Examination of Luton Local Plan
Total Page：16
File Type：pdf, Size：1020Kb
EXAMINATION OF LUTON LOCAL PLAN STAGE 2 HEARING SESSION MATTER 6: MEETING OBJECTIVELY ASSESSED NEED FOR HOUSING 23 SEPTEMBER 2016 CENTRAL BEDFORDSHIRE COUNCIL (REPRESENTOR REF: 933222) 1 Appendix 1: Luton, Dunstable and Houghton Regis Urban Capacity Study, August 2016 Appendix 2: Schedule of employment sites considered within the Luton Employment Land Review as being potentially suitable for residential redevelopment Appendix 3: Brighton and Hove Local Plan Inspectors report dated 13 December 2013 (relevant extracts). 2 55. Should the capacity/provision figure of 6,700 be referred to as the housing requirement for Luton over the plan period? If so, is this made sufficiently clear in the Plan? Should the figure also be expressed as an annual average (eg 6,700 divided by 20 years = 335/year)? Is it intended that the capacity will be delivered equally over the plan period or staggered? 55.1 Without prejudice to Central Bedfordshire Council’s (“CBC’s”) concerns (see Question 62 and 65) regarding Luton Borough Council’s (“LBC’s”) assessment of urban capacity potential, as set out within this Statement (Question 58), it is clear from LBC’s published evidence base (namely the SHLAA 2016 (EDO46) is that all references to potential housing land capacity for Luton within the LP should be updated to either: (i) 8,173 dwellings between the period 2016/17 to 2030/31 (the remaining LP years); or (ii) 10,333 dwellings between the period 2011/12 to 2030/31 (the period covered by the LP). 55.2 As set out within CBC’s statement to Question 74, all available evidence (and as agreed between CBC and LBC within the Statement of Common Ground Addendum) (“SoCG Addendum”) is to the effect that the policy-on OAN housing requirement figure referred to within LP should be at least 8,500 dwellings between the period 2011 and 2031. For monitoring purposes this at least figure could be expressed as an annual average (425 dwellings per annum). 56. Are Policies LP 2 and 15 flexible enough? Should they refer to at least 6,700 dwellings? How likely is it that this figure might vary over time? 56.1 As set out within elsewhere within CBC’s statements on a number of occasions Policies LP2 and 15 should set out a housing provision / requirement figure of at least 8,500 dwellings over the period covered by the LP. 56.2 Expressing the housing requirement as a minimum figure ensures that Policies LP2 and 15, and the LP more generally, is sufficiently flexible to enable LBC to positively support additional housing growth, subject to infrastructure capacity and other relevant material considerations, to help meet a greater proportion of Luton’s identified housing needs. 3 57. Policy LP 2 A identifies housing capacity from various sources adding up to 6,900. The same sources as expressed in LP 15 A add up to 7,000 [the difference being the capacity from housing allocations – 2,400 in the former and 2,500 in the latter, with the total given in Appendix 4 as 2,420] Which is correct? [see ‘minor modification’ MOD30 which indicates 2,400] Both overall totals exceed the stated capacity of 6,700 – so should the capacity be 6,900? 57.1 As set out within the SoCG Addendum, both CBC and LBC agree that Luton’s capacity is at least 8,500 dwellings within the LP period. Policy LP2A should therefore refer ‘at least 8,500 dwellings’. 58. The Council has prepared an updated SHLAA (July 2016). Does this indicate that there should be any change to the stated capacity for Luton of 6,700 and any other parts of the plan? 58.1 Yes. As set out within the SoCG Addendum, both CBC and LBC agree that the stated capacity for Luton is ‘at least 8,500 dwellings’. 58.2 Without prejudice to CBC’s soundness concerns regarding the SHLAA 2016, namely that the process has failed to: (i) Revisit the SHLAA assessment to change physical and policy constraint assumptions on development potential (Planning Practice Guidance (“PPG”) ID:3-026); (ii) Consider appropriate densities options which make effective use of an acute supply of land (NPPF paragraph 17); (iii) Consider making more efficient use of underused employment sites through mixed-use development options (NPPF paragraph 17); and (iv) Ensured that the unnecessary long term protection of sites allocated for employment use has been avoided (NPPF paragraph 22), paragraphs 4.4 to 4.6 and Table 4.1 of the SHLAA 2016 (ED046) confirm Luton has potential land capacity to deliver at least 8,173 dwellings within the remaining years of the LP i.e. the period between 2016/17 and 2030/31. This capacity comprises: (a) 4,236 dwellings deliverable within the next five years; (b) 2,945 dwellings developable within years six plus; and (c) 992 dwellings on sites, which are considered suitable, but currently have one or more outstanding availability and achievability issues that Luton Borough Council (“LBC”) can proactively work with landowners / developers to address over the LP period. 