Castle Point Local Plan Examination 04/21 Matter 5: Housing Allocations
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Castle Point Local Plan Examination 04/21 Matter 5: Housing Allocations Local Policy HO16 Land at Oak Tree Farm, Hadleigh Hearing Statement jb planning associates Chells Manor, Chells Lane, Stevenage, Herts, SG2 7AA e-mail [email protected] url www.jbplanning.com tel 01438 312130 fax 01438 312131 Castle Point Local Plan Examination Hearing Statement for Mr J D Armitage and CALA Homes Matter 5 Contents 1 Q.132 .......................................................................................................... 1 2 Q.133 .......................................................................................................... 2 3 Q.134 .......................................................................................................... 2 4 Q.135 .......................................................................................................... 4 5 Q.136 .......................................................................................................... 4 6 Q.137 .......................................................................................................... 6 7 Q.138 .......................................................................................................... 7 8 Q.139 .......................................................................................................... 8 Appendices Appendix 1 Ecological Statement Appendix 2 Flood Risk and Drainage Statement Appendix 3 Highways Statement Appendix 4 Tree Report and Addendum jb planning associates hearing statement 04/21 Castle Point Local Plan Examination 1 Hearing Statement for Mr J D Armitage and CALA Homes Matter 5 Matter 5: Housing Allocations 1. This hearing statement has been prepared by JB Planning Associates on behalf of Mr J D Armitage (landowner of the HO16 allocation) and CALA Homes and relates to the proposed allocation of land at Oak Tree Farm, Hadleigh (Policy HO16). Issue: Are the proposed housing allocations justified, effective and consistent with National Policy? Local Policy HO16 Land at Oak Tree Farm, Hadleigh Q.132 What is the justification for the site capacity being ‘up to 65 new homes’? 2. In our Regulation 19 representations we raised an objection to Policy HO16 and the reference to the site capacity being ‘up to 65 new homes’. The evidence base supporting the submitted Local Plan (sLP) provides an inconsistent view of the site’s capacity as seen in the SHLAA 2018 schedule of sites (H-008) suggesting a capacity estimate of 61 dwellings whereas the large Site Capacity Assessment Update 2019 (H-013) suggests that the site’s capacity is 65 dwellings assumed to comprise of detached and semi-detached dwellings together with open space. 3. It is a generally accepted principle that site capacities in emerging and adopted Local Plan allocations are based on an estimate of site capacity often applying a gross site area and assumed density. However, the true capacity of a site can only really be tested and determined at the planning application stage where detailed site specific technical work will inform the amount of development appropriate given a whole range of factors such as detailed design, layout, site constraints, protection and retention of existing landscape features, highway access proposals to name but a few. 4. The site promoter’s preference is to avoid artificially constraining the capacity of the site through the use of the term ‘up to’. This concern has been discussed with Council Officers and we note that the Council are promoting a main modification (M10.63) to replace ‘up to’ with ‘around’. We note that this modification is to be made to all of the proposed housing allocations, demonstrating a consistent approach in recognising the restrictive wording of Policy HO16 which we support. jb planning associates hearing statement 04/21 Castle Point Local Plan Examination 2 Hearing Statement for Mr J D Armitage and CALA Homes Matter 5 Q.133 With particular regard to the Great Wood and Dodd’s Wood SSSI, would the Policy be effective in protecting and enhancing biodiversity? 5. Part 3 of Policy HO16 sets out four requirements that development should follow and Requirement c requires that development ‘respects and retains, as far as possible the established hedge and tree-lined field boundaries’. Natural England commented on Policy HO16 at the Regulation 19 stage and while acknowledging the justification for HO16 set out in Paragraph 10.52 which highlights both the Belfairs LNR and the Great Wood and Dodd’s Wood SSSI designations their preference is that Policy HO16 should more explicitly seek the protection of these designations and how biodiversity can be effectively integrated into the development and achieving an overall net gain in biodiversity. 