider on large sites, it may mean a greater focus on how when estimating delivery on large housing sites, such sites are developed. based around the three key elements in the three- tier analytical framework at Figure 16. Our research provides those in the public and private sector with a series of real-world benchmarks in this complex area of planning for large scale housing, which can be particularly

18 INSIGHT START TO FINISH

Key findings:

1 Large schemes can take 2 Lead-in times jumped 5+ years to start post-recession

In developing a local plan, but especially Whilst attention and evidence gathering in calculating a 5YHLS position, it is is often focused on how long it takes to important to factor in a realistic planning get planning permission, the planning to approval period dependent on the size delivery period from gaining permission of the site. Our research shows that if a to building the first house has also been scheme of more than 500 dwellings has increasing. Our research shows that the an outline permission, then the average planning to delivery period for large sites time to deliver its first home is two or completed since 2007/08 has jumped three years. However, from the date at compared to those where the first which an outline application is validated completion came before 2007/08. This is it can be 5.0 - 8.4 years for the first home a key area where improvements could be to be delivered dependent on the size of sought on timeliness and in streamlining the site. In these circumstances, such pre-commencement conditions, but is also sites would make no contribution to likely impacted by a number of macro factors completions in the first five years. including the recession and reductions in local authority planning resources.

3 Large greenfield sites 4 Outlets and tenure deliver quicker matter

Large sites can deliver more homes per Our analysis suggests that having year over a longer time period, with this additional outlets on site has a positive seeming to ramp up beyond year five impact on build 0ut rates, although there of the development on sites of 2,000+ is not a linear relationship. Interestingly, units. However, on average these longer- we also found that schemes with more term sites also have longer lead-in times. affordable housing (more than 30%) built Therefore, short term boosts in supply, out at close to twice the rate as those with where needed, are likely to also require a lower levels of affordable housing as a good mix of smaller sites. Furthermore, percentage of all units on site, but those large scale greenfield sites deliver at with 20-29% had the lowest rates of all. a quicker rate than their brownfield Local plans should reflect that – where equivalents: the average rate of build out viable – higher rates of affordable housing for greenfield sites in our sample was supports greater rates of delivery. This 34% greater than the equivalent figure principle is also likely to apply to other for those on brownfield land. In most sectors that complement market housing locations, a good mix of types of site will for sale, such as build to rent and self-build therefore be required. (where there is demand).

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Figure 16: Key questions for assessing large site build-out rates and delivery timelines

Planning Approval

• Is the site already allocated for development? If it is in an emerging Plan, does it need to be adopted before the site can be brought forward? • Is an SPD, masterplan or development brief required and will it help resolve key planning issues? • Is there an extant planning permission or live planning application submitted? • If outline permission is granted, when will reserved matters be submitted? • Is the proposal of the promoter consistent with local policy and/or SPD/Masterplan? • Are there significant objections to the proposal from local residents? • Are there material objections to the proposal from statutory bodies? • If planning permission is secured, is reserved matters approval required?

Lead In

• Does the scheme have pre-commencement conditions? • Is the land in existing use? • Has the land been fully assembled? • Are there any known technical constraints that need to be resolved? • If in multiple ownership/control, are the interests of all parties aligned? • Is there up-front infrastructure required before new homes can be built? • Has the viability of the proposal been established and is the feasibility consistent with known infrastructure costs and the likely rate of development? • Does the proposal rely on access to public resources and what evidence is there on when those will be available? • Is the scheme led by a promoter or master developer who will need to dispose of phases to a house builder before completions begin?

Build Out

• How large is the site? • How strong is the local market? • Does the site tap into local demand from one or more existing neighbourhoods? • Will delivery be affected by competing sites? • How many sales outlets will be supported by the scale, configuration and delivery model for the site? • What is the track record of the promoter/master developer in delivery of comparable sites? • How active are different housebuilders in the local market? • What proportion of affordable housing is being delivered? • Are there policy requirements for a specific mix of housing types and are there other forms of housing – such as build to rent? • When will new infrastructure – such as schools – be provided to support the new community? • Are there trigger points or phasing issues that may affect the build-out rate achievable in different phases?

Source: Lichfeilds analysis

20 INSIGHT START TO FINISH Appendices

Contents

Appendix 1: Definitions and notes 22 Appendix 2: Large sites tables and sources for sites also found in the Letwin Review 23 Appendix 3: Small sites tables 28

21 INSIGHT START TO FINISH Appendix 1: Definitions and notes

The ‘lead in’

Measures the period up to first completion of a house on site from the validation date of the first planning application made for the scheme. The lead-in time covers both the planning approval period and planning to delivery periods set out below. The lead-in time does also include the date of the first formal identification of the site as a potential housing allocation (e.g. in a LPA policy document), but consistent data on this for the sample is not available.

The ‘planning period’

Measured from the validation date of the first application for the proposed development (be that an outline, full or hybrid application). The end date is the decision date of the first detailed application which permits the development of dwellings on site (this may be a full or hybrid application or the first reserved matters approval which includes details for housing). A measurement based on a detailed ‘consent’ was considered reasonable and proportionate milestone for ‘planning’ in the context of this research.

The ‘planning to delivery period’

Includes the discharge of any pre-commencement and any opening up works required to deliver the site. It finishes on completion of the first dwelling.

The date of the ‘first housing completion’

On site (the month and year) is used where the data is available. However, in most instances the monitoring year of the first completion is all that is available and in these cases a mid- point of the monitoring period (1st October, falling halfway between 1st April and the Due to the varying ages following 31st March) is used. of the assessed sites, the implementation of some schemes was more advanced than others and, as a function of the desk-based nature of the The ‘annual build-out rate’ research and the age of some of the sites assessed, there have been some data Each site is taken or inferred from a number of sources. This includes Annual Monitoring limitations, which means Reports (AMR’s) and other planning evidence base documents produced by local authorities there is not a complete data set for every assessed (see footnote 1), contacting the local planning authority monitoring officers or planners and in site. For example, lead-in a handful of instances obtaining the information from housebuilders. time information prior to submission of planning applications is not available for the vast majority of sites. And because not all of the sites assessed have commenced housing delivery, build-out rate information is not universal. The results are presented

accordingly. tables sites Large 2: Appendix

22 Appendix 2: Large sites tables

Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Ebbsfleet Gravesham/ 15,000 2009/10 127 79 55 50 44 40 60 141 312 Dartford The Hamptons Peterborough 6,320 1997/98 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 224 224 154 157 71 67 101 34 54 100

Rugby Radio Station Rugby 6,200 N/A

East of Kettering Kettering 5,500 2016/17 43 93

Sherford Plymouth 5,500 2016/17 7 106

Priors Hall Corby 5,200 2011/12 56 21 59 87 170 155 273

Wichelstowe Swindon 4,500 2008/09 158 93 195 64 100 61 44 60 57

Monkton Taunton Deane 4,500 2012/13 22 76 220 191 222 148 Heathfield The Wixams Bedford 4,500 2008/09 8 190 160 138 113 109 109 44 37 47

Cambourne South 4,343 1999/2000 42 361 213 337 620 151 377 267 219 190 162 206 154 151 129 239 201 95 126 Cambridgeshire Eastern Expansion Milton Keynes 4,000 2008/09 154 359 371 114 473 138 Area (Broughton Gate & Brooklands) Locking North Somerset 3,700 2011/12 23 45 97 75 10 21 86 Parklands Stanton Cross Wellingborough 3,650 N/A

Beaulieu Park Chelmsford 3,600 2015/16 40 110 262

Northampton North Daventry 3,500 2017/18 50 SUE Great Western Park South 3,300 2011/12 110 204 232 392 237 274 78 Oxfordshire Oakley Vale Corby 3,100 2001/02 35 89 289 258 346 487 520 233 174 159 107 96 103 51 40 9 70

Kings Hill Tonbridge and 3,024 1996/97 140 140 140 140 140 126 219 104 237 166 281 300 224 93 55 90 84 108 91 74 41 31 Malling North West Cam- Cambridge and 3,000 2016/17 73 bridge South Cambridgeshire West of Havant and Win- 3,000 2009/10 38 71 30 82 112 135 196 241 Waterloo chester Cranbrook East Devon 2,900 2012/13 187 419 356 299 214 241

West of Kempston Bedford 2,760 2010/11 52 102 144 167 124 175 103 93

South of the M4 Wokingham 2,605 2012/13 37 175 56 29 166 419

Winterstoke Village North 2,550 2014/15 132 185 242 161 Somerset Emersons Green East South 2,550 2014/15 274 197 318 280 Gloucestershire Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Land East Icknield Test Valley 2,500 2009/10 184 257 103 181 135 229 146 184 Way South Wokingham 2,490 2013/14 6 104 120 135 118 Wokingham North Wokingham 2,391 2010/11 28 99 23 0 95 112 66 154 Wokingham Broadlands Bridgend 2,309 1999/2000 288 331 307 193 204 156 64 104 91 28 81 50 147 11

Western Bath and North 2,281 2011/12 59 147 93 61 163 154 45 Riverside East Somerset Arborfield Wokingham 2,225 2016/17 57 114 Garrison Charlton Hayes, South 2,200 2010/11 83 87 163 333 281 193 301 168 Northfield Gloucestershire Clay Farm/ Cambridge 2,169 2012/13 16 265 399 153 467 Showground Site (Great Kneighton) Chapelford Urban Warrington 2,144 2004/05 211 214 166 262 224 141 180 183 247 60 160 66 30 Village Ledsham Cheshire West and 2,000 2016/17 41 90 Garden Village Chester Graven Hill Cherwell 1,900 2016/17 1 28

Elvetham Heath Hart 1,869 2000/01 192 300 297 307 287 238 103 139 6

Hunts Grove Stroud 1,750 2010/11 2 87 106 80 58 7 2 22

Dickens Heath Solihull 1,672 1997/98 2 179 196 191 207 88 124 64 249 174 16 96 110 4 0 0 13 10 26 12 96

Red Lodge Forest Heath 1,667 2004/05 65 93 181 79 57 79 61 101 213 101 78 23 75 111

South West Bicester Cherwell 1,631 2011/12 40 107 133 179 210 231 196 (Phase 1 Kingsmere)

Centenary Quay Southampton 1,620 2011/12 102 58 103 137 257 8

Northumberland Park North Tyneside 1,513 2003/04 54 194 171 93 179 100 69 117 96 53 82 64 86

Parc Derwen Bridgend 1,500 2010/11 8 103 134 201 199 197 157 186

Jennet’s Park Bracknell Forest 1,500 2007/08 153 154 145 168 136 179 235 93 37 0 28

Melton Road Rushcliffe 1,500 2016/17 40 126

Great Denham Bedford 1,450 data only 92 150 159 71 122 150 125 211 168 avalibale from 2009/10 Love’s Farm, Huntingdonshire 1,438 2007/08 34 186 336 302 216 60 108 59 85 St Neots South Maldon Garden Malden 1,428 2017/18 1 Suburb Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Bolnore Village Mid Sussex 1,358 2012/13 30 54 88 73 36 124

Park Prewett Hospital Basingstoke and 1,341 1998/99 58 82 37 102 0 0 0 0 0 307 214 219 146 33 34 56 7 30 16 Deane Ashford Ashford 1,300 2005/06 83 0 124 14 64 58 155 103 49 70 67 138 90 Barracks (Repton Park) Oxley Park (East & Milton Keynes 1,300 2004/05 52 166 295 202 115 91 75 163 West) Kempshott Park Basingstoke and 1,252 2000/01 78 310 229 213 281 84 33 24 Deane Holborough Quarry Tonbridge and 1,211 2006/07 85 137 91 47 18 100 59 12 43 64 60 101 Malling Staynor Hall Selby 1,200 2005/06 12 141 115 10 43 62 46 59 79 162 79 34 50

Picket Twenty Test Valley 1,200 2011/12 147 178 180 176 164 145 175

Trumpington Cambridge and 1,200 2012/13 141 143 67 100 94 Meadows South Cambridgeshire Broughton Milton Keynes 1,200 2003/04 114 105 170 409 204 180 18 (Broughton & At- terbury) Orchard Park Cambridge 1,120 2006/07 100 290 148 103 95 56 34 15 75 39 30 2

Velmead Farm Hart 1,112 1989/90 1 104 193 89 101 52 101 113 130 74 102 48 4

Cheeseman’s Green Ashford 1,100 2014/15 59 47 102 157 (Finberry) Zones 3 to 6, Omega Warrington 1,100 2017/18 15 South Boulton moor South 1,058 2014/15 22 96 96 116 Derbyshire Highfields Farm South 1,056 2016/17 141 204 Derbyshire Monksmoor Farm Daventry 1,000 2013/14 6 65 98 128 122

Northampton North of Daventry 1,000 2016/17 108 100 Whitehills SUE Taylors Farm/Sher- Basingstoke and 991 2004/05 56 79 81 86 88 51 143 141 88 91 75 0 12 field Park Deane Queen Elizabeth II Hart 972 2012/13 56 165 110 228 213 96 Barracks Little Staniton Corby 970 2009/10 106 116 74 121 102 93 89 86 26

North of Popley Basingstoke and 951 2007/08 65 57 16 28 0 0 15 118 84 60 Deane Ingress Park Dartford 950 2002/03 184 275 100 74 0 119 0 0

Nar Ouse Millenium Kings Lynn and 900 2007/08 32 77 0 0 0 0 30 22.5 22.5 68 0 Commuity West Norfolk West Park Darlington 893 2004/05 60 104 98 66 69 19 35 10 16 51 35 28 14 42

South Bradwell Great Yarmouth 850 2015/16 60.3 60.3 60.3 Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Prospect Place Cardiff 826 2007/08 185 48 0 0 0 0 0 76 170

Abbotswood Test Valley 800 2011/12 30 190 157 114 152 90 20

Dowds Farm Eastleigh 795 2006/07 54 189 187 44 102 47 66 76 30

Land at Popley Fields/ Basingstoke and 751 2006/07 105 172 118 186 126 44 Marnell Park Deane Hungate York 720 2009/10 90 52 11 9 7 187 8

Northside Gateshead 718 1999/2000 46.8 46.8 46.8 46.8 46.8 56 46.8 46.8 46.8 46.8 46.8 16 30 31 33 25 43

Land at West Blyth Northumbeland 705 2008/09 6.25 6.25 6.25 6.25 32 66 51 127 78 90

Rowner Renewal Gosport 700 2010/11 4 100 70 45 89 101 79 97 Project Channels - North Chelmsford 700 2015/16 31 172 110 Chelmsford The Parks, formally Bracknell Forest 697 2006/07 -94 104 88 101 54 47 72 59 94 78 Staff College Staiths South Bank Gateshead 667 2003/04 24 58 44 48

Land south of Northumberland 644 2005/06 18.7 18.7 18.7 18.7 18.7 18.7 18.7 17 24 37 60 57 54 Wansbeck General Hospital Former Pontins Lancaster 626 2006/07 16 22 4 5 Holiday Camp

Ochre Yards Gateshead 606 2004/05 83 68.2 68.2 68.2 68.2 68.2 46 4 52 2

Former Runwell Chelmsford 575 2016/17 91 90 Hospital Land adjoining Man- Trafford 550 N/A chester Ship Canal Pamona Docks Trafford 546 N/A

Thingwall Lane Knowlsey 525 2013/14 79

St. James Village Gateshead 518 2000/01 41.4 41.4 41.4 41.4 41.4 41.4 41.4 41.4 41.4 41.4 14 13 18 15

University Chelmsford 507 2014/15 216 3 Campus Chelmsford Land at Siston Hill South 504 2006/07 77 211 96 63 57 Gloucestershire Land West of Mid Sussex 500 N/A Copthorne Sources for sites also found in the Letwin Review

Arborfield Green (Arborfield Five Year Housing Land Supply Statement and appendix on Strategic Development Locations at 31st March 2018 published 9th October 2018 Garrison) http://www.wokingham.gov.uk/planning-policy/planning-policy-information/evidence-topics/

Ledsham Garden Village Various Housing Land Monitor Reports https://consult.cheshirewestandchester.gov.uk/portal/cwc_ldf/mon/

Great Kneighton (Clay Farm) Partly provided by Cambridgeshire County Council and included in numerous AMR’s https://www.cambridge.gov.uk/annual-monitoring-reports

Trumpington Meadows Included in numerous AMR’s for Cambridge and South Cambridgeshire (site crosses boundaries) https://www.cambridge.gov.uk/annual-monitoring-reports and https://www.scambs.gov.uk/planning/local-plan-and-neighbourhood-planning/ annual-monitoring-report/ Graven Hill Various Annual monitoring reports https://www.cherwell.gov.uk/info/33/planning-policy/370/monitoring-reports South West Bicester Various Annual monitoring reports (Kingsmere Phase 1) https://www.cherwell.gov.uk/info/33/planning-policy/370/monitoring-reports Great Western Park Housing Land Supply Statement April 2018 http://www.southoxon.gov.uk/sites/default/files/30.04.2018%20Housing%20Land%20Supply%20Statement%20FINAL%20(2)%20combined. pdf Ebbsfleet: First phase at Springhead Park and Northfleet South from Gravesham AMR’s 2009/10 to 2012/13

2009-10: 127 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0010/69823/AMR2010.pdf 2010-11: 79 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0010/69814/AMR2011.pdf 2011-12: 55 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0009/92448/Gravesham-Authority-Monitoring-Report-2011-12-May-2013.pdf 2012-13: 50 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0010/92449/Gravesham-Authority-Monitoring-Report-2012-13-interim-May-2013.pdf 2013/14: 87 dwellings, based on total completions form Gravesham to 2012/13 of 311 and total completions to the start of 2014/15 in the Ebbsfleet Garden City Latest Starts and Completion Figures totalling 398.

2014/15 to Ebbsfleet Garden City Latest Starts and Completion Figures: https://ebbsfleetdc.org.uk/tracking-our-performance/ 2017/18: Appendix 3: Small sites tables

Site Name Local Planning Size Site Name Local Planning Size Site Name Local Planning Size Authority Authority Authority Cookridge Hospital Leeds 495 GCHQ Oakley - Phase 1 Cheltenham 262 Auction Mart South Lakeland 94

Stenson Fields South Derbyshire 487 Hewlett Packard (Land Adjacent Bristol, City of 242 Parcel 4 Gloucester Business Tewkesbury 94 To Romney House) Park Horfield Estate Phase 1 Bristol City 485 128-134 Bridge Road And Nos Windsor and 242 York Road Hambleton 93 Council 1 - 4 Oldfield Road Maidenhead Farnborough Business Park Rushmoor 476 Hoval Ltd North Gate Newark and 196 Land At Green Road - Reading Reading 93 Sherwood College Bickershaw Colliery Wigan 471 Notcutts Nursery, 150 - 152 Cherwell 182 Caistor Road West Lindsey 89 London Road Farington Park, east of Wheelton South Ribble 468 Sellars Farm Stroud 176 The Kylins Northumberland 88 Lane Bleach Green Gateshead 456 Land South of Inervet Campus Off Milton Keynes 176 North East Area Professional Crawley 76 Brickhill Street, Walton, Milton Keynes Centre, Furnace Drive Kingsmead South Milton Keynes 450 Queen Mary School Fylde 169 Land at Willoughbys Bank Northumberland 76 Council New Central Woking Borough 445 London Road/ Adj. St Francis East Hertford- 149 Watermead, Land At Kennel Lane Tewkesbury 72 Council Close shire Land at former Battle Hospital Reading Borough 434 Land off Gallamore Lane West Lindsey 149 Land to the North of Walk Mill Wychavon 71 Council Drive New World House Warrington 426 Doxey Road Stafford 145 Hawthorn Croft (Off Hawthorn West Lindsey 69 Avenue Old Slaughterhouse Site) Radyr Sidings Cardiff 421 Former York Trailers (two schemes Hambleton 145 Land off Crown Lane Wychavon 68 - one Barratt, one DWH) Luneside West Lancaster 403 Bracken Park, Land At Cor- West Lindsey 141 Former Wensleydale School Northumberland 68 ringham Road Woolley Edge Park Wakefield 375 Land at Farnham Hospital Waverley 134 Land at Lintham Drive South Glouces- 68 tershire Former Masons Cerement Works and Mid Suffolk 365 North of Douglas Road South Glouces- 131 Springfield Road South Kesteven 67 Adjoining Ministry of Defence Land tershire Former NCB Workshops (Port- Northumberland 357 Land to the east of Efflinch Lane East Staffordshire 130 Land off Cirencester Rd Stroud 66 land Park) Chatham Street Car Park Reading 307 Land to the rear of Mount Cheshire West 127 Land south of Pinchington Lane West Berkshire 64 Complex Pleasant and Chester Kennet Island Phase 1 - H, M, Reading 303 Primrose Mill Site Ribble Valley 126 Land at Prudhoe Hospital Northumberland 60 T, U1, U2 Land at Dorian Road Bristol, City of 300 Kennet Island Phase 1B - E, F, Reading 125 Oxfordshire County Council Cherwell 60 O & Q Highways Depot Land at Fire Service College, Cotswold 299 Land between Godsey Lane and South Kesteven 120 Clewborough House School Cherwell 60 London Road Towngate East Land at Badsey Road Wychavon 298 Bibby Scientific Ltd Stafford 120 Land at the Beacon, Tilford Road Waverley 59

Land at Brookwood Farm Woking 297 Land west of Birchwood Road Bristol, City of 119 Land to Rear Of 28 - 34 Bedale Hambleton 59 Road Long Marston Storage Depot Stratford-on- 284 Former Bewbush Leisure Centre Crawley 112 Hanwell Fields Development Cherwell 59 Phase 1 Avon Site M & G Sports Ground, Golden Tewkesbury 273 Land south of Station Road East Hertford- 111 Fenton Grange Northumberland 54 Yolk and Middle Farm shire Land at Canons Marsh Bristol, City of 272 Poppy Meadow Stratford-on- 106 Former Downend Lower School South Glouces- 52 Avon tershire Land off Henthorn Road Ribble Valley 270 Weeton Road/Fleetwood Road Fylde 106 Holme Farm, Carleton Road Wakefield 50

Land Between A419 And A417 Cotswold 270 Former York Trailers (two schemes Hambleton 96 Land off Elizabeth Close West Lindsey 50 - one Barratt, one DWH) Hortham Hospital South 270 North East Sandylands South Lakeland 94 Gloucestershire The Lichfields perspective

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Disclaimer This publication has been written in general terms and cannot be relied on to cover specific situations. We recommend that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. Lichfields accepts no duty of care or liability for any loss occasioned to any person acting or refraining from acting as a result of any material in this publication. Lichfields is the trading name of Nathaniel Lichfield & Partners Limited. Registered in England, no.2778116. © Nathaniel Lichfield & Partners Ltd 2020. All rights reserved. lichfields.uk @LichfieldsTT APPENDIX 2 Latest Planning Dwelling Site Application (No. 1) capacity 18/19 19/20 20/21 21/22 22/23 23/24 24/25 25/26 26/27 27/28 28/29 29/30 30/31 31/32 32/33 H22 Land at Village Farm, Birmingham Road 12 066

H20 Land south of Coleshill Road, Ansley Common 450 05050606065605550

H1 - Land at Holly Lane, Atherstone PAP/2014/0542 499 25 25 50 75 75 75 60 60 54

Part of H1 - Durnos Nursery, Holly Lane, Atherstone PAP/2014/0540 121 28 28 28 37

H2 Land to north west of Atherstone off Whittington 1282 107 107 107 107 107 107

H3 Land off Sheepy Road, Atherstone 46 20 26

H15 Land at Church Farm, Baddesley Ensor 47 0101010107 H6 Allotments adjacent to Memorial Park, Coleshill 30 0101010 H16 Land south of Grendon Community Hall 7 7 H17 - Former Sparrowdale School site NEW APPLICATION and Recycling centre Spon Lane GRANTED ON THIS Grendon SITE (PAP/2018/0287 and PAP/2019/0396 - 56units approved 56 25 31 H19 Land between Church Road & Nuneaton Road, Hartshill 400 25 25 50 50 50 50 50 50 50 H24 Land at Manor Farm, Austrey Lane, Newton Regis PAP/2016/0266 30 16

H7 Land to east of Polesworth & Dordon 1969 120 120 120 120 120 120 H13 Land west of Robey's Lane PAP/2018/0755 1270 50 107 107 107 107 107 107 107 107 107 PAP/2019/0022 H25 - Land south of Shuttington Outline Granted - Village Hall 27/05/2020 24 12 12 PAP/2017/0202 (22/11/2018) and H26 - land north of Orton Road, PAP/2016/0280 Warton (28/06/2019) 128 0404444 H21 Former School redevelopment site, Attleborough Lane/Vicarage Lane, Water Orton 48 24 24 H14 Site at Lindridge Road adj Langley SUE 141 41 50 50 H28 - Land south of Islington Farm, Wood End 28 028 TOTALS 6588 0 53 59 65 165 222 355 359 539 553 540 545 513 460 4428 1st Phase 2nd A5 Phase A5

Pegasus Options 2 Housing Supply Table as follows;

Year - Plan Period 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 Sub Total Totals Completions (net) 75 38 119 223 251 363 203 298 1570 1570 Windfall Allowance 60 60 60 60 60 60 60 60 60 60 60 660 660 Planning Permissions 0 132 328 414 282 105 60 20 1341 1301 -3% minus lapse rate (excluding 2020/21) New Options 2 Allocations Trajectory - Annual Totals Within Plan Period 0 535965165222 355 359 539 553 540 545 513 460 4428 4428

Annual Totals Within Plan Period 75 38 119 223 251 363 203 298 132 381 473 407 330 342 435 419 599 613 600 605 573 520 7999 7959 1st Phase 2nd A5 Phase A5 RED TEXT HIGHLIGHTS PEGASUS CHANGES TO NWBC26C TRAJECTORY ALP23

September 2020 | NCO | P20-1287

NORTH WARWICKSHIRE LOCAL PLAN EXAMINATION

LOCAL PLAN – ADDITIONAL DOCUMENTS CONSULTATION RESPONSE

LAND NORTH OF ANSLEY COMMON

ON BEHALF OF COUNTRYSIDE PROPERTIES

Pegasus Group

|

Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester

©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited Countryside Properties Additional Documents Response

Contents Page No.

