Response to Calderdale MBC Local Plan Publication Draft 2018 Highstone Homes Site LP1109 Land south of Northedge Lane, Hipperholme September 2018 Contents 1. Introduction 2. General Policies in the Calderdale Publication Draft Local Plan 3. Rejected Site – LP1109 Appendices 1. Aerial Images of Questionable SD7 Housing Sites 2. Landscape Statement / Green Belt analysis – Pegasus April 2018 3. Highway Site Appraisal – Paragon Highways May 2018 __________________________________________________________________________________ Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse 1 1.0 Introduction 1.1 This statement has been prepared to respond to the Calderdale MBC Local Plan Publication Draft having regard to whether the Draft Plan is sound when considered against the four tests of soundness as set out in the National Planning Policy Framework (the “Framework”). Plans are ‘sound’ if they are: - Positively Prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; - Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; - Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and - Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework. 1.2 Johnson Mowat make the following comments in relation to a number of Draft Policies in the Publication Draft and to the rejection of site LP1109, Northedge Lane, Hipperholme, Brighouse on behalf of Highstone Homes, who have in interest in the site. __________________________________________________________________________________ Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse 2 2.0 General Policies in Calderdale Publication Draft Local Plan 2.1 A brief summary of our comments are as follows: - The Housing Requirement (Policy SD3) is not sound. The housing requirement should be a minimum target. It is based on the MHCLG Standard Methodology which may change at the end of September 2018. The housing requirement does not take account of the Council’s own evidence (OAN Review) and will fail to meet the baseline economic growth forecast and the forecast job growth identified in the Local Plan. In other words, it will harm economic growth and put undue upward pressure on house prices. Solution: Increase the housing requirement and identify additional land for housing. - The distribution of growth is not adequately explained or justified within the Local Plan text. - The Local Plan is too reliant on the delivery of two Garden Suburbs to deliver the housing requirement. We will produce evidence as to why these sites will not deliver in full over the life of the plan Solution: Identify additional land for housing. - We question the deliverability of a number of identified housing sites in Policy SD7 on a number of grounds – density; location in relation to existing settlement; inadequate access; existing green space. A number of the smaller sites should not be included as housing allocations, and could be dealt with as windfall should they come forward. Solution: Remove non-deliverable sites. Avoid windfall duplication. Identify additional land for housing. - Insufficient sites have been identified (regardless of our consideration that the housing requirement is too low) in order to provide a buffer in the event of existing commitments and allocations not coming forward as envisaged. Solution: Identify additional land for housing. - Policy HW2 (Health Impact Assessment) is not justified. Sites selected / or allocations should be in sustainable locations. If so, there is no need for Health Impact Assessments. - Policy IM5 (Ensuring Development Supports Sustainable Travel) requires further detail in relation to what constitutes ‘significant amounts of movement’. - Policy HS5 (Self Build and Custom Housebuilding). We object to the unjustified requirement of 5% of sites above 100 dwellings requiring self-build and custom build plots. __________________________________________________________________________________ Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse 3 Policy SD3 – Housing requirement 2.2 We object to the 840 dwelling per annum (2018/19 – 2032/33) housing requirement set out in Policy SD3, which is based on the MHCLG standard methodology, published in September 2017. We do not consider the housing requirement in Policy SD3 to be sound, as it fails the positively prepared, justified and effective tests on the Framework. 2.3 The previous Initial Draft Local Plan proposed a housing requirement of 1,125 dwellings, which is significantly higher than the proposed 840 per annum requirement in the Publication Draft. It is disappointing that the OAN Review May 2018 (Turley / Edge Analytics) that was commissioned by the Council and forms part of the Evidence Base, has not been taken into account, which concludes that in order to meet the baseline economic forecast, the OAN for Calderdale is 1,000 dpa (2016 – 2035). In order to meet the required job growth identified in the Local Plan 1,129 homes per annum will be required. 2.4 The OAN Review evidences that the requirement is considerably higher than that proposed in the Local Plan. It is clear that the Local Plan housing requirement falls short of the evidence base. Johnson Mowat are aware of analysis being undertaken by a consortium of developers in relation to the OAN information, which deals in detail with the evidence base and the shortcomings of the Local Plan chosen housing requirement. 2.5 The housing requirement in the Draft Local Plan is based on the MHCLG standard housing methodology published in September 2017. The Council should be minded that the figure may change following the publication of the household projections in September 2018, after which the methodology may be adjusted, resulting in a different requirement. Furthermore, aside from the fact that the MHCLG methodology may change, the methodology figure should be considered as a minimum starting point. This is acknowledged in the Council’s own evidence in the OAN Review. 2.6 Section 3 of the Housing Technical Paper informs that the housing requirement was chosen by Elected Members at a Cabinet meeting in February 2018, with Members opting for Option B which was the standard housing methodology excluding an uplift for undersupply, employment growth and flexibility of choice of sites. The Housing Technical Paper makes reference to the Turley / Edge Analytics OAN Review, concluding that Members resolved to plan to meet housing need calculated using the standard methodology. It appears that the Local Plan is politically driven, rather than based on appropriate, up to date evidence. There is no reference __________________________________________________________________________________ Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse 4 in the Housing Technical Paper about the MHCLG standard methodology being a minimum starting point. Consideration does not appear to have been given to attempting to justify a higher requirement, even though doing so would align with the Council’s spatial vision and objectives of aligning economic / jobs growth in the borough with the appropriate provision of housing. 2.7 In order to make Policy SD3 sound, it is recommended that the Council takes into consideration the available and up to date evidence contained in the OAN Review, which supports the Northern Powerhouse agenda, and the Leeds City Regional Local Enterprise Partnership, and aligns the housing requirement with the economic growth aspirations of the Borough. The housing requirement in Policy SD3 should be increased. 2.8 The consequences of increasing the housing requirement are obvious, in that the Council will be required to identify additional land for housing. Should the housing requirement be increased to 1,000 dpa for example, land for a further 2,400 dwellings will be required over the plan period (based on information contained in Table 6 of the Housing Technical Paper). Distribution of Growth (Section 6.2) 2.9 Whilst there is some text relating to the distribution of the housing requirement, there is no specific policy. While Table 6.10 identifies the quantum of housing via allocations in each area, there is no justification regarding the distribution. 2.10 The text refers to the focus of development in Halifax and the historic distribution of nearly 50% in Halifax in the Core Strategy preferred options, and 20% to Brighouse, as well as identifying environmental constraints for continuing this focus (topography, flooding, SPA and SAC’s). The text lacks detail in terms of what the proposed solution is to distributing growth. The distribution of housing in Table 6.10 results in more development in Brighouse than Halifax (49% of new allocations are in Brighouse, compared with 30% in Halifax, and overall