& Lyle

Redcar & Cleveland Local Development Framework Preferred Options Communities DPD

Land at Kilton Lane, Brotton

Representations on Behalf of George Wimpey (North ) Ltd.

Policy CM1 Strategic Mixed Use Regeneration Sites

1. Policy CM1 lists only two Strategic Mixed Use Regeneration Sites (SMUR), both of which are located in the main conurbation. Our clients George Wimpey () Ltd would seek the allocation of a further SMUR in the East Cleveland Villages sub-area on land at Kilton Lane, Brotton – see Figure 1.

2. The total gross area shown on the attached plan extends to approximately 14ha of which about 9.5ha ( edged red) is suitable, available and deliverable/developable for a mix of built development uses. The remaining 4.5 ha (edged green) is suitable for open space uses and landscaping.

3. It is considered that the main body of the site is suitable for a mixed use development comprising: housing, retailing, community uses and related commercial development . The suitability of the site for housing development is addressed through our representations on Policy CM3 which conclude that a further housing allocation is required in Brotton to meet housing needs and demand especially in Phase 2 of the LDF period and potentially beyond. In this way development of housing on this site would not impact on the delivery of housing on Preferred Allocation CM3dd - which George Wimpey (North Yorkshire) Ltd supports. The actual amount of land that could be allocated for housing development at Kilton Lane can be tailored to meet future demands within Brotton and indeed the wider East Cleveland Villages sub-area, up to 2021 and potentially beyond.

4. The Land at Kilton Lane therefore has the potential to act as a Strategic Mixed Use Development site, in the same way that the land to the north of Skelton has done in recent years, and satisfy a wide range of existing and future development needs associated with Brotton and indeed the East Cleveland Villages sub-area as a whole.

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5. The Kilton Lane site is strategically located adjacent to the A174 Bypass. It therefore offers a highly accessible location for a variety of land uses aimed at meeting the needs and requirements of Brotton and the East Cleveland sub-area the whole. In relation to the land to the east of Kilton Lane, (Area B on Figure 1) a site that is generally flat and therefore physically well suited to larger floor plan commercial and community developments.

6. We consider that as part of any strategic mixed use development an element of retail development would be entirely appropriate. It is apparent from a review of retail provision in Brotton and the other East Cleveland villages that the quantity and quality of both convenience and comparison goods floorspace available is well below what one might expect is necessary to adequately meet the needs of the resident population of this area. As a result there is a substantial outflow of expenditure to the larger supermarkets in and the conurbation. This pattern is clearly demonstrated in the Council’s 2006 Strategic Retail, Leisure and Office Study. Table 3.1 of this Study indicates that 73% of residents of the ‘Rural East’ undertake their main food shop at supermarkets outside of the Rural East area with 42% travelling to Morrisons in Redcar.

7. The 2006 study also shows that the local shops in Brotton, Loftus and Skelton are used primarily for top-up shopping and that 82% of residents undertake their non-food shopping outside the Rural east area.

8. This means that residents of this area have to travel considerable distances to meet their main shopping needs. This situation is unsustainable because most of these journeys will be undertaken by private car and this leads to increased and potentially avoidable CO2 emissions. It also results in the substantial leakage of expenditure from this area that might otherwise be used to create jobs and promote the vitality and viability of settlements such as Brotton. Residents of this area currently have no choice in this matter because the quantity and quality of provision simply does not exist. There is for example no large supermarket in East Cleveland

9. There is therefore a clear need for additional retail provision in East Cleveland. Unfortunately there are no opportunities within or on the edge of existing local centres that are realistically available, suitable and viable, and capable of satisfying this requirement. The only option therefore is an out of centre location that is highly accessible to all residents. The land at Kilton Lane provides the best location for any new provision as it is centrally located within the East Cleveland area and because it is adjacent the A174 By-Pass. It is therefore highly accessible to all residents and will reduce travel distances and times.

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10. The development of a modest 20,000 – 30,000sq ft supermarket in this location would not impact unacceptably on stores within existing centres as it would largely derive its turnover from clawing back expenditure that currently leaks to supermarkets Redcar and beyond . Shops in the existing centres will continue to perform their current ‘neighbourhood’ role as predominantly top-up shopping destinations.

11. The development of a medium sized supermarket on the land at Kilton Lane could also act as a catalyst for the development of a range of other services and facilities and deliver a truly mixed use scheme that will promote job creation and regeneration in East Cleveland. The exact scale, mix of uses and phasing of delivery will need to be agreed with the Borough Council through the DPD.

