Leeds - Planning 9 Bond Court 1st Floor Planning Policy Leeds Hambleton District Council LS1 2JZ Civic Centre T: 0113 2425155 Stonecross Brompton Northallerton DL6 2UU Your ref: Our ref: EW/J1076026 By e -mail: [email protected] 17 September 2019 Dear Sirs HAMBLETON COUNCIL LOCAL PLAN PUBLICATION (REGULATION 19) DRAFT CONSULTATION We write to submit representations to the Local Plan Publication Draft Consultation on behalf of our client, Taylor Wimpey UK Limited, in support of site ref S/058/005a and S/058/006a, land east and west of Easby Lane, Great Ayton. The Council will be aware that representations to the emerging plan in respect of both sites were made to the the Issues and Options Consultation in January/February 2016, along with the Preferred Options Consultation of October – December 2016, and the Alternative Sites Consultation of April – June 2017. In brief summary we consider that sites S/058/005a and S/058/006a are significantly more acceptable in planning terms than other housing allocation options for Great Ayton. Our further comments and representations are set out below. For reference these representations include the following information: • Covering Letter from Carter Jonas dated 17 September 2019; • Appendix 1 Heritage Technical Note – BWB, dated 16 September 2019; • Appendix 2 Summary of sites assessed within Great Ayton as part of the Emerging Local Plan, dated 16 September 2019; • Call for Sites Consultation Representations – Carter Jonas, dated 4 September 2015; • Easby Lane East Masterplan - Pegasus, dated August 2015; • Easby Lane East Landscape Statement – Pegasus, dated August 2015; • Flood Risks and Drainage Constraints – iD Civils Design Ltd dated August 2015; • Easby Lane East Heritage Report – Cater Jonas dated December 2016; and • Croft Transport Solutions Report and Drawings dated August 2015. Soundness Paragraph 35 of the NPPF requires Plans submitted for examination to be prepared in accordance with legal and procedural requirements and meet the four tests of ‘soundness’ for Local Plans to be: • Positively prepared; • Justified; • Effective; and • Consistent with National Policy. Policy S2 Strategic Development Needs The 2018 HEDNA suggests that there is an Objectively Assessed Need (OAN) of 315 dwellings per annum (dpa) or 6,615 homes over the Plan period. This is the figure that the Council has chosen to use as the housing requirement within the Publication Draft and is over and above the figure identified within the Local Housing Need set out by the national Standard Methodology (Planning Practice Guidance Paragraph: 004 Reference ID: 2a-004-20190220, Revision date: 20 02 2019). Despite this we note that, whilst the Standard Method identifies a minimum annual housing need figure, it does not produce a housing requirement figure and does not take into consideration economic growth. The Hambleton Economic Strategy 2014-24 seeks to create 3000 jobs over the 10 year period. It is noted that the Economic Led Housing Need as set out in the HEDNA suggests that the Cambridge Econometrics (CE) August 2017 forecasts result in an employment growth of 165 jobs per annum over the period 2016-2035. This is below the level sought in the Economic Strategy, indicating that there may be potential for a further increase in the housing figure to support the Economic Strategy. We therefore consider it prudent for the Council to increase the housing requirement to provide further flexibility for the future. Further commentary in relation to this matter is set out within the Representations on Housing Matters which is included within Appendix 1. It is therefore considered that Policy S2 is not sound as it is not positively prepared or justified. A further increase in the housing requirement would enable this policy to be considered sound. Given the above, sites such as our client’s land interest at site refs. S/058/005a and S/058/006a could assist with the provision of additional land residential development and should therefore be reconsidered. Policy S3 Spatial Distribution At the heart of the Local Plan is a settlement hierarchy essentially carried forward from the 2007 Core Strategy (CS). CS Policy CP4 sets out a hierarchy of development as the basis for distributing (housing) growth broadly proportionate to the size of population settlement (2001 Census) and therefore (simplistically) the distribution of housing need. In particular, we support the designation of Great Ayton as a Service Village. We consider this remains a valid starting point. Those centres which do or could provide the highest level of facilities and connectivity and accessibility by public transport should be the main focus of growth. Parts of the District are subject to various environmental, physical and policy constraints and designations. In ensuring a sustainable pattern of development it is important these considerations are taken into account. Nevertheless the hierarchy should be considered on a site by site basis, rather than as a mechanism to exclude development. We suggest that in light of the comments above and the need for flexibility