Persimmon/439830/3283/P30/M1 3

PERSIMMON/439830/3283/P30/M13, PERSIMMON/439830/3346/P30/M1 3, PERSIMMON/439830/3450/P30/M13, PERSIMMON/439830/3508/P30/M13, PERSIMMON/439830/3512/P30/M13, PERSIMMON/439830/3583/P30/M13, PERSIMMON/439830/3660/P30/M13, PERSIMMON/439830/3708/P30/M13, DURHAM LOC PERSIMMON/439830/3918/P30/M13, PERSIMMON/439830/4315/P30/M1 3, EXAMINATION PERSIMMON/439830/3609/P31/M13

Response to Inspector’s Matters, Issues and Questions

Made on Behalf of Persimmon Homes North East & Charles Church

Matter 13: HOUSING (Policy 29-34)

Preamble

13.1 On behalf of our client Persimmon Homes and Charles Church, we write to provide comments in response to the Submitted Durham Local Plan, following our previous representations on the consultation for the Proposed Pre-Submission Draft in October 2013.

13.2 Our client is one of the UK’s leading house builders, committed to the highest standards of design, construction and service. They have a large number of site interests across Durham and therefore are very keen to engage with the Council and assist in preparing a sound plan which is positively prepared, justified, effective and consistent.

Persimmon Homes and Charles Church Site Interests in Durham

13.3 This is a list of our client’s site interests upon which we will be commenting individually in statements either now or at stage 2 of the EIP:

1. Site H8 — Merryoaks, Durham;

2. Site H19 — South of Drum, Chester-le-Street;

3. Site H28 — South Knitsley Lane, Consett;

4. Site H33 — West House Farm, Sacriston;

5. Site H37 — West of Woodstone Village, Fencehouses;

6. Site H39 — Brooms Public House, Urpeth;

23034/AS/ME/Matter 13 1 August 2014 13.5 13.4 23034/A5IME/Matter

These On justified Draft make questions

Key Does framework Q including deliverable a) valuation there permission occupation, and

impacts does reasonableness

13.1

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and H41 H49 H44

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at H71 at H72 H75 adjacent

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inspector

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Coundon Aykley

Housing Bournmoor

Burnhope

clients,

10% easily

achievable

provide

the

allowing — — — — — —

with

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West Canney Eldon

Rear Former fling Dunelm accommodation

following

this

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Commitments

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Sites (1/BR/09)

(2/60/06

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Road,

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Auckland;

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the

period

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Aycliffe;

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and

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Easington

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Charles

Sniperley

and

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reasonable in

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Submission dwellings,

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inevitable

Policy

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as 2014

with

the the

to of

a BARTON WILLMORE

13.6 It should be noted that within Table 2 Components of the Housing Requirement within Policy 3 states that current commitments within Durham equate to 13,547 units, however at Paragraph 7.4 under Existing Housing Commitments, this figure is measured as 13,459, with the figure for houses completed since 1st April 2012 standing the same in both references as 2,252.

13.7 This therefore leaves a shortfall of some 88 units which have not been accounted Lr within the overall housing target and more importantly within the residual target of 15,583.

13.8 It is also noted that within Policy 30; Housing Land Allocations when combining the housing allocation figures it results in a figure of 15,573; this is therefore a 10 unit shortfall on the residual target identified above.

13.9 This results in an overall shortfall when combining shortfall in commitments and

shortfall in allocations of 98 units. Table 2 assumes a rounding up of the target to account for the overall target of 31,400. However this means that either a mistake

has been made within the reference between Table 2 and Paragraph 7.4 or a resulting shortfall of 80 units exists.

13.10 Irrespective of this, the Council’s current approach (summarised in Policy 3 and its explanatory text) outlines that the sources of supply comprise solely of completions

(2011 — 2013), commitments and allocations. There is no allowance for factors such as demolitions, windfall or non-implementation of commitments or allocations. As such it would only take a small alteration to any of the sources of supply that the Council has assumed as a result of these other factors to create a scenario where the Council’s housing requirements can no longer be met. We would therefore advocate the consideration of expanded allocations or additional sites to ensure that a suitable buffer exists so that the Council can continue to identify enough housing land to meet its requirements.

Inspector’s Questions

Housing Land Allocations (Policy 30) a) Do the sites allocated in the Plan, together with the housing commitments, provide a range and choice of sites capable of meeting objectively assessed need and delivering the Spatial Approach for the future development of County Durham?

