County Durham Plan Examination - Hearing Statement Matter 8: Housing Land Supply Barratt David Wilson Homes

a) Commitments Is the assumption in Table 2 in the Plan that 15,946 homes will be provided on ‘commitments as at 30 September 2018’ justified?

BDW do not consider that the commitments as at September 2018 are justified as a large number of are unlikely to ever come forward for the following reasons:

1. The Council state that ‘…it is unlikely that all of these [commitments] will come forward during the Plan period for a variety of reasons such as abnormal costs, including land contamination, or a lack of house builder interest’ (paragraph 24, Housing Need and Residual for Allocation and Evidence Paper 2. Historically, based on the councils own evidence, 17% of sites with permission have lapsed (paragraph 25, Housing Need and Residual for Allocation and Evidence Paper). 3. The Council’s evidence base also states that 2,159 houses included with the commitments, were at committee more than 6 months ago. In some cases, these unresolved S106 agreement cases are 10 years old (paragraph 37, Housing Need and Residual for Allocation and Evidence Paper). It should be noted that the majority of these applications will not be compliant with the emerging plan, for example compliance with NDSS and provision of older person housing, and as such may not be suitable for approval following adoption of the Local Plan.

This clearly demonstrates that there are numerous issues associated with the 15,946 homes identified in table 2 and their contribution to future delivery is far from guaranteed. b) Windfalls and development on unallocated sites in built up areas (policy 6) Is policy 6 relating to development on unallocated sites in the built up area justified and will it be effective in encouraging housing development in locations that are consistent with the Plan’s spatial strategy and national policy? BDW do not wish to comment at this stage. Is the windfall allowance of 80 dwellings per year 2021 to 2035 on sites under 0.4 hectares (12 dwellings) justified and consistent with national policy? Should an allowance also be made for windfalls on sites of over 0.4 hectares? We support the Council’s removal of a windfall allowance for larger sites, as an adopted Local Plan should mean that windfall are less prevalent.

We note the Council have reduced the allowance from small windfall from 130 houses per year to 80 houses per year. We would urge the Council to remove this windfall allowance and instead accept as an additional flexibility in the supply, thereby allowing small windfall sites and larger sustainable sites to come forward.

Matter 8 Barratt David Wilson Homes c) Empty homes and demolitions Should the Plan make clear that changes in the number of empty homes and the number of homes lost through demolitions and conversions will be taken into account in annual monitoring against the net requirement for 1,308 homes per year? We agree that the Plan should refer to the change, including a column in past measures of housing supply which would be the number of gross completions, minus demolitions and minus empty homes to give the net housing additions.

BDW note that the Council state it is difficult to do anything more than estimate the future impact on housing supply. Due to the lack of robust evidence that empty homes will be brought back in to use that this should only provide flexibility to the supply and should not be included within the supply at this stage. d) Student housing Is the assumption in paragraph 4.25 of the Plan that new student accommodation, including that proposed in policy 16.2 (Table 9 allocations PBSA1 to PBSA6), will make no contribution towards meeting the need for 1,308 homes per year justified and consistent with national policy and guidance? BDW agree with student housing being excluded from the housing supply. Student accommodation is a specialist form of property designed to meet specific needs and its occupancy is restricted to a very limited demographic group, which means it does not contribute to market housing availability. e) Methodology for selecting allocations Was the approach to selecting housing allocations, summarised in paragraph 4.84 of the Plan, justified and consistent with national policy and guidance? In particular, did the approach take account of site availability, likely economic viability, suitability, and relevant opportunities and constraints (including in relation to the character and appearance of the area; heritage assets; open space, sport and recreational buildings and land; accessibility by sustainable modes of transport; highway safety; flood risk; and social infrastructure)? BDW consider that, to ensure a sustainable approach is taken, the Council should have sought to ensure that when assessing suitable, deliverable, viable greenfield sites the hierarchy set out in the Settlement Study (2018, Ref. S2) should have also been applied. It is unclear from the wording of the second bullet point of paragraph 4.84 whether or not this was the approach taken by the Council. The Council should therefore demonstrate what approach was taken in relation to greenfield sites and additional clarification is required in the supporting text.

