Examination of Suffolk Coastal Plan – Site Allocations and Area Specific Policies Document Comments regarding SCDC FINAL Housing Land Supply Position – Sept 2016 Clearly the Council has continued to experience difficulties in providing accurate estimates of land supply. One cannot have total confidence even in this latest paper, given basic errors in predecessor documents. An evidently rushed and chaotic process has been pursued in order to achieve the required number of dwellings for the 5-year plan. This has led to the last minute resurrection of Policy SSP4 at Aldringham which had been ruled out prior to the Preferred Options stage and at double the density originally envisaged. Policy SSP4 is listed in Appendix A of SCDC Housing Land Supply Assessment, dated June 2016 (F-09) with the comment “Subject to challenge to Site Allocations Document – Aldringham now has a Designated Neighbourhood Plan Area”. The Council had removed that comment by the time it published its August 2016 Update (F-11), presumably having ignored or dismissed Representation 8002 from Aldringham-cum-Thorpe Parish Council which referred to its previously stated wish to “consider any proposals in conjunction with developing our Neighbourhood Plan”. Aldringham-cum-Thorpe Parish Council had neither been informed nor consulted about SSP4 prior to this “Submission” stage, but during the Hearings, the Inspector told me that the Hearings themselves provided an opportunity for such challenges and objections to be reviewed. It is now clear that SCDC had already dismissed all representations regarding SSP4 prior to the Hearings. This latest Housing Land Supply Position indicates that the Council has a satisfactory 5.4 years land supply including a 5% buffer. Therefore SSP4 is not necessary to meet District demand. Indeed even after the removal of its 40 houses from the Plan, that figure of approximately 5.4 years land supply will not change. I once again request that the Inspector finds that SSP4 should be deleted and Aldringham-cum-Thorpe Physical Limits be returned to its 2015 position. Should the Inspector nevertheless decide that a site at Aldringham will be needed within the 5 year period, I would ask that she rules that the Council must refer the matter to our ongoing Neighbourhood Planning process. I recognise that the Inspector, in her wisdom and after considering all the Parish’s objections and evidence that I put forward at the Hearings, may still be minded to retain the SSP4 allocation. Should that be the case, I would ask her to require the Council to reassess its viability calculations based upon “Gross Development Value” reflecting actual prices paid in Aldringham-cum-Thorpe for the 12 month period and “Target Land Value” appropriate for un-farmed scrubland. I anticipate that such correction to the viability model would lead to a significant reduction in the number of units, quite possibly finding that the originally envisaged 20 units would be viable offering a much lower housing density more appropriate to a rural setting. I refer to Planning Practice Guidance - Viability and plan making - key factors to be taken into account - Gross Development Value which states that “Values should be based on comparable, market information”. In response to Issue 10, Question 46, Mr Aust (author of the Council’s Viability Report (D-15) dated February 2016) explained that in order to achieve financial viability for a potential Developer, he had found it necessary to change the assumptions made when the site had been previously assessed. He stated that when the site had originally been assesse, Gross Development Value had been derived from CIL rate which for Aldringham is set as “High”. Mr Aust explained that he had found it difficult to break out the actual property sales for Aldringham separately without examining sales data pertaining to each street. I have concluded from what Mr Oust told us at the Hearing that the calculations for Aldringham would have been based on the much larger IP16 post code area. If that was the case, it would go a long way to explain why revised viability modelling suggested to the Council an increase of the allocation SSP4 from 20 to 40 units in order to achieve the notional viability threshold. The Market Town of Leiston dominates the housing stock in post code area IP16 with approximately 3000 dwellings. Leiston is a post industrial market town with large numbers of relatively low value Victorian terraced houses. There is little opportunity for employment in Leiston and property prices are accordingly significantly lower than the surrounding areas. Aldringham is a small rural village close to Leiston with fewer than 400 houses and quite distinctly different. Properties in Aldringham are much sought after particularly for