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Calderdale Local Plan Representations to Housing Requirement Update and Potential Supply Consultation

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Calderdale Local Plan Representations to Housing Requirement Update and Potential Supply Consultation Calderdale Local Plan Representations to Housing Requirement Update and Potential Supply Consultation Persimmon Homes (West Yorkshire) February 2020 © 2020 Nathaniel Lichfield & Partners Ltd, trading as Lichfields. All Rights Reserved. Registered in England, no. 2778116. 14 Regent’s Wharf, All Saints Street, London N1 9RL Formatted for double sided printing. Plans based upon Ordnance Survey mapping with the permission of Her Majesty’s Stationery Office. © Crown Copyright reserved. Licence number AL50684A 50725/01/CD/AJk 18198426v2 Calderdale Local Plan : Representations to Housing Requirement Update and Potential Supply Consultation Contents 1.0 Introduction 1 2.0 Housing Requirement 2 Revised Modelling work by Turley – August 2019 2 Summary 3 3.0 Issues with Proposed Supply 4 Failure to identify appropriate uplift to housing allocation supply 4 Previously agreed adjustment to Garden Suburb site LP1463 4 Shortfalls in delivery at Garden Suburb sites and other identified draft allocations 5 Windfalls 8 Flexibility 8 Summary 9 4.0 Proposed Additional Sites 10 Hall Lane, Northowram (ref: LP0766) 10 Land off Soaper Lane and Land at Burned Road, Shelf (LP1034 and 1035) 12 5.0 Further sites needed to meet Housing Requirement 14 Lower Edge Road, Elland (ref: LP0220) 14 Upper Lane, Northowram (ref: LP1141) 15 6.0 Conclusions 17 Calderdale Local Plan : Representations to Housing Requirement Update and Potential Supply Consultation 1.0 Introduction 1.1 On behalf of Persimmon Homes (West Yorkshire) (“Persimmon”), Lichfields is pleased to submit representations to Calderdale Council’s ‘Housing Requirement Update and Potential Supply’ consultation. 1.2 Lichfields has made representations to each round of consultation on the emerging Local Plan on behalf of Persimmon and appeared at the Stage 1 hearing sessions in June and July 2019. 1.3 In each of our representations we have been clear that the minimum housing requirement in the emerging Local Plan needs to take account of the economic growth ambitions and policies contained in the Local Plan. Although this current consultation indicates that the Council is attempting to take some account of these factors, for the reasons set out within this representation we do not feel that the approach being pursued by the Council is appropriate, and the Local Plan continues to remain unsound. 1.4 This representation sets out an alternative housing requirement which would adequately support the employment growth advanced by the emerging Local Plan and also reviews the supply of sites preferred by the Council to meet this need. 1.5 Persimmon has control of the following sites: 1 Land at Hall Lane, Northowram (ref: LP0766); 2 Land at Soaper Lane and Burned Road, Shelf (refs: LP1034 and LP1035 respectively); and, 3 Land at Upper Lane, Northowram (ref: LP1141) 4 Land at Lower Edge Road, Elland (ref: LP0220); 1.6 Sites 1 and 2 are now proposed to be allocated in the Local Plan through this current consultation, however sites 3 and 4 have been rejected as housing allocations. 1.7 The allocation of sites 1 and 2 listed above is fully supported. It is also advocated that sites 3 and 4 should be allocated in the Local Plan to meet the shortfall in housing land identified in these representations. The representations include further information to justify that these sites are sustainable and deliverable housing sites. Pg 1 Calderdale Local Plan : Representations to Housing Requirement Update and Potential Supply Consultation 2.0 Housing Requirement 2.1 The Publication Draft Local Plan proposed the provision of 12,600 homes over the plan period (840 dwellings per annum (dpa)). This was based on the indicative figures published by Government in September 2017 when the standard method was first published for consultation. 2.2 Following the close of Stage 1 of the examination hearing sessions, the Inspector wrote to the Council (ref: INS07) to explain that they considered that the housing requirement: ‘…is higher than 840 dpa and is likely to amount to at least 1,001 dpa.’ (our emphasis) 2.3 In response to the Inspector’s findings, the Council now proposes to base the emerging Local Plan on a requirement of 997 dpa (ref: CC22). 2.4 Persimmon considers that the Council should be pursuing a significantly higher housing requirement in its emerging Local Plan. A detailed response on this matter has been prepared by Barton Willmore on behalf of a consortium of developers including Persimmon, which has been submitted as a separate representation to this consultation. The findings of that representation are however summarised below. Revised Modelling work by Turley – August 2019 2.5 The Inspector’s post Stage 1 hearings letter to the Council explained at paragraphs 10 and 11 that an uplift to the 840 dpa requirement was necessary to support the likely employment growth envisaged by the emerging Local Plan. It also explained that this uplift was likely to result in a minimum requirement of at least 1,001 dpa (Lichfields emphasis). 