1. INTRODUCTION 1 2. LAND NORTH OF ANSLEY COMMON 1 3. HOUSING REQUIREMENTS 3 4. INFRASTRUCTURE REQUIREMENTS 3 5. STEPPED TRAJECTORY 4 6. LEAD IN TIMES 5 7. DELIVERY RATES 6 8. BUFFER & FLEXIBILITY 7 9. TRAJECTORY 9 10. CONCLUSION 9

September 2020 | NCO | P20-1287

1. INTRODUCTION

1.1 This representation has been prepared by Pegasus Group on behalf of Countryside Properties who has land interests within North Warwickshire Borough. This statement provides a response to the ‘Local Plan- Additional Documents’ in respect of Countryside Properties’ interest at Land North of Ansley Common.

1.2 These representations relate specifically to the schedule of potential main modifications (NWBC20E) and further evidence that has been produced in respect of housing need and supply, including NWBC26A, NWBC26B and NWBC26C.

2. LAND NORTH OF ANSLEY COMMON

2.1 Land North of Ansley Common is located to the west of the established residential area of Hartshill (Category 3 Local Service Centre), north of Coleshill Road/Ansley Common, and currently comprises of greenfield land. It is identified in the emerging Local Plan as Reserve Site RH2. A Site Location Plan is included at Appendix 1 to these representations.

2.2 To the east, the site sits adjacent to the recent residential development (PAP/2016/0199) known as ‘The Larches’. The south of the site is also characterised by existing residential development with the established fenceline separating the proposed site from the existing properties at Ansley Common. The northern boundary is formed by the Bar Pool Brook Watercourse beyond which is woodland and further residential development. The western boundary is within an agricultural field beyond which is an existing agricultural property.

2.3 The site benefits from being in a very sustainable location. The site is well located in relation to existing schools, including Nathaniel Newton Infant School (0.5 miles), Michael Drayton Junior School (0.7 miles) and Hartshill School (0.6 miles), as well as other local services and facilities, whilst also being located in close proximity to Hartshill Hayes Country Park providing good access to outdoor recreation.

2.4 In addition, the site benefits from regular bus services in close proximity on Coleshill Road which provide links to Nuneaton and adjacent villages. Furthermore, bus services to Nuneaton bus station also provide the opportunity for linked trips to wider destinations. Non-car modes of travel therefore provide a genuine opportunity to reduce car use. The site also benefits from good road

September 2020 | NCO | P20-1287 Page | 1

connections to the A5, M42, M6 and M69 motorways which provide excellent links to surrounding cities including Leicester and Birmingham and is therefore well- located to deliver sustainable development.

2.5 The development of Land North of Ansley Common provides the opportunity to deliver housing for the Borough as part of phased development, in particular the delivery of a substantial proportion of much needed affordable homes as part of the first phases of the development. Overall Land North of Ansley Common will provide a comprehensive and carefully planned residential extension of Hartshill, informed by specialist technical input in relation to transport, flood risk/drainage, ecology and arboriculture.

2.6 The development of the site will integrate with the surrounding residential context including providing direct links with the recently developed housing site to the east which has been brought forward by the same developer (Westleigh Partnerships which has since been acquired by Countryside Properties) and the wider residential area. The development of the site also offers the opportunity for a landscape led residential development that considers the sites wider landscape context whilst also sitting comfortably alongside the settlement boundary of Hartshill and ensuring an appropriate access solution is provided in dialogue with Warwickshire County Council.

2.7 In terms of economic sustainability, jobs will be created during the construction phase of housing (including indirect employment through the construction supply chain). The development would also help support local shops and services through new financial spend into the local economy and this may result in induced employment being created. In addition, a significant number of job opportunities are available in the surrounding area for the new residents.

2.8 Land North of Ansley Common is a site that has the physical and environmental capacity to deliver new homes. It is clear the site provides a good opportunity for a sustainable development, and one which should be used efficiently so to meet the housing needs of the area and the delivery of much need affordable housing. Land North of Ansley Common should therefore be identified as a housing allocation rather than form part of the wider reserve site RH2.

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3. HOUSING REQUIREMENTS

3.1 In respect of OAHN the LP is based primarily upon evidence contained within the Strategic Housing Market Assessment Update (CD8/10) published in September 2015, over 5 years ago, which utilised the 2012 SNHP. The Inspector identifies within INSP21 that the 2018-based SNHP indicate a likely uplift in household formation in coming years relative to previous, data series.

3.2 Utilisation of the 2018 SNHP would result in the minimum housing requirement rising to 10,015. As set out in NWBC27, this is an increase of 417 dwellings over the plan period. Countryside Properties consider the 2018 SNHP should now be utilised to determine the OAHN for the purposes of this Local Plan on the basis the SHMA is out of date. Therefore, the housing requirement should be amended to a minimum of 10,015 over the proposed 22 year plan period. The required flexibility in supply should also be provided to ensure this OAHN can be delivered within the Plan period.

3.3 At present, the flexibility in the proposed supply contained within the emerging Local Plan would be insufficient to deliver a minimum of 10,015 homes, even if all identified sources of supply were realised within the plan period.

3.4 It is noted that the Council contends, through NWBC27, that there is no effective potential for additional supply to be brought forward in North Warwickshire, however land north of Ansley Common is identified as a reserve site and can be brought forward in the short term to boost supply.

3.5 M34 should be amended accordingly.

4. INFRASTRUCTURE REQUIREMENTS

4.1 The Inspector, within INSP18, recognises that a significant element of the development proposed relies upon the improvements to the A5. The following three options were set out by the Inspector to overcome fundamental issues of soundness:

a) await the outcome of the HIF bid and unambiguously identify the likely source(s) of funding for the dualling of the A5; or

b) put forward alternative sites that do not rely on highways improvements for which funding is not certain or unknown; or

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c) withdraw the plan.

4.2 Whilst it is agreed that MHCLG funds have been identified for the improvements to the A5 corridor as part of the RIS process, it is clear from the ‘Additional Documents’ subject to this consultation, including NWBC26 written in July 2020, there is still no agreement between Homes England, Highways England, Warwickshire County Council, the Department for Transport and the MHCLG on the delivery of such a scheme or indeed the timescales for delivery. NWBC26 highlights that such agreement is required prior to determining the ‘actual stepped trajectory.’

4.3 In light of the above lack of clarity in respect of the delivery of the A5 improvements, Countryside Properties considers it necessary for alternative sites to be allocated, such as Land North of Ansley Common, that do not rely on such improvements. If an alternative strategy is not pursued, the Local Plan should at the very least identify further allocations, that are not reliant upon the A5 improvements. This would include identifying Land North of Ansley Common which currently forms part of the wider RH2 reserve site, as a housing allocation. This site is consistent with the settlement hierarchy set out in LP2 which identifies Hartshill with Ansley Common as a Category 3 Local Service Centre. Policy LP2 requires development within the Borough to be ‘proportionately distributed and be of a scale that is in accordance with the Borough’s settlement hierarchy.

5. STEPPED TRAJECTORY

5.1 INSP20 requests the establishment of a stepped housing trajectory which aligns to the overarching requirement of the Plan period with an appropriate degree of flexibility, justified by revisited evidence of lead-in-times and delivery rates.

5.2 The Council has prepared a number of stepped trajectories and it is understood from NWBC27 that the Option 2 trajectory is the Council’s preferred option. This stepped trajectory assumes a continuation of 203 dpa until 2018 and rising incrementally to 775 dpa in the final eight years of the plan period.

5.3 Countryside Properties does not support the introduction of the stepped trajectory; one that has been contrived to respond to an unsound distribution of proposed housing growth where delivery is predicated on the as yet uncommitted A5 improvements.

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5.4 In addition, no clear evidence has been provided by the Borough Council in devising this stepped trajectory, the effect of which will be to result in identified housing need, both market and affordable, not being met within the Borough in the short to medium term. This is particularly pertinent in respect of affordable housing where need remains high and is identified by the Borough Council as being between 149 and 267 dwellings per annum which, at the top end of that range, is significantly higher than the annual housing requirement until 2024.

5.5 In line with INSP21 the stepped trajectory should not unnecessarily delay meeting identified development needs and it is therefore questioned whether it is appropriate that the Local Plan will fail to boost supply until 2024/25, some 13 years into a 21 year plan period. Inclusion of land north of Ansley Common, part of RH2, as an allocation rather than a reserve site could assist in boosting housing supply in a sustainable location prior to 2024./25.

6. LEAD IN TIMES

6.1 The Council’s evidence of lead in times and delivery rates published within NWBC24B, Annex 1 is not supported by Countryside Properties.

6.2 In light of the lack of evidence in respect of lead-in times for development of the scale of proposed allocations within the emerging Local Plan it is considered necessary to rely on national trends.

6.3 Lichfield’s ‘Start to Finish’ Second Edition was published in February 2020 and provides more up to date evidence in respect of lead-in times. This concludes the following average lead-in times nationally for a range of sites:

Site Size Average Average Average Validation of 1st Planning Planning to Application to 1st Approval Delivery Completion Period Period

50-99 1.4 2.0 3.3 years

100-499 2.1 1.9 4.0 years

500-999 3.3 1.7 5.0 years

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1,000-1,499 4.6 2.3 6.9 years

1,500-1,999 5.3 1.7 7.0 years

Source: Lichfields Start to Finish ‘Second Edition’ 2020

6.4 In respect of H2 and H7 the supply trajectory assumes first deliveries on both sites in April 2025, some 4.5 years from today’s date. Applications have not been submitted in respect of either site and therefore first completions should be pushed back to April 2028 at the very earliest in line with national trends evidence set out above.

7. DELIVERY RATES

7.1 The delivery rates assumed in respect of a number of proposed allocations are considered completely unrealistic. The Inspector’s view contained within INSP20, that there is no compelling justification for anticipated build-out rates significantly above national trends is supported by Countryside Properties. The Council’s approach to the delivery trajectory, of applying either 50 dwellings per annum per sales outlet, or accepting trajectories provided by developers without significant scrutiny, is not a robust approach.

7.2 It should again be noted that Lichfield’s ‘Start to Finish’ Second Edition, published in February 2020, concludes the following average rates nationally at which new homes are built on sites:

Site Size Start to Finish 2016 Start to Finish 2020 Difference ‘First Edition’ build-out ‘Second Edition’ rates build-out rates

50-99 27 22 -5 (-19%)

100-499 60 55 -5 (-8%)

500-999 70 68 -2 (-3%)

1,000-1,499 117 107 -10 (-9%)

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1,500-1,999 129 120 -9 (-7%)

Source: Lichfields Start to Finish ‘Second Edition’ 2020 (see Appendix 2)

7.3 The maximum annual delivery rates assumed by the Council on a number of the proposed allocations should be amended as overall, it is considered that the application of the above delivery rates is a realistic and justified approach which takes account of market absorption. The table below sets out the difference between the average delivery rates contained within NWBC26C and national trends contained within the recently published Start to Finish Report.

Site Number of Start to Finish NWBC average Difference Allocation proposed 2020 average build-out rates Dwellings build-out rates

H1 499 55 55 0 (0%)

H2 1,282 107 160 +53 (+50%)

H7 1,969 120 209 +89 (+74%)

H13 1,270 107 127 +20 (+19%)

H20 450 55 56 +1 (+2%)

7.4 In light of the above, the supply trajectory should be amended in respect of H2, H7 and H13 in line with the national trends evidence identified in the tables above. The assumed delivery rates for H2 and H7 are significantly in excess of what can realistically be expected even with multiple sales outlets and is therefore not justified.

8. BUFFER & FLEXIBILITY

8.1 INSP18 highlighted that a phased trajectory with a 5% five year land supply buffer ‘may be appropriate.’ INSP20 again requests the establishment of a stepped trajectory with ‘an appropriate degree of flexibility, justified by revisited evidence of lead-in times and delivery rates.’

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8.2 NWBC26 provides the Council’s approach to the issue of flexibility within the housing trajectory. It is clear that a 5% five year housing land supply buffer has not been included within the trajectory as a 5% buffer has only been applied to the forward supply minus any sites that benefit from planning permission. A 3% lapse rate has then been applied to the committed supply. This approach is incorrect and unsound and does not provide the necessary buffer or an appropriate degree of flexibility required.

8.3 A non-implementation rate is very different to a buffer. The buffer performs a totally different role. It is not a tool to ensure the local plan requirement can be met, but simply seeks to allow supply to be moved forward in the plan period, endeavouring to bring forward additional capacity now to ensure housing is boosted significantly and ensure that in the immediate future shortfalls do not occur. In essence it is there to enable housing supply to have a fighting chance of being boosted significantly. Therefore, the buffer should be applied to the committed supply not yet delivered irrespective of the non-implementation rate. To overcome this issue of unsoundness further supply needs to be identified within the emerging Local Plan. This is particularly important within a stepped trajectory as such an approach would clearly result in a delay in meeting identified development needs.

8.4 A 5% buffer alone does not constitute the necessary flexibility required for the proposed housing strategy. Whilst it is recognised that a 3% non-implementation rate has been applied to the committed supply, the housing trajectory is predicated on the A5 improvements being delivered within specific date milestones. Countryside Properties considers that reliance on the A5 improvements being delivered, and delivered in line with the assumed milestones, represents a significant risk to the strategy and the ability of the housing requirement of 9,598 homes being delivered within the Plan period. This is particularly true as the A5 improvement project remains uncommitted as it is still subject to further clarification and detail.

8.5 It is accepted that the Local Plan seeks to provide limited flexibility through the identification of reserve sites. However, in light of the above, it is clear the reserve sites identified are required to meet the OAHN over the plan period. Countryside Properties consider that the identified reserve sites do not provide the necessary flexibility within the housing trajectory to provide any certainty that the identified housing needs can be met within the Plan period. To address this unsoundness, further reserve sites should be identified that are not reliant upon the A5

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improvements and in order to provide the necessary flexibility to ensure certainty of delivery.

9. TRAJECTORY

9.1 Having regard to national trends evidence and the requirement to provide a 5% buffer, further allocations are required to ensure the delivery of the OAHN within the plan period.

9.2 A revised trajectory has been prepared and is attached at Appendix 3 to these representations. This demonstrates the need to allocate additional land necessary to deliver a minimum of a further 1,967 homes to 2033 to meet an OAHN of 9,598 homes or a minimum of a further 2,445 homes to 2033 to meet an increased OAHN of 10,015 homes in line with the 2018 SNHP.

10. CONCLUSION

10.1 In relation to neighbouring need, it is noted that North Warwickshire has agreed to accommodate the unmet need from Neighbouring LPAs and the housing requirement, including cross boundary provision, is now expressed as a minimum (MM34). This approach is supported by Countryside Properties. However, the 2018 SNHP should now be utilised to determine the OAHN for the purposes of this Local Plan. Therefore, a revised housing requirement should be identified of a minimum of 10,015 over the 22 year plan period.

10.2 Countryside Properties has identified significant concerns in respect of the housing trajectory which is not based on robust trends. The housing trajectory contained within NWBC26C does not identify a 5% buffer and fails to have regard to national trends evidence on lead-in times and build out rates. It has been demonstrated that additional land is required to be allocated to ensure the OAHN can be delivered within the Borough to 2033. Part of the solution, to rectify this unsoundness, would be to allocate RH2 (Land North of Ansley Common) as a housing allocation rather than a reserve site.

10.3 A lack of housing development within Hartshill within the plan period and beyond will result in local housing needs not being met. In addition, the lack of proposed housing will result in a significant imbalance between the jobs available and the economically active local population to support sustainable economic growth. This mismatch between the provision of jobs and homes will inevitably lead to

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unsustainable commuting patterns, placing increasing strain on local infrastructure.

10.4 Land North of Ansley Common is a suitable and sustainable location for the delivery of much needed homes including a significant proportion of affordable housing to meet local housing requirements. The site represents a deliverable and developable proposition, being available now and providing every prospect that a significant number of homes can be delivered within the next 5 years as part of initial phases of the development.

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APPENDIX 1 14 LEGEND: Issues Bethany

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© This drawing is copyright of Countryside Properties (UK) Limited and must not be copied or reproduced in whole or in part, nor used in conjunction with any project without Countryside's written consent. DRAWING_LOCATION APPENDIX 2 INSIGHT FEBRUARY 2020 Start to Finish What factors affect the build-out rates of large scale housing sites? SECOND EDITION Lichfields is the pre-eminent planning and development consultancy in the UK We’ve been helping create great places for over 50 years.

lichfields.uk Executive summary

Lichfields published the first edition of Start to Finish in November In too many local plans and five-year land supply cases, 2016. In undertaking the research, our purpose was to help inform there is insufficient evidence for how large sites are the production of realistic housing trajectories for plan making and treated in housing trajectories. Our research seeks to fill decision taking. The empirical evidence we produced has informed the gap by providing some benchmark figures - which numerous local plan examinations, S.78 inquiries and five-year land can be of some assistance where there is limited or supply position statements. no local evidence - but the averages derived from our analysis are not intended to be definitive and are no Meanwhile, planning for housing has continued to evolve: with alternative to having a robust, bottom-up justification for a revised NPPF and PPG; the Housing Delivery Test and Homes the delivery trajectory of any given site. England upscaling resources to support implementation of large sites. Net housing completions are also at 240,000 dwellings per annum. With this in mind, it is timely to refresh and revisit the evidence on the speed and rate of delivery of large scale housing sites, now looking at 97 sites over 500 dwellings. We consider a wide range of factors which might affect lead-in times and build-out rates and have drawn four key conclusions.

We have drawn four key conclusions:

1 Large schemes can take 5+ years to start 2 Lead-in times jumped post recession

Our research shows that if a scheme of more than 500 dwellings has Our research shows that the planning to delivery period for large an outline permission, then on average it delivers its first home in sites completed since 2007/08 has jumped compared to those where c.3 years. However, from the date at which an outline application is the first completion came before 2007/08. This is a key area where validated, the average figures can be 5.0-8.4 years for the first home improvements could be sought on timeliness and in streamlining pre- to be delivered; such sites would make no contribution to completions commencement conditions, but is also likely impacted by a number of in the first five years. macro factors.

3 Large greenfield sites deliver quicker 4 Outlets and tenure matter

Large sites seem to ramp up delivery beyond year five of the Our analysis suggests that having additional outlets on site has a positive development on sites of 2,000+ units. Furthermore, large scale impact on build-out rates. Interestingly, we also found that schemes with brownfield sites deliver at a slower rate than their greenfield more affordable housing (more than 30%) built out at close to twice the equivalents: the average rate of build out for greenfield sites in our rate as those with lower levels of affordable housing as a percentage of all sample is 34% greater than the equivalent brownfield. units on site. Local plans should reflect that – where viable – higher rates of affordable housing supports greater rates of delivery. This principle is also likely to apply to other sectors that complement market housing for sale. Key sites assessed, with combined yield of 213k+ dwellings; 97 sites figures 180 had 500+ homes

average time taken from outline decision notice to first dwelling completions on c.3yrs sites of 500+ homes

the average time from validation of the first planning application to the first dwelling being 8.4yrs completed on schemes of 2,000+ dwellings

the average annual build-out rate for a scheme of 2,000+ 160 dpa dwellings (median: 137)

the average annual build rate of a scheme 68 dpa of 500-999 dwellings (median: 73)

higher average annual build-out rate on +34% greenfield sites compared with brownfield sites

average completions per outlet on sites with one outlet, dropping to 51 for sites of two 61 dpa outlets, and 45 for sites with three outlets INSIGHT START TO FINISH

01 Introduction

This is the second edition of our review on the speed of delivery on large-scale housing development sites. The first edition was published in November 2016 and has provided the sector with an authoritative evidence base to inform discussions on housing trajectories and land supply at planning appeals, local plan examinations and wider public policy debates. Over this period, housing delivery has remained at or near the top, of the domestic political agenda: the publication of the Housing White Paper, the new NPPF, an emboldened Homes England, a raft of consultations on measures intended to improve the effectiveness of the planning system and speed up delivery of housing. Of particular relevance to Start to Finish was the completion of Sir Oliver Letwin’s independent review of build out (“the Letwin Review”), the inclusion within the revised NPPF of a tighter definition of ‘deliverable’ for the purposes of five-year housing land supply (5YHLS) assessment, and the new Housing Delivery Test which provides a backward Our research complements, rather than supplants, looking measure of performance. The policy aim is to focus more the analysis undertaken by Sir Oliver Letwin in his attention on how to accelerate the rate of housing build out, in Review. The most important differentiation is that the context of the NPPF (para 72) message that the delivery of a we focus exclusively on what has been built, whereas large numbers of new homes can often be best achieved through each of the sites in the Letwin Review included larger scale development such as new settlements or significant forecasts of future delivery. Additionally, the Letwin extensions to existing villages and towns, but that these need a Review looked at 15 sites of 1,500+ homes, of which realistic assessment of build-out rates and lead in times of large-scale many (including the three largest) were in London. By development. contrast, the examples in this research sample include 46 examples of sites over 1,500 homes across England This second edition of Start to Finish is our response to the latest and Wales, the majority of which are currently active. policy emphasis. It provides the planning sector with real-world As with the first edition of our research, we have benchmarks to help assess the realism of housing trajectory excluded London because of the distinct market and assumptions, particularly for locations where there have been few delivery factors in the capital. contemporary examples of strategic-scale development. The first edition looked in detail at how the size of the site affected build-out rates and lead in times, as well as other factors such as the value of the land and whether land was greenfield or brownfield. We have Contents updated these findings, as well as considering additional issues such 01 Introduction 1 as how the affordability of an area and the number of outlets on a site impacts on annual build-out rates. 02 Methodology 2 5 We have also expanded the sample size (with an extra 27 large 03 Timing is everything sites, taking our total to 97 large sites, equivalent to over 195,000 04 How quickly do sites build out? 9 dwellings) and updated with more recent data to the latest 05 What factors influence build-out rates? 14 monitoring year (all data was obtained at or before the 1st April 2019). 06 Conclusions 18

1 INSIGHT START TO FINISH 02 Methodology 180 sites The evidence presented in this report analyses by significant amounts of pre-application how large-scale housing sites emerge through engagement and work, plus the timescale of the the planning system, how quickly they build local plan process. out, and identifies the factors which lead to 97 The ‘planning to delivery’ period follows faster or slower rates of delivery. large sites of 500 immediately after the planning approval period units or more We look at the full extent of the planning and measures the period from the approval and delivery period. To help structure the of the first detailed application to permit research and provide a basis for standardised development of dwellings and the completion measurement and comparison, the various of the first dwelling. 27 stages of development have been codified. additional sites Figure 1 sets out the stages and the milestones Development and data compared with our used, which remain unchanged from the first Whilst our analysis focuses on larger sites, we 2016 research edition of this research. The overall ‘lead-in have also considered data from the smaller time’ covers stages associated with gaining sites for comparison and to identify trends. The an allocation, going through the ‘planning geographic distribution of the 97 large sites and approval period’ and ‘planning to delivery comparator small sites is shown in Figure 2 8 period’, finishing when the first dwelling is and a full list can be found in Appendix 2 (large sites also included completed. The ‘build period’ commences when sites) and Appendix 3 (small sites). in Sir Oliver Letwin’s the first dwelling is completed, denoting the Efforts were made to secure a range of locations review end of the lead-in time. The annualised build- and site sizes in the sample, but there is no way out rates are also recorded for the development of ensuring it is representative of the housing up until the latest year where data was available market in England and Wales as a whole, and at April 2019 (2017/18 in most cases). Detailed thus our conclusions may not be applicable definitions of each of these stages can be found in all areas or on all sites. In augmenting our in Appendix 1. Not every site assessed will sample with 27 additional large sites, new necessarily have gone through each component to this edition of our research, we sought to of the identified stages as many of the sites include examples in the Letwin Review that we considered had not delivered all dwellings were outside of London, only excluding them permitted at the time of assessment, some have not delivered any dwellings. Information on the process of securing a Box 1: Letwin Review sites development plan allocation (often the most significant step in the planning process for 1. Arborfield Green (also known as large-scale schemes, and which – due to the Arborfield Garrison), Wokingham nature of the local plan process - can take decades) is not easy to obtain on a consistent 2. Ledsham Garden Village, Cheshire West basis across all examples, so is not a significant & Chester focus of our analysis. Therefore, for the 3. Great Kneighton (also known as Clay purposes of this research the lead-in time Farm), Cambridge (included in the first reflects the start of the planning approval edition of this research) period up to the first housing completion. 4. Trumpington Meadows, Cambridge The ‘planning approval period’ measures the 5. Graven Hill, Cherwell validation date of the first planning application 6. South West Bicester, Cherwell on the site (usually an outline application but sometimes hybrid), to the decision date of the 7. Great Western Park, South Oxfordshire first detailed application to permit dwellings 8. Ebbsfleet, Gravesham and Dartford in the scheme (either full, hybrid or reserved (included in the first edition of this matters applications). It is worth noting that research) planning applications are typically preceded

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when it was difficult to obtain reliable data. The The sources on which we have relied to secure study therefore includes the Letwin Review’s delivery data on the relevant sites include: case studies listed in Box 1. 1. Annual Monitoring Reports (AMRs) and In most instances, we were unable to secure other planning evidence base documents1 the precise completion figures for these sites produced by local authorities; that matched those cited in the Letwin Review. 2. By contacting the relevant local planning Sources for data Lichfields has obtained on authority, and in some instances the completions for those sites that also appear in relevant County Council, to confirm the the Letwin Review are included at the end of data or receive the most up to date figures Appendix 2. from monitoring officers or planners; and 3. In a handful of instances obtaining/ confirming the information from the relevant house builders.

