Epping Forest District Council Representations to the Draft Local Plan Consultation 2016 (Regulation 18) Stakeholder ID 3381 Name Andy Butcher on behalf Strutt & Parker of Countryside Properties Method Email Date 19/1/2017 This document has been created using information from the Council’s database of responses to the Draft Local Plan Consultation 2016. Some elements of the full response such as formatting and images may not appear accurately. Should you wish to review the original response, please contact the Planning Policy team: [email protected] Letter or Email Response: Draft Epping Forest District Local Plan Consultation: Response on behalf of Countryside Properties Land South of Vicarage Lane, North Weald Bassett (Site SR-0158A) December 2016 CONTENTS Introduction Comments on the Draft Local Plan Conclusion Appendices Appendix 1 – Site Plan Appendix 2 - Brochure land south of Vicarage Lane, North Weald Bassett (Site SR-0158A) 1.0 Introduction 1.1 Strutt & Parker have been instructed by Countryside Properties to submit representations to the Draft Epping Forest District Local Plan (DLP) consultation. Previous submissions were made to Epping Forest District Council (EFDC) in connection with land south of Vicarage Lane North Weald Bassett by the landowners in the Issues and Options Community Choices Consultation in 2012 and subsequently by Countryside Properties for the Site Promoter Survey in July 2016. The land in question is identified on the plan at Appendix 1. In the EFDC Strategic Land Availability Assessment (SLAA) 2015, it was identified as site references SR-0076 and SR-0158A. In the DLP the two have been combined under SR-0158A and are shown for allocation at draft Policy P6. 1.2 Countryside Properties have a proud history of building high quality residential developments throughout Essex and have a proven track record of working in collaboration with key stakeholders and local communities to bring forward and deliver high quality sustainable development. Locally to Epping Forest District, Countryside are delivering a new housing development of some 3,600 homes along with community facilities and infrastructure at Beaulieu, north Chelmsford in line with the planned development of the City Council in their Local Plan. 1.3 These representations are accompanied by a brochure which incorporates a concept masterplan Countryside have commissioned to demonstrate how site SR-0158A could be developed to assist in meeting the District’s housing requirements. This document sets out comments on those issues of greatest relevance to our client’s interests in the consultation. 1.4 Countryside have an agreement with the landowners to promote and develop the site and therefore, as a residential developer, can confirm that the site is available for the construction of new homes. Countryside have also undertaken a number of background studies which confirm that the site is deliverable and would be happy to discuss these with the Council in due course. 2.0 Comments on the Draft Local Plan 2.1 Countryside Properties have detailed comments on the DLP in respect of : - The draft vision of objectives for Epping Forest District (3.26). Objectively Assessed Housing Needs (3.45 – 3.56) Housing supply and delivery (3.62 and Appendix 5) The Vision for North Weald Bassett And the following draft policies: SP2 SP4 SP5 H1 H2 ? DM1,2 4, 5 and 6 DM 9 DM 10 P6 D2 Draft Vision and Objectives for Epping Forest District 2.2 The overall strategic vision Response to the Draft Local Plan Consultation 2016 (Regulation 18) Stakeholder ID 3381 Name Andy Butcher on behalf of Countryside Properties 1 for the District and the Local Plan objectives expressed at 3.26 of the Plan is supported, particularly those elements relating to the need to make provision for objectively assessed market and affordable housing needs within the District, ensuring homes provide an appropriate mix of sizes, types and forms of tenure to meet local needs, and the creation of balanced, mixed and well integrated communities. In this regard the allocation of site SR-0158A would contribute to meeting those objectives for the reasons set out in these representations and the accompanying brochure. 