2.6 The Council therefore commissioned Turley to undertake further analysis of the relationship between the Council’s housing requirement and its growth aspirations (ref: CC21). Turley recommended that 1,040 dpa would likely be needed to support the “policy-on” employment forecast, which anticipates the creation of circa 10,318 jobs in total between 2018 and 2033. Persimmon fully supports this approach and minimum requirement of 1,040 dpa. 2.7 The Council’s approach, however, is to take the 1,040 dpa figure forward for the first 10 years of the plan, with a baseline figure of 910 dpa applied for the subsequent 5 years. This results in an overall figure of 997 dpa over the 15 year plan period – a shortfall of 650 dwellings over the plan period compared to the preferred approach derived by its own consultants Turley. The reasoning given by the Council for accepting the ‘policy on plus transport’ scenario but only applying this for the first 10 years of the Plan is given at paragraph 5 of document CC22 which states: ‘The 2019 Turley study identified a requirement of 1,040 homes per annum to support the ‘policy-on plus transport’ economic growth forecast. The Council is generally persuaded by the 2019 Turley study; however, whilst logical and methodical, it is inevitably based on various assumptions. It makes assumptions about economic activity, about commuting rates, about population change and household formation rates, about participation rates in the job market and so on. There is uncertainty about the extent to which these assumptions will hold good for 15 years, and some of these variables are volatile.’ 2.8 The NPPF (paragraph 22) requires strategic policies to look ahead over a minimum 15 year period. It is entirely appropriate to rely on economic modelling such as that produced by Turley for the lifetime of a Local Plan. Indeed, that is the very intention of such forecasting. Pg 2 Calderdale Local Plan : Representations to Housing Requirement Update and Potential Supply Consultation 2.9 Persimmon objects to the Council’s revised proposed housing requirement. The decision to ignore the evidence prepared by Turley is unjustified and not consistent with national policy, and the Local Plan cannot be found to be positively prepared nor sound on this basis. Summary 2.10 The Council’s decision to support the ‘policy on’ employment scenario modelled by Turley but then only apply this to the first 10 years of the plan period is unjustified and not consistent with national policy. Furthermore it is clear that there is not an absence of suitable sites to deliver the housing requirement identified in the Turley report. Indeed, as these representations demonstrate, Persimmon is in control of currently rejected sites which are in sustainable locations, technically developable, and capable of delivering approximately 190 homes. 2.11 To be found sound, the emerging Local Plan must be based on a minimum housing requirement of 1,040 dpa (15,600 for the plan period). Pg 3 Calderdale Local Plan : Representations to Housing Requirement Update and Potential Supply Consultation 3.0 Issues with Proposed Supply 3.1 This section of the representation discusses a number of issues with the proposed future supply of housing land which is being taken forward in the draft Local Plan. 3.2 From the outset it is important to note the very poor record of delivery of housing in Calderdale in recent years. The recently published 2019 Housing Delivery Test results show that Calderdale only achieved a result of 48%, making it the worst performing authority in the region and only narrowly avoiding the trigger for the presumption in favour of sustainable development in accordance with paragraph 11, footnote 7 of the NPPF. In this context, it is vital that the emerging Local Plan identifies sufficient sites which are deliverable and unencumbered by technical constraints so that housing can be delivered quickly. Failure to identify appropriate uplift to housing allocation supply 3.3 The Council’s Housing Requirement Update consultation document states that the assumptions around extant planning permissions and windfalls remain as published in the submission version of the Local Plan and as discussed at the Stage 1 hearings (paragraph 5.1). This is shown in Table 2 of the Council’s consultation document (page 6) which clearly states that the sources of housing land supply remain the same between the Publication Draft Local Plan and what is now being consulted upon. The sub-total of this existing supply is 3,182 homes. 3.4 The Council’s proposed updated housing requirement of 14,950 homes over the plan period represents an increase of 2,350 homes compared to the Publication Draft requirement of 12,600. Given that the sources of existing supply are unchanged, one would expect the capacity of the new sites to be at least 2,350.
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