Calderdale Local Plan Representations to Housing Requirement Update and Potential Supply Consultation
Persimmon Homes (West Yorkshire) February 2020
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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.
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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.
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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).
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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. However, the capacity of the new sites put forward only amounts to 2,094 homes1. This is a shortfall of 256 homes.
3.5 Table 2 of the Council’s consultation document also shows that the capacity of the proposed allocations is now 11,882 homes – an increase of 2,422 homes. It is therefore assumed that the capacity of some previously identified draft allocations has increased in total by 328 homes. No evidence has been provided to demonstrate which sites now have increased capacities, although it is noted that paragraph 5.1 of the Council’s consultation document states that:
‘The assumptions around the capacity and mix of uses have been revised on a number of the existing allocations (over and beyond minor changes to reflect revised layouts etc). This additional supply contributes to meeting the revised housing requirement figure which will be explored during the next set of hearings.’
3.6 If the Council has increased the capacities of some of the previously identified draft allocations this should be explicitly set out and these adjustments should form part of this consultation. Without the ability to scrutinise these apparent adjustments the draft Plan cannot be taken back to examination on a justifiable basis, and the current approach is therefore unsound. Previously agreed adjustment to Garden Suburb site LP1463
3.7 The importance of scrutinising any amendments to the capacity of proposed allocations is evidenced by the significant reduction in the plan period capacity of Garden Suburb site LP1463 (Land between Highmore Lane and Bradford Road, Brighouse), which the Council subsequently
1 This figure includes the additional 98 units identified in the email from the Programme Officer dated 20th January 2020 regarding the discrepancies at three of the new Elland sites
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agreed with the land promoter through a Statement of Common Ground (document ref: CC 07) following submission of the draft Plan.
3.8 In the SoCG, and then verbally stated at the Stage 1 hearing sessions, it was agreed by the Council that site LP1463 could only realistically deliver 1,305 homes within the plan period, with the remainder to be delivered post plan period. This is a shortfall of 693 homes which should be accounted for through the identification of additional sites as part of this consultation, however the Council now appears to be reneging on this agreement following a report made to the Local Plan Working Group.
3.9 The Council’s report to the Local Plan Working Group dated 9th October 2019 lists a number of ‘assumptions’ which, it claims, would boost the speed of delivery on allocated sites in the plan period and, as a result, remove the need to accommodate some 1,500 dwellings from the uplifted housing requirement in the existing Green Belt (paragraph 4.21). The first of these assumptions is that:
‘Modern methods of construction’ will accelerate delivery as they becoming [sic] increasingly common-place during the latter years of the Plan – this would enable the Thornhills Garden Suburb to deliver in full over the life of the Plan, facilitating the delivery of approximately 600 additional dwellings with no further loss of Green Belt’
3.10 The Statement of Common Ground with the site promoter is dated June 2019. No further evidence has been provided since that time as to what these modern methods of construction are or how they would be employed at site LP1463, and nor is any further evidence or discussion of this matter given in the Local Plan Working Group report. The claim is therefore clearly unjustified, and, if not corrected, will result in the Local Plan falling significantly short in meeting the District’s minimum housing needs.
3.11 It is also questioned whether the housing market could readily absorbed such an accelerated supply of new homes on a single site. Lichfields’ Start to Finish research (discussed in greater detail below) found that absorption rates are a key metric which shape the rate of annual delivery on strategic sites. Shortfalls in delivery at Garden Suburb sites and other identified draft allocations
Garden Suburb Sites
3.12 In our previous representations we have demonstrated that the lead-in times and delivery rates assumed by the Council for the two Garden Suburb sites have been overestimated, and do not align with national evidence on the delivery of similar sized strategic sites set out in Lichfields’ Start to Finish research paper2.
3.13 The Start to Finish research shows that, the ‘planning approval period’ (the period from the validation date of the first planning application for the scheme to the decision date of the first application which permits development of dwellings on site) grew exponentially with the size of the sites which were reviewed. For sites of over 1,500 dwellings, the average planning approval period was over five years, and, for sites over 2,000 dwellings, over six years. It then took over a year to deliver the first dwelling on site on developments of 1,500 – 1,999 dwellings.
2 Start to Finish: How quickly do large-scale housing sites deliver? (Lichfields, November 2016)
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3.14 In terms of delivery rates, the research again found a direct correlation between increasing site size and increasing build rates. The average annual build-rate for the largest sites (of 2,000 or more units) was in the region of 161 dwellings per annum.
3.15 Both Garden Suburb sites are located within the Green Belt and contain multiple landowners and are subject to significant technical constraints. As a result of their Green Belt status, planning applications will not likely be submitted until the Local Plan is adopted. This consultation has resulted in a delay to the examination process, and as a result it is considered that the Local Plan will not be adopted until at least April 2021, given the need to analyse the results of this consultation, reschedule and hold the remaining hearing sessions and then consult on any Main Modifications. The average 7 year period should therefore be applied from April 2021 – at the start of year 4 (2021/22). Table 3.1 below provides a more realistic indication of the likely levels of delivery from these two sites, using average build-rates derived from the Start to Finish research.