23034/AS/ME/Matter 13 3 August 2014 13.11 13.12 13.13 23034/A5/ME/Matter 13.14 there development conurbations allowance b) position, methodology. Belt? Our as our the plan However Our Our housing a What response plan. client result client period client exceptional 2. 4. 3. 5. 1. 7. 6. 8. 9. 10. 11. 12. 13. 14. allocations: our Detailed is supports in should supports for being also 13 with the to client across terms Site to Site Site Site Site Site Site Site Site Site Site Site Site Site windfalls, Matter include respectfully current have the too comments Hi H19 H8— H33 H28 H37 H41 H39 H44 H71 H49 H72 at H75 the objects circumstances the of the ability Coundon low, — 4 consideration — inclusion — — — — — — — — — — Merryoaks, Sniperley our of existing South South West general West Canney Eldon West Brooms Rear Former Dunelm county the and and this to to client’s on requests the of council of House of (3/CO/2, achieve Whins, of examination. Knitsley future provision of the Easington High Hill, Public Woodstone Stables; Fennel Park, direction Drum, policy but Durham; the commitments, land) to Council’s for 4 Farm, Bishop West should following Newton justify the Durham sustainability focus House, Lane, 5, 3/CO/S further Grove, Chester-le-Street; on Council identified tO of Sacriston; addition Road, the Auckland; Village, be Consett; housing given Aycliffe; Policy removal & Urpeth; (with land & Easington housing basis looking 3/CO/25); 15-year Crook; Offices; future proposal development, Fencehouses; of a to 30, of in requirement modified the sites: of to Durham the the Colliery; with increase housing sites proposed following overall to latest the boundary be from City

WILLMORE being allocated are distribution the target land SHLAA? August sites provided the provision, and target BARTON a suitable supply for Green to within other 2014 Are and the the of in BARTON WILLMORE

15. Site at Bournmoor (2/BO/06 & 2/BO/lO); and

16. Site at Aykley Heads — Adjacent to Police Headquarters; Skid Pan 17. Site at Burnhope

13.15 We will be providing separate representations on each of these sites under Stage 2 of the EIP, however specific sites have the potential to make additional contributions to the identified shortfall and we therefore have highlighted the details below.

Hi Sn4oerley Park - BOUNDARYOBJECTION

13.16 Whilst our client supports the allocation as a strategic site we strongly object to the currently defined boundary. We request that the boundary is revised as a main modification of the proposed plan to include our client’s interest. The proposal forms a logical infill as considered within the Deliverability Statement included with this statement.

13.17 As identified within our statement regarding Matter 7; Durham City the proposed site lies within the both the same landscape character area and the same broad landscape type as the current allocation. There is no distinction between the physical boundaries of the allocation site and that of our client’s site, indeed features such as field boundaries and woodland tree and hedge patterns following the same irregular patterns, with varying condition, size and shape.

13.18 The Landscape Statement submitted in support of these representations explores the historical context of the Sniperley Farm parkland. It concludes that the ‘parkiand’ reference relates in a historical context to a far tighter boundary surrounding Sniperley Farm and as such the designation based on a wider usage should not restrict development.

13.19 The strong physical boundary of the A691 to the west will resist coalescence with any neighbouring community and therefore ensure that the plan maintains adherence to the NPPF which stipulates at Paragraph 85 (final bullet point) that ‘When defining boundaries, local planning author/ties should define boundaries c/early, using physical features that are readily recognisable and likely to be permanent Clarity can be achieved with the definition of the western boundary of

23O34lASlMElMatter13 5 August 2014 13.20

13.21

13.22

13.23

23034/AS/ME/Matter 13.24

the character

With allocation area,

deliver H28 request

whilst object to Preferred

H41 As previously

included Coundon client’s We Coundon

should contained Boummoor Green Chester-le-Street target Whilst identify

been

the

stated

also

allocation

South

Canney

regard which

identified

for Belt,

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north,

that

site

consider

within new

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Options

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at within

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and required

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note

OBJECTION -

given

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OBJECTION

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Coundon

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Preferred

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from units.

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boundary map South

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OBJECTION

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logical

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whilst

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WILLMORE It

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and

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2014

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well can

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that the

our

the

has the

to BARTON WILLMORE

the Council wish to secure an appropriate mix of dwelling types and sizes. The allocation of the Bournmoor site would appropriately re-address the imbalance that could exist within Bournmoor

Ayk/ey Heads - OBJECTION WRONG USE

13.25 As stated within our submission on Matter 8; Other Strategic Sites it is agreed between parties that an omission within the Strategic Employment Site Allocation has occurred and the intended housing allocation adjacent to the proposed replacement Policy HQ has been excluded. This site was identified within the SPD; which is cited within the supporting text of policy 7 at paragraph 4.103. We therefore respectfully request that the site is reintroduced through modifications to the plan as outlined as Site 17 of the SPD.