BDW has significant concerns over the site selection methodology based on our experience promoting three development sites, each of which has been dismissed without due regard to national policy and guidance. The sites and the inconsistencies with policy are set out below:

 Brandon South – non-Green Belt site adjacent to a major employment area (Meadowfield Industrial Estate) in a high viability area. The site was considered suitable but not viable by the Council, however BDW can deliver a policy compliant development at the site. The only other sites allocated for housing in the same delivery area are at Bearpark, where a recent planning application by Taylor Wimpey has been withdrawn over viability concerns.  Whitworth Park Phase 6 – a non-Green Belt site in Spennymoor which is proposed for deallocation after being identified for homes in the Sedgefield Local Plan. The site represents the next phase of development on a BDW Homes site.

Matter 8 Barratt David Wilson Homes  Brasside Stores – a brownfield site in the Green Belt within Durham City monitoring area. The site has not been fully assessed as a housing site prior to the Council searching for ‘greenfield’ Green Belt sites, in line with paragraph 137 of the NPPF.

In relation to economic viability, BDW consider that this approach has not been followed in the allocation of housing in Central Durham. Only two allocations are proposed, both of which are in Bearpark. These allocations are:

 H7: Cook Avenue, estimated yield of 200 dwellings; and,  H8: Cook Avenue North, estimated yield 50 dwellings.

The Council cannot demonstrate deliverability at Cook Avenue, Bearpark, as evidenced by the fact that a recent Taylor Wimpey planning application (Ref. DM/18/00129/FPA) was recently withdrawn due to a variety of issues relating to the schemes viability and incompatibility with the existing businesses on the adjacent employment site. In this context the Council’s housing land allocations provide no certainty of housing delivery within the Central Durham area.

BDW’s Brandon South site was found to be suitable in the Council’s Exceptional Circumstances analysis, however it was dismissed based on economic viability (Exceptional Circumstances 2019 ref. G4). Despite this a sensitivity test increasing sales revenues by 5% found that the site would be viable. In addition to this as detailed in our response to Matter 4 (please see paragraphs 2 – 17 of our Hearing Statement), the development of Brandon South is economically viable and the Viability Appraisal demonstrates that both schemes are deliverable and are able to make a proportionate contribution to the relief road, local road improvements, sustainable travel and any increase costs for M4(2) and M4(3), along with the identified S106 Contributions.

The land at Whitworth Park Phase 6 in Spennymoor is clearly suitable as it has previously been allocated for residential development in the Sedgefield Local Plan. The Council’s decision to deallocate the site, despite BDW’s progress in delivering the earlier phases of the allocation has not been fully explained by the Council in their evidence base.

The omission of Brasside Stores does not comply with the NPPF’s policy approach of identifying suitable brownfield sites in the Green Belt before allocating greenfield Green Belt sites. The site is available and suitable for development. The Council has not assessed the site against the five purposes of the Green Belt to understand to what extent it serves a Green Belt function and the harm of losing these functions against bringing forward a brownfield Green Belt site before releasing greenfield sites from the Green Belt.

The examples above clearly demonstrate that the Council’s approach to selecting allocations across the County has not been consistent with national policy and guidance and therefore is not sound or justified.

Matter 8 Barratt David Wilson Homes f) Housing allocations Are the housing allocations proposed in policy 4 (Table 7) and shown on the policies map justified? In particular, are they in suitable locations in the context of the Plan’s vision, objectives and overall spatial strategy, and is there a reasonable prospect that they will be available and could be viably developed at the point envisaged? Are the site specific requirements set out in Table 7 justified?  Durham City allocations (other than Sniperley Park and Sherburn Road)  Central Durham allocations  North West Durham allocations  Mid Durham allocations  South Durham allocations  East Durham allocations  West Durham allocations BDW consider that the approach to housing allocations and the resultant allocations proposed in Policy 4 has not been followed through to the allocation of housing in Central Durham. As set out in BDW’s response to Matter 2, there is a misalignment between the location of housing allocations and the economic growth aspirations of the Plan. As such, the proposed allocations are not in suitable locations to support the Plans’ vision, objectives and overall spatial strategy.

BDW consider that this approach to housing allocations has not been followed in the allocation of housing in Central Durham. Only two allocations are proposed, both of which are in Bearpark. These allocations are:

• H7: Cook Avenue, estimated yield of 200 dwellings; and, • H8: Cook Avenue North, estimated yield 50 dwellings.

