Public Participation on a Development Plan Document Consultation on Proposals for a Draft Local Plan 8 June 2012 – 23 July 2012 Report of Representations, Officer Comments and Recommendations on Strategic Policies SP5 and SP6 Site Allocations Local Plan Working Group 17 October 2013 1 Contents Page Policy SP5 3-14 Policy SP6 15-29 Saffron Walden 30-60 Great Dunmow 61-86 Elsenham 87-106 Great Chesterford 107-119 Newport 120-132 Stansted Mountfitchet 133-146 Takeley/Little Canfield 147-178 Thaxted 179-186 Clavering 187-192 Henham 193-200 Radwinter 201-204 Stebbing 205-207 Other Villages 208-216 Appendix 1 – List of Sites promoted in response to Draft Plan 217-254 2012 Note: Under the officer recommendation section changes to the draft plan are indicated by a strikethrough for text which is proposed to be deleted and bold for new text. 2 Strategic Policy SP5 Strategic Policies SP5-SP6 Policy SP5 – Meeting Housing Need Summary of Representations Around 1,000 comments were made in response to this policy. The majority of these (around 900) were standard representations of support for the policy because it no longer includes a proposal for a new town of 3,000 homes as the Council’s preferred housing strategy. Elsenham and Henham Parish Councils strongly support the housing strategy. Their representations and the standard representations also included objection to the policy on the following grounds; it is confusing to make provision for housing for a period which began in 2001, already 11 years ago. The original Local Plan (adopted 2005) made provision for housing up to 2011, so the new Local Plan should start from that date. Paragraph 12.19 is wrong to state that provision of homes up to 2012 should be in accordance with the Regional Strategy. This will soon be revoked and certainly will be by the time of the adoption of the Local Plan in November 2013. Paragraph 12.11 states that provision should be made for 338 dwellings per annum which means for a 27 year period the total is 9,126 homes, not 9,870. One individual supports the policy on the grounds that it will supply affordable housing, which is needed. Takeley Parish Council welcomes the policy to deliver bungalows and 11/2 storey homes to meet the needs of the local community. One specialist housing provider identifies a need in the district for more extra care housing. Great Dunmow Town Council and Great Dunmow Neighbourhood Plan Steering Group consider there is a lack of justification for the economic scenario and a lack of consideration of population change over the plan period. The ambition to provide 40% affordable housing is supported in principle but it is not clear if this is feasible given the fact there is no viability assessment of the plan. They also feel that the impact of windfall sites should be clearly and logically stated. A number of individuals object to the policy mainly on the basis that the numbers of homes required to be provided is too high. People have mentioned that in a time of recession fewer houses are likely to be needed and that the Edge Analytics work on which the housing forecasts are based is providing an over optimistic job growth forecast in these circumstances. Some people also feel that the numbers are excessive taking into account applications which are already in the pipeline. Some people feel it is not clear what criteria have been used to decide how many new houses should go in Great Dunmow and Saffron Walden. 3 Strategic Policy SP5 Some individuals, concerned about development in Saffron Walden in particular have queried the basis for seeking 40% affordable housing saying that this seems unreasonably high and will create new estates with high levels of benefit dependency unless jobs are also provided. Saffron Walden Friends of the Earth, Save Saffron Walden Town Centre and 1 individual object to the housing strategy saying it is in breach of at least 6 of the 10 plan objectives. They also object to the use of the word minimum in the site allocation policies. The Home Builders Federation feels the Council’s statistics are inconsistent and confusing. All the scenarios revert to zero growth after 2027 which is unrealistic and unjustified. The plan should show whether there has been under delivery and include a 5% or 20% buffer as required by the NPPF. Agents and landowners promoting development sites are concerned that the housing numbers are too low and do not meet the housing needs identified in the Strategic Housing Market Assessment (SHMA). Additional figures are suggested. Some are suggesting the housing figures should be based on the Regional Spatial Strategy and there is not enough evidence in the plan to demonstrate why the economic scenario has been chosen. Some people have made reference to the 2011 Census and suggested that initial results mean population and household growth forecasts will be revised upwards in most parts of the country. There is concern that no allowance has been made for schemes which have planning permission but are never completed. The Chelmsford Dioscesan Board of Finance considers the Council should identify suitable reserve sites to provide for flexibility to cover shortfalls in housing supply for the plan period. Some landowners have suggested that the policy should refer to a minimum total number of homes, consistent with the use of the word minimum in the individual site allocations policies to give more flexibility in the consideration of sites. NHS North Essex have made reference to the fact that site allocations policies require provision of 5% as 1 and 2 bed bungalows and Stansted Mountfitchet Policy 3 makes provision for 35 retirement dwellings. Such development would result in an increase in the number of elderly people in need of care within the catchment. This is likely to have a significant impact on the NHSNE’s funding programme for the delivery of healthcare provision within it’s area and it is imperative that development proposals for or that include older person’s accommodation and extra care units identify the health care impacts arising from such development and include appropriate mitigation. The Showman’s Guild want the site allocations for Gypsies and Travellers included in the Local Plan and not a separate document which they consider would have less weight in future land allocation policies. One landowner who has previously promoted a site for gypsy and travellers also considers these sites should be dealt with in this local plan so that allocation of sites and drafting of policy is dealt with comprehensively. This would allow the document to take 4 Strategic Policy SP5 account of other competing or complementary land uses and designation and to make sure that sites are deliverable. This would make sure the travelling community is dealt with in a fair and reasonable manner. National Planning Policy Framework In terms of the Core Planning Principles the NPPF says; every effort should be made objectively to identify and then meet the housing needs of an area and respond positively to wider opportunities for growth. Plans should take account of market signals such as land prices and housing affordability and set out a clear strategy for allocating sufficient land which is suitable for development, taking account of the needs of the residential and business communities. Specifically in relation to the delivery of housing local planning authorities are required to: Use their evidence base to make sure that their local plan meets the full, objectively assessed needs of market and affordable housing in the housing market area Identify and annually update a supply of deliverable sites to provide five years worth of housing against their housing requirements with an additional buffer of 5% to ensure choice and competition in the market for land. Where there has been a record of persistent under delivery local planning authorities should increase the buffer to 20% Illustrate the expected rate of delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing. Local Planning Authorities may make an allowance for windfall sites in the five year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply. Plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community. Identify size, type, tenure and range of housing required in particular locations. Set policies for meeting affordable housing needs where these have been identified To promote sustainable development in rural areas housing should be located where it will enhance or maintain the vitality of rural communities In relation to the evidence base local planning authorities should have a clear understanding of housing needs in their area. They should prepare a Strategic Housing Market Assessment to assess their full housing needs. This should identify the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which meets household and population projections taking account of migration and demographic change. They should also prepare a Strategic Housing Land Availability Assessment to 5 Strategic Policy SP5 establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period. Sustainability Appraisal June 2012 The policy will have positive impacts on the objective to improve the population’s health and promote social inclusion through the delivery of a range of housing units to meet the needs of the population including affordable units, rural housing, housing for key workers, the disabled, elderly and agricultural/rural workers and sites for gypsies, travellers and travelling show people.