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East Riding Local Plan Review Options Document

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East Riding Local Plan Review Options Document Appendix A Your Ref: Contact Officer: Roger Gray Forward Planning Telephone: 01482 612614 East Riding of Yorkshire Council Email: [email protected] County Hall Beverley Date: 20 December 2018 East Riding of Yorkshire HU17 9BA Dear Mr Palmer, East Riding Local Plan 2012 - 2029 – Local Plan Review Options Document. Thank you for consulting Hull City Council inviting comments on the East Riding Local Plan Review Options Document. The Council have the following comments to make: Scale of housing development The Council support the general approach put forward through option C, namely the continuing focus of development in the urban area of Hull as the regional city, including some redistribution of housing requirements between East Riding and Hull, as is the currently adopted approach. Hull’s housing requirement is currently fixed in the adopted Local Plan as 620 per annum. The adopted housing requirement was based on 59 additional dwellings per year being allocated to Hull from the overall HMA requirement figure (i.e. from ERYC) – in addition to evidenced need in Hull of 561 dwellings. The current LHN figure for Hull sits in a range between 226 and 409 when tested within the current standard methodology. PPG stresses that the LHN figure should be a starting point for establishing the housing requirement. Therefore it is not necessarily appropriate to set an option purely based on this. The Council expect that the housing requirement for the city will ultimately be higher than the base LHN figure. A report on the ‘Impact of LPEG proposals on housing need’ prepared as evidence to the Hull Local Plan, in the face of what was then being proposed as the new methodology, suggested a figure of between 519 and 571 per annum would be appropriate to meet identified needs in the city, based on an uplift from a baseline equivalent to the higher of the standard methodology figures. This provides a guide to how the LHN for Hull might be adjusted to provide a requirement should it be reviewed. The same evidence for the Local Plan identified that an uplift on the baseline could lead to a requirement for the East Riding of 1,145. The Hull Local Plan requirement of 620 would allow for approx. 50 dwellings per year to be redistributed to Hull to support the currently agreed strategy between the authorities and accepted by Local Plan Examination Inspectors. This would result in a requirement for the East Riding of 1,095 per annum which would represent a more deliverable range and provide for ambitions to deliver affordable housing1. 1 620 – 571 = 50; 1,145 – 50 = 1,095 Appendix A If this figure were to be used, the equivalent approach between the currently adopted Local Plans for Hull and the East Riding could be retained. Since the East Riding of Yorkshire Local Plan was adopted in 2016 the city has witnessed strong levels of housing completions. Over the last 3 years average delivery has been in excess of 620 houses per annum, while the East Riding of Yorkshire has failed to meet its requirement of 1400. The revised approach proposed by the East Riding of Yorkshire in option C will continue to support the distribution of housing to Hull whilst enabling the East Riding to achieve a more realistic housing requirement. Ultimately much still depends on the outcome of the Government’s intention to publish a revised LHN standard methodology, and these figures can only be indicative at this stage in the absence revised LHN figures. The Council however see the LPEG paper offers a well considered and realistic view of how potential changes could impact and therefore guides the most appropriate option to take forward. Distribution of development The Council agrees with a settlement hierarchy that retains focus on the ‘Major Haltemprice Settlements’ as a part of the urban area of the Regional City, and therefore as a highly sustainable location to support future housing growth. Sub Areas The sub area approach remains important for understanding the broad character of different parts of the East Riding, but also the key relationships between settlements. The sub area approach of the adopted Local Plan directs 45% of new housing development to the Beverley and Central, and Holderness and Southern Sub areas, Settlements in the Beverley and Central sub area would provide the vast majority of this. Of importance to Hull is how development is managed to support market interventions. It remains important to the overall delivery of the wider city that there continues to be a focus of development in this area and that a detailed framework exists that guides decisions on the edge of and in proximity to the city – to ensure its continued growth. Housing supply and delivery Hull City Council supports the approach to over allocation of sites to provide flexibility in supply. It recognises the importance this brings to maintaining developable supply and a five year supply to retain control of planned development. Oversupply could also support a higher level of affordable housing where demand for development increases. The Council suggest that the proposed approach to reserve allocations could be seen as artificially constraining supply where ultimately all sites would be subject to a site assessment methodology, and to be allocated would need to have satisfied criteria. The only basis for when it would appear acceptable for sites to be reserved would be where there were clear sequential criteria which suggest some preference for when one site could come forward over another– for example in terms of flood risk. This approach has been taken at Kingswood, Hull where sequentially less favourable sites are held as later phase sites. This option also brings little certainty to local communities where a site is allocated but with a potential to be developed at any time depending on 5 year supply – or not at all. It is unclear how this approach could work. There appears significant scope for abuse depending on wider land ownership where this could be used to manipulate release of reserve sites ahead of non- reserve ones. As a consequence it is considered sites should either be allocated or not and no reserve sites proposed unless there are exceptional reasons for this. This ensures a flexible supply of sites which in turn should ensure local housing requirements are met. Within Hull we over allocated sites by 20% and have seen our housing requirements exceeded in the last 3 years. Appendix A Scale and distribution of employment land The Council notes that further evidence has been commissioned to inform future needs and land requirements, and that an updated ELR will inform the strategy and any changes to employment allocations identified in the Plan. It is therefore difficult to comment in detail in the absence of this. The Council recognise the important role of the LEP strategy in guiding future economic development objectives for Hull and neighbouring authorities – particularly ER given its close integration with the city. The LEP is currently preparing a detailed submission towards a Local Industrial Strategy and this will be central to informing the future direction of the ER Local Plan. The Council supports the current allocations around the city, particularly those that continue to bring focus to the A63 / A1033 strategic corridor which links through the city providing access, enabling key developments including Green Port Hull. The Council is also supportive of the Yorkshire Energy Park proposed at Hedon. A planning application has been submitted for this scheme but the Council consider it would be helpful to give recognition to this scheme through allocation, particularly if it is determined that development will be in phases, so to give clarity as to its overall extent. The allocation should also make clear the type of development appropriate on the site, including the necessity for uses to be closely aligned to the energy and renewable infrastructure that provides the rationale for its development. The allocation also needs to make a direct link to how necessary mitigation / compensation for the scheme could be provided and secured through appropriate designation / allocation of such sites. The Council have submitted a land bid in respect of the land it owns in this location. Scale and distribution of retail and town centre development The Council notes that further evidence has been commissioned to inform future floorspace required for town centre uses such as retail and leisure needs, and that a new Town Centres Retail and Leisure Study will provide recommendations for potential policy revisions in order to support the vitality and viability of centres. It is therefore difficult to comment in detail in the absence of this. The Council support a hierarchy of centres in which Hull City Centre acts as the focus for the wider city region. Retail and leisure facility catchments spread widely, and therefore rightly should be the focus for a significant proportion of identified growth. Centres in the East Riding sit below this. Most recent evidence prepared for the Hull Local Plan and the Public Inquiry regarding development of retail floorspace at Kingswood has highlighted the reducing need for floorspace and fragility of retail and leisure development schemes within the city centre. This trend continues as is demonstrated by the changing retail environment nationally. The Council would not therefore be expecting significant retail / leisure allocations to be made within sequentially less preferable locations that could impact on Hull City Centre. In reality the Council would be surprised if any major retail allocations were designated within the Beverley and Central sub area and would be likely to object to their inclusion. Housing Mix The Council’s own policy is to encourage developers of larger sites to provide a higher proportion of 3+ bedroom houses to encourage a range of aspirational housing.
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