Geoffrey Prince Associates Ltd 16 Kimble Close, Knightcote, Warwickshire CV47 2SJ
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Geoffrey Prince Associates Ltd 16 Kimble Close, Knightcote, Warwickshire CV47 2SJ Telephone & Fax 01295 770772 Langridge Homes Email [email protected] Ltd 827055 agent Geoffrey Prince Strategic site appraisals, feasibility studies, 196755 development plans, planning applications, appeals and public inquiries for urban and rural regeneration projects, town expansion schemes, housing, retail and PlanningPolicy industrial sites. RushcliffeBoroughCouncil Also, military, airport, tourism and waste DevelopmentControl planning. CivicCentre WestBridgford NOTTINGHAM NG25FE 22March2016 DearSirs Rushcliffe LAPP Part 2 Consultation Ihavebeeninstructedbythelandowners,LangridgeHomesLimited,tomakerepresentationsontheLAPPPart 2. PleasethereforefindattachedastatementsettingourrepresentationstogetherwithaPlanningStatementof thesitewhichLangridgeHomesispromoting(SHLAARef364;GreenBeltAssessmentRefCOT8). The representations are focussed on Chapter 2 Housing Development and Chapter 3 Green Belt, and in particularto: Question 4 where we consider that the LAPP should allocate further greenfield land for housing developmentatCotgrave;and Question20,whereweconsiderthatfurthersafeguardedlandshouldbedesignatedinRushcliffe; Weshouldbegratefulifyoucouldacknowledgereceiptoftheserepresentationsandkeepmeinformedofthe nextstepsintheLAPPPart2process. IamsubmittingseparaterepresentationsontheGreenBeltAssessmentconsultation. Yourssincerely GeoffreyPrince Enc Registered in England and Wales Reg No 4306504 Rushcliffe Borough Council Representations prepared by GPA Ltd LAPP Part 2(b) Green Belt Review for Langridge Homes Ltd LAPP Part 2 Land and Planning Policies - Issues and Options Representations submitted by GPA Ltd on behalf of Langridge Homes Ltd I have been instructed by Langridge Homes Ltd (LH) to comment on the Rushcliffe Borough Council (GBC) LAPP Part 2 Issues and Options. My representations are focussed on Chapter 2 Housing Development and Chapter 3 Green Belt. Langridge Homes Ltd do not consider that LAPP Part 2 will allocate sufficient sites to meet the housing requirements of Core Strategy Policy 3 Spatial Strategy due to uncertainties in the delivery of the three sustainable urban extensions. In order to meet the requirements of the Core Strategy it recommends that: Land for an approximately 2,000 additional houses will need to be allocated on land adjoining the main built up area of Nottingham (Rushcliffe) and on sites adjoining the Key Settlements including at Cotgrave. To ensure that the LAPP is resilient further safeguarded land should be identified and include all land which is assessed as being of low or low-medium Green Belt importance unless there are other policy constraints such as flood risk, environmental and heritage designation, access problems which will pose significant constraints to the delivery of these sites. Our rationale making these recommendations is set down below. Chapter 2 - Housing Development This policy states that a minimum of 13,150 new dwellings will be provided over the plan period 2011-2028, of which 7,650 will be provided adjoining the main built up area of Nottingham (within Rushcliffe). Of these 7,000 are to be provided in three sustainable urban extensions (SUEs). The LAPP Part 2 does not propose to make any further adjustments to meet outstanding requirement of 650, as these can be built on sites within the main built up area. The Core Strategy also proposes that a further 5,500 will be provided beyond the main built up area including 2,020 at sites allocated in the Core Strategy at Bingham (1,000), RAF Newton (550) and the former Cotgrave Colliery (470). The LAPP Part 2 does not propose any further allocations at these locations, but does propose to make additional allocations amounting to 1,500 dwellings at East Leake (400) , Keyworth (450), Radcliffe on Trent (400) and at Ruddington (250). The remainder of the requirement will be made up from SHLAA sites, sites with planning permissions/under construction and infill/change of use sites. Policy 3 of the Core Strategy also set down a delivery pattern, as follows: 2011-2013 - 500 (250 pa) 2013-2018 - 2,350 (470 pa); 2018-2023 – 6,500 (1,300 pa); 2023-2028 – 4,100 (820 pa). The housing trajectory at Appendix D of the Core Strategy shows how the houses will be delivered over the plan period. This Trajectory is appended to these representations. 