Additional Evidence Letter
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ASHFIELD DISTRICT COUNCIL Urban Road, Kirkby-in-Ashfield, Nottingham, Tel: 01623 450000 East Midlands. Fax: 01623 457474 NG17 8DA www.ashfield-dc.gov.uk Ms J Kingaby, Inspector C/O Ms C Edwards, Programme Officer Loxley House Station Street Nottingham NG2 3NG Contact: Maria Bailey Our Ref: Direct Line: 01623 457383 Your Ref: E-Mail [email protected] Date: 28th January 2014 Dear Ms Kingaby RE: BROXTOWE BOROUGH, GEDLING BOROUGH, NOTTINGHAM CITY ALIGNED CORE STRATEGIES – ADDITIONAL WORK SUBMITTED FOR EXAMINATION FROM GEDLING Members of Ashfield District Council’s Planning Committee and Hucknall Area Committee have considered a report into the additional work submitted for Examination by Gedling Borough Council for the ACS Examination. These considerations resulted in the following comments being put forward for the Inspectors attention. Whilst the Statement of Common Ground is a welcome step forward, Ashfield District Council is disappointed that the document has been submitted to the Inspector prior to Ashfield being consulted. This again highlights the continuing concerns of ADC in Gedling’s approach to ‘Duty to Co-operate’ legislation. ADC will be submitting a separate document outlining any areas of disagreement or where further clarification is required with regard to the Statement of Common Ground. This document will be with you next week. At a meeting between Ashfield and Gedling officers on 10 th December 2013 Gedling presented a set of scenarios to Ashfield which were discussed at the meeting. No decisions or indications were made at the meeting and further information was requested. The Statement of Common Ground does not include details of joint working arrangements/commitment by Gedling to deliver infrastructure in Ashfield. Top Wighay Farm Whilst the more detailed infrastructure requirements have been presented, the Council are concerned at the estimated costs of ‘essential’ works (£13m - £15m) plus the cost of providing affordable homes. Gedling Borough Council now recognise that 30% affordable housing will not be viable for a scheme of this size and 1000 dwellings are required to cross subsidise the employment land allocation at Top Wighay Farm which would P.G. MARSHALL, Chief Executive otherwise be non deliverable. It is noted that the additional information includes a viability appraisal of different scenarios. ADC officers are looking further into the viability information provided. This allocation is presented on the basis that it was safeguarded land in the current Local Plan. This designation came about due to the proposal for the implementation of a tram system, without this the whole allocation and its sustainability should be looked at afresh. The remainder of land is still intended to be safeguarded for development in the future which again raises serious concern. Policy 4 identifies a requirement for 10ha of employment land for Gedling of which 9ha are located on a greenfield site next to Hucknall at Top Wighay Farm. This reflects simply bringing forward a site from the Local Plan 2005 where the Inspector stated that the employment land allocation at Top Wighay Farm was the only viable alternative that was left to the Inspector. It was identified that Top Wighay Farm is relatively remote from the Main Urban Area of Gedling Borough and the areas most in need of new jobs but there was no evidence before him that other sites could be brought forward and this remains the case. In light of this conclusion the allocation needs to be completely reviewed not just carried forward automatically. Gedling’s Sustainable Community Strategy identifies that “Supporting business and retail in the Borough was highlighted as important in our consultation.” It also highlights that 80% of the residents of Gedling are located in Greater Nottingham suburbs of Arnold and Carlton. It is Ashfield’s opinion that the vast majority of employment land at Top Wighay does not serve local people in Gedling Borough as 80% of the residents of Gedling are located in Greater Nottingham suburbs of Arnold and Carlton Ashfield District Council would again raise the viability of this development. To be clear Ashfield District Council does not dispute the amount of employment land required to meet Gedling’s needs but takes issue with the sustainability of the location in meeting the identified needs and the objectives of Gedling’s own Core Strategy vision. North of Papplewick Lane Given that Gedling BC are proposing to reduce the scheme from 600 dwellings to 300 dwellings the cost of essential infrastructure, estimated to be a minimum of £8.25m, plus the cost of delivering affordable housing at 30% will impact on the viability of any future development scheme. It is noted that a planning application has been submitted to Gedling Borough Council for 300 homes plus a school annex and associated open space. It is unclear if the ‘essential’ infrastructure will be delivered if the application is approved at this time as the