Distribution of Development and Local Plan Strategy Sites and Strategic Locations (Crewe) Hearing Dates: Thu 22 & Fri 23 Sept 2016
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Cheshire East Council Local Plan Strategy Examination Proposed Changes Hearings: Council’s Response to Hearing Statements Matter 5.2: Distribution of Development and Local Plan Strategy Sites and Strategic Locations (Crewe) Hearing Dates: Thu 22 & Fri 23 Sept 2016 Cheshire East Council Proposed Changes Council's Response Statement: Matter 5.2 MATTER 5.2: CREWE Introduction This Response Statement has been prepared by Cheshire East Council (“the Council”) at the invitation of the Inspector to respond to issues raised in participants’ Proposed Changes Matter 5.2 Hearing Statements. It addresses the main points of contention raised in those statements, but only to the extent that these are new points that have not been covered in the Council’s Proposed Changes Hearing Statement for Matter 5.2 [PCM5.2.001] or other documents previously submitted by the Council at earlier stages of the Examination. Furthermore, this Response Statement seeks only to address those issues that are relevant to the tests of soundness and does not seek to address detailed matters that will be appropriate to consider through the development management process. Key Documents The following documents are relevant to this response: • Local Plan Strategy Proposed Changes (Consultation Draft) ("Revised LPS") [RE F003] • Cheshire East Local Plan Strategy Habitats Regulations Assessment, Final Report and Summary Report ([SD 004] and [SD 005]) • Sustainability Appraisal Volume 2 - Strategy Sites and Strategic Locations (July 2016) [PC B030] • Habitats Regulations Assessment Addendum: Proposed Changes [RE F005] • LPS Proposed Changes - Habitats Regulations Assessment Implications (July 2016) [PC B031] • Consultation Response Proformas ("CRP") [PC B005] • Crewe Final Site Selection Report ("CFSSR") [PC B011] • Site Selection Methodology ("SSM") [RE F010] • Council’s Hearing Statement: Local Plan Strategy Site and Strategic Locations (Crewe) (2014) ("Crewe HS2014") [M14.2.001] • Council’s Proposed Changes Response Statement: Matter 2 - Planning for Growth Overall Development Strategy ([PCM2.001a] • Council’s Resumed Hearing Statement: Matter 4 – Spatial Distribution of Development [RM4.001] • Council’s Hearing Statement: Matter 1 - Legal and Procedural Matters (2014) [M.1.001] • Spatial Distrubution Update Report ("SDUR") [PS E035] • Cheshire East Housing Development Study ("HDS") [PS E033] 1 Cheshire East Council Proposed Changes Council's Response Statement: Matter 5.2 • Alignment of Economic, Employment and Housing Strategy Report ("AEEHSR") [PS E032] • Inspector's Further Interim Views on the Additional Evidence Produced by the Council during the Suspension of the Examination and its Implications for the Submitted Local Plan Strategy ("FIV") [RE A021] • Infrastructure Delivery Plan Update (July 2016) [PC B033] • The Urban Potential Assessment (UPA) results [PS E039b] • North Crewe Highways Technical Summary - July 2016 [PC B023] • North Crewe ViSSIM - Forecasting Note Update 2016 [PC B038] • Local Plan Strategy Highway Settlement Summaries (June 2016) ([PC B022] • Housing Supply and Delivery Topic Paper– (August 2016 Update) ("HS&DTP") [PC B037] • Council’s Resumed Hearing Statement: Matter 3 – Green Belt, Safeguarded Land and New Strategic Green Gap Policy [RM3.001] • Heritage Impact Assessments ("HIA") [RE F017] Council’s Response The following reproduces the Inspector’s questions, identifies the issues raised in other participants' hearing statements for Matter 5.2 and includes the Council’s response. a. General i. Is the Vision and development strategy for Crewe appropriate, justified, effective, sustainable, viable, soundly based and consistent with the Plan’s strategy; and does it reflect current regeneration initiatives, including the Northern Gateway/All Change for Crewe: High Growth City strategy and potential implications of HS2? Issue 1: The ‘Strategic Employment Area’ designation on Figure 15.1 of the Revised LPS should be amended Matters Raised By Participants • The current ‘Strategic Employment Area’ designation, on Page 193 in Figure 15.1 of the Revised LPS does not accurately reflect Bentley’s existing operational site or the land in which planning permission for expansion has been granted; 2 Cheshire East Council Proposed Changes Council's Response Statement: Matter 5.2 • In order to accurately reflect Bentley’s existing operations and land ownership, it is requested that the ‘Strategic Employment Area’ and the ‘Crewe Town Map’ at Figure 15.1 is amended, as shown on the map provided. Council's Response 1. The ‘Strategic Employment Area’ is not an allocation; the map could be revised during the preparation of the SADPD; there is an ongoing dialogue between Bentley and the Council. 2. The Council has already considered such a request (CRP [PC B005], p489). 3. The Council recognises the important role that Bentley plays, as a major employer within the Borough and has an ongoing dialogue with them. In recognition of this, a Bentley Masterplan is being prepared which will feed into the production of the SADPD. 