Table 3.1 Anticipated Delivery - Garden Suburb Sites Site First delivery Average build rate (dpa) Site Yield Local Plan Lichfields Local Plan Lichfields Local Plan Lichfields LP1463 2024/25 2028/29 222 135 1998 675 LP1451 2024/25 2028/29 140 135 1257 675
3.16 Based on the national evidence set out in Start to Finish, which the Council claims in the Housing Topic Paper that it has relied on, it is considered that the combined plan period yield from both Garden Suburb sites will be 1,350, at most. This represents a shortfall of 1,905 homes. Notwithstanding the evidence that underpins our analysis, even if it was not accepted but the revised figure for site LP1463 was taken from the Statement of Common Ground that the Council has agreed with the site promoter, there would be a shortfall of 693 homes as discussed above.
Other Allocations
3.17 In addition to the significant shortfall in delivery which we anticipate will occur at the Garden Suburb sites, our analysis has highlighted a number of other proposed allocations which we believe are not developable. These are listed in the table below alongside our justification.
Table 3.2 Undevelopable Allocations
Site Site Area PDLP Comments (gross / net) Capacity Ha Previously identified allocations LP0945 - Pond Quarry, 1.81 / 1.81 62 Site is a former quarry with a very large chasm Lightcliffe Road, Brighouse, occupying most of the site rendering it completely HD6 2JJ undevelopable in its current state. Due to the Government’s Land Fill Tax the inert material required to fill this void is simply no longer available as inert materials are now recycled on site to avoid them being treated as a waste. The site is completely undevelopable and unviable. LP0174 - End of Wilton Street 2.82 / 2.55 15 No suitable access roads and the land is unviable HD6 2QY due to levels LP1053 - Squire Hill Quarry, 3.75 / 2.26 68 Former quarry site and the level of cut and fill Brighouse, HD6 required to makes this site unviable. Quarry is also ransomed by 1054 to the east. Access would need to come through this allocation in order to achieve suitable widths within a single land ownership LP1054 - Land off, Brookfoot 1.23 / 0.9 32 Site is too steep and is needed to provide access to
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Lane, Brighouse, HX3 9SX the allocation to the west site not deliverable as would be mainly road and levels make delivery of housing and a highway impossible. LP1398 - Land on the West 4.11 / 2.9 87 Access not achievable from south from Rochdale Side of Brockwell Lane, Road due visibility and existing access Triangle, Sowerby Bridge, arrangements whereby 2 accesses are in close HX6 3PQ proximity. Access is also un achievable from Brockwell Gate which is an un adopted road. Access would need to come from LP1412 therefore ransomed. Further to this, accessing both sites off Lower Brockwell Lane is also not suitable or achievable. Site is also far too steep to viably develop. Site can therefore not be accessed or developed. LP1412 - Land North of, 0.61 / 0.28 8 As above, access not suitable Lower Brockwell Lane, Sowerby Bridge, HX6 3PB LP1078 - Land between, 10.62 / 5.15 149 There has been no interest in this site from any Dewsbury Road and New Hey developers despite active marketing. This is due to Road, Rastrick, Brighouse, the poor ground conditions (Elland flag sub strata) HD6 and poor access. Site is considered unviable. LP1216 - Land of, Mill Lane 9.6 / 6.57 197 Council state access is to come via Mill Lane. Mill and Old Lane, Boothtown, Lane is not suitable, and therefore the only way to Halifax, HX3 6TP access the site is through allocation LP1229. However, LP1229 will not come forward due to access and ownership issues. Site levels also differ dramatically. LP1229 - Near royd, 16.68 / 15.79 474 As referred to above, this site can only be accessed Ovenden, Halifax HX3 6TP via a new bridge which requires 3rd party land. It is understood that the 3rd party landowner is unwilling to release this land. Notwithstanding these issues, the site topography also renders it undeliverable. LP0782 - Land off Cock Hill 5.86 / 5.52 166 Access is not suitable to deliver this and adjacent Lane, Shelf, Halifax allocation 1543 (discussed below) as the highway is not wide enough. LP1543 - Land North and 11.17 / 11.02 331 Site can only be accessed via above site LP0782. North West of, Wase House Access is not suitable as it is ransomed off Wade Road, Shelf, Halifax House Avenue and not achievable off Wade House Road. 2020 additional allocations LP0573 - Land adjacent Mill 2.81 / 2.35 200 The site is predominantly Flood Zone 3 and should Royd Street, Mill Royd Street, not be allocated when there are other sequentially Brighouse, HD6 preferable sites available. The site also contains multiple landowners offering established services, making it very difficult to tie up landowners to deliver comprehensive development. LP0983 - Land at, Maltings 1.35 / 0.91 30 The majority of the site is covered by TPO trees Road, Wheatley, Halifax and is undevelopable. In addition, the approach roads are unsuitable to support additional residential development. LP1128 - Land off Park Lane, 1.06 / 1.06 38 Narrow site with steep topography. Access road Siddal, Halifax, HX3 width is unsuitable to achieve development. LP1409 - Wood Lane, Off 4.31 / 3.63 109 Persimmon is the only developer which has met Ovenden Wood Road, with the site owner for this site. It is not being Wheatley, Halifax, HX2 0TQ promoted by any developer as part of this consultation. Very steep topography renders the site undevelopable. Only road frontage is to Wood Lane which Council’s Highways Officer’s state is too steep with poor visibility. Site is surrounded by
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Green Belt on all 4 sides. Its allocation would result in Green Belt release beyond the site itself to provide new robust Green Belt boundaries. LP1567 - Land adjacent to 20.53 / 15.88 445 Landowner is only interested in selling the north Exley Lane, North of Elland, eastern half of the allocation for housing. The Elland remainder (south of the railway) will continue as a caravan park. Allocation capacity should be reduced to 220.