section 106 discussions are still ongoing. ADC has developed a response to this application following consultation. Gedling Borough Council’s previous approach to this site involved the development of a masterplan if the reduction is pursued then the overall aims and objectives of the masterplan would be undeliverable and would require a fresh approach. P.G. MARSHALL, Chief Executive With regard to flooding, it is noted that the Environment Agency has objected to the scheme due to the lack of information about the drainage scheme proposed. It is unclear what costs will be associated with any future scheme at this stage. Taking all the evidence into consideration, Ashfield DC has serious concerns that the necessary infrastructure cannot be delivered. Bestwood Village The arguments against any development for Bestwood village remain the same as for the previous sites. Although the allocation has been substantially reduced from 500 to 200 dwellings it is still a large scale development for a village of this size and will result in infrastructure requirements that are non deliverable due to cost versus profit from the scheme. Summary of Ashfield’s concerns 1. At the time of the Examination in Public it was not considered by Ashfield District Council that the impact on the infrastructure of Hucknall of the specific allocations of Top Wighay, North of Papplewick Lane and Bestwood Village combined with the proposals set out in the emerging Ashfield Local Plan had been fully assessed in the Aligned Core Strategy or the Infrastructure Delivery Plan. This prejudices current and future scope for development in Hucknall by “mopping up” any existing infrastructure capacity whilst providing no ongoing support for infrastructure. Whilst the evidence produced by Gedling BC since the EIP is positive, it is still unclear if the infrastructure requirements set out have undergone a viability assessment and if they are deliverable and still places pressure on Ashfield District Council in terms of the future. Whilst a Protocol for Management of section 106 Planning Obligations has been proposed, it falls well short of a definitive agreement on how planning obligations and any CIL will go towards meeting the additional burdens placed on Hucknall’s infrastructure. The Protocol has not been amended since the EIP and Gedling Borough Council has made no effort to do so to alleviate Ashfield’s concerns although it is likely that a revised draft will go before their Members in April of this year. However, this would be easily reviewed and gives no comfort. As such, there is no firm commitment by Gedling to work with Ashfield to deliver the infrastructure. 2. Gedling Borough Council has not sufficiently addressed Ashfield’s concerns regarding the impact of development in Gedling Borough on the delivering of development in Hucknall. Nor justified the requirements for sites adjacent to Ashfield District Council’s boundary rather than their own boundary. Although there have been meetings between the two Councils to discuss Gedling BCs proposals on the boundary of Hucknall, Ashfield DC considers that it has not received sufficient information from Gedling BC to address many of the questions raised about the delivery of infrastructure in Hucknall and, as far as Ashfield DC is concerned, there are still unresolved issues to address. 3. Ashfield has concerns that if development proposed on the boundary comes forward first it will compromise the delivery of development in Ashfield by absorbing existing infrastructure capacity. This would jeopardise Ashfield’s position with regard to meeting the District’s objectively assessed housing needs. In terms of education, the questions raised by Ashfield DC are still unanswered. Questions to address include: P.G. MARSHALL, Chief Executive Q. Will the proposed developments at Top Wighay and North of Papplewick Lane meet the requirements for on-site Primary School provision as set out in the Aligned Core Strategy IDP? Q. Has Gedling BC determined if the secondary schools in Hucknall can meet the combined development requirements? Q. Can the requirement for secondary school provision be met at Holgate Academy? Q. If not, where will a new secondary school be located to address this requirement? Whilst it is acknowledged that Nottinghamshire County Council has indicated that Holgate Academy is capable of accommodating the additional number of pupils anticipated from developments in Ashfield and Gedling, this was subject to a feasibility study being undertaken. It is unclear if a feasibility study has yet been undertaken and it is also unclear if the Holgate Academy has been consulted at this stage. With regard to transport, at the time of the EIP Ashfield did not consider the evidence produced by Gedling was sufficient. Whilst it is acknowledged that additional work has been undertaken, it is unclear if the infrastructure requirements can be delivered at this stage when you take into account the viability evidence that has been submitted. This is also the case for health requirements.