58.3 Furthermore, once housing completions between 2011/12 to 2015/16 (SHLAA 2016 Table 2.1) have been taken into account (2,160 housing completions) LBC’s evidence is that the potential land capacity of Luton over the period covered by the LP (2011 to 2031) is at least 10,333 dwellings. 4 58.4 Without prejudice to CBC’s concerns (outlined above) regarding the robustness of LBC’s SHLAA process, all references to potential housing land capacity for Luton within the LP should be updated to either: (iii) 8,173 dwellings between the period 2016/17 to 2030/31 (the remaining LP years); or (iv) 10,333 dwellings between the period 2011/12 to 2030/31 (the period covered by the LP). 59. Will the joint Growth Options Study be likely to have any bearing on the assessment of housing capacity in Luton given the Project Brief (February 2016) requires the consultants to review all existing and published plans, studies and topic papers with respect to land supply in the study area? 59.1 As set out within CBC’s Statement to Stage 1 and outlined during the Stage 1 sessions, LBC would not support the inclusion of a review of Luton’s urban capacity potential as part of the joint Growth Options Study (“JGOS”). The JGOS will therefore not provide any further assessment of housing capacity in Luton beyond that set out within the Luton SHLAA 2016. 60. In assessing Luton’s housing capacity have the following potential sources of supply been correctly taken into account and are they based on robust evidence 60.1 No. 60.2 Please refer to CBC’s statement to Question 62. 62. Are the assessments of capacity above, where appropriate, based on appropriate assumptions about densities? The 2015 SHLAA refers to 50 dph (2.14) but Table 2.4 indicates a high % of completions in recent years at over 50 dph. 62.1 No. 62.2 One of the core planning principles set out within the NPPF (paragraph 17) is to encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental use. Specifically regarding densities the NPPF encourages (paragraph 47) local planning authorities to set out their own approach to housing density to reflect local circumstances. As part of encouraging good design the NPPF aims to 5 ensure that developments optimise the potential of sites to accommodate development whilst responding to local character and history, and reflect the identity of local surroundings (paragraph 58). 62.3 Maximising urban housing potential through higher density is one of a number of emerging changes to the NPPF that are currently being considered by the Government. The proposed changes seek to boost Government’s policy emphasis to maximise the use of previously developed land within urban areas and encourage higher density residential development around accessible transport hub locations (Consultation on the proposed changes to the national planning policy, December 2015). Although the changes to the NPPF are still to be confirmed, they do indicate the likely future direction of Government density policy and emphasise the important contribution that higher density development within accessible and central town centre locations can make towards helping to meet identified housing needs. 62.4 Whilst it is acknowledged within the SHLAA 2016 (ED046) that in some instances where site specific technical evidence is available, the density assumptions applied are higher that LBC’s basic density assumption of 50 dwellings per hectare (“dpa”), CBC remains firmly of the view that LBC’s assessments of urban capacity are not based on justified density assumptions that are consistent with current and emerging national policy. 62.5 There is an acceptance within many towns and cities across England, which like Luton have high demand for housing but an acutely restricted supply of land due to tightly defined administrative boundaries, that to proactively meet identified housing needs (as required by national policy) that there is a need to optimise land potential through encouraging and support residential development at levels considerably higher than 50dph within town centre and other accessible urban locations. 62.6 Indeed the SHLAA 2016 states (paragraph 2.19) that ‘due to the built-up nature of Luton and limited supply of open spaces, it is likely that the majority of development will continue the historic patters of being delivered above 50dph. This statement alone confirms that the SHLAA’s default density assumption under assesses future urban capacity. 62.7 Encouraging higher density development is supported within the CABE Better Neighbourhoods: Making Higher Densities Work publication, which outlines that building at higher densities can provide significant benefits for developers and residents alike.