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For and on Behalf of Mr Neil Prior

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For and on Behalf of Mr Neil Prior For and on behalf of Mr Neil Prior REPRESENTATIONS TO ROTHERHAM METROPOLITAN BOROUGH COUNCIL SITES AND POLICIES PUBLICATION VERSION 2015 Land between Worksop Road (A57) and Sheffield Road (B6059), South Anston Prepared by DLP Planning Limited Sheffield November 2015 Mr Neil Prior Prepared by: Ben Mitchell BA (Hons) MPlan Planner Approved by: Michael Edgar BA (Hons) DIP TP MRTPI Director Date: November 2015 DLP Planning Limited V1 – Velocity Village Tenter Street Sheffield S1 4DE Tel: 0114 228 9190 Fax: 0114 272 1947 DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning Limited accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk. 2 Land between Worksop Road (A57) and Sheffield Road (B6059), South Anston \\Sheffield-Svr\Job Files\Yorkshire\YK\YK2138 - YK2600\YK2306-1\Final Rep 2015\YK2306-1_Representations_Land Between Worksop Road And Sheffield Road_South Anston.Msg.Doc Mr Neil Prior Contents Page 1.0 INTRODUCTION 5 2.0 ISSUES OF SOUNDNESS 7 Introduction 7 Case law 8 Adopted Core Strategy 9 Emerging Sites and Policies DPD 10 Progress since the Core Strategy was adopted 11 The Chelmer Model and OAN as set out in the Framework 12 National Planning Policy Framework 13 The Approach to Objectively Assessed Need in the Framework 14 The Planning Practice Guidance 14 The importance of meeting affordable housing needs 17 Conclusion on Approach to the Objectively Assessed Need for Housing 17 The approach to the Objectively Assessed Need for Housing 17 The two stages to determining the Objectively Assessed Need for Housing 18 Core Strategy Housing Need 19 Employment growth 20 Patterns of Commuting 20 House prices and affordability 21 Affordable Housing 22 The SPRU Chelmer Model Assessment 23 The Evidence Base 24 The Starting Point 24 Activity Rates and the impact of changes to the pension age 25 Household representation rates 27 Summary of projections and associated assumptions: 31 Commentary on output of modelled scenarios 34 Delivery of Large Sites 35 Assumptions regarding timescales and delivery rates 36 Five year land supply 38 Summary of the Sites DPD SA/SEA process 39 Summary and changes that need to be made to ensure the proposed plan is sound and legally compliant? 39 3.0 COMMENTS ON POLICIES 42 National Planning Policy Framework (The Framework) 42 The test of soundness 42 Positively prepared 42 Justified 43 Effective 44 Consistent with national policy 44 General objections regarding soundness 44 Policy SP1: Sites Allocated for Development 46 Policy SP 11 – Five year Housing Supply 46 Policy SP 16 – Land Identified for Industrial and Business Uses 47 Policy SP 66 – Access to Community Facilities 48 Land between worksop Road (A57) and Sheffield Road (B6059), South Anston 48 3 Land between Worksop Road (A57) and Sheffield Road (B6059), South Anston \\Sheffield-Svr\Job Files\Yorkshire\YK\YK2138 - YK2600\YK2306-1\Final Rep 2015\YK2306-1_Representations_Land Between Worksop Road And Sheffield Road_South Anston.Msg.Doc Mr Neil Prior 4.0 SITE APPRAISAL: Land between Worksop Road (A57) and Sheffield Road (B6059), South Anston 49 Site Description 49 Site Access 50 Capacity 56 Suitable 57 Available 61 Achievable 61 5.0 CONCLUSION 62 6.0 APPENDICES 63 Appendix 1: Site Plan 1:5000, Land between Worksop Road (A57) and Sheffield Road (B6059), South Anston Appendix 2: South Anston, Proposed Site Plan (Ref. RB/2011/0802) Appendix 3: 12th October 2015, Letter from Neil Prior to Rotherham MBC Planning Policy Team Appendix 4: Site Survey Sheets (May, 2013) Appendix 5: 2011 Issues and Options Extract 4 Land between Worksop Road (A57) and Sheffield Road (B6059), South Anston \\Sheffield-Svr\Job Files\Yorkshire\YK\YK2138 - YK2600\YK2306-1\Final Rep 2015\YK2306-1_Representations_Land Between Worksop Road And Sheffield Road_South Anston.Msg.Doc Mr Neil Prior 1.0 INTRODUCTION 1.1 This report has been prepared by DLP Planning Ltd on behalf of Mr. Neil Prior in response to Rotherham MBC’s Publication Draft Sites and Policies DPD (2015). Mr Prior’s client has development interests at ‘land between Worksop Road and Sheffield Road, South Anston’. Figure 1 below identifies the site location. Figure 1: Site location plan for land between Worksop Road and Sheffield Road, South Anston. 1.2 These representations support the removal of this site from Green Belt designation and subsequent allocation for housing. The site represents a sustainable extension to South Anston and is available, suitable and achievable within the plan period. 