3.18 The total shortfall resulting from the failure to deliver housing at the above sites would be 2,186 homes. We would encourage Council officers, and potentially in due course the Inspector, to visit each of these sites and consider whether any willing developer, be they a large plc or small local builder, could feasibly develop these sites for housing when the above constraints have been taken into consideration. Windfalls
3.19 The decision to include a windfall allowance in the calculation of net housing requirement is based on past windfall delivery rates from 2008/09 – 2015/16 (paragraph 4.11 of the Housing Technical Paper). Over this period, an average of 328 dwellings per annum have been delivered on windfall sites, although the number of windfalls delivered each year has been generally falling over this time, from 564 in 2008/09 to 131 in 2015/16 (Table 1, Annex 1 of Housing Technical Paper).
3.20 Given the trend of falling windfall delivery it is considered inappropriate to increase levels going forwards, thereby relying on housing needs to come from unknown sources. In the context of very poor levels of housing delivery in Calderdale, as evidenced by the 2019 HDT results, the most certain way to meet housing needs is by allocating sufficient land rather than rely on windfall sites. Flexibility
3.21 In our previous representations on behalf of Persimmon we have commented on the lack of flexibility in the proposed site allocations. The Council now claims to have increased the degree of flexibility by identifying a total supply of 15,064 homes compared to a minimum requirement of 14,950 (a difference of 114 homes).
3.22 This difference is equivalent to 0.8% of the minimum housing requirement and still does not provide enough flexibility to ensure that the Local Plan is sufficiently robust to deal with changing circumstances and unforeseen issues of site deliverability. A sufficient flexibility allowance also allows for choice in the land market and provides the opportunity to delivery housing above the planned minimum requirements should the demand exist in the future.
3.23 As set out above, the draft Local Plan is reliant on the delivery of some large allocations, in particular the two Garden Suburb sites at Brighouse/Rastrick. Persimmon has serious reservations regarding the delivery of these sites due to the Council’s assumed lead-in times and delivery rates. Should these sites, or any other proposed allocations, not deliver in full during the plan period, for any reason, then the Plan will fail to meet its identified housing requirement.
3.24 It is considered illogical that a lapse rate is applied to extant planning permissions, but not to site allocations, which in most cases are subject to less technical scrutiny than applications and are often allocated without a willing developer or site promoter. On this basis, and in light of the likely shortfalls in delivery at the Garden Suburb sites, the inclusion of a 10% flexibility allowance on all allocations is advocated. The Local Plan cannot be considered to be positively prepared without such an allowance.
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Summary
3.25 In this section we have highlighted a number of issues with the Council’s general approach to identifying the Local Plan housing land supply, including unjustified amendments to existing but unspecified draft allocations and the failure to provide a sufficient flexibility allowance. We have also demonstrated the significant shortfalls in housing delivery which are likely to arise as a result of the over-estimated delivery at the Garden Suburb sites and the allocation of other sites which have been shown to be undevelopable.
3.26 In the table below we illustrate the cumulative effect these matters will have on likely housing delivery across the plan period if the Local Plan remains as currently drafted and further sites for housing are not allocated. Lichfields Scenario 1 is based on the same housing requirement as now advocated by the Council; Lichfields Scenario 2 is based on what is considered to be the correct minimum housing requirement as discussed in Section 2.0 of this representation.
Table 3.3 Housing Requirement and Supply Scenarios Calderdale Lichfields Scenario 1 Lichfields Scenario 2 A OAN (10 x 1,040) + (5 x 910) (10 x 1,040) + (5 x 910) 1,140 B Plan Period requirement 14,950 14,950 15,600 (A x 15) C Extant Planning - 1,888 -1,888 -1,888 Permissions (+ 10% lapse rate) D Windfalls - 1,294 E Residual requirement (B – 11,768 13,062 13,712 (C+D)) F +10% flexibility allowance N/A 1,306 1,371 should sites not deliver as anticipated G Total amount of homes 11,768 14,368 15,083 to be provided on new allocations (E + F) H Site Allocations Capacity 11,882 7,4633 7,4633 F Surplus / Shortfall (G – H) 114 dwelling over-supply 6,905 dwelling shortfall 7,620 dwelling shortfall
3.27 A significant number of additional available and deliverable housing sites will need to be identified in the emerging Local Plan in order to address the inevitable shortfall in delivery and reverse the trend of persistent under-delivery in Calderdale.