through an increased housing number that there should be a broader distribution in sustainable locations further down the settlement hierarchy, including the service villages. Given the availability of shops, services and public transport links, it is appropriate for the service villages, including Great Ayton, to take additional housing sites to provide flexibility and thus for the Plan to adopt a more balanced approach to spatial distribution, whilst still recognising the position of the market towns at the top of the settlement hierarchy. This also help to maintain the position of the service villages also. Sites such as S/058/005a (land east of Easby Lane) and S/058/006a (land west of Easby Lane) are available, suitable and deliverable and could provide the Council with further flexibility. Further commentary in relation to this matter is set out within the Part 1 Taylor Wimpey Representations on Housing Matters prepared by Lichfields. Policy HG1: Housing Delivery The NPPF identifies in paragraph 73 that “strategic policies should include a trajectory illustrating the expected rate of housing delivery over the Plan period, and all Plans should consider whether it is appropriate to set out the anticipated rate of development for specific sites.” The recently released 2019 SHLAA includes delivery information for committed schemes over the next five years, however it is unclear if a trajectory has been prepared by the Council to illustrate the expected rates of delivery of proposed allocations across the Plan period. It is therefore considered that the draft Local Plan is not consistent with national policy, as there is no clearly identifiable trajectory available to ascertain whether the Council has considered the rate of housing delivery across the Plan period and as a result, whether local housing needs will continue to be met. Allocations: Area 14 Stokesley Area We welcome the acknowledgement of the need for housing within Great Ayton via the identification of GTA1: Skottowe Crescent, Great Ayton, however we have concerns in relation to the location and characteristics of this site which are set out below. We therefore question draft housing allocation GTA1 for the following reasons: • Heritage Impact • Landscape • Limited Community Support • Rationale for the selection of the site • Comparison with other options Heritage Impact We note that Historic England (Mr Ian Smith (ID: 1025458)) objected to the site at the Alternative Sites Consultation due to the loss of this currently-open area and the potential harm to elements which contribute to the significance of the Great Ayton Conservation Area and the setting of a number of Listed Buildings to the south of the site. These include the Grade I Listed Church of All Saints and the Grade II* Listed Ayton Hall. The Council’s Heritage Background Paper and Impact Assessment dated August 2018 (HBP) states that “development of the site has the potential to harm elements that contribute to the significance of the heritage assets by altering the rural setting of Grade II* Listed Ayton Hall and Grade I Listed Church of All Saints” . The southeastern corner of the site abuts the Conservation Area boundary and has therefore been considered to be amber within the Council’s Sustainability Appraisal Site Assessment. The closest listed building is the Grade II farm buildings to the north of Ayton Hall, which are approximately 46m south east of the southern site boundary. BWB have undertaken a review of the HBP in relation to the assessment of site GTA1 and a note containing their comments is appended to this representation. The review identifies that the HBP fundamentally underestimates the scope and degree of potential impacts that the development of the site would have upon the identified heritage assets, some of which are of the highest Grade and of exceptional architectural and historic interest in the national context. The contribution of sites to the significance, within setting, of these assets is not assessed in sufficient detail to understand potential impacts, including impacts upon the archaeological resource. The indication that development would not give rise to harm to the significance of these assets, subject to the adoption of is not considered correct and the requirement set out in the Plan that development should not cause harm will be unachievable. The review concludes that the allocation of the site would be unsound. A brief summary is provided below of the heritage constraints relevant to the site and the potential scope and degree of development impacts which would arise should the allocation be brought forward. As noted in the HBP the site historically comprised a three linear strip field, part of a wider field pattern extending to the west and indicative of a medieval foundation as part of the agricultural setting to the historic settlement. The historic core of settlement falls to the south of the site and the 1856 Ordnance Survey plan (surveyed 1853) shows Ayton Hall and associated parsonage and All Saints Church with extensive grounds extending to the west and south.