Phasing of Sites - OBJECTION

13.26 Our client objects to the phasing policy included within Policy 30 as it is does not allow great enough flexibility in the ability to deliver the allocated housing provision. We made representations at the pre-submission stage, however, the policy has not taken account of the need to ensure choice and competition in the market and allow flexibility in the phasing plan. Should the policy wording with regards to phasing remain as per submitted we suggest the following alterations to the phasing of individual sites:

1. Site Hi — Sniperley Park — Short Term - Retain

2. Site H8 — Merryoaks, Durham — Short Term - Retain

3. Site H19 — South of Drum, Chester-le-Street — Medium Term

— Alter to Short Term

4. Site H28 — South Knitsley Lane, Consett — Medium Term - Retain

5. Site H33 — West House Farm, Sacriston — Short Term — Retain

6. Site H37 — W Woodstone Village, Fencehouses — Long Term

— Alter to Short Term

7. Site H39 — Brooms Public House, Urpeth — Long Term — Alter to Short Term

8. Site H41 — Canney Hill, Bishop Auckland — Short Term — Retain

23034/A5/ME/Matter 13 7 August 2014 13.27 13.28 13.29 23034/AS/ME/Matter Our the the Indeed delivering infrastructure within against It then seen scenario. retained, proposal policy Our allocation was identifies site promote services. Policy Yield is cumulative phasing client also specifics client determined a - to the 9. to 10. 11. 12. 13. 16 suitable the OBJECTION policy noted be identified higher stop it (Sustainable that Whilst is plan. believes community restructuring strongly has plan 13 identified restricting Site Alter requirements Site Site of Site Term Retain Site Retain of ‘an a impact that, replacement the these site densities without each the by H44 H49 estimate H71 H72 H75 to that for — potential should adopting recommends individual identified Alter Short of as sites housing benefits — — Design — — — delivery the the Rear of the Eldon Former W. Dunelm prejudicing being for to to phasing of Term would policy Fennel aforementioned could developments said Short of to in come the an sites Whins, sites allocation; in approximate. and within Easington High the prejudice Stables average short the a) not number that have Grove, Term will forward that will Built the improvements of 8 West Newton prejudice medium the the the allow the term be — aims have Environment). Easington Policy of Council Medium density the do short Road, considered phasing potential at sites yield dwellings Paragraph sites of not Aycliffe proposal. term delivery an good the the term 16 Crook are result earlier Offices prescribed Term and having to requirement delivery coming indeed Colliery plan, access under — able faces in both to of developable — Medium in 7.15 — This stage. further Short — This be whilst the housing Retain an to Short considers strict of forward — to service issue delivered of does unacceptable move within potential Medium other is Term transport Term the within also detail The Term adherence an of

WILLMORE in not supporting forward area allocated in provision — early each ensuring deliverability, Durham. — unacceptable the on August within Policy consider — case to

BARTON. based links each ability assist delivery housing impact. within it of 30 Stage 2014 sites that and If was text and site the the be on in to a BARTON WILLMORE

2 of the Examination in Public this matter of principle needs to be considered within this strategic policy.

Buffer - OBJECTION

13.30 For part b) of the policy we request that it also makes reference to the need for an appropriate buffer of 20% (on the basis of persistent under delivery against past housing targets) to ensure that it accords with the Framework.

13.31 In addition for monitoring Policy 30, we request that both the indicators and the target refer to not just the five year housing land supply as currently drafted, but also the appropriate buffer of 20% in accordance with the Framework and on the basis of the Council’s persistent under delivery against relevant housing targets over the last 5 years.

13.32 As it stands the five year housing land supply outlined in the Council’s Strategic Housing Land Availability Assessment (“SHLAA”)published in October 2013 does not provide enough detail to demonstrate that the Council has the required deliverable housing land when the required buffer of 20% is taken into account. Likewise the SHLAAalso does not provide sufficient detail of how the Council are to deliver

developable sites within the medium term (6-10 years) and the longer term (11 — 15 years). Our detailed analysis of this is contained in our comments relating to Matter 4. The lack of this information in a clear housing trajectory means it is unclear how the Council intend to deliver its housing requirement over the plan period and ensure a ready supply of sites is able to offered throughout the plan period. We understand the Council are currently undertaking this work and look forward to reviewing it in due course.

Q 13.3 Addressing Housing Need (Policy 31) a) Is the approach to providing affordable housing appropriate, soundly based, justified with robust evidence, effective, deliverable, viable and consistent with national policy, particularly in terms of: i. The latest Strategic Housing Market Assessment indicates a net shortfall of 674 affordable dwellingslyear. How will this amount of affordable housing be delivered, including the size, type and tenure of affordable housing and the means of meeting the objectively assessed need for affordable housing?