3.28 Even if the Council were to ignore our evidence regarding the delivery of the Garden Suburb sites and maintained the estimated delivery set out in its Statements of Common Ground for those sites, it would still result in a shortfall of 5,693 homes based on a requirement of 997 dpa, or 6,408 homes based on a requirement of 1,040 dpa.
3 Publication Draft Capacity of 9,460 plus 2,094 capacity of new sites put forward in current consultation (=11,554) minus 1,905 shortfall at Garden Suburb sites (=9,649) identified at para 3.16, minus 2,186 shortfall at other sites (=7,463) identified at para 3.18
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4.0 Proposed Additional Sites
4.1 Persimmon fully supports the inclusion of the following additional sites within the emerging Local Plan to meet identified local housing needs. The sites are fully within the control of Persimmon Homes and are available for development now. Hall Lane, Northowram (ref: LP0766)
4.2 This site was previously proposed to be allocated in the Local Plan Initial Draft (2017) and was only removed from the Publication Draft of the Plan following the Council’s decision to set a lower housing requirement using the government’s standard method for assessing local housing needs. The Council has therefore already concluded that the site is a suitable and sustainable location for housing and it is therefore entirely logical and reasonable that this site is now to be allocated in the context of a higher housing requirement.
4.3 The following information has previously been submitted to the Council during previous rounds of consultation on the emerging Local Plan:
• Site Masterplan
• Transport and Access Appraisal
• Landscape Statement
• Preliminary Ecological Appraisal
4.4 The above assessments can be made available again should the Council wish to receive further copies.
Developable Area and Heritage Constraints
4.5 The draft allocation has an indicative capacity of 120 units based on developable area of 3.08 hectares and a development density of 39 dwellings per hectare (total site area is 5.81 hectares). The Council’s Site Report notes that the developable area has been reduced to avoid the tree belts which are protected by a Tree Preservation Order, and also to protect the setting of the Grade II* listed Marsh Hall which is located 150m north of the site boundary.
4.6 Lichfields has undertaken an appraisal of the significance of Marsh Hall and its setting, and the historical evolution of site LP0766. This appraisal is included at Appendix 1 of this representation.
4.7 It is thought that before the 1850s the proposed development site was an open field and was probably visible from Marsh Hall in the context of the wider agricultural setting. The rural character is still evident through the separation of Marsh Hall from Northowram. Other than its general rural context, Marsh Hall does not appear to have commanded any particular views across the immediate landscape.
4.8 The view south from Marsh Hall towards the proposed development site was, from the mid-19th century, enclosed by a belt of trees which separated the site from three smaller fields to the north. While a view of the proposed development site is currently possible from Marsh Hall, it makes little or no contribution to the significance of the 16th-century house over and above a general rural setting. The tree belt is shown to have been broken on the OS Map of 1968. Aerial photographs of the site show that the break in the tree belt has been maintained to the present day.
4.9 Persimmon has prepared a masterplan for the site which proposes the re-establishment of the historic tree belt at the northern boundary of the site with native species to reinstate the historic
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planting and contain views of the site (Figure 4.1). Persimmon’s indicative masterplan could provide 174 dwellings at the site.
4.10 The appraisal finds that the proposal would follow historic precedent and closely reflect the existing view which is defined by the tree boundary to the south. Screening the site by reinstating the historic tree belt will also allow for the most efficient use of the allocation.
4.11 It is therefore considered that there is no reason to restrict the developable area of the site as is currently suggested in the Council’s Site Assessment. The requirement to infill the tree belt at the north of the site could be listed within the ‘Site Specific Considerations’ in the Local Plan.
Figure 4.1 Indicative Masterplan
Site Summary
4.12 The removal of the site from the Green Belt is considered to be justified. The strength of the revised Green Belt boundary will not be compromised as a result of the allocation. The TPO woodland at the site would remain and would form an integral landscape feature within the development.
4.13 A Transport and Highways Assessment has been undertaken which shows that the site is accessible and a suitable access can be provided from Hall Lane – Upper Lane would not be required for vehicular access.
4.14 The heritage appraisal at Appendix 1 of this representation has demonstrated that there is no need to removal the northern parcel of the site from the developable area, and that there is historical precedent for the reinstatement of the woodland belt at the norther part of the site which would screen any development from Marsh Hall. The site is capable of delivering 170 – 180 homes.
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Land off Soaper Lane and Land at Burned Road, Shelf (LP1034 and 1035)
4.15 Persimmon has control of both of these sites which are located adjacent to each other. Both sites were previously proposed to be allocated in the Local Plan Initial Draft (2017) and were only removed from the Publication Draft of the Plan following the Council’s decision to set a lower housing requirement using the government’s standard method for assessing local housing needs. The Council has therefore already concluded that the sites are suitable and in a sustainable location for housing and it is therefore entirely logical and reasonable that this site is now to be allocated in the context of a higher housing requirement.
