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Harborough Local Plan Examination Written Statement Matter 2

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Harborough Local Plan Examination Written Statement Matter 2 Harborough Local Plan Examination Written Statement Matter 2 Prepared for: Client: David Wilson Homes Property: Land at Burnmill Farm, Market Harborough Date: September 2018 INTRODUCTION 1. 1.1. This Position Statement has been prepared by Fisher German on behalf of David Wilson Homes in respect of its land interests Burnmill Farm, Market Harborough (Policy MH3: Burnmill Farm). 1.2. The site is the subject of a Full Planning application for the residential development of the site for 128 dwellings. The application (17/02020/FUL) was made in November 2017 and is anticipated to be reported to Planning Committee in September 2018. An update on the planning application will be provided to the Inspector ahead of the Hearing Sessions commencing. 2 MATTER 2: The housing requirement and its 2. delivery 2.1 Is the uplift of 25 dpa associated with growth at Magna Park appropriate? 2.1. The HEDNA Planned Growth Scenario does not take account of the proposed major distribution scheme located within the M6, M69 and M1 triangle in Harborough; Magna Park. It is right therefore that the Council has taken this into account by increasing the housing requirement by 25 dpa above the HEDNA figure. This will seek to ensure that out commuting is reduced as far as possible in line with the Plan’s objectives. 2.3 Are the assumptions about delivery start dates and rates from the SDAs reasonable? 2.2. The emerging Local Plan relies on the delivery of four large scale sites (Scraptoft SDA – 1,200 dwellings; Overstone Park – 600 dwellings; Blackberry Grange – 350 dwellings; and, Lutterworth SDA – 1,500 dwellings). Sites of such a scale, particularly those in excess of 500 dwellings take a significant time to deliver. 2.3. The Council has already experienced this with the strategic allocation made in the Core Strategy which designated over 1,000 dwellings as part of a ‘Strategic Development Area’ (SDA). Over 8 years since the adoption of the Core Strategy (2011), the SDA has delivered only 36 dwellings 1 . 2.4. These timescales are not unusual for a site of this scale. Evidence collated as part of the NLP ‘Start to Finish’ report (Appendix 1), November 2016, found that the determination period of a planning application for a 500 + dwelling site is in the order of 5.3 to 6.9 years. This is primarily due to the complex planning issues related to both the principle of development and the detail of implementation. Where applications have been determined more quickly than the average, this is as a result of matters being substantially addressed prior to submission which, when combined with the determination period, still adds up to the same amount of time; as the report states “there is rarely a way to short-circuit planning”. The NLP report goes on to state: “Planned housing trajectories should be realistic, accounting and responding to lapse rates, lead-in times and sensible build rates. This is likely to mean allocating more sites rather than less, with a good mix of types and sizes, and then being realistic about how fast they will deliver so that supply is maintained throughout the plan period. Because no one site is the same – and with significant variations from the average in terms of lead-in time and build rates – a sensible approach to evidence and justification is required.” 2.5. The ‘Report into the Delivery of Urban Extensions’ (February 2014), prepared by Hourigan Connolly on behalf of Gladman developments (Appendix 2) undertook a wider view of delivery. It concludes that on average, from submission of the planning 1 Harborough District Council 5 Year Housing Land Supply August 2018, Page 12 3 application through to the delivery of on-site infrastructure and the first dwellings, takes an average of 9 years (note: the Hourigan Connolly report reflects the findings of the NLP Report i.e. for an application of 500+ dwellings it takes in the order of 5.3 to 6.9 years to get to the point of determination). 2.6. The Housing Trajectory (HSG14) sets out delivery of 94 dwellings in 2021/22 and a further 108 dwellings in 2022/23 for the Scraptoft North SDA. Having regard to the above, given that a planning application is yet to be made, delivery in 2021/22 is not considered realistic. It would instead be more realistic to assume delivery of the first dwellings in 2024/25. Similarly, the Lutterworth East SDA, is only recently the subject of a Scoping Opinion. The proposal for 3,000 dwellings requires the delivery on a new road bridge over the M1 motorway. Whilst it is recognised that the delivery of this will be triggered by the delivery of a certain quantum of housing it is considered that the delivery rates proposed are overly ambitions having regard to the issues that will need to be resolved and infrastructure implemented to get the site out of the ground. 