6. In response to this representation the Council are promoting a Main Modification to Policy HO16 (M10.66). 7. In order to determine whether this modification to the policy is required the Ecology Partnership on behalf of the site promoter has undertaken an initial Ecological Assessment of the site and produced a brief Ecological Statement which is at Appendix 1 of this Hearing Statement. While clearly further Protected Species Surveys will be required as part of the preparation of a planning application, we are satisfied that the Main Modification proposed and replacing policy requirement 3 c in the sLP will ensure that Policy HO16 is sound and we therefore support this proposed modification. Q.134 Is the allocation of land for housing within an area of Flood Zone 2 and 3 justified in terms of the sequential test? Would the Policy be effective in applying the results of the Exception Test? 8. The Council have prepared a Sequential and Exception Test for Housing Site Options Review 2020 (CC-014) as well as providing, as part of the evidence base to support the sLP a Strategic Flood Risk Assessment Levels 1 and 2 (CC-009 and CC- 010). 9. The selection of proposed housing sites in the sLP was informed by an earlier Sequential and Exceptions Test paper prepared in November 2018 (CC-007). The latest review of these tests in 2020 (CC-014) has only arisen as a result of modest jb planning associates hearing statement 04/21 Castle Point Local Plan Examination 3 Hearing Statement for Mr J D Armitage and CALA Homes Matter 5 changes to the housing land supply situation and continues to rely on the SFRA Level 2 2018 findings (CC-010). 10. In relation to the land at Oak Tree Farm, Hadleigh (HO16) the Sequential Test results confirms that 90% of the proposed allocation is within Flood Zone 1 with the remaining 10% being in Flood Zone 2 (3%) and Flood Zone 3a (7%). The results confirm that 30 dwellings are deliverable on the site in years 1-5 ie the 5-year housing land supply period. 11. In relation to the Sequential Test results for developable sites this suggests that the remaining estimated site capacity of 35 dwellings is developable within years 6-15 of the plan period. We are unclear how these judgments have been made and confirm that the full capacity of the site can be delivered in the first five years after the adoption of the plan. 12. Turning to the Exceptions Test results set out in Table 5 the Oak Tree Farm site is recorded as having significant positive impacts in relation to sustainability objectives relating to the provision of both market and affordable homes and minor positive impacts relating to other sustainability objectives such as landscape character, flooding and air quality. 13. The wider sustainability benefits of the proposed allocation deal with Part 1 of the Exception Test and we would add that the location of the proposed allocation is highly sustainable being within 10 minutes walking distance of Hadleigh High Street and two Primary Schools at Westwood Academy and Hadleigh Infants School. The site is also within a 5 minute walk of bus services along Daws Heath Road with the nearest bus stop being close to the junction of Daws Heath Road and Central Avenue. 14. The Exception Test Part 2 concerns flood risk management and safety and the Council’s assessment is that as the majority of the site (90%) is within Flood Risk Zone 1 then it is possible, through design, to avoid those parts of the site at risk of flooding which we would fully concur with. We would anticipate that the northern part of the site which is identified at most risk of flooding according to the Environment Agency’s records can provide areas for open space and biodiversity net gain and avoiding development in this small part of the overall allocation. jb planning associates hearing statement 04/21 Castle Point Local Plan Examination 4 Hearing Statement for Mr J D Armitage and CALA Homes Matter 5 15. To support the Council’s evidence on flood risk, further site-specific evidence in relation to flood risk is provided at Appendix 2 of this Hearing Statement. This initial work confirms the position on flooding from rivers and surface water in so far as this affects the extreme northern part of the allocation. The statement also confirms that no development would be proposed within Flood Zones 2 and 3a and also confirms that a suitable sustainable drainage regime can be implemented taking account of the usual attenuation requirements for 1 in 100 year storm events and climate change. Q.135 Would the policy be effective in minimising impacts on and providing net gains for biodiversity consistent with Paragraph 170 of the Framework? 16. It has been established in responding to Q.133 above that the policy as drafted in the sLP would not, in itself, be effective from a biodiversity