1 March 2016 Rushcliffe Borough Council Representations prepared by GPA Ltd LAPP Part 2(b) Green Belt Review for Langridge Homes Ltd It is clear that the Spatial Strategy is not working with considerable slippage in housing delivery already recorded and acknowledged by Officers representing Rushcliffe Borough Council at a recent appeal (Decision Date 15 December 2015) (Ref 2277522, Land at Abbey lane, Aslockton) which was allowed on the grounds that the Council could not demonstrate a five year housing land supply. This is despite the Inspector to the Local Plan Core Strategy Public Examination agreeing to the adoption of the ‘Liverpool’ method for calculating housing land supply and the housing trajectory, whereby delays in bringing forward the SUEs and other strategic site allocations would result in a lower housing requirement in the short term (upto 2018) before making up the backlog supply in the second half of the plan period as these sites came on stream However, the evidence regarding the non- delivery of the SUEs and other strategic sites allocated in the Core Strategy outside the built up area is so compelling that it is unlikely that the Council will be unable to deliver its housing provision of 13,150 dwellings over the plan period without a major shift in its housing supply strategy. The table below summaries our understanding of the current planning current status of these sites. This table shows that: By 2020 the three SUEs should have delivered 1,850 dwellings, but given that no planning applications have yet to be submitted for two of the SUEs (at Clifton and East of Gamston), and at the other (Land off Melton Road, Edwalton) planning applications are under consideration, then we consider that only the Edwalton SUE will have delivered any houses by 2020. Optimistically we consider that this SUE may start to deliver in 2018/19 and by the end of 2019/2020 may have delivered around 250 dwellings. This represents a shortfall in supply from this source over the next 5 years of 1,600 dwellings, at a time when supply from the SUEs should be on a rapidly rising upward curve; By 2020 the Core Strategy allocations beyond the built up area should have delivered 1,550 dwellings. The land at former Cotgrave Colliery is under construction and can expected to be complete by 2020 (470 dwellings). Although the other two sites have the benefit of outline planning permissions, they appear to be a long way from submitting reserve matters applications. The land north of Bingham is owned by the Crown Estate and there is no indication of this land being marketed to a developer/housebuilder. On this basis we consider that development at RAF Newton and Bingham will also be delayed. Assuming that development may commence by 2018/19 (an optimistic assumption), then these two sites may deliver around 300 dwellings in total by 2020. Thus the total supply from this source is estimated at 770 by 2020, a shortfall of 780 based on the housing trajectory; By 2020 delivery from other sites/locations (ie SHLAA sites, sites to be allocated in the LAPP Part 2 beyond the built up area and infill/change of use sites is estimated to deliver 2,201 dwellings – we consider that this total is achievable. Thus, between 2011 and 2020 some 5,450 dwellings should be delivered, but the evidence indicates that only 3,221 will be delivered (including completions to date), a shortfall of 2,229 dwellings (approximately 40%). It is unlikely that this shortfall in supply can be made up during the remainder of the plan period, and indeed there may be further delays in bringing forward the SUEs and other allocated sites outside the built up area. Indeed the evidence from the rest of the Nottingham HMA (ie in Gedling and Broxtowe) shows that they too are having difficulties in meeting their housing supply targets due to too much reliance on large complex strategic sites allocated in the Aligned 2 March 2016 Rushcliffe Borough Council Representations prepared by GPA Ltd LAPP Part 2(b) Green Belt Review for Langridge Homes Ltd Core Strategy. The same story emerges from the adjoining Leicester and Leicestershire HMA, where 12 SUEs have been proposed since 2007 and as yet none have delivered any houses, although one has recently started. It is abundantly clear therefore that Rushcliffe will need to make some fundamental adjustments to its LAPP Part 2 by making additional allocations on the edge of the built up area of Nottingham (in Rushcliffe) and also in settlements beyond the built up area. Location Core CS Housing Revised Planning Status Comment Strategy Trajectory Housing Requirement Target by Trajectory 2020 Target by 2020 Main Built up Area of Nottingham South of 3,000 600 Awaiting Planning Unlikely to deliver Clifton SUE Application any houses within timeframe – planning delays, infrastructure requirements, S106/CIL Melton Road, 1,500 600 Outline Planning Potential to start Edwalton SUE applications under delivering consideration towards end of 5 year period – say 250 by 2020 East of 2,500 650 Awaiting planning Unlikely to deliver Gamston SUE applications any houses within timeframe – planning delays, infrastructure requirements, S106/CIL