12. The allocation of a Strategic Mixed Use regeneration site in East Cleveland would be in line with the adopted spatial and locational strategy of the Council and would represent a sound long term plan led approach to meeting the needs of residents in this part of Redcar & Cleveland. The land at Kilton Lane, Brotton provides the best opportunity to make such an allocation.

13. In the light of the above we would request that Policy CM1 is amended to identify the land at Kilton Lane, Brotton as a Strategic Mixed Use Regeneration Site CM1c and that consequential amendments are made to other relevant policies in the DPD.

Figure 1

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Redcar & Cleveland Local Development Framework Preferred Options Communities DPD

Land at Kilton Lane , Brotton

Representations on Behalf of George Wimpey (North Yorkshire) Ltd.

Chapter 3 – Delivering New Housing

Paragraphs 3.4 and 3.5 1. RSS Policy sets out the net dwelling requirement for Borough to 2021 and the formula for calculating the minimum net additional housing requirement for the years post 2021. It is noted however that in RSS Paragraph 3.89 it states: “ It is emphasised that the gross and net dwelling provisions set out in Policy 28 are guideline figures and do not represent a ceiling. LDF’s may make the case for higher figures as appropriate.” As a result the net additional housing figures in Policy 28 and paragraph 3.5 on the Communities DPD should be seen as being the minimum housing requirements that Redcar & Cleveland Borough should seek to ensure it delivers through the LDF. The text of the DPD should be amended to reflect this approach

Paragraph 3.13 - Small Windfall Completions 2. It is accepted that windfall completions over recent years have contributed towards the overall supply of new dwellings in the Borough. However the supply from this source has been variable and cannot be relied upon. Paragraph 59 of PPS3 states “Allowances for windfalls should not be included in the first 10 years of land supply unless local planning Authorities can provide robust evidence of genuine local circumstances that prevent specific sites from being identified.” Contrary to this guidance however the Council does not provide any evidence as to why it is unable to identify further specific sites for housing development and instead justifies the windfall allowance on the basis of past trends.

3. It is clear from the Preferred Options Communities DPD and the SHLAA that the Council is able to identify more than enough sites, as potential housing allocations to meet the RSS net additional housing requirement. There is no reason therefore why the council could not allocate additional sites to meet the full RSS net housing requirement without the need to include a windfall allowance within its calculations.

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4. This approach of course will not preclude windfalls coming forward over the plan period which will add marginally to the housing land supply and make up for the non-delivery of allocated sites . Such an arrangement would ensure, in line with the plan-led approach, that the LDF contains sufficient allocations to satisfy the minimum net additional housing requirement identified in RSS whilst at the same time introduces an element of flexibility into the housing land supply. It also accords with the guidance that the RSS net housing requirements are ‘guideline’ and not ceiling figures. The delivery of on average 35 windfall dwellings per annum is equivalent to less than 8% of the overall requirement, and would not impact on overall spatial strategy for the Borough.

Paragraph 3.14 - Net Housing Requirement 5. In the light of comments in relation on Windfall Allowances the net housing requirements shown in the table in 3.14 should be amended by the removal of the ‘small windfall allowance’ element – at least for the next 10 years of the plan – in line with PPS3. This will result in the need to bring forward the allocation of additional sites though the Communities DPD.

6. Other considerations that need to be borne in mind when assessing the net housing requirement are the fact that the RSS figures are ‘guidelines and not ceilings and that it is imperative that allocations actually result in the delivery of the number of units by the date given. Some ‘over- allocation’ may therefore be prudent to ensure the net housing requirement is achieved within the plan period and maintain a continuous five year housing land supply.

Paragraphs 3.137 – 3151 – Housing Design 7. Whilst fully appreciating the national policy drive towards achieving the variety of standards prescribed within the above, we would seek to ensure that the role of individual site viability should not be forgotten.

8. We request that the application of these and other policies, which add to the costs of development, are viewed in a wider context so as to ensure that sites that are to be brought forward, are not suppressed on grounds of viability.

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Redcar & Cleveland Local Development Framework Preferred Options Communities DPD

Land at Kilton Lane , Brotton

Representations on Behalf of George Wimpey (North Yorkshire) Ltd.