4.16 The following information has previously been submitted to the Council during previous rounds of consultation on the emerging Local Plan:
• Site Masterplan
• Green Belt Review
• Transport and Access Appraisal
• Ecology Report
4.17 The above assessments can be made available again should the Council wish to receive further copies.
Site Summary
Figure 4.2 Soaper Lane / Burned Road Indicative Masteplan
4.18 It is noted that the combined indicative capacity of these sites has now reduced from 106 in the Local Plan Initial Draft to 85. It is unclear why the indicative density and capacities of the sites
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has reduced; however Persimmon has prepared a masterplan which shows how the sites could be laid to provide approximately 100 homes (Figure 4.2).
4.19 The sites are sustainably located. Michaels’s Primary School and Shelf Junior and Infant School lie within 0.5km and 1km of the sites respectively. Bus links are available within 400m of the site from both Carr House Road and Copper Lane and these provide regular services to Halifax, Bradford and Leeds. The centre of Shelf is located 400m to the south.
4.20 The Council’s ‘Greenbelt Review Final Report 2016’ concludes that Green Belt Parcel ‘GB196-00’ in which both sites LP1034 and LP1035 are located, is a ‘Mid Sensitive Green Belt Parcel’ which meets only 0 – 2 of the identified purposes of the Green Belt. A separate Green Belt Review by Pegasus Group found that sites performed poorly against all five Green Belt purposes identified in the NPPF, and that they had low landscape value. It is therefore considered that the removal of these sites from the Green Belt would be justified.
4.21 The Council’s Site Assessment Report for both sites concluded that their development would not have a significant impact on the road network, and separate highways assessment work commissioned by Persimmon concurs with these findings.
4.22 There are no known heritage or ecological constraints on or within the vicinity of the sites, and both land parcels lie within Flood Zone 1.
4.23 It is also noted that the Council is proposing to allocate the field immediately to the south of LP1035 for residential development (LP1036). Persimmon have been in discussions with the landowner for this site with a view to bringing all three land parcels (i.e. sites LP1034, 1035 and 10360) forward together as part of a comprehensive development. Persimmon’s initial masterplan for sites LP1034 & LP1035 already shows a potential road link to serve this land.
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5.0 Further sites needed to meet Housing Requirement
5.1 As demonstrated in Section 3.0 of this representation, the Council has failed to identify sufficient sites to meet the minimum local housing needs for the plan period. It is considered that additional sites with sufficient capacity to provide at least 5,500 homes need to be identified to meet the Council’s 997 dpa requirement. This would rise to 6,197 homes to meet a 1,040 dpa requirement in order for the plan to be considered positively prepared in accordance with paragraph 35 of the NPPF.
5.2 The two sites discussed below are within the control of Persimmon Homes and are available for development now. The sites could make a significant contribution towards meeting the current shortfall in housing capacity if allocated in the Plan. Lower Edge Road, Elland (ref: LP0220)
5.3 This site was previously proposed to be allocated in the Local Plan Initial Draft (2017) and was only removed from the Publication Draft of the Plan following the Council’s decision set a lower housing requirement using the government’s standard method for assessing local housing needs. The Council has therefore already concluded that the site is a suitable and sustainable location for housing, and it should therefore be allocated ahead of those new allocations listed in Table 3.2 of these representations which have been demonstrated as being undevelopable.
Figure 5.1 Lower Edge Road - Indicative Masterplan
5.4 Representations have been submitted to both the Initial Draft and Publication Draft consultations which have demonstrated how the land under the control of Persimmon Homes, which fronts onto Lower Edge Road, could provide up to 170 homes (see Figure 5.1). The representations submitted to the Initial Draft consultation also included the following technical documents which demonstrate the site’s deliverability:
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• Landscape Statement
• Heritage Plan
• Transport and Access Appraisal
• Ecology Report
5.5 In summary, it is considered that the removal of this site from the Green Belt is justified given that a strong defensible Green Belt boundary will be achieved. A Green Belt review by Pegasus Group (included with Persimmon’s previous representations on this site) concurs with the Council’s findings that the revised Green Belt boundary would continue to perform strongly when assessed against the five Green Belt purposes following the allocation of the site.
5.6 The Council’s Site Assessment Report notes that the site has heritage constraints resulting from its location within the setting of Elland New Hall (Grade I listed) and Appleyard Farm (Grade II listed). With regards to Appleyard Farm, this would remain in situ following the development of the allocation, and the openness immediately surrounding the building will not be affected and it is considered that no impact will occur on the setting of the asset. This view is shared by the Council in its Site Assessment Report.
5.7 The potential for impact on Elland New Hall is more sensitive given its Grade I status, however the land to the south and east of this building (western part of the allocation) is outside of Persimmon’s control. It would therefore be possible to develop the balance of the allocation within Persimmon’s control for up to 170 units and keep this land permanently open to respect the setting of the asset. Indeed, this mitigation has been recommended by the Council and Historic England and could be implemented without impact to the delivery of Persimmon’s proposal for the site.