Figure 1: Timeline for the delivery of strategic housing sites

Securing an allocation

Submission to Site Promotion and Local Secretary of Plan Consultations State (SoS) Suspension of Examination in Public (EIP) Inspector finds ! examination or Local Plan sound withdrawal of Adoption of Local Plan Local Plan Local Planning Authority adopts Local Plan Securing planning permission

Pre-Application Work EIA Screening Planning approval period* Local Planning ! and Scoping Lead-in time* Authority Outline Application minded to Full Planning approve Application S106 Judicial SoS call in/ S106 ! Review application Reserved matters (potential refused/ Planning for) appeal lodged

permission period * Planning to delivery granted Discharge pre-commencement conditions

On site completions Start on site Delivery of infrastructure ‘Opening up works’ ! (e.g. roads) and 1 First housing mitigation (e.g. ecology, completion flooding etc) period* Build

Delivery of dwellings Scheme complete 1 Monitoring documents, five-year land supply reports, housing trajectories (some in land availability Data obtained only for some sites Data obtained for all sites *Definition for research purposes assessments), housing development reports and newsletters Source: Lichfields analysis

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Figure 2: Map of site sample by size of site (total dwellings)

196,714 Large housing sites units on large sites Number of Units of 500 or more 2,000+ homes 1,500-1,999

1,000–1,499 16,467 500–999 units on small sites Small housing sites Number of Units under 500 homes 100–499 35 <100 sites of 2,000 homes or more

Source: Lichfields analysis

4 INSIGHT 03 START TO FINISH Timing is everything: how long does it take to get started?

In this section we look at lead in times, the considered deliverable where there is clear evidence time it takes for large sites to get the necessary that housing completions will begin on site within planning approvals. Firstly, the changing five years”. (emphasis added) c.3 years context of what ‘deliverable’ means for What constitutes ‘clear evidence’ was clarified development. Secondly, the ‘planning approval average time from in a number of early appeal decisions and in the obtaining outline period’ (the time it takes for large sites to get Planning Practice Guidance2 and can include permission to first the necessary planning approvals). And thirdly, information on progress being made towards dwelling completion the ‘planning to delivery period’ (the time submission of a reserved matters application, on sites of 500+ from approval of the first detailed application any progress on site assessment work and homes to permit development of dwellings to the any relevant information about site viability, completion of the first dwelling). ownership constraints or infrastructure provision. In this context, it is relevant to look The new definition of ‘Deliverable’ at how long it takes, on average, for a strategic The question of how quickly and how much housing site to progress from obtaining outline housing a site can begin delivering once it permission to delivering the first home (or how has planning permission, or an allocation, has long it takes to obtain the first reserved matters become more relevant since the publication approval, discharge pre-commencement of the new NPPF with its new definition conditions and open up the site), and then how of deliverable. Only sites which match the much housing could be realistically expected to deliverability criteria (i.e. suitable now, be completed in that same five-year period. available now and achievable with a realistic prospect that housing will be delivered on Based on our sample of large sites, the the site within five years) can be included in a research shows that, upon granting of outline calculation of a 5YHLS by a local authority. This permission, the time taken to achieve the first definition was tightened in the revised NPPF dwelling is – on average c.3 years, regardless of which states that: site size. After this period an appropriate build- out rate based on the size of the site should “sites with outline planning permission, permission also be considered as part of the assessment of in principle, allocated in the development plan or deliverability (see Section 4). Outline planning identified on a brownfield register should only be permissions for strategic development are not

Figure 3: Average time taken from gaining outline permission to completion of the first dwelling on site (years), compared to site size

3.5 3.1 3.2 3.1 3.0 2.9 3.0 2.8

2.5 2.5 2.5

2.0

1.5

1.0

0.5

Outline permission to first dwelling completed (years) 0.0 500-999 1,000-1,499 1,500-1,999 2,000+

Site size (dwellings) Mean Median 2 Planning Practice Guidance Reference ID: 68- Source: Lichfeilds analysis 007-20190722

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always obtained by the company that builds Comparison with our 2016 the houses, indeed master developers and other land promoters play a significant role in findings bringing forward large scale sites for housing Planning Approval Period Only sites of fewer development3. As such, some of these examples Our latest research reveals little difference than 499 dwellings will include schemes where the land promoter are on average likely between the average planning approval period or master developer will have to sell the site to deliver any homes by site size compared to the same analysis in the (or phases/parcels) to a housebuilder before within an immediate first edition (see Table 1). However, it is important five year period. the detailed planning application stage can to remember that these are average figures commence, adding a step to the planning to which come from a selection of large sites. There delivery period. are significant variations within this average, Figure 4 considers the average timescales with some sites progressing very slowly or for delivery of the first dwelling from the quickly compared to the other examples. This is validation of an outline planning application. unsurprising as planning circumstances will vary This demonstrates that only sites comprising between places and over time. fewer than 499 dwellings are – on average - likely to deliver anything within an immediate Table 1: Average planning approval period by size of site (years) five year period. The average time from 1st edition This research 4 Site Size validation of an outline application to the research (years) (years) delivery of the first dwelling for large sites 50-99 1.1 1.4 ranges from 5.0 to 8.4 years dependent on the size of the site, i.e. beyond an immediate five- 100-499 2.4 2.1 year period for land supply calculations. 500-999 4.2 3.3

1,000-1,499 4.8 4.6

1,500-1,999 5.4 5.3

2,000+ 6.1 6.1

Source: Lichfields analysis

Figure 4: Average timeframes from validation of first application to completion of the first dwelling

9 8.4

8 6.9 7.0 2.3 7

6 1.7 5.0 2.3 5 3 Realising Potential - our 4.0 research for the Land 4 1.7 Promoters and Developers 3.3* Federation in 2017 - found (years)Duration 3 1.9 6.1 that 41% of homes with 5.3 2.0 4.6 outline planning permission 2 3.3 were promoted by specialist land promoter and 1 2.1 development companies, 1.4 compared to 32% for volume 0 house builders. 50-99 100-499 500-999 1,000-1,499 1,500-1,999 2,000+ 4 The planning approval Site size (dwellings) period could also include a hybrid or full application, Average planning approval period Average planning to delivery period *does not sum due to rounding but on the basis of our examples this only impacts a small number of sites Source: Lichfields analysis

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Planning to Delivery Period A similar trend is apparent considering the 55 sites that delivered their first completions after Although there is little difference between the 2007/08. These have significantly longer planning average planning approval periods identified to delivery periods than those where completions in this research compared to our first edition began prior to the recession. The precise reasons Sites that delivered findings, the average lead-in time after securing are not clear, but is perhaps to be expected given their first completion planning permission is higher (Figure 5). It is during or after the the slowdown in housing delivery during the 2007/08 recession this period during which pre-commencement recession, and the significant reductions in local have significantly planning conditions have to be discharged as authority planning resources which are necessary longer planning to well as other technical approvals and associated to support discharge of pre-commencement delivery periods than commercial agreements put in place. sites which began conditions. However, delays may lie outside the before. planning system; for example, delays in securing This is likely due to the inclusion of more recent necessary technical approvals from other bodies proposed developments in this edition. Of the and agencies, or market conditions. 27 new sites considered, 17 (63%) completed their first dwelling during or after 2012; this compares to just 14 (20%) out of 70 sites in the first edition of this research (albeit at the time of publication 8 of these sites had not delivered their first home but have subsequently). This implies that the introduction of more recent examples into the research, including existing examples which have now commenced delivery5, has seen the average for planning to delivery periods lengthening.

Figure 5: Planning to delivery period, total average, pre and post-2008

4.5 4.0 4.0 3.5 3.5

3.0 2.6 2.7 2.6 2.5 2.4 1.9 2.0 1.9 1.9 1.4 1.5 1.1 1.0 1.0

0.5 Average planning to delivery period (years) Figure 5: Five of the large 0.0 sites examples do not have 500-999 1,000-1,499 1,500-1,999 2,000+ a first dwelling completion Site size (dwellings) recorded in this research

5 Completions begun pre-2008 Completions begun post-2008 All years Priors Hall has been (37 sites) (55 sites) (92 sites) amended since the first edition based on more Source: Lichfeilds analysis recent data

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In demand: how quickly do high pressure areas determine strategic applications for housing? Using industry-standard affordability ratios, we found that areas with the least affordable places to purchase a home (i.e. the highest affordability ratios) tended to have longer planning to delivery times than areas that were more affordable. This is shown in Figure 6, which splits the large site sample into national affordability quartiles, with the national average equating to 8.72.

The above analysis coincides with the fact (Table 2) that sites in the most affordable locations (lowest quartile) tend to be smaller than those in less affordable locations (an average site size of c.1,150 compared to in excess of 2,000 dwellings for the three other quartiles). Even the least affordable LPAs (with the greatest gap between workplace earnings Table 2: Site size by 2018 affordability ratio and house prices) have examples of large schemes Affordability ratio Average site size with an average site size of 2,000+ dwellings. It may (workplace based) be that the more affordable markets do not support the scale of up-front infrastructure investment that 2.5 – 6.4 1,149

is required for larger-scale developments and which 6.5 – 8.7 2,215 lead to longer periods before new homes can be built. However, looking at the other three quartiles, 8.8 – 11.0 2,170 the analysis does also suggest that planning and 11.1 – 44.5 2,079 implementation becomes more challenging in less affordable locations. Source: Lichfields analysis

Figure 6: Planning approval period (years) by 2018 affordability ratio

8

6.8 7

6 5.6 5.4 2.9 5 4.4 1.8 2.0 4 1.5 3

2 3.9 3.4 3.8 2.9 1 Average planning approval period (years) period approval planning Average

0

More affordable 2018 affordability ratio (national quartiles) Less affordable

1st: 2.5 to 6.4 2nd: 6.5 to 8.7 3rd: 8.8 to 11.0 4th: 11.1 to 44.5

Planning approval period Planning to delivery period

Source: Lichfields analysis

8 INSIGHT 04 START TO FINISH How quickly do sites build out?

The rate at which new homes are built on sites Average Annual Build-out rates is still one of the most contested matters at local Figure 7 presents our updated results, with plan examinations and planning inquiries which our additional 27 sites and the latest data for 160 dpa address 5YHLS and housing supply trajectories. all sites considered. The analysis compares the the average annual The first edition of this research provided a size of site to its average annual build-out rate. build rate for schemes range of ‘real world’ examples to illustrate what Perhaps unsurprisingly, larger sites deliver on of 2,000+ dwellings a typical large-scale site delivers annually. The average more dwellings per year than smaller research showed that even when some schemes sites. The largest sites in our sample of over were able to achieve very high annual build-out 2,000 dwellings, delivered on average more than rates in a particular year (the top five annual twice as many dwellings per year than sites of figures were between 419-620 dwellings per 500-999 dwellings, which in turn delivered an annum), this rate of delivery was not always average of three times as many units as sites sustained. Indeed, for schemes of 2,000 or more of 1-99 units. To ensure the build-out rates dwellings the average annual completion rate averages are not unduly skewed, our analysis across the delivery period was 160 dwellings excludes any sites which have only just started per annum. delivering and have less than three years of data. This is because it is highly unlikely that the first annual completion figure would actually cover a whole monitoring year, and as such could distort the average when compared to only one other full year of delivery data.

Figure 7: Build-out rate by size of site (dpa)

180 35% 160 160 29% 30% 140 120 25% 120 21% 107

100 20%

80 68 15%

60 55 9% 9% 10% 7% 40

22 4% as % of total dwellings on site) 5%

Housing delivery (dwellings per annum) per deliveryHousing (dwellings 20 Housing delivery (dwellings per annum

0 0 50-99 100-499 500-999 1,000-1,499 1,500-1,999 2,000+

Site Size (dwellings)

Housing delivery (dwellings per annum) Housing delivery (dwellings per annum as % of total dwellings on site) Source: Lichfields analysis

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We include the relevant percentage growth rates in this edition’s analysis; this shows that the proportion of a site’s total size that is build out each year reduces as site size increases. In most cases the median annual Our use of averages refers to the arithmetic mean delivery rate is lower across the sample sites. In most cases the median than the mean for of the rates seen on the larger sample sites is larger sites. lower, as shown in Figure 8; this reflects the small number of sites which have higher delivery rates (the distribution is not equal around the average). The use of mean average in the analysis therefore already builds in a degree of optimism compared with the median or ‘mid-point scheme’.

Figure 8: Minimum, mean, median and maximum build-out rates by size of site (dpa)

350

Mean 300 Median

250

200

150

100

Housing delivery (dwellings per annum) per deliveryHousing (dwellings 50

0 50-99 100-499 500-999 1,000-1,499 1,500-1,999 2,000+

Source: Lichfields analysis Site Size (dwellings)

Table 3: Median and mean delivery rates by site size

Median housing Mean annual Mean annual Median delivery as Site Size Number of sites delivery (dwellings delivery (dwellings delivery as % of % of total on site per annum) per annum) total units on site

50-99 29 27 33% 22 29%

100-499 54 54 24% 55 21%

500-999 24 73 9% 68 9%

1,000-1,499 17 88 8% 107 9%

1,500-1,999 9 104 7% 120 7%

2,000+ 27 137 4% 160 4%

Source: Lichfields analysis

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Comparison with our 2016 Variations for individual schemes can be findings marked. For example, the 2,605 unit scheme South of the M4 in Wokingham delivered Comparing these findings to those in the first 419 homes in 2017/18, but this was more than edition of this research, there is very little double the completions in 2016/17 (174) and the Site build-out rates difference between the averages observed average over all six years of delivery so far was for individual years (median was not presented) for different site are highly variable. just 147 dwellings per annum. sizes, as set out below. The largest difference is For example, one Even when sites have seen very high peak years scheme in Wokingham a decrease in average annual build-out rates for delivered more than sites of 1,000-1,499 dwellings, but even then, of delivery, as Table 5 shows, no sites have been twice as many homes this is only a reduction of 10 dpa or 9%. able to consistently delivery 300 dpa. in 2017/18 as it did in the year before. As with the first edition of the research, these are averages and there are examples of sites which deliver significantly higher and lower than these averages, both overall and in individual years. Figure 8 shows the divergence from the average for different site size categories. This shows that whilst the average for the largest sites is 160 dpa and the median equivalent 137 dpa, the highest site average was 286 dpa and the lowest site average was 50 dpa for sites of 2,000+ dwellings. This shows the need for care in interpreting the findings of the research, there may well be specific factors that mean a specific site will build faster or slower than the average. We explore some of the factors later in this report.

Table 4: Mean delivery rates by site sizes, a comparison with first Table 5: Peak annual build-out rates compared against average edition findings annual delivery rates on those sites

Average 2016 edition 2020 edition Peak annual Site size Site size annual research research Difference Site build-out (dwellings) build-out rate (dwellings) rate (dpa) (dpa) (dpa) (dpa)

Cambourne, South 50-99 27 22 -5 (-19%) 4,343 620 223 Cambridgeshire Table 5: Please note The Oakley Vale, Hamptons was included as 100-499 60 55 -5 (-8%) 3,100 520 180 Corby an example of peak annual delivery in the first edition Eastern Expansion 500-999 70 68 -2 (-3%) 4,000 473 268 Area, Milton Keynes with one year reaching 520 completions. However, Clay Farm, evidence for this figure 1,000-1,499 117 107 -10 (-9%) 2,169 467 260 Cambridge is no longer available and as it was not possible to South of M4, 1,500-1,999 129 120 -9 (-7%) 2,605 419 147 Wokingham corroborate the figure it has been removed. The analysis Cranbrook, East has been updated to reflect 2,000+ 161 160 -1 (-0.62%) 2,900 419 286 Devon the latest monitoring data from Peterborough City Source: Lichfields analysis Source: Lichfields analysis Council.

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Longer term trends The impact of the recession on This section considers the average build-out build-out rates rates of sites which have been delivering over It is also helpful to consider the impact of a long period of time. This is useful in terms of market conditions on the build-out rate of large planning for housing trajectories in local plans scale housing sites. Figure 10 overleaf shows when such trajectories may span an economic the average delivery rate of sites of 2,000 or cycle. more dwellings in five-year tranches back to In theory, sites of more than 2,000 dwellings 1995/96. This shows that although annual will have the longest delivery periods. build-out rates have improved slightly since Therefore, to test long term averages we have the first half of the 2010’s, they remain 37% calculated an average build-out rate for sites of below the rates of the early 2000’s. The reasons 2,000+ dwellings that have ten years or more of for the difference are not clear and are worthy completions data available. of further exploration – there could be wider market, industry structure, financial, planning For these sites, the average annual build-out or other factors at play. rate is slightly higher than the average of all sites of that size (i.e. including those only part In using evidence on rates of delivery for way through build out), at 165 dwellings per current/historic schemes, some planning annum6. The median for these sites was also 165 authorities have suggested that one should dwellings per annum. adjust for the fact that rates of build out may have been affected by the impact of the This indicates that higher rates of annual recession. We have therefore considered how housing delivery on sites of this size are more the average rates change with and without likely to occur between years five and ten, i.e. including the period of economic downturn after these sites have had time to ‘ramp up’. (2008/09 – 2012/13). This is shown in Table 6 It might even relate to stages in delivery when and it reveals that average build-out rates are multiple phases and therefore multiple outlets only slightly depressed when one includes this (including affordable housing) are operating at period, but may not have fully recovered to the same time. These factors are explored later their pre-recession peaks. We know that whilst in the report. the recession – with the crunch on mortgage

Figure 9: Average build-out rate for sites over 2,000 homes by length of delivery period (dpa)

180 165 160 160 155

140

120

100

80

60

40 Housing delivery (dwellings per annum) per deliveryHousing (dwellings 6 This is based on the 20 completions of seven examples, Chapelford 0 Urban Village, Broadlands, Kings Hill, Oakley Vale, Sites with 10+ years of delivery (7) Sites with 5+ years of delivery (24) All sites (27) Cambourne, The Hamptons and Wixhams Source: Lichfields analysis

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availability – did have a big impact and led to the flow of new sites slowing, there were mechanisms put in place to help sustain the build out of existing sites. However, setting aside that stripping out the recession has a modest impact on the statistical averages for the sites in our sample, the more significant point is that – because of economic cycles - larger sites which build out over five or more years are inherently likely to coincide with a period of economic slowdown at some point during their build out. It therefore makes sense for housing trajectories for such sites to include an allowance for the prospect that, at some point, the rate of build out may slow due to a market downturn, albeit the effect may be smaller than one might suspect.

