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Persimmon Homes - Covering Letter.Pdf; Persimmon Homes - General Response.Pdf; Persimmon Homes - Grange Road, Botley.Pdf; Persimmon Homes - Hamble Airfield.Pdf

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Persimmon Homes - Covering Letter.Pdf; Persimmon Homes - General Response.Pdf; Persimmon Homes - Grange Road, Botley.Pdf; Persimmon Homes - Hamble Airfield.Pdf Page 1 of 1 From: Sent: 17 February 2016 15:21 To: '[email protected]' Cc: Subject: Eastleigh Borough Local Plan 2011-2036 Issues & Options Consultation Attachments: Hamble Airfield - Baseline Transport Assessment.pdf; Hamble Airfield - Development Framework Plan.pdf; Hamble Airfield - Ecological Apprasial Phase 2.pdf; Hamble Airfield - Landscape and Masterplanning Note.pdf; Hamble Airfield - Minerals addendum.pdf; Persimmon Homes - Covering Letter.pdf; Persimmon Homes - General Response.pdf; Persimmon Homes - Grange Road, Botley.pdf; Persimmon Homes - Hamble Airfield.pdf Dear sir or madam, Please find attached a response to the Eastleigh Borough Local Plan 2011-2036 Issues & Options Consultation on behalf of Persimmon Homes. The response consists of the following documents: z Covering Letter z General Response on behalf of Persimmon Homes z Site specific response relating to Hamble Airfield, which is accompanied by: { Baseline Transport Assessment { Development Framework Plan { Phase 2 Ecological Survey { Landscape and Masterplanning Note { Minerals Addendum z Site specific response relating to Grange Road, Botley I hope the above information is suitably clear, but if you do require any further details please do not hesitate to contact me. I would appreciate confirmation that you have received this response. Kind regards, Persimmon Homes 08/08/2018 Eastleigh Borough Council Local Plan 2011-2036 Issues & Options Persimmon Homes – General Response Introduction I would like to thank you for the opportunity to comment on the Eastleigh Local Plan 2011-2036 Issues & Options (I&O) Document. Overall the document is a fair reflection of the issues facing the Borough, and does outline a wide range of options available to meet development needs moving forward. This is a general response relating to the contents of the Issues & Options Document and addresses a number of the questions within it. More site specific responses are being made separately in relation to our land interests in the Borough, which are: • Hamble Airfield • Grange Road, Botley Duty to Cooperate The acknowledgement of the role of PUSH and the LEP in light of the duty to cooperate is welcomed in paragraphs 2.12-2.16, as is the recognition of the work being prepared to update the South Hampshire Strategy (SHS). Whilst the need for Eastleigh to progress its Local Plan Review is pressing, in order to meet increasing development needs, the wording of paragraph 2.15 is concerning in that there appears to be no commitment (the word intention is used) to take account of the SHS Review. The importance of the duty to cooperate cannot be underestimated, especially in an area which is so clearly interdependent such as South Hampshire. The intention to utilise the important sub-regional work is a step in the right direction, but there needs to be a commitment to engage proactively with the Authorities in PUSH if Eastleigh are insistent on progressing their Plan ahead of the SHS. Issues & Options Document – Question 2 The list of evidence documents appears relatively comprehensive. However, there is no indication that a Gap Review specific to Eastleigh has been undertaken. The evidence base lists the PUSH “Policy Framework for Gaps” as one of a suite of documents that needs updating, but whilst this may revisit the criteria for assessing gaps across the sub-region, this document will not do the specific task of reviewing the existing gaps within Eastleigh Borough. Given how important gaps are locally, and how they are being used to determine current applications, and as part of the assessment of sites through the Plan, it is necessary to undertake a review of the Gaps to inform the consideration of sites within the Local Plan. Until this review is undertaken it is not possible to truly compare the relative site selections being put forward as some may have far more - 1 - impact on settlement coalescence than others. This issue is even more apparent when considering options that consist of multiple sites (such as Option A), as certain sites may well be acceptable in terms of their impact on the Borough’s gaps, whereas others may not be. Similarly, a landscape assessment for the Borough has not been undertaken. The evidence list considers the 2011 Hampshire Integrated Character Assessment as still relevant, but this document merely identifies different character areas in the Borough, rather than objectively assessing the inherent qualities of each area. The landscape value of the countryside needs to be assessed as a whole in order to inform individual site assessments, which in turn inform site options. The SA that supports the I&O Document includes questions (12.1 and 12.4) which relate to both Gaps and landscape and setting. This indicates that both these factors are being used to determine the suitability of sites in the Local Plan, without the proper evidence to justify