retirement and as second homes. They typically sell at a much higher value than is the average for IP16. Mr Aust’s remodelling, based upon 40 houses instead of the originally envisaged 20 houses and using revised assumptions on open market value and land value, have resulted in Land Value at the Aldringham site being recalculated as 142% of “Target Land Value” indicating viability well in excess of target. As well as increasing the proposed allocation from 20 to 40 houses, density would be increased to 30.12 units per Hectare, by far the highest density of any sites listed in Tables B of the Viability Report. The Viability Study Report states in 7.4.1 that for open market properties, the revised model has “assumed sales values based on post code averages for the last 12 months, plus up to a maximum of 10% uplift” and that the key data sources referred to were Rightmove, Zoopla and Land Registry data. Following the Hearings, I have attempted to identify and analyse Aldringham data from those data sources. Rightmove and Zoopla provide searches on market data by post code area (IP16 in this case) but not at the lower level of Parish or Village. The Land Registry search tool is more versatile but I have not found a way to use it to search only for either Aldringham or Aldringham- cum-Thorpe Parish. However, Land Registry does provide an on-line tool to search by post code area with the option of downloading the data items selected. Once downloaded it is possible to identify all transactions relating to completed sales in Aldringham-cum-Thorpe Parish and Aldringham. By using this tool, I have been able to analyse Land Registry data for the full year 2015 which shows that Average price paid for houses sold in Aldringham-cum-Thorpe Parish was 59% above the average for IP16 as a whole (report enclosed below). I conclude that the Council’s Viability Study is most probably flawed as a consequence of its decision to derive market value for Aldringham from Sales within the much wider (Leiston area) post code (IP16). Consequentially the potential Gross Development Value at the Site has been very significantly underestimated. I suspect that no “sanity check” was carried out on the results of the revised mathematical calculation. Had the Council chosen to share with the Parish Council its plans to include SSP4 site within the Plan, it is quite likely that the error would have come to light through access to local knowledge. W.R. Halford – Author of Objection no. 7860 15 September 2016 Enclosed below: Results from search of Land Registry for Completed Sales in Post Code area IP16 during 2015 Land Registry House Price Paid Data Set for period 01/01/15 to 31/12/15 Search parameters Post code: IP16 Property Types: Detached, Semi detached, Terraced New build and Not New build Estate type: Freehold Transaction category: Standard Summary Average price paid Aldringham £292,250 42% in excess of the average price paid in IP16 Average price paid Aldringham-cum-Thorpe Parish £328,839 59% in excess of the average price paid in IP16 Average IP16 (Leiston and surrounding areas) £206,196 saon paon street locality town district Individual house sale transactions 257000 16/07/2015 IP16 4WH D N F 2 MEADOW RISE ALDRINGHAM LEISTON SUFFOLK COASTAL 210000 07/10/2015 IP16 4WH S N F 5 MEADOW RISE ALDRINGHAM LEISTON SUFFOLK COASTAL 270000 16/07/2015 IP16 4QZ D N F 14 ALDRINGHAM PARK ALDRINGHAM LEISTON SUFFOLK COASTAL 249000 12/01/2015 IP16 4QZ D N F 19 ALDRINGHAM PARK ALDRINGHAM LEISTON SUFFOLK COASTAL ASH TREE 285000 13/08/2015 IP16 4QJ D N F COTTAGE ALDEBURGH ROAD ALDRINGHAM LEISTON SUFFOLK COASTAL 575000 19/05/2015 IP16 4QH S N F FIVE ACRE BARN ALDEBURGH ROAD ALDRINGHAM LEISTON SUFFOLK COASTAL 245000 30/06/2015 IP16 4PR D N F HOLLYWOOD ALDEBURGH ROAD ALDRINGHAM LEISTON SUFFOLK COASTAL 260000 27/04/2015 IP16 4PW S N F 2 MEADOWSIDE ALDEBURGH ROAD ALDRINGHAM LEISTON SUFFOLK COASTAL 316500 27/02/2015 IP16 4PZ D N F SEVENBROOMES MILL HILL ALDRINGHAM LEISTON SUFFOLK COASTAL 255000 14/07/2015 IP16 4PT D N F THE LODGE ALDEBURGH ROAD ALDRINGHAM LEISTON SUFFOLK COASTAL ALDRINGHAM-CUM- 445000 17/07/2015 IP16 4NA D N F 1 PEACE PLACE THORPE (THORPENESS) LEISTON SUFFOLK COASTAL ALDRINGHAM-CUM- 475000 08/12/2015 IP16 4NZ T N F 6 OLD HOMES ROAD THORPE (THORPENESS) LEISTON SUFFOLK COASTAL ALDRINGHAM-CUM- 368750 10/07/2015 IP16 4NZ T N F 3 OLD HOMES THORPE (THORPENESS) LEISTON SUFFOLK COASTAL ALDRINGHAM-CUM- 392500 20/03/2015 IP16 4NT T N F 4 THE DUNES THORPE (THORPENESS) LEISTON SUFFOLK COASTAL 220000 04/12/2015 IP16 4TY T N F 1 WHITE COTTAGES SIZEWELL LEISTON SUFFOLK COASTAL 173000 31/07/2015 IP16 4TY T N F 2 WHITE COTTAGES SIZEWELL LEISTON SUFFOLK COASTAL 190000 01/10/2015 IP16 4SD T N F 4 RATTLA CORNER THEBERTON LEISTON SUFFOLK COASTAL DOUGHTY WYLIE 165000 12/03/2015