Table 6: Impact of recession on build-out rates

Build-out rates excluding Build-out rates in all years Build-out rates pre-recession recession years (2008/9-2012/13)

Average rate Sample size Average rate Sample size Average rate Sample size

All large sites 115 77 126 68 130 21 500+

All large sites 160 27 171 25 242 6 2,000+

Greenfield sites 181 14 198 12 257 3 2,000+

Source: Lichfields analysis

Figure 10: Average build-out rate by five year period for sites over 2,000 dwellings (dpa)

250 235

200 190 181

147 150 136

100

50 Housing delivery (dwellings per annum) per deliveryHousing (dwellings

0 1995/96-1999/00 2000/01-2004/05 2005/06-2009/10 2010/11-2014/15 2015/16-2017/18*

Delivery period Source: Lichfields analysis

13 INSIGHT START TO FINISH 05 What factors can influence build-out rates?

Having established some broad averages and how delivered for three years or more. This analysis these have changed over time, we turn now to shows that sites in areas of higher demand +34% look at what factors might influence the speed (i.e. less affordable) deliver on average more at which individual sites build out. How does dwellings per annum. higher average annual build-out housing demand influence site build out? What is Our analysis also coincides with the fact that rates on greenfield the impact of affordable housing? Does it matter sites in less affordable areas are on average land compared with whether the site is greenfield or brownfield? c.17% larger than those in more affordable brownfield What about location and site configuration? areas. The average site size for schemes in In demand: do homes get delivered areas where affordability is below the national faster in high pressure areas? average is 1,834 dwellings. For those delivered in areas where the affordability is greater than One theory regarding annual build-out rates is the national average, average site size is 2,145 that the rate at which homes can be sold (the dwellings. So, it is possible that the size of site – ‘absorption rate’) determines the build-out rate. rather than affordability per se – is a factor here. This is likely to be driven by levels of market demand relative to supply for the product being Do sites on greenfield land deliver supplied. more quickly? This analysis considers whether demand for The first edition of this research showed that housing at the local authority level affects greenfield sites on average delivered quicker delivery rates by using (industry-standard) than their brownfield counterparts. In our affordability ratios. Higher demand areas are updated analysis this remains the case; large indicated by a higher ratio of house prices greenfield sites in our sample built out a third to earnings i.e. less affordable. Whilst this faster than large brownfield sites. is a broad-brush measure, the affordability In the life cycle of a site, our data also shows ratio is a key metric in the assessment of that greenfield sites had shorter planning to local housing need under the Government’s delivery periods (2.0 years compared to 2.3 for standard methodology. Figure 11 shows the brownfield sites), although on average, longer sample of 500+ unit schemes divided into those planning approval periods (5.1 years compared where the local authority in which they are to 4.6 for brownfield sites). located is above or below the national median affordability ratio (8.72) for sites which have

Figure 11: Build-out rates by level of demand using national Figure 12: Build-out rates on brownfield and greenfield sites median 2018 workplace based affordability ratio (dpa) (dpa)

140 140

120 120

100 100

80 80 131 60 126 60 99 98 40 40

20 20 Housing delivery (dwellings per annum) per deliveryHousing (dwellings Housing delivery (dwellings per annum) per deliveryHousing (dwellings 0 0 More affordable than Less affordable than Brownfield Greenfield national average (<8.72) national average (>8.72)

Source: Lichfields analysis Source: Lichfields analysis

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Housing mix and variety not be. On this basis, we use the outlets metric as Among the more topical issues surrounding a proxy for variation. Based on the limited data delivery rates on large-scale sites is the variety available for this analysis, if two phases are being of housing on offer. The Letwin Review posited built out at the same time by the same housebuilder Having more outtlets that increasing the diversity of dwellings on large (e.g. two concurrent parcels by Bovis) this has been counted as one outlet with the assumption there is operating at the same sites in areas of high housing demand would help time will on average achieve a greater rate of build out. The report little variety (although it is clear that some builders quicken build-out concluded that a variety of housing is likely may in reality differentiate their products on the rates. to appeal to a wider, complementary range of same site). This data was derived from sites in a potential customers which in turn would mean relatively small number of local planning authorities a greater absorption rate of housing by the local who publish information relating to outlets on site. market. It therefore represents a small sample of just 12 sites, albeit over many different years in which the number Consistent data on the mix of sizes, types and prices of outlets varied on the same site, giving a total of 80 of homes built out on any given site is difficult to data points i.e. individual delivery rates and number of source, so we have used the number of sales outlets outlets to compare. on a site as a proxy for variety of product. This gives the prospect of multiple house builders each Our analysis confirms that having more outlets seeking to build and sell homes for which there operating at the same time will on average have a is demand in the face of ‘competing’ supply from positive impact on build-out rates, as shown in Figure other outlets (as revealed by the case study of Land 13. However, there are limits to this, likely to be due South of the M4 in Wokingham). Letwin stated to additional capacity from the outlets themselves as that “…it seems extraordinarily likely that the presence well as competition for buyers. of more variety in these aesthetic characteristics would On a site-by-site basis, the average number of create more, separate markets”7. Clearly, it is likely that outlets open over the site’s entire delivery lifetime on many sites, competing builders may focus on a had a fairly strong correlation with annual delivery, similar type of product, for example three or four both as a percentage of total dwellings and in absolute bed family housing, but even across similar types of terms, with a greater number of outlets contributing dwelling, there will be differences (in configuration, to higher levels of delivery. However, the completions design, specification) that mean one product may be per outlet did reduce with every additional outlet attractive to a purchaser in the way another might operating in that year.8

Figure 13: Build-out rates by number of outlets present (dpa)

450

400

350

300

250

200

150

100 7 Letwin Review draft analysis report (June 2018) Housing delivery (dwellings per annum) per deliveryHousing (dwellings 50 - final bullet of para 4.25 8 Average completions per 0 outlet on site with one outlet 0 1 2 3 4 5 6 7 8 9 10 was 61dpa, dropping to Outlets 51dpa for two outlets and Source: Lichfields analysis 45dpa for three outlets.

15 INSIGHT START TO FINISH

Geography and Site Configuration Keynes Council suggesting an average of c.12 parcels were active across the build period. In this An under-explored aspect of large-scale site second edition of this research the Milton Keynes delivery is the physical opportunity on site. examples remain some of the sites with the For example, some schemes lend themselves to highest annual build-out rates. simultaneous build out of phases which can have the impact of boosting delivery rates in that year,

for example, by having access points from two Table 7: Parcels at Land South of M4, Wokingham alternative ends of the site. Other sites may be reliant on one key piece of infrastructure which Parcel Developers Completions make this opportunity less likely or impractical. reference (active outlets) in 2017/18

In the first edition of this research we touched SP1 Bellway (1) 59 on this point in relation to Eastern Expansion None - parcel SP2w Bellway and Bovis (-) Area (Broughton Gate & Brooklands) of Milton completed Keynes. As is widely recognised, the planning SP3 Crest Nicholson (1) 47 and delivery of housing in Milton Keynes is Taylor Wimpey and David distinct from almost all the sites considered in SP4 140 Wilson Homes (2) this research as serviced parcels with the roads already provided were delivered as part of the SP9_1 Bloor, Bovis and Linden (3) 169

Milton Keynes delivery model. Multiple house None - parcel SP10 Darcliffe Homes (-) builders were able to proceed straight onto the completed

site and commence delivery on different serviced SP11 Taylor Wimpey (1) 4 parcels, with monitoring data from Milton Source: Lichfields analysis

Figure 14: Map of parcels at Land South of M4, Wokingham

Source: © Google Earth 2020/ Wokingham Local Plan

16 INSIGHT START TO FINISH

In this edition we look at the case study of Land Affordable choices: do different South of the M4 in Wokingham. In 2017/18 tenures provide more demand? the site achieved a significant 419 completions. Our findings on tenure, another form of Using the local authority’s granular recording of ‘variety’ in terms of house building products, delivery on the site to date, we have been able to Schemes with more are informed by data that is available on about consider where these completions were coming affordable housing half the sites in our large site sample. From built out at close to forward from within the wider 2,605 dwelling this the analysis shows schemes with more twice the rates as scheme. As shown in Figure 14, in that year those with lower affordable housing built out at close to twice new homes were completed on five separate levels. the rate as those with lower levels of affordable parcels with completions ranging from 4 to housing as a percentage of all dwellings on site. 169 dwellings. On some of these parcels (SP9_1 However this is not always the case. Schemes and SP4) there were two or three separate with 20-29% affordable housing had the lowest housebuilders building out, and in total on the build-out rates, both in terms of dwellings and site there were seven different house building proportionate to their size. companies active (the impact of multiple outlets on build-out rates is explored later in this report). The parcels are located in separate parts of the site and each had their own road frontages and access arrangements which meant they are able to come forward in parallel. This can enable an increased build rate.

Source: Lichfields analysis

Figure 15: Build-out rates by level of affordable housing (dpa and percentage)

160 16%

142 140 135 14%

12% 12.1% 120 12% 107 104 10.0% 100 98 10%

80 8% 6.5% 5.9% 60 6%

40 4% Housing delivery (dwellings per annum) per deliveryHousing (dwellings

20 2% Housing delivery (dwellings per annum as % of total dwellings on site)

0 0 0-9% 10-19% 20-29% 30-39% 40%+ Level of affordable housing on site (% of total dwellings)

Housing delivery (dwellings per annum) Housing delivery (dwellings per annum as % of total dwellings on site) Source: Lichfields analysis

17 INSIGHT START TO FINISH 06 Conclusions

Recent changes to national planning policy helpful in locations where there is little recent emphasise the importance of having a realistic experience of such strategic developments. Whilst expectation of delivery on large-scale housing we present some statistical averages, the real sites, whilst local authorities now find themselves relevance of our findings is that there are likely subject to both forward and backward-looking to be many factors which affect lead-in times housing delivery performance measures. A and build-out rates, and that these - alongside number of local plans have hit troubles because the characteristics of individual sites - need to be they over-estimated the yield from some of considered carefully by local authorities relying their proposed allocations. Meanwhile, it is no on large sites to deliver planned housing. longer sufficient for a 5YHLS to look good on In too many local plans and 5YHLS cases, there paper; the Housing Delivery Test means there are is insufficient evidence for how large sites are consequences if it fails to convert into homes built. treated in housing trajectories. This research To ensure local authorities are prepared for these seeks to fill the gap with some benchmark figures tests, plan making and the work involved in - which can be of some assistance where there maintaining housing land supply must be driven is limited or no local evidence. But the average by realistic and flexible housing trajectories, derived from our analysis are not intended to based on evidence and the specific characteristics be definitive and are no alternative to having a of individual sites and local markets. For local robust, bottom-up justification for the delivery authorities to deliver housing in a manner which trajectory of any given site. It is clear from is truly plan-led, this is likely to mean allocating our analysis that some sites start and deliver more sites rather than less, with a good mix of more quickly than the average, whilst others types and sizes, and being realistic about how have delivered much more slowly. Every site is fast they will deliver so supply is maintained different. Therefore, whilst the averages observed throughout the plan period. Equally, recognising in this research may be a good starting point, the ambition and benefits of more rapid build out there are a number of key questions to consider on large sites, it may mean a greater focus on how when estimating delivery on large housing sites, such sites are developed. based around the three key elements in the three- tier analytical framework at Figure 16. Our research provides those in the public and private sector with a series of real-world benchmarks in this complex area of planning for large scale housing, which can be particularly

18 INSIGHT START TO FINISH

Key findings:

1 Large schemes can take 2 Lead-in times jumped 5+ years to start post-recession

In developing a local plan, but especially Whilst attention and evidence gathering in calculating a 5YHLS position, it is is often focused on how long it takes to important to factor in a realistic planning get planning permission, the planning to approval period dependent on the size delivery period from gaining permission of the site. Our research shows that if a to building the first house has also been scheme of more than 500 dwellings has increasing. Our research shows that the an outline permission, then the average planning to delivery period for large sites time to deliver its first home is two or completed since 2007/08 has jumped three years. However, from the date at compared to those where the first which an outline application is validated completion came before 2007/08. This is it can be 5.0 - 8.4 years for the first home a key area where improvements could be to be delivered dependent on the size of sought on timeliness and in streamlining the site. In these circumstances, such pre-commencement conditions, but is also sites would make no contribution to likely impacted by a number of macro factors completions in the first five years. including the recession and reductions in local authority planning resources.

3 Large greenfield sites 4 Outlets and tenure deliver quicker matter

Large sites can deliver more homes per Our analysis suggests that having year over a longer time period, with this additional outlets on site has a positive seeming to ramp up beyond year five impact on build 0ut rates, although there of the development on sites of 2,000+ is not a linear relationship. Interestingly, units. However, on average these longer- we also found that schemes with more term sites also have longer lead-in times. affordable housing (more than 30%) built Therefore, short term boosts in supply, out at close to twice the rate as those with where needed, are likely to also require a lower levels of affordable housing as a good mix of smaller sites. Furthermore, percentage of all units on site, but those large scale greenfield sites deliver at with 20-29% had the lowest rates of all. a quicker rate than their brownfield Local plans should reflect that – where equivalents: the average rate of build out viable – higher rates of affordable housing for greenfield sites in our sample was supports greater rates of delivery. This 34% greater than the equivalent figure principle is also likely to apply to other for those on brownfield land. In most sectors that complement market housing locations, a good mix of types of site will for sale, such as build to rent and self-build therefore be required. (where there is demand).

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Figure 16: Key questions for assessing large site build-out rates and delivery timelines

Planning Approval

• Is the site already allocated for development? If it is in an emerging Plan, does it need to be adopted before the site can be brought forward? • Is an SPD, masterplan or development brief required and will it help resolve key planning issues? • Is there an extant planning permission or live planning application submitted? • If outline permission is granted, when will reserved matters be submitted? • Is the proposal of the promoter consistent with local policy and/or SPD/Masterplan? • Are there significant objections to the proposal from local residents? • Are there material objections to the proposal from statutory bodies? • If planning permission is secured, is reserved matters approval required?

Lead In

• Does the scheme have pre-commencement conditions? • Is the land in existing use? • Has the land been fully assembled? • Are there any known technical constraints that need to be resolved? • If in multiple ownership/control, are the interests of all parties aligned? • Is there up-front infrastructure required before new homes can be built? • Has the viability of the proposal been established and is the feasibility consistent with known infrastructure costs and the likely rate of development? • Does the proposal rely on access to public resources and what evidence is there on when those will be available? • Is the scheme led by a promoter or master developer who will need to dispose of phases to a house builder before completions begin?

Build Out

• How large is the site? • How strong is the local market? • Does the site tap into local demand from one or more existing neighbourhoods? • Will delivery be affected by competing sites? • How many sales outlets will be supported by the scale, configuration and delivery model for the site? • What is the track record of the promoter/master developer in delivery of comparable sites? • How active are different housebuilders in the local market? • What proportion of affordable housing is being delivered? • Are there policy requirements for a specific mix of housing types and are there other forms of housing – such as build to rent? • When will new infrastructure – such as schools – be provided to support the new community? • Are there trigger points or phasing issues that may affect the build-out rate achievable in different phases?

Source: Lichfeilds analysis

20 INSIGHT START TO FINISH Appendices

Contents

Appendix 1: Definitions and notes 22 Appendix 2: Large sites tables and sources for sites also found in the Letwin Review 23 Appendix 3: Small sites tables 28

21 INSIGHT START TO FINISH Appendix 1: Definitions and notes

The ‘lead in’

Measures the period up to first completion of a house on site from the validation date of the first planning application made for the scheme. The lead-in time covers both the planning approval period and planning to delivery periods set out below. The lead-in time does also include the date of the first formal identification of the site as a potential housing allocation (e.g. in a LPA policy document), but consistent data on this for the sample is not available.

The ‘planning period’

Measured from the validation date of the first application for the proposed development (be that an outline, full or hybrid application). The end date is the decision date of the first detailed application which permits the development of dwellings on site (this may be a full or hybrid application or the first reserved matters approval which includes details for housing). A measurement based on a detailed ‘consent’ was considered reasonable and proportionate milestone for ‘planning’ in the context of this research.

The ‘planning to delivery period’

Includes the discharge of any pre-commencement and any opening up works required to deliver the site. It finishes on completion of the first dwelling.

The date of the ‘first housing completion’

On site (the month and year) is used where the data is available. However, in most instances the monitoring year of the first completion is all that is available and in these cases a mid- point of the monitoring period (1st October, falling halfway between 1st April and the Due to the varying ages following 31st March) is used. of the assessed sites, the implementation of some schemes was more advanced than others and, as a function of the desk-based nature of the The ‘annual build-out rate’ research and the age of some of the sites assessed, there have been some data Each site is taken or inferred from a number of sources. This includes Annual Monitoring limitations, which means Reports (AMR’s) and other planning evidence base documents produced by local authorities there is not a complete data set for every assessed (see footnote 1), contacting the local planning authority monitoring officers or planners and in site. For example, lead-in a handful of instances obtaining the information from housebuilders. time information prior to submission of planning applications is not available for the vast majority of sites. And because not all of the sites assessed have commenced housing delivery, build-out rate information is not universal. The results are presented

accordingly. tables sites Large 2: Appendix

22 Appendix 2: Large sites tables

Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Ebbsfleet Gravesham/ 15,000 2009/10 127 79 55 50 44 40 60 141 312 Dartford The Hamptons Peterborough 6,320 1997/98 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 290.3 224 224 154 157 71 67 101 34 54 100

Rugby Radio Station Rugby 6,200 N/A

East of Kettering Kettering 5,500 2016/17 43 93

Sherford Plymouth 5,500 2016/17 7 106

Priors Hall Corby 5,200 2011/12 56 21 59 87 170 155 273

Wichelstowe Swindon 4,500 2008/09 158 93 195 64 100 61 44 60 57

Monkton Taunton Deane 4,500 2012/13 22 76 220 191 222 148 Heathfield The Wixams Bedford 4,500 2008/09 8 190 160 138 113 109 109 44 37 47

Cambourne South 4,343 1999/2000 42 361 213 337 620 151 377 267 219 190 162 206 154 151 129 239 201 95 126 Cambridgeshire Eastern Expansion Milton Keynes 4,000 2008/09 154 359 371 114 473 138 Area (Broughton Gate & Brooklands) Locking North Somerset 3,700 2011/12 23 45 97 75 10 21 86 Parklands Stanton Cross Wellingborough 3,650 N/A

Beaulieu Park Chelmsford 3,600 2015/16 40 110 262

Northampton North Daventry 3,500 2017/18 50 SUE Great Western Park South 3,300 2011/12 110 204 232 392 237 274 78 Oxfordshire Oakley Vale Corby 3,100 2001/02 35 89 289 258 346 487 520 233 174 159 107 96 103 51 40 9 70

Kings Hill Tonbridge and 3,024 1996/97 140 140 140 140 140 126 219 104 237 166 281 300 224 93 55 90 84 108 91 74 41 31 Malling North West Cam- Cambridge and 3,000 2016/17 73 bridge South Cambridgeshire West of Havant and Win- 3,000 2009/10 38 71 30 82 112 135 196 241 Waterloo chester Cranbrook East Devon 2,900 2012/13 187 419 356 299 214 241

West of Kempston Bedford 2,760 2010/11 52 102 144 167 124 175 103 93

South of the M4 Wokingham 2,605 2012/13 37 175 56 29 166 419

Winterstoke Village North 2,550 2014/15 132 185 242 161 Somerset Emersons Green East South 2,550 2014/15 274 197 318 280 Gloucestershire Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Land East Icknield Test Valley 2,500 2009/10 184 257 103 181 135 229 146 184 Way South Wokingham 2,490 2013/14 6 104 120 135 118 Wokingham North Wokingham 2,391 2010/11 28 99 23 0 95 112 66 154 Wokingham Broadlands Bridgend 2,309 1999/2000 288 331 307 193 204 156 64 104 91 28 81 50 147 11

Western Bath and North 2,281 2011/12 59 147 93 61 163 154 45 Riverside East Somerset Arborfield Wokingham 2,225 2016/17 57 114 Garrison Charlton Hayes, South 2,200 2010/11 83 87 163 333 281 193 301 168 Northfield Gloucestershire Clay Farm/ Cambridge 2,169 2012/13 16 265 399 153 467 Showground Site (Great Kneighton) Chapelford Urban Warrington 2,144 2004/05 211 214 166 262 224 141 180 183 247 60 160 66 30 Village Ledsham Cheshire West and 2,000 2016/17 41 90 Garden Village Chester Graven Hill Cherwell 1,900 2016/17 1 28

Elvetham Heath Hart 1,869 2000/01 192 300 297 307 287 238 103 139 6

Hunts Grove Stroud 1,750 2010/11 2 87 106 80 58 7 2 22

Dickens Heath Solihull 1,672 1997/98 2 179 196 191 207 88 124 64 249 174 16 96 110 4 0 0 13 10 26 12 96

Red Lodge Forest Heath 1,667 2004/05 65 93 181 79 57 79 61 101 213 101 78 23 75 111

South West Bicester Cherwell 1,631 2011/12 40 107 133 179 210 231 196 (Phase 1 Kingsmere)

Centenary Quay Southampton 1,620 2011/12 102 58 103 137 257 8

Northumberland Park North Tyneside 1,513 2003/04 54 194 171 93 179 100 69 117 96 53 82 64 86

Parc Derwen Bridgend 1,500 2010/11 8 103 134 201 199 197 157 186

Jennet’s Park Bracknell Forest 1,500 2007/08 153 154 145 168 136 179 235 93 37 0 28

Melton Road Rushcliffe 1,500 2016/17 40 126

Great Denham Bedford 1,450 data only 92 150 159 71 122 150 125 211 168 avalibale from 2009/10 Love’s Farm, Huntingdonshire 1,438 2007/08 34 186 336 302 216 60 108 59 85 St Neots South Maldon Garden Malden 1,428 2017/18 1 Suburb Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Bolnore Village Mid Sussex 1,358 2012/13 30 54 88 73 36 124

Park Prewett Hospital Basingstoke and 1,341 1998/99 58 82 37 102 0 0 0 0 0 307 214 219 146 33 34 56 7 30 16 Deane Ashford Ashford 1,300 2005/06 83 0 124 14 64 58 155 103 49 70 67 138 90 Barracks (Repton Park) Oxley Park (East & Milton Keynes 1,300 2004/05 52 166 295 202 115 91 75 163 West) Kempshott Park Basingstoke and 1,252 2000/01 78 310 229 213 281 84 33 24 Deane Holborough Quarry Tonbridge and 1,211 2006/07 85 137 91 47 18 100 59 12 43 64 60 101 Malling Staynor Hall Selby 1,200 2005/06 12 141 115 10 43 62 46 59 79 162 79 34 50

Picket Twenty Test Valley 1,200 2011/12 147 178 180 176 164 145 175

Trumpington Cambridge and 1,200 2012/13 141 143 67 100 94 Meadows South Cambridgeshire Broughton Milton Keynes 1,200 2003/04 114 105 170 409 204 180 18 (Broughton & At- terbury) Orchard Park Cambridge 1,120 2006/07 100 290 148 103 95 56 34 15 75 39 30 2

Velmead Farm Hart 1,112 1989/90 1 104 193 89 101 52 101 113 130 74 102 48 4

Cheeseman’s Green Ashford 1,100 2014/15 59 47 102 157 (Finberry) Zones 3 to 6, Omega Warrington 1,100 2017/18 15 South Boulton moor South 1,058 2014/15 22 96 96 116 Derbyshire Highfields Farm South 1,056 2016/17 141 204 Derbyshire Monksmoor Farm Daventry 1,000 2013/14 6 65 98 128 122

Northampton North of Daventry 1,000 2016/17 108 100 Whitehills SUE Taylors Farm/Sher- Basingstoke and 991 2004/05 56 79 81 86 88 51 143 141 88 91 75 0 12 field Park Deane Queen Elizabeth II Hart 972 2012/13 56 165 110 228 213 96 Barracks Little Staniton Corby 970 2009/10 106 116 74 121 102 93 89 86 26

North of Popley Basingstoke and 951 2007/08 65 57 16 28 0 0 15 118 84 60 Deane Ingress Park Dartford 950 2002/03 184 275 100 74 0 119 0 0

Nar Ouse Millenium Kings Lynn and 900 2007/08 32 77 0 0 0 0 30 22.5 22.5 68 0 Commuity West Norfolk West Park Darlington 893 2004/05 60 104 98 66 69 19 35 10 16 51 35 28 14 42

South Bradwell Great Yarmouth 850 2015/16 60.3 60.3 60.3 Site name Local Planning Site Year of first Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Year Authority size housing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 completion Dwellings per annum

Prospect Place Cardiff 826 2007/08 185 48 0 0 0 0 0 76 170

Abbotswood Test Valley 800 2011/12 30 190 157 114 152 90 20

Dowds Farm Eastleigh 795 2006/07 54 189 187 44 102 47 66 76 30

Land at Popley Fields/ Basingstoke and 751 2006/07 105 172 118 186 126 44 Marnell Park Deane Hungate York 720 2009/10 90 52 11 9 7 187 8

Northside Gateshead 718 1999/2000 46.8 46.8 46.8 46.8 46.8 56 46.8 46.8 46.8 46.8 46.8 16 30 31 33 25 43

Land at West Blyth Northumbeland 705 2008/09 6.25 6.25 6.25 6.25 32 66 51 127 78 90

Rowner Renewal Gosport 700 2010/11 4 100 70 45 89 101 79 97 Project Channels - North Chelmsford 700 2015/16 31 172 110 Chelmsford The Parks, formally Bracknell Forest 697 2006/07 -94 104 88 101 54 47 72 59 94 78 Staff College Staiths South Bank Gateshead 667 2003/04 24 58 44 48

Land south of Northumberland 644 2005/06 18.7 18.7 18.7 18.7 18.7 18.7 18.7 17 24 37 60 57 54 Wansbeck General Hospital Former Pontins Lancaster 626 2006/07 16 22 4 5 Holiday Camp

Ochre Yards Gateshead 606 2004/05 83 68.2 68.2 68.2 68.2 68.2 46 4 52 2

Former Runwell Chelmsford 575 2016/17 91 90 Hospital Land adjoining Man- Trafford 550 N/A chester Ship Canal Pamona Docks Trafford 546 N/A

Thingwall Lane Knowlsey 525 2013/14 79

St. James Village Gateshead 518 2000/01 41.4 41.4 41.4 41.4 41.4 41.4 41.4 41.4 41.4 41.4 14 13 18 15

University Chelmsford 507 2014/15 216 3 Campus Chelmsford Land at Siston Hill South 504 2006/07 77 211 96 63 57 Gloucestershire Land West of Mid Sussex 500 N/A Copthorne Sources for sites also found in the Letwin Review

Arborfield Green (Arborfield Five Year Housing Land Supply Statement and appendix on Strategic Development Locations at 31st March 2018 published 9th October 2018 Garrison) http://www.wokingham.gov.uk/planning-policy/planning-policy-information/evidence-topics/

Ledsham Garden Village Various Housing Land Monitor Reports https://consult.cheshirewestandchester.gov.uk/portal/cwc_ldf/mon/

Great Kneighton (Clay Farm) Partly provided by Cambridgeshire County Council and included in numerous AMR’s https://www.cambridge.gov.uk/annual-monitoring-reports

Trumpington Meadows Included in numerous AMR’s for Cambridge and South Cambridgeshire (site crosses boundaries) https://www.cambridge.gov.uk/annual-monitoring-reports and https://www.scambs.gov.uk/planning/local-plan-and-neighbourhood-planning/ annual-monitoring-report/ Graven Hill Various Annual monitoring reports https://www.cherwell.gov.uk/info/33/planning-policy/370/monitoring-reports South West Bicester Various Annual monitoring reports (Kingsmere Phase 1) https://www.cherwell.gov.uk/info/33/planning-policy/370/monitoring-reports Great Western Park Housing Land Supply Statement April 2018 http://www.southoxon.gov.uk/sites/default/files/30.04.2018%20Housing%20Land%20Supply%20Statement%20FINAL%20(2)%20combined. pdf Ebbsfleet: First phase at Springhead Park and Northfleet South from Gravesham AMR’s 2009/10 to 2012/13

2009-10: 127 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0010/69823/AMR2010.pdf 2010-11: 79 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0010/69814/AMR2011.pdf 2011-12: 55 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0009/92448/Gravesham-Authority-Monitoring-Report-2011-12-May-2013.pdf 2012-13: 50 completions https://www.gravesham.gov.uk/__data/assets/pdf_file/0010/92449/Gravesham-Authority-Monitoring-Report-2012-13-interim-May-2013.pdf 2013/14: 87 dwellings, based on total completions form Gravesham to 2012/13 of 311 and total completions to the start of 2014/15 in the Ebbsfleet Garden City Latest Starts and Completion Figures totalling 398.

