Tony

Further to the publication online of the hearing statements, we have been reviewing the Matter 3 statement submitted by the Council. It is apparent at Appendix 1 that the Council has changed the delivery assumptions on a number of the draft allocations, bringing a number of these sites forward into the 5 year supply. The amount of units added to the 5 year supply is significant; from our calculations it totals 1,721 additional dwellings. These are new sites, not previously identified as deliverable in the evidence base. We had previously sought clarification at the pre-hearing meeting as to what housing supply evidence the Council would be relying upon at the examination, and we had been working to that information in the preparation of our own statements. This position has now changed without any notice.

In Peel’s Matter 3 statement, we have questioned the delivery of a number of sites identified within the 5 year supply. This was based upon on the assessment undertaken by Robin Brocklehurst and John Broadbent on behalf of Peel and other examination participants (Taylor Wimpey (UK) Ltd, Barratt Homes and Persimmon Homes North West). Representatives of those parties have been copied into this e-mail. We are concerned that a number, if not all, of the additional sites now identified cannot be considered deliverable. Accordingly Peel have instructed Mr Brocklehurst and Mr Broadbent to undertake a review of the deliverability of these additional sites now identified to deliver in years 1-5. Our initial investigations have already identified that the first amended 3 sites on the list have significant question marks over deliverability, namely:  11SC Eskrick Street: There is no planning consent and the site forms part of the designated Wildlife corridor along the River Croal/Middle Brook.  15SC Wordsworth Mill: Extant planning consent for 14 dwellings but the site included in the supply for 25 dwellings.  38SC Astley Lane / Waverley Road – Extant planning consent for 22 dwellings. Remainder of the site is in existing employment use.

This information will be prepared as an addendum to the assessment commissioned by Peel and the other parties named above, as submitted with Peel’s Matter 3 statement, and we propose to submit it to the examination. We are familiar with the strict rules regarding written submissions; however we raised this specific topic at the pre-hearing meeting consider that the change in delivery assumptions on these sites represents a significant shift in the Council’s position, without reference to the submitted evidence base. We consider that that the addendum should be accepted in the interests of fairness, and it would potentially aid the smooth running of the hearing session by reducing or eliminating the need for us to discuss the deliverability of each of the new sites.

Given the timescales involved and bearing in mind the forthcoming Easter holidays, the earliest that we would be able to submit the additional information is on the 22nd April i.e. 7 days in advance of the Matter 3 hearing. However we would firstly be grateful for your response as to whether such additional written information would be accepted by the Inspector. I look forward to hearing from you in due course.

Regards

John Coxon BSc (Hons) MPlan MRTPI Principal Consultant

Emery Planning Partnership Ltd trading as Emery Planning Registered in England No. 4471702