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ID970901 Greenhill and Brownfield Reps.Pdf Representations SEDGEMOOR LOCAL PLAN REVIEW - REGULATION 19 PUBLICATION VERSION (JANUARY 2017) 1.0 Introduction 1.1.1 These representations have been prepared by Ian Jewson Planning Ltd on behalf of Greenhill & Brownfield and relate to Sedgemoor District Council’s (SDC’s) consultation on the Proposed Submission Local Plan (January 2017). Whilst Greenhill & Brownfield has a general interest in SDC’s forward planning it also has specific interests in relation to land referred to as H057a (land at edge of Woolavington) and H337 (land west of Sedgemoor Way) in the Strategic Housing Land Availability Report 2016. Where relevant these representations will highlight the potential for residential development on this land. IJP previously submitted reps in relation to the Stage 1 Consultation review of the Local Plan (October 2015). An additional consultation took place between June and August 2016 which focussed on Bridgwater and the Tier 1 settlements. 1.1.2 These representations provide comments on the soundness of the proposed policies in relation to the specific questions raised by the Regulation 19 consultation with reference to evidence base documents where relevant. 1.1.3 Specific consideration has been given to the following policies: • Policy S 2 (Spatial Strategy for Sedgemoor) • Policy S 3 (Infrastructure Delivery) • Policy S 4 (Sustainable Development Principles) • Policy T 2 (Tier 2 Settlement Objectives) • Policy T 3 (Tier 2 Settlement Housing) • Policy D 7 (Affordable Housing) Representations 1.1.4 These policies are discussed in turn in the following sections and where appropriate we have made suggested changes for the policy to be considered sound. 2.0 Policy S 2 (Spatial Strategy for Sedgemoor) Housing and Employment Requirement 2.1.1 The Strategic Housing Market Assessment (SHMA) prepared by Peter Brett Associates in September 2016 concludes that the Objectively Assessed Housing Need (OAHN) in Sedgemoor is (annually over the 2011-32 period) 644 dwellings per annum (13,530 over the full emerging Plan period). We welcome that the SHMA figure identified in the Local Plan Review has been expressed as a ‘minimum requirement’ as this reflects the NPPF’s aim of boosting significantly the supply of housing. 2.1.2 The SHMA identifies a demographic based need for between 609 and 635 dwellings per annum. It bases the OAHN of 644 dwellings per annum on the highest of the demographic scenario ranges which would meet the predicted job growth forecast figure and takes into account an allowance for concealed households. Taking all of this evidence together the SHMA suggests that across the District there is a good match between potential job growth and the likely growth in the resident workforce. 2.1.3 The SHMA has also provided clarity on the additional housing need likely to be generated from Hinkley Point C (HPC). 2.1.4 However, it is important to note that the HPC figures have not been added to the OAHN. The SHMA states that HPC is expected to provide around 900 additional jobs with many more jobs created in the construction phase, which will necessitate the need for additional housing in Sedgemoor. The SHMA also predicts that there will be a further 176 jobs created from the impact of HPC (i.e. other jobs created as a result of the direct new jobs at HPC). The overall Representations likely effect in Sedgemoor is at least an additional 708 residents in employment but this could be significantly higher. 2.1.5 With the figures for the additional jobs created in Sedgemoor from HPC added in to the Oxford Economics (OE) forecast the level of housing required according to the SHMA is 653 dwellings per annum based on past trends. This is higher than the 644 dwellings per annum identified as the OAHN. In our view the higher figure (653) which takes into account growth from HPC should be used in the Local Plan Review. 2.1.6 Due to the uncertain impact of HPC we consider that the level of growth required may be much higher than the 653 dwellings identified based on past trends. The uncertain impact is summarised in Paragraph 57 of the SHMA which suggests that assumptions will change as the project evolves: ‘‘Whilst the HPC position is summarised at the point of drafting, the project position will evolve quickly. Base assumptions which underpinned the planning process to inform the Development Consent Order Accommodation Strategy will change. Local unemployment figures and the workforce profile and projections will also evolve. The project makes provision for the Socio-Economic Advisory Group(SEAG) to monitor the housing impacts and the Councils have secured housing mitigation funds to respond to local concerns. The HCA are also directly engaged locally to expedite a complimentary programme of ‘Starter Homes’ and EDFE own a large tranche of land with outline planning consent for housing.’’ 