2014/15 to Ebbsfleet Garden City Latest Starts and Completion Figures: https://ebbsfleetdc.org.uk/tracking-our-performance/ 2017/18: Appendix 3: Small sites tables

Site Name Local Planning Size Site Name Local Planning Size Site Name Local Planning Size Authority Authority Authority Cookridge Hospital Leeds 495 GCHQ Oakley - Phase 1 Cheltenham 262 Auction Mart South Lakeland 94

Stenson Fields South Derbyshire 487 Hewlett Packard (Land Adjacent Bristol, City of 242 Parcel 4 Gloucester Business Tewkesbury 94 To Romney House) Park Horfield Estate Phase 1 Bristol City 485 128-134 Bridge Road And Nos Windsor and 242 York Road Hambleton 93 Council 1 - 4 Oldfield Road Maidenhead Farnborough Business Park Rushmoor 476 Hoval Ltd North Gate Newark and 196 Land At Green Road - Reading Reading 93 Sherwood College Bickershaw Colliery Wigan 471 Notcutts Nursery, 150 - 152 Cherwell 182 Caistor Road West Lindsey 89 London Road Farington Park, east of Wheelton South Ribble 468 Sellars Farm Stroud 176 The Kylins Northumberland 88 Lane Bleach Green Gateshead 456 Land South of Inervet Campus Off Milton Keynes 176 North East Area Professional Crawley 76 Brickhill Street, Walton, Milton Keynes Centre, Furnace Drive Kingsmead South Milton Keynes 450 Queen Mary School Fylde 169 Land at Willoughbys Bank Northumberland 76 Council New Central Woking Borough 445 London Road/ Adj. St Francis East Hertford- 149 Watermead, Land At Kennel Lane Tewkesbury 72 Council Close shire Land at former Battle Hospital Reading Borough 434 Land off Gallamore Lane West Lindsey 149 Land to the North of Walk Mill Wychavon 71 Council Drive New World House Warrington 426 Doxey Road Stafford 145 Hawthorn Croft (Off Hawthorn West Lindsey 69 Avenue Old Slaughterhouse Site) Radyr Sidings Cardiff 421 Former York Trailers (two schemes Hambleton 145 Land off Crown Lane Wychavon 68 - one Barratt, one DWH) Luneside West Lancaster 403 Bracken Park, Land At Cor- West Lindsey 141 Former Wensleydale School Northumberland 68 ringham Road Woolley Edge Park Wakefield 375 Land at Farnham Hospital Waverley 134 Land at Lintham Drive South Glouces- 68 tershire Former Masons Cerement Works and Mid Suffolk 365 North of Douglas Road South Glouces- 131 Springfield Road South Kesteven 67 Adjoining Ministry of Defence Land tershire Former NCB Workshops (Port- Northumberland 357 Land to the east of Efflinch Lane East Staffordshire 130 Land off Cirencester Rd Stroud 66 land Park) Chatham Street Car Park Reading 307 Land to the rear of Mount Cheshire West 127 Land south of Pinchington Lane West Berkshire 64 Complex Pleasant and Chester Kennet Island Phase 1 - H, M, Reading 303 Primrose Mill Site Ribble Valley 126 Land at Prudhoe Hospital Northumberland 60 T, U1, U2 Land at Dorian Road Bristol, City of 300 Kennet Island Phase 1B - E, F, Reading 125 Oxfordshire County Council Cherwell 60 O & Q Highways Depot Land at Fire Service College, Cotswold 299 Land between Godsey Lane and South Kesteven 120 Clewborough House School Cherwell 60 London Road Towngate East Land at Badsey Road Wychavon 298 Bibby Scientific Ltd Stafford 120 Land at the Beacon, Tilford Road Waverley 59

Land at Brookwood Farm Woking 297 Land west of Birchwood Road Bristol, City of 119 Land to Rear Of 28 - 34 Bedale Hambleton 59 Road Long Marston Storage Depot Stratford-on- 284 Former Bewbush Leisure Centre Crawley 112 Hanwell Fields Development Cherwell 59 Phase 1 Avon Site M & G Sports Ground, Golden Tewkesbury 273 Land south of Station Road East Hertford- 111 Fenton Grange Northumberland 54 Yolk and Middle Farm shire Land at Canons Marsh Bristol, City of 272 Poppy Meadow Stratford-on- 106 Former Downend Lower School South Glouces- 52 Avon tershire Land off Henthorn Road Ribble Valley 270 Weeton Road/Fleetwood Road Fylde 106 Holme Farm, Carleton Road Wakefield 50

Land Between A419 And A417 Cotswold 270 Former York Trailers (two schemes Hambleton 96 Land off Elizabeth Close West Lindsey 50 - one Barratt, one DWH) Hortham Hospital South 270 North East Sandylands South Lakeland 94 Gloucestershire The Lichfields perspective

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Disclaimer This publication has been written in general terms and cannot be relied on to cover specific situations. We recommend that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. Lichfields accepts no duty of care or liability for any loss occasioned to any person acting or refraining from acting as a result of any material in this publication. Lichfields is the trading name of Nathaniel Lichfield & Partners Limited. Registered in England, no.2778116. © Nathaniel Lichfield & Partners Ltd 2020. All rights reserved. lichfields.uk @LichfieldsTT APPENDIX 3 Latest Planning Dwelling Site Application (No. 1) capacity 18/19 19/20 20/21 21/22 22/23 23/24 24/25 25/26 26/27 27/28 28/29 29/30 30/31 31/32 32/33 H22 Land at Village Farm, Birmingham Road 12 066

H20 Land south of Coleshill Road, Ansley Common 450 05050606065605550

H1 - Land at Holly Lane, Atherstone PAP/2014/0542 499 25 25 50 75 75 75 60 60 54

Part of H1 - Durnos Nursery, Holly Lane, Atherstone PAP/2014/0540 121 28 28 28 37

H2 Land to north west of Atherstone off Whittington 1282 107 107 107 107 107 107

H3 Land off Sheepy Road, Atherstone 46 20 26

H15 Land at Church Farm, Baddesley Ensor 47 0101010107 H6 Allotments adjacent to Memorial Park, Coleshill 30 0101010 H16 Land south of Grendon Community Hall 7 7 H17 - Former Sparrowdale School site NEW APPLICATION and Recycling centre Spon Lane GRANTED ON THIS Grendon SITE (PAP/2018/0287 and PAP/2019/0396 - 56units approved 56 25 31 H19 Land between Church Road & Nuneaton Road, Hartshill 400 25 25 50 50 50 50 50 50 50 H24 Land at Manor Farm, Austrey Lane, Newton Regis PAP/2016/0266 30 16

H7 Land to east of Polesworth & Dordon 1969 120 120 120 120 120 120 H13 Land west of Robey's Lane PAP/2018/0755 1270 50 107 107 107 107 107 107 107 107 107 PAP/2019/0022 H25 - Land south of Shuttington Outline Granted - Village Hall 27/05/2020 24 12 12 PAP/2017/0202 (22/11/2018) and H26 - land north of Orton Road, PAP/2016/0280 Warton (28/06/2019) 128 0404444 H21 Former School redevelopment site, Attleborough Lane/Vicarage Lane, Water Orton 48 24 24 H14 Site at Lindridge Road adj Langley SUE 141 41 50 50 H28 - Land south of Islington Farm, Wood End 28 028 TOTALS 6588 0 53 59 65 165 222 355 359 539 553 540 545 513 460 4428 1st Phase 2nd A5 Phase A5

Pegasus Options 2 Housing Supply Table as follows;

Year - Plan Period 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 Sub Total Totals Completions (net) 75 38 119 223 251 363 203 298 1570 1570 Windfall Allowance 60 60 60 60 60 60 60 60 60 60 60 660 660 Planning Permissions 0 132 328 414 282 105 60 20 1341 1301 -3% minus lapse rate (excluding 2020/21) New Options 2 Allocations Trajectory - Annual Totals Within Plan Period 0 535965165222 355 359 539 553 540 545 513 460 4428 4428

Annual Totals Within Plan Period 75 38 119 223 251 363 203 298 132 381 473 407 330 342 435 419 599 613 600 605 573 520 7999 7959 1st Phase 2nd A5 Phase A5 RED TEXT HIGHLIGHTS PEGASUS CHANGES TO NWBC26C TRAJECTORY ALP24

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Forward Planning Team Senior Planning Policy Officer 05th October 2020 North Warwickshire Borough Council The Council House 086 MR 051020 NWBC South Street Atherstone Warwickshire CV9 1DE

Email: [email protected]

Dear Sir / Madam

DRAFT NORTH WARWICKSHIRE LOCAL PLAN ADDITIONAL DOCUMENTS CONSULTAION

I write on behalf of my clients, Ciel Properties Holdings Ltd (CPH), in respect of the above consultation.

Local Plan Progress CPH have supported the preparation of the Local Plan and its intention to facilitate appropriate and sustainable development to address the identified development needs in the plan period in the Borough and the wider area. It is understood that the examination of the Local Plan has been unavoidably delayed, but now that there is clarity in respect of the deliverability of the key infrastructure required to support the spatial strategy, CPH would very much welcome the swift progression of the Local Plan through the remaining examination process and to adoption in order to allow the implementation of that strategy.

Development Strategy MM34 (& MM71) in the draft schedule of Main Modifications (NWBC20E) now ensures that there is a clear commitment in Policy LP6 to the provision of the actual quantum of development that is required to address the identified needs in the Borough in the plan period and address unmet needs in the wider area. That is welcomed by CPH.

The proposed modification to Policy LP7 Housing Development (MM36) is noted. However, as a consequence the Policy would not provide the clarity required by the NPPF for either the developer or the decision maker in terms of what is actually required and how a proposal would be judged in the development management process. I would, therefore, refer you to the original duly made representations submitted on behalf of CPH in respect of this policy.

Whilst a modification to Policy LP9 Affordable Housing is proposed (MM37), the Borough Council will be aware of the Government’s proposed changes the planning system in respect of the provision of affordable housing that will have a direct bearing on the requirements set out in this policy. Whilst those changes have not yet been confirmed the policy wording should at least recognise that a change in approach will undoubtedly be required in due course, notably in the type and mix of affordable housing to be provided.

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Policy LP39 and Site H14: Site at Lindridge Road The Borough Council will be aware that CPH have a controlling interest in the site to the north of Lindridge Road, that is proposed to be removed from the Green Belt and allocated for residential development in the Draft Local Plan (Policy LP39 Site H14).

A number of the additional consultation documents (e.g. Ad45 Local Plan Additional Sustainability Appraisal Update) highlight the suitability of the proposed allocation site in that respect and its valuable role as part of a “portfolio” of deliverable development sites that will facilitate a continual supply of both market and affordable housing within a sustainable spatial strategy. The site does not contain any significant environmental constraints that cannot be appropriately mitigated, notably through the scheme design (which the SA does not consider and would further improve the site’s “score”), and is ideally placed to meet the Borough’s identified development needs and/or, given its relationship with Birmingham city and its proposed expansion, the unmet needs arising in the city.

The draft schedule of Main Modifications includes modification MM91 that identifies a proposed amendment to the site allocation policy to address a concern raised by the Environment Agency in relation to a small part of the site being located within the floodplain of the watercourse that borders the site. It is, however, apparent from the subsequent documentation (AD51A, AD51B & AD54) that there is only a relatively minor flood risk and that can be appropriately addressed by ensuring that the built development within the site is set back from the watercourse. That clearly does not affect the overall suitability of the site as a development allocation.

Indeed, the Masterplan Document submitted to the Borough Council highlights how this matter would be appropriately addressed through the scheme design to arrange the built form outside of the floodplain and the provision of SUDS features. Moreover, the Masterplan document also confirms that with this approach the capacity of the site would be circa 140 dwellings as set out in the draft Local Plan.

Therefore, MM91 is not objected to in principle, but the proposed text suggests that the extents of the allocation is indicative and based on the EA flood zones until such time as more detailed FRA modelling becomes available. That is a somewhat unclear position, and it would be simpler to clearly define the full extent of the allocation site (built development and associated green infrastructure) to be removed from the Green Belt using the natural boundaries of the site. A provision can then be added to the policy that requires the built development to be located outside of the floodplain. The matter would then be appropriately addressed through the normal development management process.

Moreover, there remains a lack of clarity in relation to the revised Green Belt boundaries in the Borough as shown on the Proposals Map. It has previously been highlighted on a number of occasions that despite H14 being proposed to be removed from the Green Belt and allocated for development under Policy LP39, the Site H14 is also shown as being located within the Green Belt on the Proposals Map. It is assumed that this is an error, but it clearly has potential to create confusion in relation to the status of the site and its future role in meeting the identified development needs in the Borough.

The draft schedule of Main Modifications also includes modification MMX in relation to the site. Notwithstanding the comments made in the duly made representations in relation to the relationship between Site H14 and the Langley Sustainable Urban Extension (in Birmingham city), and the required clarity in the wording of the first bullet point in Policy H14 in that respect, MMX simply highlights the physical relationship between the two sites and is not objected to.

I trust that the above comments are clear, but should you have any queries in respect of the matters raised, then please do not hesitate to contact me.

Yours faithfully

Mark Rose Director

ALP25

LAND AT TAMWORTH ROAD

NORTH WARWICKSHIRE LOCAL PLAN: POTENTIAL MODIFICATIONS CONSULTATION

REPRESENTATIONS ON BEHALF OF TAYLOR WIMPEY UK LIMITED

JBB8456.C7412 07 October 2020

North Warwickshire Local Plan: PMMs Consultation Representations on behalf of Taylor Wimpey UK Ltd

rpsgroup.com

REPORT

Document status

Version Purpose of document Authored by Reviewed by Approved by Date

North Warwickshire Local Plan: Darren Oakley/ Cameron Austin- V1 07/10/20 PMMs Consultation. Alasdair Thorne Fell

This report was prepared by RPS Consulting Services Ltd (‘RPS’) within the terms of its engagement and in direct response to a scope of services. This report is strictly limited to the purpose and the facts and matters stated in it and does not apply directly or indirectly and must not be used for any other application, purpose, use or matter. In preparing the report, RPS may have relied upon information provided to it at the time by other parties. RPS accepts no responsibility as to the accuracy or completeness of information provided by those parties at the time of preparing the report. The report does not take into account any changes in information that may have occurred since the publication of the report. If the information relied upon is subsequently determined to be false, inaccurate or incomplete then it is possible that the observations and conclusions expressed in the report may have changed. RPS does not warrant the contents of this report and shall not assume any responsibility or liability for loss whatsoever to any third party caused by, related to or arising out of any use or reliance on the report howsoever. No part of this report, its attachments or appendices may be reproduced by any process without the written consent of RPS. All enquiries should be directed to RPS.

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Contents 1 INTRODUCTION ...... 2 2 THE STRATEGIC GAP ...... 3 3 HOUSING TRAJECTORY & LAND SUPPLY ...... 4 4 SITE SELECTION PROCESS ...... 8 5 NEED FOR GREATER FLEXIBILITY ...... 10 6 PROPOSALS - LAND AT TAMWORTH ROAD ...... 12 7 CONCLUSIONS ...... 15

Appendices Appendix 1 Housing Allocation Delivery Assessment:

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1 INTRODUCTION RPS is instructed by Taylor Wimpey UK Limited (”TW”) to represent their interests in relation to the North Warwickshire Local Plan (“NWLP”), and to formally respond to the “Potential Main Modifications Consultation” (“PMM”) on their behalf.

Structure of Report This submission is structured to provide a specific response to relevant PMMs [set out schedule NWBC20E] proposed by North Warwickshire Borough Council (“the Council”), along with additional representations in support of those specific responses. The report structure is as follows: • Section 1: Introduction; • Section 2: Representations in support of omission site Land at Tamworth Road (SHLAA ref: PB0303) (‘the Site’); • Section 3: Representations in support of changes to Policy LP5 (Meaningful Gap); • Section 4: Representations critiquing the Council’s proposed changes to the housing trajectory and housing land supply position; • Section 5: Representations on the proposed resolution of issues relating to the site selection process; • Section 6: Representations advocating for more flexibility as part of the PMM process; and • Section 7: Conclusions This statement of representations provides a response to the PMM’s Consultation on behalf of TW as an input to assist the Inspector in the next round of Examination hearings to be held later in 2020. RPS would like to be involved in future hearing sessions, and welcome the invitation to participate, based on the information submitted in this statement. In summary, whilst RPS welcomes the proposed changes to certain parts of the Plan, namely Policy LP5, RPS’ view is that there remain issues unresolved soundness issues related to the supply of housing land. The supply proposed, and modified, by the Council remains undeliverable in the Plan period due the heavy reliance on a cache of large-scale allocations. Whilst RPS do not dispute deliverability of many of these sites, many are reliant on the completion of strategic infrastructure before they can be unlocked, a process which has frustrated delivery to date and the position still remains somewhat opaque. As a consequence, much of the Council’s supply is rear loaded and there is concern that the Plan will simply not meet their housing requirement within the plan period. The position of RPS and TW is that greater emphasis is needed on short term delivery from robust and reliable sources of supply, that can ‘fill the gap’ until the strategic sites start delivering – which we find will be beyond the current plan period.

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2 THE STRATEGIC GAP

PMM25 PMM25 presents a number of modifications to Policy LP5 in relation to the Local Plan approach to dealing with development proposals on land designated within the defined gap between Polesworth, Dordon and Tamworth settlements. Under this modification, the Council proposes the renaming of the policy from its original title of ‘Meaningful Gap’ to ‘Strategic Gap’, as well as proposing the removal of the third limb of the policy. The third limb states (as submitted): “All new development within the gap should be small in scale and not intrude visually into the gap or physically reduce the size of the gap.” Subsequently, a new third limb of the policy is proposed, which states: “Development should not significantly reduce the visual separation between Polesworth with Dordon, and Tamworth.” The second limb of the policy remains as drafted and continues to make reference to the need to “maintain a meaningful gap”. This wording should be amended to reflect the changes to limb one and the policy name. In response, RPS remains of the opinion that the area of North Warwickshire located between Tamworth built-up area, the M42 and south of the B5000, and defined as part of the Meaningful Gap in the submitted Plan, is not adequately justified. Nonetheless, the proposed modification would allow for development of an appropriate scale and design to take place, subject to it addressing visual separation between the named settlements. This represents and improvement on the previous wording of the policy, which sought to effectively restate (unjustifiably) the overly restrictive policy limitation on development at this location. Therefore, in terms of the policy wording set out in the modification, RPS is broadly supportive. However, there appears to be an omission from the schedule of proposed main modification issued by NWDC that requires attention. This is in relation to paragraph 7.32 of the NWLP Regulation 19 document, which states, “In order to retain the separate identity of these settlements, new development should not visually or physically reduce the size of this gap.” [emphasis added] The wording of this paragraph is now not consistent with the wording under PMM25. Furthermore, the wording of this paragraph is also, arguably, a form of policy wording in that it seeks to influence the location of development in the area by way of a criterion, but it is set out in the reasoned justification. Consequently, the paragraph should either be modified to be made consistent with it or, ideally, deleted entirely. Such a modification is entirely reasonable to make as it merely represents a ‘consequential’, though necessary, modification to the submitted Plan.

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3 HOUSING TRAJECTORY & LAND SUPPLY

North Warwickshire Housing Delivery The NWLP was submitted for Examination more than 2 years ago in March 2018 and the Plan has continued to be delayed as a result of issues associated with awaiting the announcement of the Government Housing Infrastructure Fund (”HIF”). The HIF funding is necessary to deliver the required infrastructure associated with a number of significant housing allocations proposed within the Local Plan. The funding remains uncertain and is required to facilitate works on the A5 upon which the plan relies. As the Local Plan continues to be delayed at Examination, the Council’s housing delivery has been amended to attempt to continue to meet the housing requirement set within the plan but in an increasingly small timeframe. RPS has seen very little progress in the delivery of the proposed strategic allocations, despite a number of live planning applicaitons submitted, a factor which will have no doubt been frustrated further following the impacts o Covid-19 in Q2/Q3 of 2020. A number of strategic allocations meet a significant amount of the Council’s housing requirement and cannot progress without the adoption of the Local Plan and HIF funding. Figure 1 clearly demonstrates that within the submitted Local Plan the Council envisaged delivery to increase post 2021 and then remain fairly stable until the end of the plan period in 2033. Both options in NWBC26 reflect much lower delivery rates until 2024, this effectively pushes delivery back towards the end of the plan period and provides less flexibility and certainty to the level of delivery within the plan period. This approach delivers the numbers required to meet the housing requirement but also allows the allocations to hold the local plan to ransom in regard to any further delays. RPS does not consider that it is appropriate to ’push back the problems’ for a review of the NWLP and firmer commitments should be made now. The Council are now in a position where an increase in flexibility is needed in the short term to facilitate housing delivery while the planning and infrastructure issues are resolved on the strategic allocations. The easiest and most effective means of increasing flexibility in the short term is by allocating an increased number of small and medium sized sustainable schemes.