2.3 Nevertheless, it is noted that DLP objective B introduces a caveat to meeting housing need; “to the extent that this is compatible with national planning policy”. It is not clear why this has been added. The National Planning Policy Framework (NPPF) is clear that a Local Plan should be prepared on a strategy that seeks to meet objectively assessed housing need (OAHN) in full. It is suggested that this caveat is removed or amended. Approach to Objectively Assessed Housing Need 2.4 The NPPF is clear on the importance of housing delivery, and on the need for planning to deliver the OAHN. This is illustrated at paragraph 17 of the NPPF which states that: “Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities” 2.5 This point is then reinforced at paragraph 47 of the NPPF, where it is stressed that Local Plans should ensure objectively assessed needs for market and affordable housing are met. Paragraph 182 of the NPPF confirms that Local Plans be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development. 2.6 Meeting housing need is therefore of paramount importance if any Local Plan is to be sound. In this respect, it is considered that the approach of the DLP of catering for a need of 11,400 against the OAHN could be challenged. This is on the basis that it fails to acknowledge the issues associated with London or take into account more up to date evidence on housing needs or address with unmet need from other authority areas. 2.7 2.8 2.9 Issues associated with London housing needs It is unclear whether the West Essex and East Hertfordshire Strategic Housing Market Assessment (SHMA, 2015), from which the District’s housing need has been derived, has accounted for projected increased out-migration from London. Up to date evidence on Housing needs Conversely, the South Essex SHMA (2016) does note that Greater London Authority (GLA) projections assume migration outflow from London to neighbouring authorities will increase beyond the level suggested by the 2012 sub national population projections, reflecting more closely pre-recession trends. These projections formed part of the evidence underpinning the Further Alterations to the London Plan (FALP). The South Essex SHMA (2016) addresses the administrative areas of Basildon Borough, Castle Point Borough, Rochford District, Southend Borough and Thurrock. It noted the relationship between these areas and London, and concluded the projected increased out-migration from London necessitated an uplift in housing need for South Essex. It is clear from the DLP and the supporting evidence that there is a similarly strong (if not stronger) relationship between Epping Forest District and London given its location and connections to the capital. As such, the OAHN should account for this and an appropriate uplift should at least be considered to ensure the Plan is sound. It is unclear whether the DLP proposes to meet what the Council consider its OAHN to be. The DLP reports that SHMA identified a need for 46,100 dwellings between 2011 and 2033; 11,300 for Epping District specifically (equating to 514 dwellings per year). However, in August 2016 Opinion Research Services (ORS) updated the overall housing need to take into account more recent information, including more up-to-date household projections. It identified a revised OAHN for the housing market area of 54,608 between 2011 and 2033. The update goes on to state that the OAHN for Epping District is 13,278 dwellings in Epping Forest (equating to 604 dwellings per year). It would appear that the DLP does not therefore fully address the District’s objectively assessed housing need of 13,278 dwellings. 2.10 Duty to cooperate and unmet needs The NPPF not only requires the Local Plan to ensure the District’s development needs are met in full, but also that the unmet needs of neighbouring authorities are considered and addressed where it would be sustainable to do so. The DLP notes at paragraph 3.16 that a Draft Memorandum of Understanding (MoU) between East Hertfordshire, Epping Forest, Harlow and Uttlesford has been produced. However, it is unclear whether any unmet development needs of other neighbouring authorities has been accounted for. At paragraph 3.35, the DLP indicates that the maximum number of dwellings that can be accommodated in the housing market area is 51,100 dwellings based on the Sustainability Appraisal of Strategic Spatial Options for the West Essex and East Hertfordshire Housing Market Area (SA of SSO) (2016). However, the SA of SSO does not fully support this Response to the Draft Local Plan Consultation 2016 (Regulation 18) Stakeholder ID 3381 Name Andy Butcher on behalf of Countryside Properties 2 view. At page 34, it states: “With respect to the overall quantum of c. 51,000 new homes, this reflects the furthest the authorities consider that they can reasonably go in delivering the most recent advice from ORS regarding housing need, ie. 54,608 homes to 2033, in light of the available evidence. Critically, the figure of c. 51,100 significantly exceeds the formal OAHN of 46,100 established through the SHMA and represents strong progress towards the revised figure.