5.8 A suitable access is capable of being achieved within land under the control of Persimmon at the site frontage along Lower Edge Road. Minor contributions to strategic highway network will be provided if required at the design stage. Upper Lane, Northowram (ref: LP1141)
5.9 Persimmon has control of rejected site LP1141. The extent of this ownership is shown edged blue on the site plan at Figure 5.2. The site is currently designated as Safeguarded Land is proposed to be white land (i.e. no specific allocation) in the emerging Local Plan. It’s allocation in the emerging Local Plan would therefore not result in any further Green Belt release. The site was also identified as a New Housing Site in the Council’s Potential Sites & Other Aspects of the Local Plan consultation (2015).
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Figure 5.2 Site Location Plan
5.10 A full planning application will shortly be submitted to the Council relating to the area edged red on the above site plan. This application will address the heritage issues which were raised during the determination of application 17/01431/FUL.
5.11 It is considered that the site is a suitable and sustainable location for housing development which, due to its size, could deliver new homes within the first five years of the plan period.
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6.0 Conclusions
6.1 This representation to the Housing Requirement Update and Potential Supply consultation has been produced on behalf of Persimmon Homes (West Yorkshire). It has analysed the proposed uplift to the emerging Local Plan housing requirement, and also the newly identified sites which are intended to meet this revised requirement. It is concluded that, despite the changes proposed by the Council, the emerging Local Plan will remain unsound.
6.2 The Council’s decision to support the ‘policy on plus transport’ 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. 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).
6.3 The Council has failed to provide sufficient evidence for why it is not allocating land with an equivalent capacity to the uplift created by the new housing requirement. The consultation document suggests that the capacity of a number of previously identified draft allocations has been amended to account for this discrepancy, however no evidence has been provided to illustrate which allocations have been amended. The Council must make this information available for assessment or identify further sites to make up for this 256 home shortfall.
6.4 A number of previously identified issues with existing draft allocations have not been addressed in this consultation. The Council agreed through a Statement of Common Ground that site LP1463 would not deliver the full capacity stated in the Publication Draft Local Plan, and that the site would fall short of this capacity by the order of 693 homes. The Council’s report to the Local Plan Working Group dated 9th October 2019 attempts to reverse this agreed position by claiming that modern methods of construction will result in increased rates of delivery in the latter years of the plan. No evidence as to what these modern methods of construction are or how they would be employed at site LP1463 has been provided, and this claim is unjustified.
6.5 The concerns which we have previously raised regarding the delivery of the Garden Suburb sites also remain unaddressed, and the delays to the Local Plan examination caused by this additional consultation have compounded this issue. It is now considered that the shortfall in delivery from both Garden Suburb sites will amount to approximately 1,900 homes.
6.6 In addition to the shortfall in delivery at the Garden Suburb sites, we have demonstrated that a significant number of the sites put forward in this consultation, as well as a number of previously identified sites, are simply not deliverable. We would urge officers to closely read our comments on these sites and also visit each of the sites we have highlighted, where it will become instantly apparent that these sites could not feasibly support housing development.
6.7 The cumulative shortfall in housing delivery is estimated to amount to approximately 6,900 homes based on the Council’s 997 dpa requirement and with the inclusion of a 10% flexibility allowance. This shortfall rises to 7,620 homes based on the evidenced need of 1,040 dpa. Even if the Council were to ignore our evidence regarding the delivery of the Garden Suburb sites and maintained the estimated delivery set out in its Statements of Common Ground for those sites, it would still result in a shortfall of 5,693 homes based on a requirement of 997 dpa, or 6,408 homes based on a requirement of 1,040 dpa.
6.8 In the context of the persistent under delivery of housing in Calderdale, as evidenced by the 2019 HDT results (48%), it is of upmost importance that the emerging Local Plan includes sites which can be demonstrated as being available and deliverable, with willing landowners and developers on board from the outset.
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6.9 The sites at Hall Lane, Northowram (LP0766) and Soaper Lane/Burned Road, Shelf (LP1034 & LP1035) have been demonstrated to be suitable and deliverable sites and their proposed inclusion within the emerging Local Plan is fully supported. It is also recommended that the sites at Lower Edge Road (LP0220) and Upper Lane (LP1141) are included within the Plan as part of a suite of additional sites to meet the shortfalls identified in this representation. All these sites have previously been deemed suitable for allocation in earlier drafts of the plan.
Pg 18 Calderdale Local Plan: Appendix 1 Hall Lane Heritage Appraisal
Appendix 1 Hall Lane Heritage Appraisal
Heritage Briefing Note
Our ref 50725/01/CD/Jfr Date February 2020 From Lichfields
Subject Hall Lane, Calderdale - Heritage Advice Note
1.0 Introduction 1.1 This heritage note assesses the suitability of residential development on the proposed development site at Hall Lane, Calderdale, to the north of Northowram. It establishes the historic development of the surrounding area and details the significance of Marsh Hall (grade II* listed) and the contribution made by its setting. The note concludes by assessing the options for a policy compliant scheme that avoids adversely affecting the significance of Marsh Hall.