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Figure 1: Housing Trajectory comparison between the Submitted Local Plan and options set out in NWBC26

900

800

700

600

500

400

300

Dwellings Dwellings Annum Per 200

100

0

Submitted Local Plan NWBC26 Options 1 NWBC26 Options 2

MM71 & MM72 These modifications set out a revised table for the overall housing land provision (Table 7) needed to meet the housing requirement of 9,598 dwellings (which itself remains unchanged). RPS notes that the ‘residual’ supply to be identified through additional allocations, totals 6,067 dwellings. In terms of the supply of sites to meet the residual, MM72 now proposes a total allocation of 6,260 dwellings, an over-supply of just 3%. In fact, the Council’s assumed delivery set out in NWBC26C when removing housing allocations identified in MM72 does not reach this figure, and totals 6,050 dwellings. The published schedule of modifications also refers to a figure of 6,574 dwellings under the category of ‘allocation’ in an unnamed table (page 55 refers), which would increase the ‘gross margin’ to 8.5%, compared to the minimum allocation required (6,067). On this basis, RPS has concerns that the level of flexibility (between 3% to 8.5%) currently built into the Plan, under Policy LP39, will be insufficient to ensure that the overall housing requirement will be achieved over the plan period. This is particularly significant in light of the Council’s proposal for a ‘stepped’ housing trajectory (currently presented only as options at this point) which will require a substantial uplift in delivery compared to recent completion rates in the Borough, from the mid-2020s onwards to over 700 dwellings per annum. RPS note that of the 6,260 dwellings set out in revised Policy LP39 (MM72), a total of 5,933 dwellings are on sites of over 400 dwellings. This equates to 95% of the total residual allocations, with the remaining 5% coming from small sites (less than 100 dwellings). There is only one site now allocated for development in the Plan for between 50 and 150 dwellings (site H14). Furthermore, not only is the Plan dependent on a relatively small number of large urban extensions to deliver the homes it, and its neighbours, need the delivery of these sites is largely

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predicated on a significant boost in local and strategic infrastructure to facilitate their development. In addition, research carried out by Lichfields (‘Start to Finish – Second Edition, February 2020) found that large schemes, of over 500 dwellings, that benefited from outline consent still took over three years to deliver the first home, whilst outline applications that had only been validated took on average between 5 to 8.4 years for the first to be built. On this basis, such sites would not make any contribution to new completions for at least five years, and potentially much longer. The Council’s own evidence base for lead in times set out in NWBC24B Appendix I constitutes 54 sites with only 2 larger than 100 dwellings in capacity and an overall average site size of 30 dwellings. It is unrealistic to base the delivery of strategic allocations on a limited number of non-strategic sites and therefore there is a need for caution in the Council’s assumptions. For these reasons, RPS considers that if the large strategic allocations are delayed, for example because of infrastructure delays or site-specific factors, then there is a clear risk that the annual delivery rates needed to keep the plan on course will not be achieved or maintained without a sufficient mix of supply, in particular a greater supply of smaller non-strategic sites. In these circumstances, RPS would suggest that a flexibility allowance the region of 15-20% would be reasonable and should be applied over above the basic residual allocation figure of 6,067. This would increase the amount of allocated land to between 6,977 to 7,280 dwellings, an uplift ranging from 910 to 1,213 dwellings. RPS suggest that he difference should comprise sites of up to 100-150 dwellings to ensure a good mix. Consequently, it is RPS’s contention that the most effective means of increasing the rate of growth in the short-term, and to assist the Council in its objective of increasing and maintaining delivery rates over the medium-term, is to increase the range and location of sites allocated in the Plan. A review of the Council’s assumed delivery rates for the allocations identified in MM72 has been undertaken and included in Appendix 1. Overall, the Council are judged as being overly optimistic in their assumed delivery with significantly differences presented in the evidence base documents NWBC25 and NWBC26C. This is due, in part, to a realignment of growth to account for the impact of the infrastructure upgrades which will be ‘unlocked’ by funding from central Government. Although there has been a commitment for funding, the exact details of how the funds will be spent and the details will need to be presented by the Council. What is clear from the change in the published position between NWBC25 and NWBC26. The totals identified in Table 1 demonstrate that when MM72 is taken into account the Council’s assumed delivery for allocations in NWBC25 is 5,575 which increased in NWBC26C to 6,050 dwellings but a more realistic assessment results in a much lower number likely being delivered up to 2033 at 4,746 dwellings. This leaves the Council in a significant position where they are potentially unable to meet the requirements of the plan as a whole, but also maintain the required levels of housing delivery year on year within the Borough. The Council have assumed a very short timeframe from when the plan is expected to be adopted and first delivery on a number of large allocations which do not benefit from any existing planning application. The TW trajectories reflect a more realistic lead in time and build out rates. The Council are expected to achieve delivery above 600 dwellings per annum from allocations but not until later in the plan period than the trajectories set out in NWBC26B.

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Table 1: Overall Delivery of Allocations within the Plan Period

18/ 19/ 20/ 21/ 22/ 23/ 24/ 25/ 26/ 27/ 28/ 29/ 30/ 31/ 32/ Total

19 20 21 22 23 24 25 26 27 28 29 30 31 32 33

NWBC25 0 49 68 68 100 246 516 527 564 547 571 590 597 566 566 5,575

NWBC26C 0 0 28 53 85 240 502 630 702 660 694 684 716 630 426 6,050

RPS 0 0 0 0 12 76 190 293 430 546 634 624 641 650 650 4,746

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4 SITE SELECTION PROCESS

MM9, MM65, MM66, and MM67 These modifications have been prepared in response to the significant objections raised by Environment Agency (EA) to the Plan, in particular concerns with how flood risk has been accounted for in the site selection process which identify a number of proposed housing allocations in area vulnerable to flooding. As a result, the Inspector has sought clarification as to how the sequential test in NPPF (2012) (paragraph 100 refers) has informed the site selection process [INSP18 para 15]. To inform the main modifications seeking to resolve the EA’s objections, the Council commissioned AECOM to prepare updated evidence titled North Warwickshire Site Specific Flood Risk Technical Note dated March 2019 [AD51A]. Comments were then provided to the Council by EA in response to this technical note, dated 9th April 2019 [AD51B]. Concurrent with this, the Council produced a response to the Inspector’s note INSP18 titled Atherstone Local Plan Allocations Sequential Test 2019 [NWBC24B, Appendix D]. Again, the EA provided its response to this draft report, dated 28th August 2019 [NWBC24B, Appendix E]. In addition, the Council has also issued a supplementary document [AD54] however it is not entirely clear what the purpose of this information is or how it is intended to assist in the examination of the Plan. In light of this documentation, RPS has a number of concerns it wishes to raise in the context of the main modification that are proposed. Firstly, none of the proposed main modifications explain why sites located at higher risk of flooding (either Flood Zone 2 or 3) have been selected in preference to those alternatives that lie in areas at the lowest risk of flooding (Flood Zone 1), including land at Tamworth Road. Nor do they refer to any great extent to the updated evidence that it has prepared as a basis for those modifications. This is important because it is not possible to understand why those site have been selected ahead of other alternatives without a comprehensive assessment of all available site options in terms of their risk of flooding now or in the future. Secondly, it would appear from the EA’s responses to the updated evidence, referred to above, that significant concerns remain with the technical provenance of the Council’s evidence as a basis for their justification for the sites that were selected for allocation. Thirdly, the evidence published by the Council [AD51A] appears to be a draft report and not a final version. RPS assumes that this is due to the level of objections raised to it by the EA, which appear to remain unresolved at this point. On this basis, RPS does not consider there to be sufficient evidence to justify the selection of sites that lie in areas of higher risk of flooding as opposed to alternative sites at lower risk.

MM73 This modification relates to a number of reserve sites identified in the Plan, currently located outside settlement boundaries, which would be brought forward in the event the Council were unable to demonstrate a five-year supply of deliverable land. RPS notes that the proposed modification seeks to insert an additional site, named Atherstone Football Ground (ref. RH3). RPS has concern with the inclusion of this site, for two reasons.

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Firstly, this site has a capacity of less than 50 dwellings and therefore would not assist in achieving a more broadly-based mix of sites advocated under our representations to MM72. Secondly, site RH3 has significant flood risk constraints, as stated in MM73. However, despite its selection as a reserve site there is no justification for its selection based on the Council’s updated sequential test analysis [NWBC24B, Appendix D]. This is because there is no reference to the any analysis of the site anywhere in this evidence document. RPS welcomes a more informed discussion of reserve sites which are capable of assisting the plan, which should be evidenced robustly, with due consideration of reasonable alternatives.

MM76 and MM77 These proposed modifications relate to two strategic allocations, totalling 1,910 dwellings between them (H1- 530 dwellings; H2 – 1,280 dwellings), which represents 31% of the residual allocation (6,067). Both the modifications seek to insert duplicate, additional text into the respective policies that will require a ‘Level 3 Flood Risk Assessment’ to be undertaken prior to consent being issued. RPS assume that this will need to be agreed by Environment Agency before any recommendation for consent can be taken to the Council’s Local Planning Committee. In addition, the modification also accepts that the results of the FRA could impact on the capacity of the sites, which could reduce the total number of dwellings that could be delivered on these allocations. RPS wish to point out that it is a requirement of the NPPF (paragraph 102) that where development (either as planning applications or site allocations) is located in areas at higher risk of flooding, a site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. Consequently, RPS consider that there is insufficient evidence to demonstrate that both these sites, if allocated, will deliver development that is safe and without the risk of increasing flood risk elsewhere, contrary to the NPPF. Until such time as the evidence is not available to meet the requirements of national policy, these sites should not be allocated in the Plan. On this basis, the modifications as drafted do not adequately address the soundness concerns raised by objectors and do not adequately address the Inspectors additional requests for clarification on flood matters (INSP18).

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5 NEED FOR GREATER FLEXIBILITY

MM7 This modification proposes changes to the supporting text (final two sentences) under the section dealing with duty to cooperate. However, the MM is actually related to the circumstances that might trigger a review of the local plan, in particular circumstances related to changes in provision of infrastructure based on future ‘work’ yet to be undertaken to support the delivery of the Plan. Based on the wording as drafted, the Council remains wedded to the ‘early review’ scenario as the most appropriate means to address these issues. This approach therefore goes to heart of how flexible the Plan is likely to be in response to future changing circumstances were they to occur. In response, RPS does not support the proposed the modification, in particular the final two sentences of MM7. As currently drafted, the wording is vague and does not adequately define the type or nature of those circumstances that would trigger an early review beyond, nor does it define what the actions are that might be needed to address such circumstance, instead simply referring to where a ‘meaningful change in provision is needed’. On this basis, it is not a positively prepared modification, and thus is not soundly-based. In this regard, the NPPF 2012 states that Plans, “…can be reviewed in whole or in part to respond flexibly to changing circumstances…” (paragraph 153 refers, emphasis added). However, as currently drafted, it is not clear what such responses might be in the context of the NWLP, which is relying heavily on the delivery of a relatively small number of large urban extensions to meet the future needs of the Borough, which in turn is based on a ‘backloading’ approach to delivery from 2025 onwards. Therefore, in addition to clarifying the type and nature of the circumstances that might trigger a plan review, RPS suggest the Plan can go beyond this and take positive action at this point in order to prevent or reduce the risk of such circumstances arising in the first place. This would include the allocation of a broader range of sites, including sites that offer a different scale of development compared to the proposed urban extension sites, and which could be brought forward quickly and with relatively lower impacts on and demands for services and supporting infrastructure. One such site is Land at Tamworth Road, on the edge of Tamworth built-up area

MM8 RPS generally supports this modification, which will result in an increase in the contribution being made by the Borough to the unmet needs of Tamworth, from 500 to 913 homes over the plan period. Nonetheless, the increase is relatively modest given it covers delivery over the next 12 years or so and therefore RPS considers that more can, and should, be done to ensure that the Plan delivers on this commitment. In particular, the Plan should make a greater contribution to the unmet needs of Tamworth or, alternatively, ensure that sufficient flexibility exists through the identification of additional sites contiguous with Tamworth built-up area. In this regard, a viable and deliverable alternative already exists and which has been promoted through the local plan review process, in particular, TW’s interests on Land at Tamworth Road

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(“the Site”). This Site represents a logical extension to Tamworth on land lying with North Warwickshire, and which could be brought forward relatively quickly, given there are no significant physical constraints to delivery of the site. This would therefore assist Tamworth in addressing its shortfall in housing land supply in a timely manner, as well as reducing the reliance in the Plan on larger, strategic urban extension sites that may not be delivered as anticipated.

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6 PROPOSALS - LAND AT TAMWORTH ROAD Omission site – Land at Tamworth Road (Policy LP39) TW has been promoting the omission site Land at Tamworth Road (SHLAA site PB030) throughout the various stages of the NWLP review process, including at the first round of examination hearings, and remains committed to delivering development in this location. It remains our view that development of the Site will not undermine the function of the Strategic Gap if the site were allocated for development in the NWLP. Furthermore, allocating this site would also address the limited flexibility in the supply of sites currently proposed, and would also assist in meeting the clear objective of contributing to the housing shortfall emanating from Tamworth. Unfortunately, to date, the Council has resisted allocating the Site on the basis that it is located within a ‘Meaningful Gap’ between Polesworth and Tamworth settlements (now to be modified to be a ‘Strategic Gap’ under MM25). However, RPS considers that there remain significant problems with the NWLP in terms of the justification and effectiveness of the Plan, and these fundamental concerns have not been adequately addressed through the proposed main modification issued by the Council [NWBC20E). Our detailed concerns with a number of main modifications are set out in subsequent parts of this submission. Nonetheless, RPS would state at this point that our response to proposed modification MM25, which includes the proposed the changes to the wording of the Gap policy (Policy LP5) are broadly welcomed and would allow development of an appropriate scale to come forward in this location provide the function of the Gap can be maintained. Outline Planning Application - 2017 As well as promoting the site through the NWLP process, an outline application was submitted to NWBC on 08 November 2017 for the following on the 6.4ha site and has been assigned the reference PAP/2017/0602: “Outline planning application for residential development up to 150 dwellings, open space, landscaping, drainage features and associated infrastructure. Detailed approval is sought for principal means of access, with all other matters reserved” As part of the submission, a suite of technical documents were provided by the project team appointed by Taylor Wimpey. This included a Planning Statement; Design and Access Statement and a Landscape and Visual Impact Assessment. Approximately 1.8ha of the site is proposed as Public Open Space (POS) accounting for 28% of the development area. A green buffer is proposed surrounding the development creating a defined southern boundary and an area of appropriate buffering to the M42 to the east of the site. The above approach to site development as demonstrated through the technical documents, would therefore help to preserve the meaningful gap, and would not lead to the coalescence of settlements. The submission documents demonstrated that Taylor Wimpey’s land interests at Tamworth Road represents a sustainable location for growth and can be delivered within the next five years to support the Council’s supply of housing land.

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Planning Appeal 2018, & Decision 2019 Around the time of the submission of the NWLP for Examination, an appeal was submitted in February 2018 for non-determination of the outline planning application on Land at Tamworth Road. The appeal decision was subsequently issued over a year later, on 1st April 2019 [AD50]. One of the main issues discussed at the inquiry was whether the proposal would adversely affect the character and function of the planned gap between the settlements of Tamworth and Polesworth (DL, paragraph 8 refers). The DL referred to emerging Policy LP5, finding that this policy restated the Core Strategy policy dealing with the ‘meaningful gap’ (Policy NW19) but also added a further requirement that any development within the gap should be small in scale and not intrude visually into the gap or reduce the size of the gap (paragraph 12 refers). The Inspector acknowledged that whilst the examination of the NWLP had progressed, it still had some way to go before it can be considered for adoption. In the light of evidence of unresolved objections, he considered that the relevant emerging policies can only receive relatively limited weight in this decision (paragraph 13 refers). Therefore, the Inspector determined the appeal against the adopted policy at the time, Policy NW19. It is important to note that the starting point for the Inspector’s decision appeared to rest on the adopted policy approach in NW19, which he considered to be a ‘longstanding policy objective’ of maintaining a ‘physical gap between Polesworth with Dordon and Tamworth’ (paragraph 14 refers). Nonetheless, the Inspector recognised that further development at the edge of Tamworth could be planned as an integral expansion of the town, without seriously affecting its established identity. However, he found the appeal site to be an isolated unplanned extension beyond the existing strong edge to the built-up area provided by Green Lane, but it would not be of such scale or effect that the identity of Tamworth would be significantly altered (paragraph 17 refers). The remainder of the DL commentary on the gap (paragraphs 18-32) focused largely on the physical distance between settlements, whilst discussion on ‘character and identity’ focused on Parcel 7, which is significantly larger and different in character to the site, with very little discussion on the potential impact likely from the site specifically. The DL thus concluded that the appeal proposal would result in a major reduction in the space between settlements, to the extent that there would no longer be an adequate ‘meaningful gap’ and the separate rural identity of Polesworth with Dordon would be weakened. He also stated that the proposal would therefore be contrary to CS Policy NW19. It would also conflict with emerging NWLP Policy LP5, to which reduced weight applies pending adoption of the plan (paragraph 33 refers). Based on the DL findings, it is our opinion that ‘physical distance’ formed the basis for the finding against the appeal site and that this underpinned the perceived inadequacy of the meaningful gap and the weakening of the separate identities of Polesworth and Dordon that would result from the proposal. However, it is now the case that Policy NW19 will be superseded by Policy LP5, and that references to physical gaps are now proposed to be deleted from Policy LP5 and replaced by new text [PMM25] following discussions at the first round of examination hearings.

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Consequently, it is also our opinion that the narrow consideration of development proposals in terms of their physical distance from neighbouring settlements cannot, reasonably, form the principle determining factor in any future decisions in the Gap once the modified Policy LP5 is adopted. On this basis, it is reasonable that a different conclusion could be drawn when assessing the same or similar proposals on Land at Tamworth Road under the new policy, if planned through the NWLP as an integral expansion of Tamworth, without seriously affecting its established identity. RPS therefore do not consider that any significant weight should now be attached to this appeal decision as a consideration of this examination process, given the subsequent changes now proposed to Policy LP5 since the time the appeal decision was issued.

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7 CONCLUSIONS In conclusion, RPS are supportive of MM25 in that the modification towards a ‘strategic gap’ between Polesworth with Dordon and Tamworth improves the previously drafted ‘meaningful gap’ but additional amendments are needed to reflect this amended Policy wording changes within the second limb of the Policy as well as the supportive text. However, RPS do not believe the need for this ‘strategic gap’ is justified within the plan. RPS remain concerned that MM71 & MM72 which set out the Council’s housing supply and Housing Allocations indicate that the Council are unable to meet the housing numbers identified from Allocations within the plan period when assessing their Housing Trajectory (NWBC26C). The Council should apply a higher flexibility allowance in the region of 15-20% above the basic residual allocation figure of 6,067. This would increase the amount of allocated land to between 6,977 to 7,280 dwellings, an uplift ranging from 910 to 1,213 dwellings. RPS suggest that the difference should comprise sites of up to 100-150 dwellings to ensure a good mix and early delivery. It is unclear within the proposed main modifications why sites located at higher risk of flooding (either Flood Zone 2 or 3) have been selected in preference to those alternatives that lie in areas at the lowest risk of flooding (Flood Zone 1), including land at Tamworth Road. The plan should provide for a larger contribution towards the unmet need of Tamworth than is identified in MM8 and ensure that sufficient flexibility exists through the identification of additional sites contiguous with Tamworth built-up area. Therefore, viable and deliverable alternative which already exists and which has been promoted through the local plan review process, in particular Land at Tamworth Road should be allocated, or at the very least considered as a deliverable Reserve Site.

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Appendix 1 Housing Allocation Delivery Assessment

H20 - Land south of Coleshill Road, Ansley Common

The site is allocated for at least 450 dwellings. The Council expect delivery to commence in 2024/25 at 50 dwellings per annum (dpa) as identified in NWBC26C, however the Council identified a different start date of 2026/27 and differing delivery rate within NWBC25 Appendix A. NWBC25 highlights that "Discussions have taken place with landowners and agents as well as WCC and the adjoining LPA – NBBC. These are ongoing. Access issues need to be resolved”. No such comments are identified in NWBC26C. The site does not currently benefit from a planning application and RPS consider that given the Council’s expected adoption date for the Local Plan in early 2021 and the lead in times necessary to submit a planning application as well as start to deliver housing on site a commencement date of 2024/25 is unrealistic for a site of this size. Given that the Council accept that the site access needs to be resolved and it would be realistic to assume that at least 9-months would be necessary for a decision to be reached it would be more realistic to return to the Council’s previous projected timeframe with delivery on site from 2026/27 at 50 dpa. Table A1: H20 Delivery in NWBC25 and NWBC26C

18/ 19/ 20/ 21/ 22/ 23/ 24/ 25/ 26/ 27/ 28/ 29/ 30/ 31/ 32/ 33/ 34/

19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

NWB 50 50 50 60 60 60 60 60 C25

NWB 50 50 50 50 50 50 50 50 50 C26C

RPS 50 50 50 50 50 50 50 50 50

H1 - Land at Holly Lane, Atherstone The site is allocated for around 530 dwellings, with an outline application for 620 dwellings currenting pending (PAP/2014/0542) however this application also covers the area identified as Part of H1 – Durnos Nursery which has a separate planning application for approximately 120 dwellings.

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Table A2 sets out the comparative delivery rates identified by the Council between NWBC25 and NWBC26C, this shows some variation with the years 2023/24 and 2026/27 being increased to 75 dpa in NWBC26C. It is unclear why this change has occurred between the Council’s evidence except that the overall site numbers have increased. RPS propose a more realistic trajectory for the site given the timeframe for the adoption of the Local Plan is to delay delivery until 2023/24 and assume a maximum delivery of 50 dpa.

Table A2: H1 Delivery in NWBC25 and NWBC26C

18/ 19/ 20/ 21/ 22/ 23/ 24/ 25/ 26/ 27/ 28/ 29/ 30/ 31/ 32/ 33/ 34/

19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

NWB 20 50 50 50 50 50 50 50 40 C25

NWB 20 50 75 50 75 50 50 40 45 44 C26C

RPS 20 50 50 50 50 50 50 50 50 50 20

Part of H1 - Durnos Nursery, Holly Lane, Atherstone Durnos Nursery is part of the wider H1 allocation with a detailed planning application for the election of up to 123 dwellings which is currently pending. The site includes a plant nursery which continues to operate. Given the lead in times necessary for delivery to begin the site is not going to delivery in the 2020/21 timeframe, a more reasonable timeframe is for delivery to commence in 2023/24. Table A3: Part of H1 Delivery in NWBC25 and NWBC26C

18/ 19/ 20/ 21/ 22/ 23/ 24/ 25/ 26/ 27/ 28/ 29/ 30/ 31/ 32/ 33/ 34/

19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

NWB 9 28 28 28 28 C25

NWB 28 28 28 37 C26C

RPS 28 28 28 28 11

H2 - Land to north west of Atherstone off Whittington

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The site is allocated for at least 1,280 dwellings and will require the provision of health and education facilities. In addition, as identified in MM77 before the development of the site, an agreed, appropriately staged programme of archaeological recording and mitigation, informed by field evaluation will be required. The Council’s trajectories differ within NWBC25 and NWBC26C with delivery increased in NWBC26C to enable the site to be fully constructed before 2033. The site is not currently supported by any planning application although as part of NWBC25 the Council state; "Discussions have taken place with landowner, agent and Hyas. Background information has been supplied as part of the representations. Additional information is being prepared." Given the projected date of adoption of the Local Plan the Council expect the site to gain full permission and begin delivering significant housing numbers in 2024/25. This amount of time is unrealistic given the complex and strategic nature of the site. When reviewing lead in times the Council’s own evidence demonstrates that in the previous 2 years of data it takes approximately 9 months to reach a decision and this timeframe was based upon much smaller sized planning applications with an average size of 26 dwellings. A more realistic trajectory is set out in Table A4 which indicates that delivery will commence 5 years post adoption of the Local Plan and an even more cautious approach could be argued based upon the timeframes set out in Lichfields Start to Finish report.

Table A4: H2 Delivery in NWBC25 and NWBC26C

18/ 19/ 20/ 21/ 22/ 23/ 24/ 25/ 26/ 27/ 28/ 29/ 30/ 31/ 32/ 33/ 34/

19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

NWB 102 103 103 103 103 153 153 153 153 156 C25

NWB 90 140 150 150 160 170 170 126 126 C26C

RPS 50 100 150 150 150 150 150 150

H19 - Land between Church Road & Nuneaton Road, Hartshill The site is allocated for a minimum of 400 dwellings and requires a Concept and Master Plan agreed with the Borough Council. The site does benefit from a pending outline planning application for 382 dwellings (PAP/2018/0140) and the Council’s expected delivery trajectory varies between NWBC25 and NWBC26C. In the Council’s most recent trajectory (NWBC26C) delivery is expected in 2021/22

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onwards. The site is yet to benefit from an outline planning application approval and a subsequent reserved matters permission will be required before construction can begin on site H19 is unlikely to deliver housing in 2021/22. A more realistic trajectory has been produced by RPS which sets delivery from 2024/25 onwards and delivery in line with the Council’s assumptions. Table A5: H19 Delivery in NWBC25 and NWBC26C

18/ 19/ 20/ 21/ 22/ 23/ 24/ 25/ 26/ 27/ 28/ 29/ 30/ 31/ 32/ 33/ 34/

19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

NWB 20 20 20 20 20 30 30 30 30 30 30 30 30 30 30 C25

NWB 25 25 25 50 25 50 50 50 50 50 C26C

RPS 25 25 25 25 50 50 50 50 50 50

H7 - Land to east of Polesworth & Dordon The site is allocated for a minimum of 2,000 dwellings. The policy requires a Masterplan Framework and Design Guide for the whole site will be prepared by the landowners, in conjunction with and approved by the Council. Additionally, given the scale of the allocation additional facilities are required as part of the development. This includes a primary school, retail and health facilities as well as highways improvements. The Council have significantly amended the delivery of the site between NWBC25 and NWBC26C.