Policy CM3 – Housing Allocations

1. George Wimpey (North Yorkshire) Ltd object to the exclusion of all or part of the land at Kilton Lane, shown on Figure 1, for housing development and open space for housing and open space.

Figure 1

2. For the reasons given in relation to our representations on the supporting text to Chapter 3 of the Preferred Options DPD we consider that there is a clear need for the Council to seek to allocate additional sites in the Communities DPD in order to be confident that it can deliver the RSS net housing requirement for the Borough within the LDF period. This

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need applies across the Borough but because of the specific regeneration, population retention and sustainability issues confronting the settlements in East Cleveland we believe the LDF specifically needs to make additional housing land allocations in this sub-area, albeit within the broad guidelines of the adopted spatial and development distribution strategy - as detailed in the Core Strategy.

3. There is also a clear evidence base that illustrates the wards of Redcar & Cleveland struggle in respect of the national indices of deprivation. In order to improve upon this current poor condition, the Local Authority needs to generate new levels of economic activity to progress the various settlement’s standing. The most logical approach to address this matter is to undertake a housing led regeneration strategy that provides new housing in accessible locations. These new dwellings must be of the form that prospective purchasers wish to purchase, that in the main are detached dwellings. These thoughts are reinforced by the SHMA that identifies the requirement for this type of dwelling.

4. The reasons given by the Council, in the Preferred Housing Allocations – Background Report, for not identifying this site ( Site 43) as a potential housing allocation in the DPD were:

“The size of the site and the potential scale of development exceeds requirement for additional housing in Brotton, East Cleveland and the Rural Area.” and

“If the site was allocated for housing, its development could hinder the development of more suitable sites near the centre of the village”

Each of these concerns is dealt with in turn below:

The site is too large for Brotton?

5. Site 43, as shown in the Housing Preferred Options - Background Evidence Report ( Figure 1) extends to approximately 14ha. It includes virtually all the land between the existing built-up edge of the village and the bypass. It is accepted that this site is much larger than that needed to meet the residual needs of Brotton and East Cleveland within the RSS current period. It is also recognised that the topography of this land towards its eastern end of the site, and the existing built form of the village, makes this area generally unsuitable for housing development . However remainder of this general area between the current built up area and the by-pass does represent a very obvious and sensible direction of future growth from Brotton and could in time meet housing needs in Brotton and East Cleveland over a much longer period, in the same way that the development of land to the north of Skelton has in recent years

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6. As a result of the potential development constraints on the site we have in previous submissions only ever sought to propose Areas A & B shown on Figure 1 as about the maximum amount of land realistically available for development. This gross area extends to some 9.5Ha with 3.5ha to the west of Kilton Lane (Area A) and 6ha to the east (Area B). A further 4.5ha of the land to the east of Kilton Lane ( Area C) is identified as potential open space / landscaping.

7. However it is equally clear that the amount of land that the Council could potentiality be made available for housing in this general location is highly flexible. For example the option clearly exists to allocate either sites A or B or alternatively parts of sites A and/or B. The option has therefore always been available to the Borough Council to tailor the amount of land that they might consider allocating, to the identified needs and demands of Brotton and East Cleveland as a whole.

8. On this basis that argument that the site is too large and might lead to an excess of housing provision in Brotton is spurious. The Council has the option through the LDF to tailor the amount and phasing of housing land supply to meet needs. It is clear however in this instance that the Council, based on the assumptions about housing land supply issues detailed in the DPD, does not consider that there is the need to allocate any land over and above the propose allocation CM3dd Land east of the Brickyards. This assumption is incorrect.

9. George Wimpey (North Yorkshire) Ltd supports the allocation of site CM3dd but as stated above we consider that there is a need to allocate additional land for development at Brotton, especially to meet housing needs post 2016 but also to meet those types of housing that are unlikely to be accommodated on site CM3dd.

10. Policy CM3dd states that this site will be brought forward in Phase 1 of the LDF and this is supported by the inclusion of this site in the Council’s Growth Point bid which requires all sites to be developed prior to 2017. This is also supported by George Wimpey (North Yorkshire) Ltd. The question therefore arises how will housing needs in Brotton be met after than date between 2016 and 2021, and beyond. To rely on potential future windfalls to met this need over this period does not reflect the plan led approach that is advocated in national and regional guidance as it does not provide a secure supply of housing. It is therefore imperative that a further allocation is made at Brotton to meet this need. Without such an allocation Policy CM3 is unsound as it does not represent the most appropriate strategy and lacks flexibility.

