North Devon & Torridge Joint Local Plan Examination
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November 2016 North Devon & Torridge Joint Local Plan Examination Hearing Statement on behalf of Chichester Homes Developments Ltd Matter 6: Town Strategies (Braunton) Pre-hearing statement on behalf of Chichester Homes Developments Ltd - Matter 6 (Braunton) 1.0 Introduction 1.1 This hearing statement is submitted on behalf of Chichester Homes Developments Ltd. Chichester Homes Developments Ltd has submitted duly made representations in response to various consultation stages of the draft Plan and welcomes the opportunity to participate in the examination hearings. 1.2 Those representations contained objections to the proposed housing requirement of the Plan, the scale of development directed towards Braunton in comparison to other settlements and the non-allocation of land east of South Park, Braunton, in which Chichester Homes Developments Ltd has an interest. 2.0 Proposed strategy for Braunton 2.1 In particular, those representations argued that the proposed distribution of housing between settlements is unjustified. Other Main Centres, such as South Molton, Northam, Ilfracombe and Great Torrington and Holsworthy are proposed to have significantly higher apportionments of the overall housing requirement than Braunton. 2.2 The proposed housing apportionment for Braunton/Wrafton does not reflect its role and function relative to other Main Centres. Paragraph 10.147 of the Plan states that Braunton is “one of the larger settlements in northern Devon and is an important local service centre providing a range of retail, education, health and community facilities and employment opportunities”. Paragraph 10.148 goes on to state that its population has increased by less than 4% between 2001-10, lower than rates of growth elsewhere in north Devon. Meanwhile, house prices are above average for North Devon and it is a priority area for the delivery of affordable housing. This is highlighted in the North Devon Council Affordable Housing Delivery Plan 2012-2017. 2.3 The Table in Appendix 1 of the Settlement and Distribution Strategy Topic Paper (May 2016) very clearly illustrates the disparity between the level of growth proposed in 2 Pre-hearing statement on behalf of Chichester Homes Developments Ltd - Matter 6 (Braunton) Braunton/Wrafton in comparison with the other Main Centres. Only 9.5% growth is proposed compared with over 20% in all the other Main Centres, some of which (Holsworthy and South Molton) have over 50% growth proposed. In terms of allocations within the plan, as proposed this will deliver only 6.5% growth in Braunton compared with much higher levels in all the other Main Centres. 2.4 However, the function and level of services in Braunton is similar to or greater than those of the other Main Centres. Section 4 of the Settlement and Distribution Strategy Topic Paper explains that there are a variety of factors which have influenced settlement-specific variation in levels of growth including existing commitments, availability of suitable sites, environmental constraints, settlement size and community aspirations for growth. The reason existing commitments in Braunton is low is as a result of the low level of housing directed towards the settlement during the last Plan period and which has contributed to the high affordable need within Braunton. 2.5 The stated reasons for rejecting a higher housing apportionment at Braunton/Wrafton are the environmental constraints that are said to restrict potential for growth. However, none of the constraints listed affect the site at South Park, Braunton which is not the subject to any designations that would be a constraint to its development, as is confirmed by the Strategic Housing Land Availability Assessment (SHLAA) Update December 2014 (ref: SHA/BRA/108) which describes the site as being suitable, available and achievable and therefore developable and concludes, “Development of this site is a logical extension to the east side of Braunton”. 2.6 An application for full planning permission (LPA ref: 61139) proposing a residential development of 55 dwellings (including 19 affordable homes) and associated works on land at South Park, Braunton was submitted on 29 April 2016. The 13 week statutory deadline for a decision was 29 July 2016. It was eventually reported to the Council’s planning committee on 12 October with an officer recommendation of approval but a decision was deferred. The proposed layout is attached as APPENDIX 1 and the officer report is attached 3 Pre-hearing statement on behalf of Chichester Homes Developments Ltd - Matter 6 (Braunton) as APPENDIX 2 which confirms officers’ view that it is a suitable site for a housing development. A non-determination appeal was submitted on 21 October (PINs ref: APP/X1118/W/16/3161459). 