2.7. Smaller, immediately deliverable, sites, such as Burnmill Farm, Market Harborough (Policy MH3) are therefore essential to the delivery of the Plan. 2.8. As detailed in the Council’s Housing Trajectory (HSG14), the site can deliver within five years. As set out in response to Matter 8, a planning application (17/02020/FUL) is currently being determined by the District Council. The application seeks planning permission for 128 dwellings. David Wilson Homes have prepared an updated trajectory for the site as detailed below: 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 34 34 34 25 Table 1: Burnmill Farm Trajectory 2.4 Is it sound to rely on the headroom provided by the currently calculated supply of 12,948 dwellings (IC3) to cater for both unmet need from Leicester and any contingency allowance for slower than anticipated delivery from allocated and committed sites? 2.9. The Plan states (para 5.1.10) that Policy H1 provides for delivery of the housing plan requirement, plus an additional 15% contingency in the supply of housing land “to allow for possible future circumstances affecting the supply of housing in the District”. This includes assisting meeting the unmet need from the other HMA authorities as well as, amongst other matters, a slower delivery of sites than anticipated. 2.10. A contingency of 15% is the minimum which the Plan should cater for to allow for slower than anticipated delivery from allocated and committed sites, alone. Indeed, we would argue that the contingency should be 20% to ensure flexibility of the Plan. 2.11. Incorporating the unmet need within the contingency is considered wholly inappropriate. The 15% contingency equates to approximately 83 dpa over the Plan period. Based on the Strategic Growth Plan Leicester and Leicestershire (January 2018) notional housing need and supply figures for the period 2031 to 2050 it is suggested that 83 dpa is far below what will need to be provided for to address the unmet need. The 4 Strategic Growth Plan indicates an uplift on Harborough’s need of an additional 513 dpa. The 15% contingency is therefore very unlikely to address the unmet need of the other HMA authorities and will clearly not address both this, and slower delivery of sites. It is not therefore sound to rely on the headroom, as currently proposed to cater for both the unmet need and any contingency for slower than anticipated delivery from allocated/committed sites. 2.5 Given that the housing requirement would be the basis for the calculation of the 5 year housing land supply, should it be increased beyond 11,140 dwellings or 557 dpa now in order to allow for a proportion of unmet need for Leicester, or should there be a trigger in the plan which increases the requirement once the amount of unmet need has been quantified? 2.12. As detailed in response to Matter 1, Planning Guidance requires the OAN to be satisfied across the housing market area (HMA) as a whole. In this case the HMA includes Leicester City Council and Oadby and Wigston Borough Council; both of which have declared that they are unable to meet their housing needs for the period 2011 to 2031. This approach is re-enforced by the revised NPPF which states that Local Plans are examined to assess whether they have been prepared in accordance with legal and procedural requirements and whether they are sound. A Local Plan is sound if it is effective meaning that it is deliverable over the plan period and based on effective joint working on cross boundary strategic matters that have been dealt with rather than deferred as evidenced by a Statement of Common Ground. 2.13. The LPAs have not yet resolved the distribution for the period to 2031. As set out above, Harborough’s ‘share’ of the unmet need could be significant. 2.14. An early review of the Plan, as proposed by the Council is not considered to be the most appropriate policy mechanism by which to resolve unmet housing need due to the time taken to undertake such a review. If the Inspector is minded to accept an early review of the Plan, it is suggested that additional flexibility is built into the Plan currently being examined and a far larger contingency in the supply provided for. 2.15. Any commitment to an early review should reflect that of North West Leicestershire which had to deal with the same issues of unmet need and commit to a review of the plan to be “commenced within 3 months [of the adoption of the Plan] and submitted for Examination within 2 years”. 5 APPENDIX 1 Start to Finish How Quickly do Large-Scale Housing Sites Deliver? November 2016 Executive Summary There is a growing recognition that large-scale housing development can and should play a large role in meeting housing need.
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