Table A6: H7 Delivery in NWBC25 and NWBC26C

18/ 19/ 20/ 21/ 22/ 23/ 24/ 25/ 26/ 27/ 28/ 29/ 30/ 31/ 32/ 33/ 34/

19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

NWB 20 20 20 20 20 197 197 197 197 197 166 166 166 166 220 C25

NWB 100 175 200 200 200 200 200 200 200 175 119 C26C

RPS 50 100 150 150 150 150 150 150 150

As part of NWBC25 Appendix A the Council provide the following commentary;

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“Housing trajectory agreed and supplied by landowners/agents - Appendix F of DB's Proof on 5 year HLS. Joint evidence is being compiled for the Local Plan examination to provide the Inspector with information and comfort that this site will be delivered as per the trajectory. Infrastructure discussions including funding have been outgoing with a number of organisations including highways - both Highways England and WCC - education and health. Planning application is being progressed and expected to be submitted later this year. Housing trajectory attached as Annexe 1: Delivery of housing expected in at least two locations at the same time. 75 units to the south of Dunns Lane and 75 units on northern part of allocation. Multiple developers therefore expected.” It is unclear within the Council’s evidence why the trajectory agreed and supplied by the landowner and agents has been amended in NWBC26C. However, the front loading of delivery as set out in NWBC25 is judged to be unrealistic given the sites size and phasing likely required. The delivery set out in NWBC26C which increases in the initial years is typical of strategic delivery. TW would advise the Council to take a cautious approach in terms of delivery which should not exceed 150 dpa. The site does not benefit from a planning application at the current time and given the required Design Guide TW does not expect delivery to commence before 2026/27 and result in a reduced number of completions up to 2033 to 900 dwellings as opposed to the Councils expected 1,709 dwellings (NWBC25) or 1,675 dwellings (NWBC26C). H13 - Land west of Robey's Lane The site is allocated for approximately 1,270 dwellings and prior to taking place a Master Plan must be agreed by the Borough Council. The comments included in NWBC25 Appendix A make reference to there being at least 2 developers delivering between 40 and 50 dwellings each. This broadly matches the expected delivery set out in this document. It does not match the delivery identified in NWBC26C which reaches 150 dpa in 2025/26 the third year of delivery.

Table A7: H13 Delivery in NWBC25 and NWBC26C

18/ 19/ 20/ 21/ 22/ 23/ 24/ 25/ 26/ 27/ 28/ 29/ 30/ 31/ 32/ 33/ 34/

19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35

NWB 100 100 107 107 107 107 107 107 107 107 107 C25

NWB 100 100 150 150 150 150 150 160 160 C26C

RPS 50 100 100 150 150 150 150 150 150 120

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The site benefits from a pending outline planning application (PAP/2018/0755) for 1,540 dwellings set out across 6 phases, albeit the approval of the scheme does not appear forthcoming, linked to the delivery of HIF led projects. The sites phasing plan does not set out expected timeframes for delivery but given that Phase A includes 235 dwellings, a primary school, sports pitches and the access roundabout the site has complex elements which will slow the initial delivery rate. Given that the pending application is for outline permission a further reserved matters permission will be required before construction can begin. Given the timescale identified for the adoption of the Local Plan in early 2021 this results in there being only two years before significant delivery is expected. Both the speed and initial delivery rate are judged as optimistic and a more realistic trajectory is set out in Table A7. Overall Conclusion Overall, the Council judgements in relation to the delivery of a number of large housing allocations are overly optimistic, there are significantly differences in their conclusions between their trajectories set out in NWBC25 and NWBC26C. The totals identified in Table A8 demonstrate that when MM72 is taken into account the Council’s assumed delivery for allocations in NWBC25 is 5,575 which increased in NWBC26C to 6,050 but a more realistic assessment results in a much lower number likely being delivered up to 2033 at 4,746 dwellings. This leaves the Council in a significant position where they are potentially unable to meet the requirements of the plan as a whole, but also maintain the required levels of housing delivery year on year within the Borough. The Housing Supply table (MMX) identified below MM75 in NWBC20E includes 6,574 dwellings being supplied by Allocations including the 5% buffer, equivalent to 6,280 dwellings. The Council accept that the housing allocations will not deliver this amount of housing and further measures are required to deliver housing in the short term to reduce this impact. This can be done effectively with an increased provision of housing from small and medium sites within the plan.

Table A8: Overall Delivery of Allocations within the Plan Period

18/ 19/ 20/ 21/ 22/ 23/ 24/ 25/ 26/ 27/ 28/ 29/ 30/ 31/ 32/ Total

19 20 21 22 23 24 25 26 27 28 29 30 31 32 33

NWBC 0 49 68 68 100 246 516 527 564 547 571 590 597 566 566 5575 25

NWBC 0 0 28 53 85 240 502 630 702 660 694 684 716 630 426 6050 26C

RPS 0 0 0 0 12 76 190 293 430 546 634 624 641 650 650 4746

Includes Housing Allocations H6, H14, H15, H16, H21, H22, H24, H25 and H28 as set out in NWBC26C.

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Ms Sue Wilson North Warwickshire Borough Council The Council House Our ref: PL00304224 South Street Atherstone Warwickshire CV9 1DE 7 October 2020

Dear Ms Wilson

NORTH WARWICKSHIRE LOCAL PLAN - ADDITIONAL DOCUMENTS 2020

Thank you for the consultation in respect of the additional information relating to the Inspector's questions and the most recent potential main modifications of July 2020.

In respect of matters raised by Historic England during the submisson stage of the Plan process I can advise that our response focuses on the content of NWBC24B Annex C (NWBC response to INSP18: Justification of allocation of sites with regard to the Historic Environment Assessment and Sustainability Appraisal) and NWBC20E (List of potential main modifications July 2020) in relation to Policies H2, H7, H15 and H24.

Policy H2 - NWBC24B Annex C MM75 and NWBC20E MM77 - Historic England has no concerns in relation to soundness of the proposed main modifications.

Policy H7 - NWBC24B Annex C MM82 and NWBC20E MM84 - Historic England has no concerns in relation to soundness of the proposed main modifications.

Policy H15 - NWBC24B Annex C MM91 and NWBC20E MM93 - Historic England would recommend deleting the second sentence after the bullet point list which refers to harm and clear and convincing justfication on the basis that this would partly duplicate the requirements of the draft Plan's own Policy LP15 and also NPPF requirements. Otherwise, we have no concerns in relation to soundness of the proposed main modifications.

Policy H24 - NWBC24B Annex C MM94 and NWBC20E MM97 - Historic England would recommend replacing the 'undesignated' reference in the second sentence with 'non-designated' in line with subsequent text within the same policy and other housing allocation site policy text. Otherwise we have no concerns in relation to the soundness of the proposed main modifications.

We hope that this information is of use to you at this time. Please do not hesitate to

Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation.

contact me should you have any queries.

Yours sincerely,

Rosamund Worrall

Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation.

ALP27

Forward Planning Team, North Warwickshire Borough Council, The Council House, South Street, Atherstone, Warwickshire, CV9 1DE

7 October 2020

By email [email protected]

Dear Sir,

North Warwickshire Local Plan Examination – Potential Main Modifications

Thank you for the opportunity to comment on the potential Main Modifications Consultation (NWBC 20E) published as part of the above and the documents that have informed that schedule.

Please accept these representations made directly on this occasion by Stoford Developments Ltd, following previous representations made to earlier stages of the Local Plan by our planning consultants Barton Willmore.

Summary

The potential Main Modifications have been encouraging and have been proposed as a means of addressing the shortcomings of the Submission Plan in respect of provision for strategic B8 development.

However, the proposed Modifications in our view do not adequately address

• the failure of work with other authorities under DtC to address positively a matter of acknowledged strategic importance • the failure of the Plan to provide a positive and proactive framework for decision making that facilitates necessary development in appropriate areas including the M6/M42 corridor and Stonebridge area and acknowledges that such development can and should provide Very Special Circumstances for development in the Green Belt • therefore the Plan is at present neither legally compliant nor sound • it is simply unacceptable to allow a third North Warwickshire Local Plan to defer the issue of positive planning for strategic B8 and rely upon directions from an Inspector, or piecemeal planning by appeal.

Stoford Properties Limited. Registered office as above. Registered in England No. 7848231 The Main Modification proposed in 2019 by Stoford, offered a ‘potential fix’, until such time as a comprehensive approach to strategic employment land could be put in place and accepted by the West Midlands Authorities. Unfortunately, NWBC have not taken this opportunity, and have instead opted for a Main Modification that is vague and equivocal. This fails to provide the positive guidance needed by both investors and decision makers.

Introduction

We are aware that this consultation relates to several documents that have been issued and prepared since the last hearing sessions in April 2019. We have focussed on NWBC 20E and referenced evidence published since April 2019, where relevant to the points that we make.

By way of a general point, we do accept that the LPA has prepared Main Modifications that include potential policies and amendments to policies, that have sought to address matters raised in Representations, Statements and at the original hearing sessions. This is welcomed. However, we note that as early as February 2020 (NWBC 25) the Council acknowledged in their letter to the Inspector, the need to

‘address pressures for economic growth and ensure availability of sufficient economic and employment opportunities for potential regeneration or redevelopment and re-use’

and they cited existing industrial estates, retaining existing uses, protecting against redevelopment as part of the solution in addressing these pressures. At that point, corresponding changes should have been alerted to the Inspector and subsequently woven into the amendments (MM35) to include the need for allocating more strategic employment sites or making the policy text more proactive as had been made plain in representations put on behalf of Stoford and others from the start of the Examination. However, neither action was undertaken.

We note the Council’s MM7, where the text advises

“Replace final two sentences with ‘In addition the Borough Council continues to commit to working collaboratively with relevant authorities and bodies to refine the scale and distribution of housing and employment needs within the housing market areas and functional economic market areas in which the Borough falls, the levels that it is appropriate for the Borough to seek to accommodate, and to working collaboratively with infrastructure providers to ensure that any impacts of growth are suitably mitigated. In the event that work identifies that a meaningful change in provision is needed compared to that set out in the Local Plan, an early review will be brought forward to address this. In any event the Council is required by statute to complete a review of the plan every five years, starting from the date of adoption’.”

Unfortunately, ‘continuing to commit’ is not enough, indeed it is no more than a commitment to undertake work required by law. Committing to discussion is not commensurate with action and delivery.

The need to address this strategic matter

Whilst the Council, and other LPAs within the West Midlands have awaited the publication of the second phase of the West Midlands Strategic Employment Sites Study which was commissioned in 2017 (we were last advised this was due for publication in August 2020), the matter of strategic need has not been without comment.

Hams Hall and Birch Coppice (both Regional Logistics Sites) have been successful in delivering strategic-scale employment land, but it is not clear where the next sites are coming from Hams Hall and Birch Coppice are effectively developed (there is one more plot at Hams Hall and the draft allocation for Birch Coppice is very small in size).

It is also notable that the Secretary of State issued a Development Consent Order in May 2020 for the WM Strategic Rail Freight Interchange. It is acknowledged that the DCO is for land outside of NWBC, and that the Market Assessment Area adjoins as opposed to includes, the area of NWBC. However, the Examining Authority’s Report (November 2019) did make a number of observations that related to a wider area, referencing the West Midlands and also, areas of North Warwickshire. It is relevant context to our position on MM35, that we cross reference this Examining Authority Report here.

‘The central location of and excellent motorway network within the West Midlands mean that the vast majority of the UK population can be reached in a 4-hour drive time, making the Region a key focus of demand from logistics companies. The concentration of population also leads to strong demand for sites within or close to the major urban areas which meet the need for ‘last mile’ distribution of goods. In addition to the need for larger units, operators also increasingly need taller buildings to accommodate greater racking capacity for storing goods’ (para 5.3.47)

This point is relevant because it is further evidence of the demand for sites, and the scale of those sites (i.e. larger units, taller buildings), and is essentially why the proposed MM wording presented by Stoford in 2019 (via Barton Willmore) is a necessary amendment to the Plan, and why the MM35 of the Council, does not go far enough.

‘There is strong demand within the West Midlands. Logistics accounts for approximately two thirds of demand but manufacturing is also important. Take up in the Region was 576,200 sq. m in 2016 (a 43% increase on the previous year) and 568,000 sq. m in 2017. The 2018 figure, at 315,900 sq. m was noticeably lower but this reflects the lack of readily available large sites and Brexit uncertainty affecting the manufacturing and automotive sectors.’ (Para 5.3.49) (our underlining)

This second extract from the Examining Authority Report is again relevant to the NWBC position. There is an absence of large readily available sites within the Borough. The Examining Authority Report states with reference to NWBC:

‘Birch Coppice and Hams Hall SRFIs lie outside of the Market Area and have very limited land available for development’ (para 5.3.54) [our underlining]

We are disappointed that the Council continue to fail to accept the lack of supply available; the strength of demand; and do not seek to utilise the geographical strengths (land and linkages) available to them, to address this matter of strategic importance through Policy LP6a. it is simply unacceptable for NWBC Local Plan again, and for a third time, defer the issue of positive provision for strategic B8 development to a future review.

In our view, to suggest that it does so would render the Plan not legally compliant.

New Policy LP6a

We have compared the suggested wording that we put forward in 2019 (via the Programme Officer), that we believe would address our concerns, and could form policy LP6a, with the Council’s proposed wording within MM35, and under each extract, provided our representations for the Inspector’s consideration.

Stoford’s proposed wording (originally to MM39 – in NWBC 20E Main MM35 Wording April 2019) and now applies to MM35 of Examination Document MWBC20E "Where evidence demonstrates an LP 6a – Additional Employment Land immediate need or demand for additional Significant weight will be given in decision taking to employment land (B1, B2 and B8) in North supporting economic growth and productivity, Warwickshire that cannot be met from land particularly where evidence demonstrates an allocated in this plan, the Council will immediate need for employment land, or a certain consider favourably proposals that meet type of employment land, that need or demand, subject to the proposal:

Stoford’s position is that the Proposed MM35 text highlighted above in the right- hand column, is not significantly positive in order to be fit for purpose. It only gives ‘significant weight’ to supporting economic growth, even where evidence demonstrates that there is an immediate need for employment land, or a certain type of employment land.

‘The NPPF states that the planning system should be genuinely plan-led. Succinct and up-to-date plans should provide a positive vision for the future of each area and a framework for addressing housing needs and other economic, social and environmental priorities’ https://www.gov.uk/guidance/local-plans

The proposed wording put forward in April 2019 via Stoford’s Planning Consultants, Barton Willmore is positively framed. It is also ‘plan led’, stating that the policy is triggered where the need cannot be met by land allocated in the Plan. It is not seeking to usurp the Plan or the plan making process.

Stoford’s proposed wording (originally to MM39 – in NWBC 20E Main MM35 Wording April 2019) and now applies to MM35 of Examination Document MWBC20E

· Being located in an area of unmet need or within Area A on Figure 4.10 of the West Midlands demand for industrial/commercial uses, Strategic Employment Sites Study of September 2015 including between junctions 6 and 11 of (or any subsequent iteration or similar strategic study) the M42 and other areas as may be defined which cannot be met via forecast supply or Local Plan within the Phase 2 West Midlands Strategic allocations. Employment Sites Study following its publication; and

It is noted that Figure 4.10 of the West Midlands Strategic Employment Sites Study 2015 (also referenced within the West Midlands Land Commission’s (WMLC’s) Final Report 2015 and Table 47 of the Greater Birmingham HMA Strategic Growth Study 2017 have already earmarked areas of highest demand in spatial terms. Whilst some 5 years have passed since the original WMSESS, the position has not changed in terms of demand i.e. it has not diluted.

Further, the provisions of the Plan need to be more locationally specific to provide certainty for potential investors and decision makers; and to address directly the fact that such locations will be in the Green Belt.

It is therefore without justification, that the Council have failed to acknowledge this and not allocated additional strategic employment sites. The approach taken, rather than allocating those sites, or specifying the location where they will be acceptable (our proposed wording), is one of deferring the matter to another date. It is unclear why the Council have taken this approach. As part of their DtC, they will have details of the final draft of the WMSESS that has been prepared for publication. During this consultation period, through the programme officer, Stoford’s consultants requested details from the Council regarding when this WMSESS might be available, noting that it had been commissioned in 2017 however no update was available. A direct enquiry to Mark Parkinson (Staffordshire County Council and Client Lead for the WMSESS LPAs) advised Stoford’s consultants on the 1 August 2020 that a final draft ‘was with the clients for sign off’. Two months have passed without this Study or its conclusion being released or referenced by the Council.

This approach taken by the Council, of deferring strategic matters, was a key concern raised by the Inspectors for the St Albans Local Plan Examination in September 2020. Paragraph 7 of their letters advises:

“The ‘Plan making’ section of the PPG provides guidance in relation to the duty to cooperate. Paragraph 022 states that strategic policy making authorities are expected to have addressed key strategic matters through effective joint working, and not deferred them or be relying on an Inspector to direct them. It advises, ‘Inspectors will expect to see that strategic policy making authorities have addressed key strategic matters through effective joint working, and not deferred them to subsequent plan updates or are not relying on the inspector to direct them. Where a strategic policy-making authority claims it has reasonably done all that it can to deal with matters but has been unable to secure the cooperation necessary, for example if another authority will not cooperate, or agreements cannot be reached, this should not prevent the authority from submitting a plan for examination.

However, the authority will need to submit comprehensive and robust evidence of the efforts it has made to cooperate and any outcomes achieved; this will be thoroughly tested at the plan examination’. (our emphasis) (Paragraph: 022 Reference ID: 61-022-20190315). We have no evidence of the efforts made.”

The Inspectors concluded at paragraph 15: ‘The Council therefore have two options available to them. The Plan can be withdrawn from examination or we can write our report recommending that it not be adopted because of a failure to discharge the DtC.’

Similar to the St Albans Inspector, Stoford have seen no comprehensive or robust efforts within the Examination Library or the Plan that the matter of strategic employment land has been grasped positively or effectively by the Council. In the absence of not allocating additional sites or committing to allocate sites (our preferred approach), the Council has opted for reliance on the 2015 SESS or a subsequent iteration of it.

Our more positive and effective approach, specifies the corridor where such sites should be located, taking account of the LPAs geography, the strategic highway network and the market signals.

A reliance on Area A (as identified in the 2015 WMSESS) (as the Council have done) is also too broad and contains a significant amount of land which may either not meet the requirements of potential occupiers and/or could be severely undermined by issues such as access and/or highway capacity. If certain parameters are not established from the outset, and the fact that much of the area where necessary development needs to be located is in the Green Belt, it will be difficult to conclude that there are deliverable and developable sites in Area A (for example) to meet the overall need.

Stoford’s proposed wording (originally to MM39 – in NWBC 20E Main MM35 Wording April 2019) and now applies to MM35 of Examination Document MWBC20E Being able to demonstrate suitable access Proposals supporting economic growth and to the strategic highway network and an productivity in that context will be looked upon acceptable impact on the capacity of that favourably provided: network; and (i) access to the strategic highway network · Being accessible or capable of being made is achievable and appropriate; reasonably accessible by a choice of means (ii) (ii) the site is reasonably accessible by a of transport, including sustainable choice of modes of transport; and, transport modes, as a consequence of (iii) (iii) the scheme is otherwise acceptable, planning permission being granted for the taking account of the living conditions of development; and those nearby and with regard to the · Not being unreasonably detrimental to the plan as a whole. amenities of nearby residential properties or the wider environment.

Stoford do not disagree with the principle of the criteria, and indeed mirror these very much within the criteria suggested above (see left hand column). However, one notable difference is firstly, the word’ provided’, listed within the LPAs wording, which carries a weight that is disproportionate to the text preceding it. Secondly, the reference to a location being capable of being made more accessible to public transport, is important. Reliance on existing networks can limit the opportunity and availability of sites, whereas taking a proactive approach of recognising where through development and the critical mass of employees, there exists opportunities to extend bus routes, introduce shuttle buses to key public transport nodes etc, should not be overlooked as is currently the case.

Stoford’s proposed wording (originally to MM39 – in NWBC 20E Main MM35 Wording April 2019) and now applies to MM35 of Examination Document MWBC20E Meeting these criteria will carry significant (No comparable text within Policy LP6a) weight in decision-taking, including the consideration of whether very special

circumstances exist which warrant the granting of planning permission for development in the Green Belt.

The West Midlands Strategic Employment Site Study will become a material consideration in decision making immediately upon its publication; and will inform the timing of and issues needing to be considered by a review of the Local Plan in accordance with paragraph [1.8*] of this Plan.” *update as necessary

Stoford’s key wording in the above is the clear and transparent reference that we believe the policy put forward by the Council, should have. The explicit reference to Green Belt locations within this policy is necessary because of the locations where need and demand arise, the geography of the Borough, and where the relationship between land and strategic highway networks is found.

Perversely, by not referencing the need for this policy to equally apply to Green Belt locations, places the policy as worded by the Council in direct conflict with their Proposed MM49, which refers to “…..Proposals for new development and limited infilling and the partial or complete redevelopment of existing employment land outside of development boundaries will be considered against Policy LP1 and LP2 and should seek in order to retain the rural character, appearance and openness of the countryside throughout the Borough (including in respect of policy LP3, Green Belt).”

If the Council’s proposed MMs stay as per MM49 and MM35, the Council will not be in a position to support the delivery of strategic employment sites that satisfy MM35 (LP6a), because they will by the very scale, massing and nature of their operation, affect the openness and appearance of land where it is within the Green Belt – which serves to be the designation of where the M42/M6 junctions are.

It is clear that MM35 and MM39 as proposed, conflict, and need to be re-worded.

This is not a new phenomena1, but one that the Council at North Warwickshire continues not to address but to postpone to a future Plan Review.

This renders the Submission Plan without appropriate, clear and positive modification, not legally compliant and unsound.

1 The neighbouring LPA area of Nuneaton and Bedworth successfully addressed the need for strategic employment sites and Green Belt release within their Local Plan. The Inspectors Report (April 2019) concludes at para. 248:

‘The Plan contains an employment land trajectory which shows significant take up in the years immediately following plan adoption. There is some doubt about the realism of this although it seems clear that the principal demand is for larger, strategic sites which require Green Belt alterations confirmed on Plan adoption. There is already evidence of positive latent demand for employment land in the Borough as demonstrated by a submitted planning application on site EMP1.’ [our underlining]

We trust that the above points can be considered, and we would welcome the opportunity to discuss these further at the re-opening of the Examination.

Please do not hesitate to contact me if I can be of further assistance.

Yours sincerely,

Jo Russell Planning Director

ALP28

TOWN AND COUNTRY PLANNING ACT 1990

REPRESENTATION RELATING TO THE NORTH

WARWICKSHIRE BOROUGH COUNCIL LOCAL PLAN

‘MAIN MODIFICATIONS AUGUST TO OCTOBER 2020’

PREPARED ON BEHALF OF KNG DEVELOPMENTS LLP

FRAMPTONS TOWN PLANNING

OCTOBER 2020

FRAMPTONS REFRENCE: PF 10054

Representations to North Warwickshire 1 Framptons Response to Main Modifications Town Planning Consultants Prepared on behalf of KNG Developments LLP October 2020 KNG DEVELOPMENTS LLP RESPONSE TO MAIN MODIFICATIONS

Introduction

1.0 Framptons Town Planning act for KNG Developments LLP who own the land identified by the

Submission version of NWBC Local Plan at Kingsbury designated by Policy LP4 as land to be

removed from the Green Belt and safeguarded.