the SA recommendations. Without a proper Gap review and landscape assessment the evidence base cannot be considered complete. Further to the above, a revised assessment of the employment needs of the Borough does not appear to have been completed. There are figures for the employment requirements of the Borough in the 2014 Employment Land Review, but these are based on PUSH figures from 2010, and the “Technical Consultation on Development Requirements (June 2015)” which does not appear to form part of the evidence base to support this Plan. Accordingly the I&O paper (page 24) confirms that further work is required to revisit the employment requirements in due course. However, it is considered that this evidence should be provided in advance of developing options for the Plan. The need for land for employment can have a significant impact on the spatial options included in the I&O Document, and without knowing the need it is unclear whether the options in the document will be sufficient. Secondly, employment needs and job growth have a direct impact on housing numbers, as there needs to be sufficient housing to accommodate new workers. The background document supporting the housing option considers that no increase in housing numbers is required to meet economic growth, but the strength of this argument is surely weakened by the acknowledgement that further work on understanding employment requirements is needed. Given that housing and job numbers are intrinsically linked, it is debatable that a conclusion on one can be made without updated information on the other. Issues & Options Document – Question 3 The key issues identified are comprehensive and the reference to the Plan needing to “take into account the wider Southampton housing market area” is welcomed. However, it is unclear as written what element the plan is taking into account. To clarify the following wording is recommended: The need to accommodate a significant increase in new housing to meet the housing needs of the Borough, and to take account of the housing needs of the wider Southampton market area. - 2 - Issues & Options Document – Question 4 The list of key development constraints is considered comprehensive. Existing gaps and the countryside designations should not be considered as constraints until they have been thoroughly reviewed. Issues & Options Document – Question 6 (and Housing Background Paper) It is useful to have the opportunity to comment on housing numbers options as this will obviously underpin the consideration of sites for housing moving forward. In terms of the background, the acknowledgement in paragraph 5.5 of the need to take account of the previous Planning Inspectorate’s findings into the 2011-2029 Local Plan is welcomed. The Inspector concluded that 564 dwellings per annum being planned for did not represent objectively assessed needs, preferring the PUSH figure of 615 as an initial starting point, but also pointing out the need to take account of affordable housing targets and market signals. In light of the Inspector’s decision, and the wording of paragraph 5.5 in assuring that this should be taken into account, it is disappointing to see figures from the 2015 Eastleigh Housing Needs Study being included as an option. It is acknowledged that this document seeks to use more recent household projections (2012), but this should not be looked at in isolation and a market area assessment based on these projections should be undertaken. The Eastleigh Housing Needs Study (EHNS) recognises that “the finding that future household growth in Eastleigh is expected to be slightly lower than across the South East is interesting given that overall population growth is expected to be stronger” , indicating that overall housing growth predicted from the 2012 household projections is higher than in previous versions (such as the 2011 projections with underpinned the PUSH SHMA). Therefore, whilst looking at Eastleigh in isolation may show a slightly lower need for Eastleigh, as compared to the SHMA, there is a requirement to take account of “the bigger picture” under the duty to cooperate. The need for this is also recognised in the most recent “Housing Background Paper” which states that “The borough forms part of the Southampton HMA, for which a refreshed Strategic Housing Market Assessment is being prepared as part of the review of the PUSH South Hampshire Strategy (October 2012). This will provide further information on the housing needs of the borough and its adjoining areas, using common assumptions for all parts of the HMA. As such, it would be inappropriate to attempt definitive conclusions on the borough’s housing requirements at this time.” Further to the above, and the fact that general housing needs are increasing across the country, the most recent Eastleigh Five Year Land Supply Position (Sept 15) acknowledges that since 2011 Eastleigh has delivered around half of its objectively assessed need (1,393 completed against a requirement of 2,768). Taking into account the information available on increasing housing needs, previous under- - 3 - delivery and the comments from the Local Plan Inspector, the inclusion of a housing target lower than the target found unsound in 2015 is considered unreasonable.
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