The Council cannot demonstrate deliverability at Cook Avenue, Bearpark, as evidenced by the fact that a Taylor Wimpey planning application (Ref. DM/18/00129/FPA) was recently withdrawn due to issues relating to viability and incompatibility with the existing businesses on the adjacent employment site. In this context the Council’s housing land allocations provide no certainty of housing delivery within the Central Durham area as they cannot be viably deliver at the point envisaged.

In comparison, Brandon South is a sustainably located, deliverable site in close proximity to existing bus routes which run along the A690 and which can contribute to the delivery of the Western Relief Road. The development of the site for housing will support the economic aspirations for the Central Durham Area, which includes Meadowfield Industrial Estate (26.67ha) and Integra61 (44.25ha), with a further 61.95ha of land safeguarded for future expansion of Integra61. The site’s proximity to these major employment sites supports sustainable travel patterns and reduces the need for increased commuting distances across the County. The site is within walking distance of a Primary School and the catchment of Brandon local centre. The site is within walking distance of GP services, community/leisure facilities and designated open space. The site is also within the catchment of the services and facilities of Durham City. The land at Brandon South is therefore suitable, available and achievable and will help support the Councils Sustainable Communities strategy.

In relation to the site specific requirements, as set out by the Council in relation to PQ13, the Plan allocations to in the Central Durham and Mid Durham areas, namely Cook Avenue and Cook Avenue

Matter 8 Barratt David Wilson Homes North, Bearpark (H7 and H8), High West Road, Crook (H22) and East of Ash Drive, Willington (H26), will have an impact on the existing congestion issues on the A167 and are therefore required to contribute towards the Western Relief Road. As stated, the Site Allocations Viability Appraisals Report (Ref. H10) did not include a cost for the contribution and there is therefore a serious question mark regarding their viability, particularly as all three sites are within a medium viability area whereas Brandon South is in a high viability area.

Given that the Durham Local Plan Traffic Impacts report concludes that a solution to:

“removing cross-city strategic journeys must be found, correcting previous errors in planning major roads through the city centre. The solution to removing these journeys is to provide a strategic alternative for east-west (or northeast- south west) movement. This is in line with a deficiency of suitable east-west connectivity in the wider north.” (page 22, Ref. T5),

It is considered imperative that those development sites that can contribute to the delivery of this infrastructure should be clearly indicated and demonstrably viable.

There is a significant risk that the Local Plan allocations will not be able to support the aspirations of the plan. BDW considers that the solution is to allocate additional sites for residential development that can provide a proportionate contribution to the delivery of the Durham City Relief Roads, including the allocation of Brandon South for residential development. g) Small and medium sized sites Will the Plan be effective in helping to ensure that at least 10% of the housing requirement of 1,308 dwellings per year is met on sites no larger than one hectare as required by national policy? BDW do not wish to comment at this stage. h) Five year supply and housing trajectory The Council’s evidence indicates that on 1 April 2019 there was a deliverable supply of 8,745 dwellings compared to a five year requirement of 6,867 dwellings. Is that evidence adequate and proportionate such that the figure is justified? Will the Plan be effective in ensuring that there will be a supply of specific deliverable sites sufficient to meet an appropriately calculated five year requirement throughout the Plan period? Does the housing trajectory contained in the Plan (Figure 3) effectively illustrate the expected rate of housing delivery over the Plan period? Paragraph 67 of the NPPF states that planning policies should identify a supply of ‘specific, deliverable sites for years one to five of the plan period’, with an appropriate buffer. Barratt Homes note that the Council have not prepared a five year housing trajectory. In order for the Plan to be found sound, the Council should prepare one and it must be in accordance with the NPPF glossary definition of ‘Deliverable’.

Matter 8 Barratt David Wilson Homes i) Overall housing land supply Overall, does the Plan identify a sufficient supply and mix of sites and contain effective policies to ensure that identified needs for housing over the Plan period can be met? The County Durham Plan does not identify a sufficient supply of homes to ensure that needs can be met across the plan period. The allocations identified, such as Bearpark (ref. H7 and H8), have no certainty of delivery and suitable sites have been discounted with no sound justification.

Notwithstanding BDW’s previous comments on the scale of development, the Plan should incorporate additional flexibility in the supply of new homes to ensure that the Council’s housing targets are consistently met throughout the plan period.

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Matter 8 Barratt David Wilson Homes