1.1 KNG Developments LLP have participated at the Examination in Public (EiP) and all previous

North Warwickshire Borough Council (NWBC) consultations including the NWBC Core Strategy;

the NWBC Site Allocation Preferred Options Consultation and the NWBC SHLAA Call for Sites

with a view to promoting land to the west of Tamworth Road, Kingsbury as a site suitable for

a residential development.

1.2 This document provides the KNG response to the Main Modifications where the Main

Modifications are relevant to the KNG Developments LLP land interest. Of particular relevance

are documents INSP18, LPA Response to INSP18 and Main Modifications NWBC20E specifically

Main Modification 24 (on page 12).

Response to Main Modifications for Kingsbury

1.3 The historical submissions by KNG Developments LLP advocated the release of land at

Tamworth Road Kingsbury from the Green Belt as the site will deliver sustainable patterns of

development. It is not intended for these submissions to repeat previous points in full in the

interests of brevity, but rather they highlight specific points of direct relevance to the Main

Modifications including the documents listed at para 1.2. above

1.4 KNG Developments supported the Submission Version of the NWBC Local Plan which allocated

land at Tamworth Road Kingsbury as Safeguarded Land to be removed from the Green Belt

pending future review under Policy LP4. The land was debated at the EiP and remains a suitable

development site in terms of it being available and lacking significant constraints.

Representations to North Warwickshire 2 Framptons Response to Main Modifications Town Planning Consultants Prepared on behalf of KNG Developments LLP October 2020 1.5 The site would be more than capable of delivering housing if it were to be removed from the

Green Belt and could make a positive contribution to meeting the housing needs of the

Borough or indeed the housing needs of the local housing market area as stated in the various

previous KNG submissions.

1.6 The KNG position remains that the release of land from the Green Belt as safeguarded land

would not lead to the unrestricted sprawl of a large built up area. (Kingsbury is not a large built

up area for the purposes of the West Midlands Green Belt which contains the spread of the

conurbation). The development will not adversely impact upon the setting and special

character of Kingsbury as a historic town. The release of land at Tamworth Road will not

undermine urban regeneration within Kingsbury. Development at Tamworth Road would not

cause neighbouring towns to merge into one another. In reality the release of Tamworth Road

would not result in actuality, or in perception that Kingsbury had merged into Tamworth or

any other settlement. There would remain a clear open tract of land beyond the extended

urban edge of Kingsbury.

KNG Position on Main Modification 24

1.7 The Main Modifications (NWBC20E) seeks in response to the Inspector’s initial findings

(INSP18) to delete Policy LP4 via Main Modification 24 (Page 12). NWBC has put forward this

modification in response to the Inspector’s comments at Paragraphs 16 and 17 of INSP18:

“16. The Council’s justification for release or safeguarding for potential future development

of land in the Green Belt is related to (i) pressures for growth, (ii) the role of different

settlements, and (iii) site specific circumstances. Those are reasonable considerations.

However, based on all the evidence before me, they do not justify the only area of safeguarded

land being adjacent to Kingsbury via policy LP4”.

Representations to North Warwickshire 3 Framptons Response to Main Modifications Town Planning Consultants Prepared on behalf of KNG Developments LLP October 2020 “17. Kingsbury is a lower order settlement than Coleshill which is also in the Green Belt. It

is surrounded by some land which has been assessed as having a similar contribution towards

the purposes of the Green Belt as around Coleshill.6 There is some ambiguity in the plan in

respect of Coleshill; some land at Coleshill was previously recommended for safeguarding

[AD20A],7 and no safeguarded land is proposed at the other ‘local service centres’ within the

Green Belt of New & Old Arley or Water Orton.8 Therefore for consistency with national policy

either the plan’s approach to safeguarding Green Belt land at Kingsbury should be revised, or

additional land should be safeguarded at other settlements in line with the plan’s settlement

hierarchy.”

1.8 KNG Developments wishes to reiterate that INSP18 is not questioning the wider methodology

of assessing the Green Belt function, the sustainability or suitability of the site at Kingsbury

identified by LP4 or indeed in principle of identifying safeguarded land given the pressures for

development in this local context. Rather the implication is that there is no evidence to suggest

other settlements, higher in the settlement hierarchy and also in the Green Belt with

comparable connectivity to cross border housing, should not also be considered for having

safeguarding allocations as simply identifying one site when others may also be similar and

suitable requires consideration. The Council has not considered additional sites and has

instead gone for the reconsideration of the need for a safeguarding policy at all. Such as

position is not supported by KNG Developments as it fails to plan positively and is not a justified

position in this local context where development pressures are high, involve cross border

issues and a high amount of Green Belt designation applies.

1.9 To justify this stance further the existing urban areas and settlements within the Borough alone

do not have sufficient capacity to deliver the full extent of the Borough’s housing and other

development needs (including commitments to neighbouring authorities) in a sufficiently

Representations to North Warwickshire 4 Framptons Response to Main Modifications Town Planning Consultants Prepared on behalf of KNG Developments LLP October 2020 flexible manner and therefore identifying safeguarded land is a realistic and clearly justifiable

option.

1.10 In North Warwickshire a combination of factors exists, which when collated equates to

exceptional circumstances being demonstrated sufficiently to justify a release of land via

allocation or safeguarding in more than one location (in additional to Kingsbury) from the

Green Belt, which can be summed up as follows: A high housing need; a large extent of Green

Belt (two thirds of the administrative area); Neighbouring Authorities with high housing needs

(Tamworth; Birmingham & Coventry); formal agreement over the need for North Warwickshire

to accommodate neighbouring growth (signed and committed MoU’s); lack of sustainable

brownfield or previously developed sites (SHLAA conclusion); SHLAA evidence that the Green

Belt will be likely to be needed; lack of suitable non-Green Belt sites in locations geographically

suited to meet the needs of neighbouring authorities; available sites which do not score highly

on Green Belt function but do score well in sustainability terms; and available sites that are

deliverable in a technical sense.

1.11 KNG Developments LLP wishes to reiterate that the Council requires a positive long-term

strategy to accommodate growth, which is seen as essential in a Borough that has two thirds

(60%) Green Belt coverage yet still requires a policy framework to enable sufficient flexibility

to respond to changing circumstances and deliver commitments made through recent

Memorandum of Understandings (MoU) with its neighbouring authorities. It submitted that

the approach being tabled via Main Modification 24 is not flexible enough considering

paragraph 153 of the Framework.

1.12 It is submitted that NWBC should review its position to delete LP4 and instead plan positively

for identifying additional sites capable of being allocated, removed from the Green Belt and

designated as safeguarded land. This is of course where the sites can demonstrate they score

appropriately in terms of Green Belt function, are well connected to the settlements they

adjoin and can deliver sustainable patterns of development. Simply deleting the policy is not

Representations to North Warwickshire 5 Framptons Response to Main Modifications Town Planning Consultants Prepared on behalf of KNG Developments LLP October 2020 planning positively as the NWBC, Birmingham City and Tamworth housing needs and indeed

the overall housing needs of the Borough are not going to lessen. By planning positively now,

whilst the Green Belt Review and other documentation collectively is considered to form a

sound evidence base, the Borough can put in place a strategy that enables appropriately

justified growth in the right locations over a more practical and cost-effective timescale.

1.13 KNG Developments would therefore request that the Main Modification 24 being proposed

for Policy LP4 at Page 12 of NWBC20E be re-considered in the interests of planning positively

and to give the NWBC Local Plan greater flexibility to respond to justified sustainable

development pressure. It is more appropriate for the Main Modifications to seek additional

safeguarded sites to bring the policy in line with the Inspector’s comments relating to the LP4

policy than it is to simply delete the safeguarding policy and delay delivery of needed housing

in high demand locations to be frustrated pending the costly full review of the Local Plan and

all the evidence gathering such a process entails.

Conclusions and action sought

1.14 For the reasons stated previously in this document and previous submissions to the NWBC

Local Plan process it remains the KNG Developments LLP position that NWBC should revisit the

safeguarding policy and identify additional sites of comparable planning status to Tamworth

Road Kingsbury.

1.15 In additional to seeking additional sites to Kingsbury the submitted policy could also be made

increasingly sound and usable by making the review mechanism more precise and flexible.

Specifically, it is again recommended that the policy advocate partial review (consistent with

para 153 of the 2012 Framework) rather than complete review in certain circumstances to

enable the safeguarded land (on multiple suitable sites rather than just Tamworth Road

Kingsbury) to be released and respond to changes in circumstances. These could be a five-year

land supply shortfall; cross border housing need from Coventry; cross border housing need

Representations to North Warwickshire 6 Framptons Response to Main Modifications Town Planning Consultants Prepared on behalf of KNG Developments LLP October 2020 from Tamworth; or cross border housing need from the Birmingham conurbation all of which

are possible scenarios for this context that would justify a faster partial review of the plan to

respond to the housing need. The needs if they are proven will in all probability require a rapid

response and by deleting the policy as currently being considered or by leaving the wording as

drafted in the Submission version considered by the EiP the safeguarded site(s) can only be

reviewed via a full review of the Local Plan which will not be flexible or enable the Council to

be able to respond rapidly to need or changes in circumstances.

1.16 In these circumstances it is respectfully submitted that to make the policy align more fully with

Central Government Guidance the wording should be changed to ensure the policy remains in

accordance with Paragraph 153 specifically ‘Each LPA should produce a Plan for its area. This

can be reviewed in whole or in part to respond flexibly to changing circumstances’ and 154

specifically ‘only policies that provide a clear indication of how a decision maker should react

to a development proposal should be included in the plan’.

1.17 To conclude rather than delete LP4 as is currently being considered by MM24 the KNG

recommendation is to retain and modify the Policy once additional sites for safeguarding are

identified and define the scenarios which would justify a partial review to justify one or all of

the safeguarded sites coming forward.

LP4 Safeguarded sites for Potential Future Development

New sites (tbc) including land at Tamworth Road Kingsbury, as identified on the Proposals Map, will be removed from the Green Belt and safeguarded for potential future development needs.

The identified areas will be protected from development other than that which is necessary in relation to the operation of existing uses, change of use to alternative open land uses or temporary uses. All proposals must not prejudice the possibility of long term development on the safeguarded land.

Representations to North Warwickshire 7 Framptons Response to Main Modifications Town Planning Consultants Prepared on behalf of KNG Developments LLP October 2020 The status of the safeguarded site will only change through a review of the local plan or a Partial

Review of the Plan should one or more of the following instances be applicable: a) A proven drop off in the 5-Year Land Supply; b) Cross border housing need from Greater Birmingham HMA; c) Cross border housing need from Tamworth Borough Council; d) Cross border housing need from the Coventry HMA; e) Significant sub-regional scale employment development being permitted in the vicinity generating an additional local housing need; and f) Significant under delivery of Affordable Housing

Framptons

October 2020

Representations to North Warwickshire 8 Framptons Response to Main Modifications Town Planning Consultants Prepared on behalf of KNG Developments LLP October 2020

ALP29

North Warwickshire Local Plan

Potential Main Modifications July 2020

October 2020

North Warwickshire Local Plan Potential Main Modifications Gladman Developments

2 North Warwickshire Local Plan Potential Main Modifications Gladman Developments

CONTENTS

1 Introduction ...... 2 1.1 Context ...... 2 1.2 Plan Making ...... 2 2 North Warwickshire Local Plan Main Modifications ...... 3 2.1 Comments ...... 3

1

North Warwickshire Local Plan Potential Main Modifications Gladman Developments

1 INTRODUCTION

1.1 Context

1.1.1 Gladman welcome the opportunity to comment on the North Warwickshire Local Plan Potential Main Modifications (July 2020).

1.1.2 Gladman Developments specialise in the promotion of strategic land for residential development and associated community infrastructure and has considerable experience in the

development industry. From that experience, we understand the need for the planning system to provide the homes and jobs that are required to meet Central Government’s objectives and the needs of local communities.

1.1.3 Our comments on the Proposed Modifications are contained in Section 2 below and are

intended to be brief. Should further hearing sessions be needed as a result of these changes then Gladman would request to be kept informed of any such sessions.

1.2 Plan Making

1.2.1 The National Planning Policy Framework sets out four tests that must be met for Local Plans

to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:

• Positively Prepared – The Plan should be prepared on a strategy which 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.

• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

• Consistent with National Policy – the plan should enable the delivery of sustainable

development in accordance with the policies in the Framework.

North Warwickshire Local Plan Potential Main Modifications Gladman Developments

2 NORTH WARWICKSHIRE LOCAL PLAN MAIN MODIFICATIONS

2.1 Comments

Main Modification MM7

2.1.1 Gladman support Main Modification 7 which sets out that the Council continues to commit to working collaboratively with relevant authorities, to refine the scale and distribution of housing and employment needs within the Housing Market Area and Functional Economic Market area where the borough falls.

2.1.2 This will be essential to ensure that the needs of both the borough and the unmet needs of the wider market area can be met in full, across the wider HMA. It is also essential moving forward for the future review of the North Warwickshire Local Plan, as the issue of unmet needs is likely to remain a key consideration for the wider HMA that all local plan reviews in

the area will have to grapple with.

Main Modification MM8

2.1.3 Gladman support Main Modification 8 which states that growth will be supported within the borough to provide housing for the Coventry and Warwickshire and the Greater Birmingham

Housing Market Areas.

Main Modification 103

2.1.4 Gladman support Main Modification 103 to insert the words ‘or adjacent to’ into paragraph 5.3 as this reflects the changes made to Policy LP2 through Main Modification 19.

Main Modification 19

2.1.5 Gladman support Main Modification 19 to accept that development directly adjacent to settlement boundaries may be acceptable. This change fully reflects the National Planning

Policy Framework and allows a level of flexibility in the provision of development beyond that

provided for through the allocations.

Main Modification 27

2.1.6 Gladman support the general content of Main Modification 27 which seeks to clearly set out

that the housing requirement for the North Warwickshire Local Plan is 9,598 dwellings across

North Warwickshire Local Plan Potential Main Modifications Gladman Developments

the Plan Period 2011 to 2033. This includes provision for the unmet needs of Tamworth of

some 919 dwellings.

2.1.7 As the total housing requirement for the borough includes the provision for the unmet needs of Tamworth, it is this figure which should be used as the basis for the calculation of the 5-

year housing land supply in North Warwickshire. This approach is clearly in accordance with guidance set out in the National Planning Policy Framework and the Planning Practice Guidance.

2.1.8 However, it is unclear from the changes proposed to paragraph 7.35 whether this is actually

the case. Therefore, for the sake of clarity and in order to ensure that the Local Plan fully reflects the National Planning Policy Framework, additional wording should be inserted into

paragraph 7.35 to clearly set out that the 5 year housing land supply will be calculated on the basis of the full housing requirement, inclusive of the provision made for unmet housing

needs.

2.1.9 This would reflect the changes to Table 7 set out through Main Modification 71 which states that Housing Requirement to 2033 is 9,598 dwellings including a redistribution from the Greater Birmingham HMA and the Coventry and Warwickshire HMA.

ALP30

Forward Planning Team North Warwickshire Borough Council The Council House South Street Atherstone Warwickshire CV9 1DE

6TH October 2020

Ref: NWLP Potential Main Modifications

Dear sir/Madam

Potential Main Modifications – H18 and RH1

Nexus Planning represent the owner of Dairy House Farm, Grendon. Land within the Local Plan policy H18 designation (Dairy House Farm Phase3); together with the majority of the RH 1 reserve allocation; Dairy House Farm Phase 3 and safeguarding route for dualling the A5, is within the ownership of my client.

Land within my clients historic control at Grendon has and is in the process of delivering dwellings at Dairy House Farm Phase 1 (85 dwellings completed) and Dairy House Farm Phase 2 (120 dwellings within 6.75 Ha of the 9 Ha H18 allocation currently under construction).

The landowner is assembling a full professional consultancy team to advise and promote land in his control through the planning process. The land is available and being promoted for residential development together with any enabling infrastructure.

We are keen to work collaboratively with the Local Planning Authority and Warwickshire County Council to deliver the Local Plan strategy, and more specifically, important road infrastructure to complement proposed A5 highway interventions that have recently been secured through government funding.

We appreciate the importance of securing an adopted Local Plan for the area as soon as possible and as such, these representations make suggestions to the Local Planning Authority that could be accommodated without significant further change to the Local Plan.

North Warwickshire Proposed Modification continued

MM72 –H18

This Major Modification seeks to delete Policy H18 on the basis that planning permission has been secured and development has commenced. As such the site becomes a commitment in Table 7 of the Local Plan.

The total land area allocated under H18 comprises 9Ha. The planning application for the H18 allocation (currently being implemented) comprised 120 dwellings within 6.75Ha of the allocated site. The remaining 2.25 Ha within the allocation does not have the benefit of a planning permission and remains in the control of the Dairy House Farm landowner.

It is clear that the original allocation boundary to the east / south east of the site was defined by an established hedgerow and public footpath with pedestrian access to the A5. This provided a strong boundary and facilitated the potential for enhanced cycle and pedestrian permeability to the site. The planning application approved within the policy H18 policy area has been designed and approved to facilitate a future phase of development. This is clear through the positioning of two residential roads within the approved scheme providing notional accesses to the approved site boundary.

It is appreciated that there may be technical highway constraints limiting the number of dwellings served from a single point of access on to Spon Lane. However it should be noted that land within my client’s ownership (including the Dairy Farm Complex and its associated access) lies immediately adjacent to the ‘residual’ H18 land providing one potential solution to the single access capacity constraint.

It is clear that the ‘residual’ 3 Ha of Policy H18 which is proposed to be deleted as an allocation through MM 72 is suitable for development. Consistent with paragraph 47 of the Framework (2012), the residual land is also available now; offers a suitable location for development (by virtue of its allocation); and is achievable, with a realistic prospect that housing will be delivered within 5 years.

When considering the above we object to the proposal to delete policy H18 on the grounds that its deletion is not Justified.

Based upon the approved 120 dwellings within 6.75 Ha of the Policy H18 allocation it is considered that the residual land could accommodate a further 40 - 50 dwellings. This should be reflected in policy.

MM73 – LP39(a) RH1

RH1 is a significant site which the Council accepts is suitable for development by virtue of the site’s allocated, albeit reserve, status. The potential major Modification clarifies that the indicative site capacity is subject to refining once infrastructure requirements, including the safeguarding routes, are known. This change is welcomed as the RH1 site, at gross site area of 40 Ha within my client’s land and 6 ha on adjacent land is likely to have a capacity significantly higher than the identified quantum as set out in the policy. Assuming a third of the site is safeguarded for the by-pass and strategic open space this would still provide an approximate net developable area of 30 Ha which could accommodate 1000 dwellings at 35 dwellings per Ha. Within the context of RH1, it is therefore suggested that the site capacity is clarified as ‘600 - 1000 dwellings’. This avoids any confusion and provides a more ‘positively prepared’ policy wording.

My client’s main concern, however, relates to restriction on bringing the site forward to a point in time when there is a need to maintain and enable supply against the five year land requirement. It is considered that this restriction severely limits certainty, providing no commitment from the Local Planning Authority that the site will be acceptable should a five year housing land supply be maintained. This has implications for both the landowner in terms of investment certainty, but more importantly the local Planning Authority and the County Council in developing successful business case bids to the government for future Housing Investment Fund (HIF) funding and / or bids for government ‘Road Investment Strategy’ (RIS) funding.

North Warwickshire Proposed Modification continued

The Councils’ success in securing Phases 1 and 2 of the improvements to the A5 (NWBC 26) together with the RIS2 (March 2020) funding within the corridor provides an important context for further investment in the corridor. As stated by the Council in NWBC26, ‘the funding of this scheme now lies with the MHCLG who have committed funds of £79.5m to ensure that improvements as outlined in the HIF bid are carried out with further improvements to the A5 being part of RIS3. (My emphasis).

Phase 3 of the improvements to the A5 comprise, inter alia, the Grendon by-pass, a key element of infrastructure to complete the duelling of the A5. Funding for this phase was not sought through the successful HIF bid process due to its potential implementation falling outside of the fund delivery timescale criteria. However, following discussion with Warwickshire County Council we understand that the phase 3 works (Grendon by -pass) together with other schemes in the County, will seek funding through RIS3 for project delivery from 2025-2030, thus potentially aligning this phase with the secured HIF funded phase 1 and 2.

Importantly, in addition to the HIF funding, RIS2 secured funding for A5 improvements between Dodwells to Longshoot, enhancing a short stretch to dual carriageway. The commentary acknowledges that the scheme will need to take into account evolving proposals for the A5 Hinkley to Tamworth (RIS, Investment Plan, The Midlands, p98). The ‘evolving proposals’ relate to the HIF funded schemes referenced above, thus demonstrating a coordinated approach to network intervention. Furthermore, RIS2 designates considerable resources under the ‘Strategic research and development pipeling’ category. This fund is used to investigate the next ‘wave’ of potential projects within the UK network to identify and support future bids as part of the RIS3 programme. Within the Midlands, RIS2 identifies the A5 from Hinckely to Tamworth as a corridor for investigation (RIS2, Strategic research and development pipeline, the Midlands, p114).

From the above it is therefore clear that the government acknowledge the importance of the A5 corridor in this location; have invested to date in its enhancement and have committed additional funds to develop proposals for additional interventions (such as the Grendon by-pass) in order to provide a fully dualled road from Hinkley to Tamworth.

What is, however, important and germane to my client’s proposition that the RH1 site’s ‘uncertainty’ due to the lack of formal allocation may be prejudicial to both my client and the aspirations of the councils can be found in the introductory narrative to the ‘Strategic research and development pipeline’ section of RIS2 which states:

‘New proposals need to consider a wide range of impacts: not only what can be promised with certainty, but also where a proposal has the potential to support wider and more ambitious local plans for development. We will expect STBs to play an active role in articulating the benefits of proposals being examined in their area. We also expect that where a proposal enables significant development nearby, the developer will contribute to the cost of delivering the scheme. There is also potential for funding from other sources to support a developing proposal. Funding contributions will make a significant difference to the likelihood of government choosing to bring forward a proposal to the next stage, and ultimately to commit it as part of the next RIS’. (my emphasis).

Within the context of the above it is clear that bids for funding that support the delivery of development and can secure developer funding towards their implementation can make a ‘significant’ difference to the likelihood of government commitment as part of RIS3.

RH1 is a large site that can deliver significant levels of housing. Furthermore, it can facilitate, through land ownership, a major stretch of the Grendon by-pass as well as providing the potential to make proportional contributions to scheme delivery. However, the current policy references, as stated earlier, clearly state that

North Warwickshire Proposed Modification continued the site can, in the first instance, only be released or bought forward at a point in time where it is needed to support a 5 year land supply – there is simply no certainty, in Local Plan policy, as to whether this will ever happen within the context of this Local Plan. In evolving a business case to the government pursuant to the RIS3 process there can, consequentially, be no certainty that the bid will assist in housing delivery or certainty regards additional developer funding as the policy status is ‘Reserve’.

In my client’s view this weakens the councils’ joint position in terms of developing a fully integrated and cogent route strategy within this area.

The NPPF (2012) is clear at paragraph 47 that ‘ to boost significantly the supply of housing, local planning authorities should:

 ….identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15…

In defining ‘developable’ footnote 12 states that ‘to be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged’.

This objective is reiterated in the current Framework at paragraph 67.

In summary, securing Phase 1 and 2 of the A5 improvement works together with the RIS funding for the A5 and the identified ‘strategic research fund’ in the corridor provides a clear government prioritisation for investment in the area. The Grendon by-pass is a major scheme that will provide ‘the missing link’ on the network. As such there is a more than ‘reasonable prospect’ that the scheme can secure funding subject to the appropriate business case being developed as part of the scheme development and bid process. That business case, as identified above, will be strengthened significantly if the scheme assisted in delivering growth and demonstrated the potential for development contributions towards implementation.

On the basis of the above, my client considers that the ‘Reserve’ status of the site should be amended and the site identified to deliver housing within the last 5 years of the Local Plan period. This would, in our view, both strengthen the potential to secure funding and contribute towards the high levels of annual growth envisaged in the ‘stepped’ housing trajectory.

We would welcome the opportunity to discuss this further with the Council(s) and agree a joint way forward to support the Council’s growth and investment strategy along this important corridor.

Yours sincerely

Roger Tustain Managing Director