11. We also consider that the land at Kilton Lane, because of its potential size and differing sub areas, is capable of accommodating a much broader range and type of housing development, for which site CM3dd is less well suited, because of its topography, location and surroundings. This includes bungalows, executive and executive-style housing.

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12. The SHMA indicates a strong level of demand for bungalows throughout the Borough but as the Council will be aware density requirements and viability issues in recent years have largely resulted in developers being unable/unwilling to include bungalows within their developments. However George Wimpey (North Yorkshire) Ltd would be willing to commit to the provision of bungalows on the land at Kilton Road should it be allocated for housing development the DPD. The scale of such provision to be determined in discussion with the Borough Council. George Wimpey (North Yorkshire) Ltd would also be willing to examine the option of executive or executive-style homes, in line with Policy CM7, on this site. Again the SHMA indicates a demand for such units in East Cleveland but there is no explicit provision proposed within the East Cleveland villages. The nearest proposed provision is in .

Allocation of Kilton Lane for housing development could hinder the development of more suitable sites closer the village centre?

13. As previously highlighted George Wimpey (North Yorkshire) Ltd support the allocation of site CM3dd and is indeed the potential developer of this site. Clearly therefore the fact that it is also seeking to pursue the allocation of land at Kilton Lane in addition to site CN3dd is a very strong indication that they do not consider the Council’s assessment on this matter to be valid.

14. The reasons for this have already been outlined above but in summary are: • The need for allocated housing land in East Cleveland and Brotton in particular exceeds that assumed by the Council; • That the Kilton Lane site can be phased for delivery to start in Phase 2 of the LDF i.e. post 2016 following the completion of CM3dd ; and • Kilton Lane site can accommodate a range of house types that neither site CM3dd or other proposed allocated sites in the East Cleveland sub area are likely to deliver e.g. bungalows.

15. Given the suggested delivery of this site in Phase 2 of the LDF period it is also clear that development on the land at Kilton Lane would not prejudice the delivery of any existing commitments in Brotton.

16. It is also our view, and it is clear from the Council’s own Background Evidence Report, that none of the other sites considered by the Council would represent a better alternative to the land at Kilton Lane. The only site closer to the village centre is Site 142 North of Brotton High Street however this site is dismissed as a potential housing allocation by the Council because it is land locked and allocated as recreational open space. The relative importance and open space/recreational value of this

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centrally located site will increase following the development of the Land East of the Brickyards.

17. In conclusion we would therefore request that an area of land at Kilton Lane is added to the list of Sites in CM3 and as a separate policy allocation e.g. CM3ii. The amount of land, the capacity of the site and the range and type of dwellings it could best deliver can be determined following subsequent discussions with the Borough Council and George Wimpey (North Yorkshire) Ltd.

18. Consequential amendments to Policies CM6 and CM7 and DP1 would also be appropriate.

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Redcar & Cleveland Local Development Framework Preferred Options Communities DPD

Land at Kilton Lane , Brotton

Representations on Behalf of George Wimpey (North Yorkshire) Ltd.

Policy CM5 – Future Direction for Growth

1. George Wimpey ( North Yorkshire) Ltd would support the inclusion of a policy to indicate future potential directions of growth beyond 2021 in the DPD. However we would object to the restriction of potential future direction of growth to just the “area to the south of Marske.” that is contained in the current draft Policy CM5. This would imply that the only direction of growth for the whole Borough, that the Council considers is appropriate to meet housing needs post 2021 is the land south of Marske. Whilst this may or may not be an appropriate direction of growth for development associated with the main conurbation it fails to meet the development needs of the Cleveland Villages sub –area.

2. As a result we would request that Policy CM5 is amended to include land south of Brotton as a potential future direction of growth for the East Cleveland area post 2021. Brotton represents the most obvious location for any such growth being centrally located in his sub-area and with the capacity to accommodate further growth in a sustainable manner. This conclusion is supported by the identification of Brotton as the location for the sub-area’s main secondary school. The are between the existing built- up area and the A174 By-pass also represents the most sustainable and deliverable /developable option and is of an appropriate scale to met future needs. Such an ‘allocation’ would compliment development within the period to 2021 as suggested through our representations on Policy CM1 and CM3. It would be fully justified, effective and in accordance with national policy and therefore sound.

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