23034/AS/ME/Matter 13 9 August 2014 13.33

13.34

13.35

23034/A5/ME/Matter

The 2013

is need) affordable Persimmon meet time affordable forward. that that satisfied their

viability reasonable Council’s The A deliver

affordable (which SHMA period).

674

concern

Council’s

Local

they viability

most

update.

the

sites

and

units

ii. affordable Central, demonstrate Durham. supported

unduly update iii. and iv. increase

the

indicates considerations

that

This

approach

have

need

housing

Plans the

Policy remains

housing recent

dwellings

justified

and amount

Homes

Is per

the

is The

the

Strategic

is and important

capacity

onerous

concerns

for year.

proportionate

the not

the

North,

need

somewhat the

requirement

current

Are

2013

Annual

and reflects

levels

housing, and

however

affordable

creates of

threatened.

provision

per

housing This that with

requirement

affordable

in Housing

to these

Charles

sets overall update

South

and

that to

across

informed

year

levels

relation

Monitoring

is accommodate

the

alternative

evidence?

short note

deliverable viability

that

based

with consistent

over

way. a

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increasingly

have

options

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advises

and thresholds

estimation Church of for

the

Market

Overall

that overall

variable

units

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burdening

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County robust 1O%

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other East

the affordable

issues

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Report

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this

per

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and

Assessment

understand

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Persimmon

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with

identified

size

Durham which

provide respect

year

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assessment

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target Council

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and need.

housing 2012-13

units

national

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housing

scale

indicated

affordable

plan

also

can

173

delivered

with

people

they

targets

The

per need

the and

comprises

historically

housing

affordable Homes

(between

obligations

issue

viability

of or

of prevent

are

incorporates

period, in

reveals

high

annum

support on requirement

Council

obligations

the

intermediate

Policy

policy?

(backlog

broadly

of reasonable,

housing a of units

between

and

and economic

the

Framework

site

fully

affordability should

however

housing

that

31.

outlined

has

dwellings

has the

2013

Charles

unrealistic

2012 assessments

are units (O.2ha) 1O%-20%)

able

and

WILLMORE

need

not

justified need

flexibility

site

equated

2011

be SHMA

set

allowance Report

newly

sites

viability?

average

housing

been

provide

(O.5ha)

in emphasises

necessary

basis.

Church

August BARTON

provided

the

within

out in over

and

the

levels

Durham

update.

coming

met arising

this

able

West

and

same

and

2015 such

2013 in

for 2014

and

this

are 175

the

the to

for in

a BARTON WILLMORE

housing market in County Durham; indicating that demand for affordable housing in the County is currently outstripping supply.

13.36 In this respect the NPPG makes clear that there is provision for plan makers to adjust their objective assessments of housing requirements to take account of affordable need (Reference ID: 2a-029-20140306). On the issue of securing affordable housing provision, the NPPG specifically states that housing figures can be increased where they could help deliver the required number of affordable homes. An upward revision to the housing numbers in County Durham could therefore help alleviate the trend of worsening market signals.

13.37 We also note that Policy 31 makes provision of increasing options for housing for elderly people. Our previous representations highlighted our concern with this. Whilst the 2013 SHMAupdate shows that older people would like to move to other types of housing, it is unclear as to why the requirement is 10%. We are not convinced the Council’s Development Viability Study (“DVS”) has fully considered the impact of imposing such a 10% provision on the viability of private or intermediate housing schemes. Furthermore, the policy requires all of the 10% of older people housing to be built to Lifetime Homes Standards. Again, the viability impact of this has not been properly tested and so should be excluded from the policy.

Q 13.4 Houses in Multiple Occupation (HMO) and Student Accommodation (Policy 32) a) Is the approach to HMO and Student Accommodation appropriate, justified with evidence, effective, soundly based and consistent with national policy?

13.38 No Comment.

Q 13.5 Sites for Travellers (Policy 33) a) Is the approach to making provision for travellers, including the level of provision and the criteria for new sites, appropriate, justified, effective, positively prepared, soundly based and consistent with national policy? b) Has the Traveller Site Needs Assessment considered cross-boundary issues related to the provision of accommodation for travellers, including the needs of neighbouring local authorities? Is it consistent with paragraph 9 of the PPTS?

23034/AS/ME/Matter 13 11 August 2014 13.39 13.40 23034/AS/ME/Matter a) of Q residential housing No based reflect No 13.6 Is the Comment. Comment. the and Type the recent stock, approach consultation consistent 13 developments and consultation appropriate, Mix to of with providing Housing within taking national on justified Policy housing (Policy a 12 mix account policy, 34? of 34) with standards dwelling, of particularly evidence, existing and types is imbalances given effective, and it appropriate

WILLMORE sizes the August

BARTON outcome soundly on in new 2014 the to