Land Allocation MDC Feb 18 Ryan S
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Mendip Local Plan Part II: Sites & Policies – Pre-Submission Consultation Consultation Response Form Please use this form to respond or make representations on Local Plan Part II and associated consultation documents. For information or advice, please contact the Planning Policy Team by email at [email protected] or phone (0300) 303 8588. Contact Details If you have appointed somebody to act as your agent, please give their contact details. All correspondence will be sent to the agent Name: Mr Shaun Ryan (landowner) Agent Name: Lee Wright Organisation (if applicable): Company Name: Wright Consult LLP Address: Bay Tree, Cooks Lane, West Cranmore, Shepton Mallet, Somerset Postcode: BA4 4RH Email: [email protected] Tel: Date Completed: 02.02.2018 Do you wish to be notified of future stages of Local Plan Part II (tick box) Ö Öaa We will contact you by e-mail only unless you confirm here (tick box) Data protection – please read - The information collected as part this consultation will be processed by the Council in accordance with the Data Protection Act 1998. The purposes for collecting this data are: to assist in plan making; and to contact you, if necessary, regarding the planning consultation process. Please note that representations must be attributable to named individuals or organisations at a postal address. Representations and contact names will be published on the Mendip website but no other personal information Copies of this form are available from Council Offices and Access Points or can be downloaded from www.mendip.gov.uk/localplanpart2 . If you require this document in another format such as Braille, large print or another language then please contact us. Please use a separate form for each site or main issue you wish to make. You can also attach one contact form to a group of representations. Please make sure any separate documents include your name –so they can be clearly identified. Please return your response by 5pm Monday 12th February 2018. By post to: Planning Policy, Mendip District Council, Cannards Grave Road, Shepton Mallet, Somerset, BA4 5BT By email to: [email protected] By hand to: The Council offices in Shepton Mallet (address above). Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation For office use Details of Objection/ Comment./Representation Name /Organisation: Lee Wright of Wright Consult LLP, on behalf of landowner Mr Shaun Ryan Please indicate the document to which your STR035 Hedges Farm, Middle Brooks, representation relates (e.g. policy, paragraph Street, BA16 0TT number, HELAA site reference) Do you consider the Local Plan is Legally Do you consider the Local Plan is Sound 1 ? 1 Compliant? Yes Ö No Yes No. Ö Do you consider it necessary to participate at examination hearings? (eg present oral Yes evidence) Please provide details below of why you consider the Local Plan is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance and soundness of the plan, please also use this box to set out your comments. HELAA Site Number STR035 Hedges Farm, Middle Brooks, Street, Somerset, BA16 0TT 1. Introduction & Summary This site was previously submitted under the land allocation process. The site is a smallholding that is not viable due to the limited amount of land connected with the smallholding. Currently the applicant keeps a small number of animals on site as more of a hobby than a commercial venture and is looking for alternative use for the site and wishes to self build their own home. There is also space for an additional 1 or 2 dwellings and these may be suitable for other self builders. 2. Issues Local Plan Part II: Pre-submission stage Sustainability Appraisal In ‘Appendix 3: Sites screened out at Initial Assessment’; the site was not screened out In ‘Appendix 5: Results of Sustainability Appraisal of sites in settlements where an allocation is required’; the site was screened out for the following reason: ‘Not suitable for development. Site would involve redevelopment of active farm buildings within a sensitive rural location on the edge of development limits. Not suitable for housing allocation.’ 1 See our Online Guidance note on what these terms mean 2 Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation 3. Comments & Summary Conclusion The farm buildings are not active, they are isolated farm buildings with no land attachment to make farming from them a commercial reality. They are in little use and whilst they contain animals, this is more of a hobby for the landowner who keeps a few animals. The adopted Mendip District Local Plan presents no development constraints on this small parcel of land that sits immediately adjacent Development Limits, other than those afforded by being located the wrong side of the Development Limit line. A small extension of the Development Limit line in this location would facilitate a small but meaningful development of circa 3 dwellinghouses. In the past 10 years there have been planning applications lodged for residential development on the two adjacent properties to the north, being ‘The Willows’, Middle Brooks, Street and ‘Old Orchard House’. Middle Brooks Street for residential development in their respective gardens that lie inside Development Limits and these have been refused for the proximity of the agricultural buildings at Hedges Farm. Cessation of farming in this location will not only bring environmental benefit to the many neighbouring residential properties, but also enable development as desired by the aforementioned neighbours. The access to the site will remain the same as it currently is, using the track that connects to Middle Brooks and the track will be upgraded and surfaced as part of any development. This will also benefit the neighbour to the east at ‘Mon Abri’. Redevelopment in this location when viewed on aerial imagery, will ‘round off’ development with existing adjacent residential properties and provide wide ranging benefit to the wider community. This site is considered ‘developable’ and ‘deliverable’. We also question whether Mendip does in fact have a five year housing land supply and whether sites being allocated to meet that five year housing land supply are ‘deliverable’ and ‘developable’, as expanded upon in the following section. The following section also raises issue with the council’s dependency on large housing sites to deliver; and that smaller sites should also be allocated as they are proven to consistently deliver in terms of numbers and timing; unlike large sites that can be stalled for many years, as is the case in Street, where the strategic site west of Brooks Road has seen limited progress and failed to even develop a masterplan, as confirmed by the council in the Street Section of documents. In conclusion, we would ask that the council consider a small change in the Development Limit line to facilitate development on this site. 4. Housing Land – Demand & Supply Local Plan Part II – Land Allocation Methodology Comments Note: (underline added by author to key policy points for emphasis) Housing Demand The National Planning Policy Framework (NPPF), paragraph 158 states: ‘Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant 3 Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation evidence about the economic, social and environmental characteristics and prospects of the area. Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals.’ Mendip District Local Plan Part II: Sites & Policies Section 3 Housing Land 3.1 Confirms the starting point for considering the delivery levels to be obtained from sites is identified in Part I of the Local Plan. 3.2 Confirms the Part I Plan established a requirement for 420 dwellings per annum and this was tested through the Local Plan examination; however, what it fails to acknowledge is that the inspector confirmed that 420 dwellings per annum should be treated as a ‘minima’. 3.5 Confirms that since the adoption of the Local Plan Part I, the council have undertaken a Strategic Housing Market Assessment (SHMA) and this provides an ‘objectively assessed need’ for housing. Section 3.6 considers it reasonable and justified within a range of 411-491 dwellings per annum and recommends that ‘as a starting point, a level towards the higher end of the range would be more robust’. The starting point for the calculation of ‘objectively assessed need’ is demographic calculations based on the most recent, available population projections. This is made clear in NPPF paragraph 159, which states that the SHMA should be used to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period, taking into account household and population projections, as well as migration and demographic change ie the most upto date housing land requirements. In section 3.7 the council recognise this to be the most upto date evidence of housing need and whilst they state this number not to have been tested through examination by the inspector, the fact that the inspector presiding over the adopted Local Plan stated that 420 dwellings per annum was a ‘minima’, should at the very least provide the council assurance that the upper range of 411- 491 dwellings per annum as recommended in the SHMA, as the most upto date requirements, is not unreasonable; and more realistically, it should guide the council to heeding the advice that they have sought that keeps pointing to a number of dwellings per annum to be way in excess of 420.