Summary
1.2 While the historic setting of Marsh Hall was defined by agricultural uses, this note establishes that the proposed development site has been used historically for quarrying and for much of the 19th and 20th centuries was concealed from view by an extensive tree belt around the site’s perimeter. Surrounding 20th-century housing developments to the east and south of the site have further changed the wider setting of Marsh Hall, reducing its sensitivity to change. The proposed development site does not contribute to the significance of Marsh Hall but does form part of its setting.
2.0 Historic Development 2.1 The area around the proposed development site saw the establishment of many small settlements and the widespread clearance of woodland for farming and quarrying from the 13th century onwards. By the 17th century the area had become wealthier and more prosperous than surrounding areas because of the high-quality of agricultural land around Northowram and the concentration of yeomen clothiers in the area. Marsh Hall was originally built in the mid-16th century to the north of the site, but was added to in 1626. Marsh Hall predates the township of Northowram, which was formed in 1662.
2.2 In the mid-19th century the area was still developing as the population of nearby Halifax expanded with the growth of the cloth trade. The OS Map of 1852 shows that the site comprised a range of open fields in agricultural use, with farm buildings facing Upper Lane and Hall Lane.
2.3 The 1894 OS Map (surveyed in 1888) (See Table 1) reveals that a large tree belt had been established around the site, separating the site from three smaller fields to the north. The southern portion of the site, referred to as the ‘North Field’, has been turned into a sandstone quarry named ‘Park Quarries’ on the OS map. This comprised seven separate quarry shafts and a range of outbuildings associated with the works. The tree belt screened it from view.
2.4 The OS Map of 1908 (surveyed in 1905) shows that the quarrying activities had ceased at the site and the shafts and outbuildings had been removed, but the tree belt was retained. This reflected the general downturn of quarrying in the area, with the last stone mine closing in 1922.
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2.5 The tree belt that separated the three small fields to the north from the former quarry site is shown to have been broken on the OS Map of 1968. Aerial photographs of the site show that the break in the tree belt has been maintained to the present day. Two large housing developments have been built to the east and south of the site in the last twenty years, including one built in the 1990s adjoining the Northowram Conservation Area and the southern boundary of the proposal site. Another was built in 2002 on the site of the former Northowram Hospital.
Table 1 Table showing the historic development of the site (green highlighted area is Marsh Hall)
Map Year Description Surveyed 1888 The map reveals a tree Published 1894 boundary existed around the perimeter of the site, concealing Park Quarries. Open fields and farm buildings are apparent to the north, east and west of the site.
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Map Year Description Surveyed 1905 The map reveals the Published 1908 loss of Park Quarries. The surrounding area experiences little change.
2015 The aerial photograph of the site shows a break in the tree boundary along the northern boundary of the proposal site. This break was made after 1955. To the north east a housing development was constructed c.2002 on the site of the former Northowram Hospital (built in the 1960s).
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Significance of Marsh Hall
2.6 Marsh Hall is a grade II* listed building that was originally built in 1550 as a yeoman clothier’s hall house with later additions made in 1626. It is a traditional building, with a single-storey centre and two-storey cross wings. The building features a very large tripartite range of mullioned and transomed windows to the centre. The building also features an arched and moulded doorway. The interior has an original decorated plaster ceiling dating from 1635.
2.7 Marsh Hall is significant as a rare example of a Pennine vernacular yeoman clothier’s hall house. The building has historic value associated with its rarity, age and its connection with the growth and prosperity of the area in the 16th and 17th centuries. It provides evidence of the wealth that the area’s yeoman clothiers made by supplementing their farming income by regularly supplying the local market with cloth. It also has architectural and aesthetic value associated with its design, materials, windows and plasterwork.
3.0 Setting of Marsh Hall 3.1 Marsh Hall stands in a rural setting north-west of the centre of Northowram and is set back slightly on the north side of Lands Head Lane. Marsh Hall previously formed part of a group of buildings with a single aisled barn to the west and outbuildings to the north. Marsh Hall has a long planning history including alterations and improvements together with ancillary outbuildings and this has changed both the main building, buildings within its curtilage and the immediate setting of the hall.
3.2 The wider setting of Marsh Hall has also changed considerably since the 19th century through quarrying activity, the planting of tree belts, the post-war construction of Northowram Hospital and the subsequent redevelopment of the hospital site for residential use. Other 20th century housing developments have also been built on the outskirts of Northowram immediately to the south of the proposed development site, although these are entirely screened from view by the mature tree belt around the site.