2.7 The disproportionate level of growth proposed in Braunton compared with other Main Centres is therefore not justified given that there is a site suitable for development on the edge of the settlement which has not been identified in the Plan. 2.8 The situation is exacerbated by the uncertainty over the delivery of the allocated site at Wrafton Glebefield which, as has been pointed out in previous representations has been allocated previously for housing across numerous previous Plan periods without a deliverable planning permission having yet been achieved. Given this uncertainty, the scale of housing proposed for Braunton is effectively even lower than is stated in the Plan. 3.0 Soundness issues 3.1 Given its status as a priority area for the delivery of affordable housing, the level of housing proposed in Braunton is considered to be unsound in that it has not been positively prepared to meet the housing needs of Braunton, it is not justified (i.e. it is not based on sound evidence and not the most appropriate strategy when considered against other reasonable alternatives) and it is not consistent with the national policy imperative to boost significantly the supply of housing. As Chichester Homes Developments Ltd’ s representations also contend that insufficient housing is being proposed within the Plan generally, the remedy to this soundness issue would be to allocate the land at South Park, Braunton for housing within the Plan. 3.2 The site is within the control of a developer with a proven track record of delivering housing in North Devon. The planning application/appeal scheme referred to above includes 19 affordable homes which would make a very important contribution to delivering affordable housing within a priority area and the site is certainly capable of assisting with the Council’s five year housing land supply. 4 Pre-hearing statement on behalf of Chichester Homes Developments Ltd - Matter 6 (Braunton) 3.3 We look forward to discussing these issues at the Braunton hearing session on the afternoon of Wednesday 30 November. 5 Pre-hearing statement on behalf of Chichester Homes Developments Ltd - Matter 6 (Braunton) APPENDIX 1 6 Eaves 34.02 29.40 29.27 House Ridge 38.88 Eaves 36.08 Eaves 36.22 Ridge 38.43 House 28.81 28.87 Eaves 35.26 Eaves 35.23 Ridge 38.15 28.28 House Eaves 35.07 Pipits Eaves 35.05 Ridge 37.48 FR 32.70 27.70 House 27.72 Eaves C 34.40 Ridge Ridge 37.15 37.16 Ithaca Ridge Ridge ELP C 35.37 36.08 Eaves 34.37 Ridge Eaves House 37.18 Eaves 26.24 Eaves 34.40 34.40 26.12 33.54 Eaves Btm of Bank El Sub Sta 32.77 25.90 26.89 South 26.86 26.29 Eaves 26.12 33.53 Wall 25.91 ELP Nairn View 26.46 Ridge 32.55 Milland 26.46 249700E 249750E 249800E 249850E House Ridge 26.11 35.43 26.05 Eaves 32.69 27.05 136300N 136300N 136300N 26.65 26.85 Ash 27.03 26.89 Track 26.85 Winchcombe 25.21 9 25.20 Liscawne 26.72 1.8m CB 26.55 26.64 Hedge Bank 8 Hedge of 26.51 Btm 26.45 Eastway 26.56 26.37 House 26.34 1.0m 24.82 7 24.78 26.23 1.8m 26.15 PW Hedge CB 26.28 Fence 6 26.09 26.10 26.15 26.0 1.0m 25.35 26.0 25.99 Wall 26.07 26.0 Ash Hedge Retaining 26.0 25.90 5 25.98 25.60 25.77 1.0m 25.93 1.8m Wall CB Retaining 25.05 25.83 24.11 24.17 1.0m 25.61 Wall Oak Retaining 25.57 4 25.65 FL 25.75 24.80 Hawthorn 25.53 25.55 25.56 25.66FL 25.50 25.69 25.59 25.62 25.62 25.54 25.48 25.43 1.0m Wall Fence Retaining 25.34 25.24 3 24.65 25.49 CB 1.8m 2 23.94 25.26 23.86 25.25 FL 24.91 1:15 25.06 1.0m 25.1325.18 25.06 Wall C 1 25.06 25.01 25.0 25.0 25.0 Retaining 24.91 25.148 25.01 25.09 25.04 24.27 25.0 1:12 25.02 25.15 25.0 24.91 25.05 Service 24.20 1:151:12 25.0 25.05 FL 24.81 24.865 24.879 24.88 Service Fangrove 24.80 24.774Service Survey of 1:12 24.30 24.683 Ash Site at 24.802 24.816 24.592 24.61 24.80 23.15 Lower Park Road 24.30 A FL 24.42 24.642 23.22 24.636 C 24.501 Private 24.512 24.711 Braunton FL 24.33 24.739 B 1:12 24.410 24.529 24.33 24.620 24.753 Road 24.370 24.320 24.438 Chichester Developments 24.58 24.36 CB 24.49 24.43 24.456 D 24.559 1.8m FL 24.46 24.2624.41 24.339 07/15 1:200@A1 PJL 24.26 24.229 24.257 24.347 24.375 24.517 24.28 24.29 0.6m 24.30 FL 24.46 22.77 24.32 KR 24.138 24.31 10 22.65 Service 24.32 24.047 24.428 24.1524.16 24.166 24.284 24.45 136250N 136250N 24.12 136250N 24.075 1.0m 24.194 24.0 23.984 24.0 24.103 24.0 1:12 Service 24.0 24.274 PW Ridge 24.388 FL 24.50 24.45 24.012 28.57 23.956 24.334 24.0 KR 0.6m 1.8m 23.865 CB KR Service 22.52 22.47 24.0 23.77 23.921 0.6m House 1:12 23.893 KR 23.992 Service FL 24.35 Eaves 5641 A03 26.04 23.959 1:15 23.802 25 17 0.6m 23.757 28.58 Service Ridge C 23.897 24.035 Service 18 24.035 5641 South Park Braunton Rev A.dwg 23.93 24.28 23.80 23.830 24.035 Ash 1:20 23.932 23.75 23.69 Ridge 1 23.834 23.62 1.8m House 30.23 23.899 23.60 Service 23.662 CB 23.62 1:15 Private 23.837 23.680 23.64 23.59