1.3 There are no physical constraints that would restrict carefully designed residential development from being brought forward on this site during the plan period and suitable access for both pedestrian and vehicles could be achieved off Sheffield Road. 1.4 Release of this site from the Green Belt for residential purposes would not undermine the essential characteristics or reasons for including land within the Green Belt as set out in paragraph’s 80 and 89 of the Framework (2012). It would represent a logical extension of the settlement which has previously been considered during the Council’s 2011 Issues and Options Consultation. 1.5 As set out in Section 2 of this representation, there is a compelling need for additional land to be allocated for housing within the Borough and ensure that future delivery can be met. This will require the allocation of additional land for development in sustainable locations. As set out within these representations, the land between Worksop Road and Sheffield meets this criterion. With that in mind, the site should be removed from the Green Belt and allocated for housing. At the very least, it should be identified as 5 Land between Worksop Road (A57) and Sheffield Road (B6059), South Anston \\Sheffield-Svr\Job Files\Yorkshire\YK\YK2138 - YK2600\YK2306-1\Final Rep 2015\YK2306-1_Representations_Land Between Worksop Road And Sheffield Road_South Anston.Msg.Doc Mr Neil Prior safeguarded land to be set aside for long term development potential at the next Local Plan review. 1.6 It is therefore requested that land between Worksop Road (A57) and Sheffield Road (B6059), South Anston be released from the Green Belt and allocated for residential development in the Rotherham Publication Draft, Sites and Policies DPD (2015). 6 Land between Worksop Road (A57) and Sheffield Road (B6059), South Anston \\Sheffield-Svr\Job Files\Yorkshire\YK\YK2138 - YK2600\YK2306-1\Final Rep 2015\YK2306-1_Representations_Land Between Worksop Road And Sheffield Road_South Anston.Msg.Doc Mr Neil Prior 2.0 ISSUES OF SOUNDNESS REGARDING THE HOUSING REQUIREMENT AND HOUSING LAND SUPPLY Introduction 2.1 This section highlights that it its submitted form the plan is unsound. This is despite the fact that all of the issues highlighted in this section have been raised with the council throughout the consultation process. 2.2 The issues stems from the fact that the Inspector for the Core Strategy found the overall level housing sound on the basis that there was to be an almost immediate review of the housing requirement based upon the promise from the council that a joint Strategic Housing Market Assessment (SHMA) was to be produced for the Sheffield and Rotherham Housing Market Area. This approach was found acceptable as the council produced evidence that there was continuing cooperation between Sheffield and Rotherham. 2.3 Since the adoption of the core strategy the following has occurred: a. The joint SHMA has not been produced – instead the council have commissioned a completely unconvincing evidence that suggests Rotherham is a separate housing market area. Contrary to guidance this approach ignores Travel to wor Patterns. This together with work undertaken for other surrounding authorities (Barnsley and North East Derbyshire etc) leads to the unlikely conclusion that Sheffield the fourth largest city in the country has no influence beyond its own borders – a conclusion that bears no connection to reality. b. There is still no evidence regarding the level of potential unmet need that will arise for Sheffield. This is despite the fact that all authorities are committed to delivering the substantial levels of employment increase in the Local Enterprise Plan (LEP). c. Case law has established that LPA’s do not need to revisit OAN for lower order plans such as this, but experience suggests that producing an out of date plan leaves the LPA at risk of the plan being found out of date at appeal (Wokingham) or unsound at examination (Harrogate). d. The lack of up to date evidence on OAN also extends to the lack of evidence or justification for the level of safeguarded land which is identified in the proposals map but not referred to in policy. e. There is no clear evidence on the trajectory of the allocated sites to demonstrate how the plan will result in a five year supply. 2.4 While these issues have been found sufficient to lead to inspectors advising council not to progress to examination we are concerned that the required allocations are not further delayed by a further stalling of the plan process. So while this section sets out these issues in greater detail we also set out how these issues of soundness may be addressed by the following: a. The commissioning of a proper evidence base b. Providing a detailed trajectory of allocated sites c. Setting out a range of likely future housing requirements which will provide the basis for the selection of sites for both allocation and safeguarded land 7 Land between Worksop Road (A57) and Sheffield Road (B6059), South Anston \\Sheffield-Svr\Job Files\Yorkshire\YK\YK2138 - YK2600\YK2306-1\Final Rep 2015\YK2306-1_Representations_Land Between Worksop Road And Sheffield Road_South Anston.Msg.Doc Mr Neil Prior d.
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