3.3 It is thought that before the 1850s the proposed development site was an open field and was probably visible from Marsh Hall in the context of the wider agricultural setting. The rural character is still evident through the separation of Marsh Hall from Northowram. Other than its general rural context, Marsh Hall does not appear to have commanded any particular views across the immediate landscape. The view south from Marsh Hall towards the proposed development site was, from the mid-19th century, enclosed by a belt of trees. While a view of the proposed development site is currently possible from Marsh Hall, it makes little or no contribution to the significance of the 16th-century house over and above a general rural setting.
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4.0 Proposal
Figure 1 Persimmon Indicative Masterplan 2017
4.1 The indicative masterplan of the site proposes the following design features:
• Vehicular access from Hall Lane, using the historic means of access to the site;
• Residential development and means of access, including primary, secondary and tertiary roads;
• Infilling exposed sections of the existing tree belt with native species to reinstate the historic planting and contain views of the site; and
• Retaining the existing field boundary stone wall where possible.
5.0 Potential Impact of Development
5.1 The wider setting of Marsh Hall has experienced change throughout the 19th and 20th centuries and the setting now features recent residential developments alongside open fields and copses of trees. The development of the site would see the reuse of the former quarry site and the re- establishment of the historic tree belt. This would therefore follow historic precedent and closely reflect the existing view which is defined by the tree boundary to the south. If the site was to be developed without re-establishing the planting other mitigation measures such as providing public open space to the north of the site might be necessary to limit the visibility of the new housing and minimise harm to the rural setting of Marsh Hall.
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6.0 Design Considerations 6.1 Design options should comply with Calderdale’s emerging built and historic environment policies, including:
• Policy SO6: Historic Environment and Design To conserve the Borough’s heritage assets, maximising their contribution to the wider economic and social objectives of the plan, and to ensure that new development and investment helps to improve and reinforce the local character and identity of Calderdale’s communities through high quality, inclusive design.
• Policy HE1: The Historic Environment Development proposals should conserve, and where appropriate, enhance, the historic environment especially those elements that make a particularly important contribution to the identity, sense of place and local distinctiveness of Calderdale. These include Calderdale’s textile/industrial heritage and landscapes and yeoman houses.
1. Screening – restoring the tree boundary to the north
6.2 The northern boundary of the proposal site was historically contained by a belt of trees that extended around the perimeter of the site. This was created in the mid-19th century, concealing quarrying activities on the site. However, the line of trees was broken along the northern boundary in the 1950s/60s which exposed the fields to the south for the first time in almost 100 years. Restoring the tree boundary and containing the site has a clear historical precedent.
6.3 The current views from Marsh Hall are contained by the southern tree boundary which screens a modern housing estate on the outskirts of Northowram 500 metres to the south. The creation of a northern tree boundary would, therefore, be suitable and would screen the development effectively. This would prevent the creation of a visible belt of development. It would also allow the greatest flexibility for the redevelopment of the site and allow for the most efficient use of the land.
2. Public space allocation
6.4 If the northern boundary were left open and the current line of sight from Marsh Hall could be reflected in the design of the layout. This could be achieved by creating public open space, SUDs or other types of green infrastructure at the northern boundary with the opportunity to potentially retain sightlines through the site. This would limit the visibility of new houses in views from Marsh Hall but would reduce the developable area of the site. This would seem a more drastic and less effective approach to mitigation given that the view from Marsh Hall through the broken northern tree boundary is not historically significant.
3. Retention of stone walls and field boundaries
6.5 The indicative masterplan of the site indicates that the stone wall that divides the northern and southern portion of the development site will be retained where possible within the development. This is a positive design feature which would respect the historic field boundaries which predate the earliest available OS Maps. This would help to retain visible elements of the site’s agricultural use and character.
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4. Appropriate buildings materials and design
6.6 The adopted and emerging heritage policies focus on improving and reinforcing the local character of the area. The nearest conservation area that offers an insight into the character of the local area is the Northowram Village Conservation Area.
6.7 The key characteristics identified in the Northowram Village Conservation Area Character Appraisal (2011) that could be included in the developments include:
• Use of very large flag stones as paving and steps;
• Buildings constructed from local stone;
• Predominance of two storey development;
• Stone and blue slate for roofs;
• Traditional window detailing, with stone surrounds and mullions, with transoms on some properties;
• Dry stones walls along footpaths and streets; and
• Green open spaces. 6.8 Detailed design of any new development would respond to the factors that contribute to this local character in terms of materials, detailing, building forms and townscape.
7.0 Conclusion 7.1 This heritage note has assessed the suitability of residential development on the proposed development site at Hall Lane, Calderdale, to the north of Northowram. Given the historic use of the site for quarrying, the extensive tree belt that conceals much of the site, and in the context of nearby residential developments, the site can accommodate residential development without affecting the significance of Marsh Hall. There is no reasonable justification on heritage grounds alone for reducing the developable area of the site. Leaving parts of the site undeveloped to retain a sense of openness or establish a line of sight from Marsh Hall would attribute undue significance to views which make no contribution to the significance of Marsh Hall. The impact of the development on the setting of Marsh Hall can be more appropriately mitigated by restoring the historic tree belt to the north of the site which would screen the development from view, allowing the site to be developed in its entirety.
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