Lichfield LP Matter 3

Wardell Armstrong Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom Telephone: +44 (0)1782 276 700 Facsimile: +44 (0)845 111 8888 www.wardell-armstrong.com

LICHFIELD LOCAL PLAN ALLOCATIONS – PART 2 EXAMINATION

EXAMINATION HEARING STATEMENT – MATTER 3

1 DOES THE PLAN DELIVER THE STRATEGIC HOUSING PROVISION TO MEET THE NEEDS OF THE PLAN AREA OVER THE PLAN PERIOD?

1.1 On behalf of the Leavesley Group of Companies, we would like to assist the Examination Hearing in the context of informed discussions on whether the new homes provided for in the Plan period accord with the Local Plan policy.

1.2 Majority of responses to consultation focussed on the allocation of land for housing, The Council helpfully produced a table (Table 3) in its report to Council regarding progressing the Plan to ‘set out the impacts on each of the settlements as a result of the existing SDA’s (identified in the Plan Strategy), completions, commitments, and proposed allocations (within the Allocations Plan).

1.3 This report demonstrated in the particular context of Fradley that the Gross Completions 2008-17 were 34no – 1.5% of the 1302 dwellings allocation under the SDA. Committed supply is 5no – 2% of the 285 dwellings committed supply 2017-22. For an SDA that comprises 35.5% of overall Plan allocation, this is a derisory delivery level. For the LPA to only to propose to allocate 80 further dwellings (actually only 63 dwellings under the current application 18/00486/FULM – with a Care Home) constitutes an imbalanced approach. An area defined as ‘Other rural’ is allocated 954 dwellings – 19% of gross supply - which as a matter of principle must provide an imbalance to the sustainability principles which underlay the adopted Plan.

1.4 The Draft Plan is irrational in that it differentiates between the Fradley SDA and the Village, proposing to amend the boundary of the village to accommodate residential allocations (80no) but that the SDA has ‘effectively met the requirements of the LP Strategy and provide a level of flexibility’ so remains untouched. This approach is considered highly irrational.

1.5 It is promoted that further site(s) should be allocated at Fradley to build in flexibility and provide certainty that the Allocations will deliver the spatial strategy for

ENERGY AND CLIMATE CHANGE ENVIRONMENT AND SUSTAINABILITY INFRASTRUCTURE AND UTILITIES LAND AND PROPERTY Wardell Armstrong is the trading name of Wardell Armstrong LLP, Registered in England No. OC307138. MINING AND MINERAL PROCESSING Registered office: Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom MINERAL ESTATES UK Offices: Stoke-on-Trent, Birmingham, Cardiff, Carlisle, Edinburgh, Glasgow, Greater Manchester, Central Manchester, London, Newcastle upon Tyne, Sheffield, Truro, International Offices: Almaty, Moscow WASTE RESOURCE MANAGEMENT

settlements. The Leavesley Group of Companies has submitted Planning Application 18/00078/OUTMEI on Hay End Lane for development on land that is suitable, achievable and deliverable. The allocation of this site is appropriate in form and function, where additional land is clearly required for housing offering choice and diversity.

1.6 The spatial distribution of growth proposed in the Focused Changes is considered not to effectively deliver the spatial strategy of the adopted Local Plan Strategy. In this context the proposed buffer of around 15% to provide sufficient flexibility requires robust analysis and further debate at Examination.

1.7 Plan targets are as an established principle in Plan making are minima. By restricting development in an inappropriate manner within a defined SDA is to defeat the objective of achieving appropriate development in sustainable locations. By imposing a defined and restricted boundary the Plan is countering Plan flexibility.

1.8 On the matter of Matter 3 – 3.5 in the Inspector’s Matter, Issues and Questions Discussion Note the Leavesley Group of Companies strongly supports the need for Qualitative aspects of housing supply in that it itself is looking to deliver on the aforementioned site:

• A care-home • Assisted living • Sheltered housing • Self-build and custom housing

1.9 We would like to support the Examination in the setting of appropriate parameters for housing provision related to the above, and indeed a wider context.

SMS/ST.15244/09082018

ST15244/ALM-002 2 August 2018