4. The Bentley site lies within the settlement boundary for Crewe and the expansion of their operations is not predicated upon the change that is requested. The Council therefore considers that the detailed allocation of the site can be most appropriately considered in the SADPD, taking into account the Bentley Masterplan. ii. Is the revised amount of development proposed at Crewe (7,700 dwellings and 65ha of employment land) appropriate, proportionate, sustainable, deliverable, justified with evidence and soundly based, including the balance between new housing and employment development? Issue 2: Housing Numbers Flexibility Factor for Crewe. Matters Raised By Participants • The Spatial Distribution Update Report does not test the most appropriate locations for the distribution of the ‘flexibility’ allowance on top of the OAHN figures; • it is necessary to identify the most appropriate settlement(s) to deliver additional development to accommodate the flexibility allowance; • as the largest and most sustainable settlement in Cheshire East, Crewe should be a clear priority location for receiving a notable proportion of the flexibility allowance; • a relatively modest 4.5% flexibility allowance is applied to Crewe (sites are allocated with the capacity to delivery 8,050 dwellings to meet the 7,700 dwelling requirement). Council's Response 5. The dwelling flexibility factor for Crewe is 8.40%; this is 1.90% more than the overall flexibility factor that has been applied across the Revised LPS of 6.5%. 3 Cheshire East Council Proposed Changes Council's Response Statement: Matter 5.2 6. The SDUR does not need to test the most appropriate locations for the distribution of the flexibility factor; indeed the flexibility factor aims to ensure that the minimum level of development that is shown in Policy PG6 is delivered in each settlement. 7. The figures quoted by the objector are incorrect; the correct figures being 8,350 dwellings are proposed for Crewe (including Site Allocations) which represents a flexibility factor of 8.40%, as shown in the CFSSR ([PC B011], Figure Crewe 3 & ¶¶9.1 & 9.2). This is 1.90% more than the overall flexibility factor that has been applied across the Revised LPS of 6.5%, as shown in the HS&DTP ([PC B037], Table 7.4, p36). Issue 3: There is the potential for market saturation in Crewe. Matters Raised By Participants • potential market saturation; • Crewe has limited appeal. Council's Response 8. A range of site types, sizes and locations are proposed for Crewe. The HS&DTP [PC B037] provides the justification regarding why the proposed level of housing delivery for Crewe (and in fact all settlements) is justifiable and deliverable: • Appendix 5 – Evidence to support Strategic Site delivery; • ¶¶7.2-7.7 - the approach taken towards SL1 Central Crewe/ SL4 Central Macclesfield; and • Appendix A - sets out delivery rates for all housing sites, including the Strategic Sites (cross-referenced in the CRP [PC B005], p488). 9. In terms of ‘market saturation’, Crewe is identified as a Principal Town in the Settlement Hierarchy of the Revised LPS (Policy PG2) and as set out in the Revised LPS Policy PG6, is expected to accommodate in the order of 7,700 new homes. It is clear that the Strategic Sites / Locations will deliver at different times during the remainder of the plan period (depending on whether they are committed or not) and this will reduce any potential for market saturation (HS&DTP, [PC B037], Appendix 3a and 3b); this coupled with the fact that slightly different products are also being delivered on each site will also ensure that this will not become an issue. An example of a site with a distinctly different product is that of site CS37 South Cheshire Growth Village, where a sustainable, high quality residential development will be created in an attractive setting, adjacent to the Grade I Listed Crewe Hall and its Registered Park and Garden and in close proximity to Crewe. Indeed, on a number of sites there will be several developers, providing different products and this is acknowledged within the HS&DTP ([PC B037], Appendix 5). Clearly the level of already committed 4 Cheshire East Council Proposed Changes Council's Response Statement: Matter 5.2 schemes in Crewe all have a role to play as well as the sites in the Revised LPS, in meeting this level of delivery. Issue 4: The employment flexibity factor should be increased to 30% Matters Raised By Participants • The Council’s approach to an additional flexibility factor added to employment land needs (in the event that there are unforeseen delays or slippage on certain sites) has been to reduce the previously suggested 30% flexibility factor down to 20%. • The circumstances at Basford West (amongst others) highlight why this is an unjustified and unsound response and indicate that the Council should be considering alternative and additional employment site allocations so as to meet needs. Council's Response 10. The 380ha of identified employment land already includes an allowance for land losses and a 20% flexibility allowance as described in the Alignment of Economic, Employment and Housing Strategies (Ekosgen) report ([PS E032], ¶¶3.55-3.58).