2.1.7 As a result of the uncertain nature of HPC the SHMA suggests that the impact should be closely monitored by Sedgemoor in the Annual Monitoring Report. Paragraph 58 of the SHMA states: ‘‘The Annual Monitoring Report will summarise project implementation, impacts and benefits and highlight any key changes to local conditions. It will therefore be important for the Council to monitor and review Representations impacts on the housing market and to maintain a dynamic view of housing need.’’ 2.1.8 In the light of the understandable uncertainty over the precise figures, it is important to take a positive view to provide flexibility and enable the provision of sufficient housing to be delivered. Further clarity on the additional housing need generated by HPC and how it will be delivered should be set out in the Local Plan Review document to ensure it is planned for appropriately in the future. Without this it is not possible to fully understand whether the overall proposed housing requirement is appropriate. 2.1.9 It is recognised that there are many unknowns on the impact of HPC which could result in unforeseen events, therefore Policy S 2 needs to ensure that it is flexible enough to address a significant housing shortfall which may occur if the project goes ahead. 2.1.10 To take into account the predicted level of housing generated from HPC based on past trends and to ensure the impact of HPC is closely monitored by the Council we consider that the beginning of Policy S 2 should be amended as follows (shown as tracked changes): ‘‘During the plan period (2011-2032), the Council will plan, monitor and manage the delivery of a minimum of 13530 13,713 new homes (644 653 per annum) and 75 hectares of land for B1, B2 and B8 uses (business, general industrial and storage and distribution) to help meet the need for new homes, support the economy and create 9,795 new jobs. The impacts of HPC on the housing market will be monitored closely by the Council in an Annual Monitoring Report to maintan a dynamic view of housing need, and if necessary the housing need adjusted to take into account the full impacts.’’ Representations 2.1.11 We note that the District Council have identified a requirement to deliver 75 hectares of employment land for B1, B2 and B8 uses to help create 9,795 jobs in the plan period. 2.1.12 We acknowledge that the requirement for around 75 hectares of employment land is likely to be proposed within the District’s core settlements including Bridgwater, Burnham, Highbridge and Cheddar. However, Policy S2 is not specific on how the employment land will be distributed in the District. 2.1.13 The Employment Land Review identifies a number of mixed use sites in lower tiered settlements which are rejected in terms of future employment potential on the basis that they are residential-led where employment uses are likely to be small scale. Policy S2 should be amended to ensure a flexible approach is provided to allow appropriate employment sites to come forward in the lower tiered settlements where opportunities exist. This is recommended in the Employment Land Review and should be translated into policy text. Settlement Hierarchy 2.1.14 We are in general support of the settlement hierarchy and the distribution of development identified in Policy S2, however we have a number of comments. 2.1.15 Policy S2 sets out the settlement hierarchy for the District and identifies Bridgwater as a Principal Town which is allocated the largest amount of the overall housing requirement in the plan period. This is a logical approach based on the level of services, facilities and employment opportunities available. However, as set out in our previous representations on earlier versions of the Local Plan Review we have concerns regarding the allocation of sites located in the floodplain which should be discounted unless it can be demonstrated that there are no other reasonable options available. For instance land at East Bridgwater (Policy B4) is identified in the Sustainability Appraisal (SA) as located in a high risk flood zone which will have a negative effect on the objective to reduce the vulnerability to climate change. Representations 2.1.16 Paragraph 100 of the NPPF is clear that: ‘‘Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as lead local flood authorities and internal drainage boards. Local Plans should apply a sequential, risk based approach to the location of development to avoid where possible flood risk to people and property and manage any residual risk, taking account of the impacts of climate change.’’ 2.1.17 Paragraph 101 goes on to clarify that ‘The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding.
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