England & Lyle Redcar & Cleveland Local Development Framework Preferred Options Communities DPD Land at Kilton Lane, Brotton Representations on Behalf of George Wimpey (North Yorkshire) Ltd. Policy CM1 Strategic Mixed Use Regeneration Sites 1. Policy CM1 lists only two Strategic Mixed Use Regeneration Sites (SMUR), both of which are located in the main conurbation. Our clients George Wimpey (North Yorkshire) Ltd would seek the allocation of a further SMUR in the East Cleveland Villages sub-area on land at Kilton Lane, Brotton – see Figure 1. 2. The total gross area shown on the attached plan extends to approximately 14ha of which about 9.5ha ( edged red) is suitable, available and deliverable/developable for a mix of built development uses. The remaining 4.5 ha (edged green) is suitable for open space uses and landscaping. 3. It is considered that the main body of the site is suitable for a mixed use development comprising: housing, retailing, community uses and related commercial development . The suitability of the site for housing development is addressed through our representations on Policy CM3 which conclude that a further housing allocation is required in Brotton to meet housing needs and demand especially in Phase 2 of the LDF period and potentially beyond. In this way development of housing on this site would not impact on the delivery of housing on Preferred Allocation CM3dd - which George Wimpey (North Yorkshire) Ltd supports. The actual amount of land that could be allocated for housing development at Kilton Lane can be tailored to meet future demands within Brotton and indeed the wider East Cleveland Villages sub-area, up to 2021 and potentially beyond. 4. The Land at Kilton Lane therefore has the potential to act as a Strategic Mixed Use Development site, in the same way that the land to the north of Skelton has done in recent years, and satisfy a wide range of existing and future development needs associated with Brotton and indeed the East Cleveland Villages sub-area as a whole. Page 1 of 11 England & Lyle 5. The Kilton Lane site is strategically located adjacent to the A174 Bypass. It therefore offers a highly accessible location for a variety of land uses aimed at meeting the needs and requirements of Brotton and the East Cleveland sub-area the whole. In relation to the land to the east of Kilton Lane, (Area B on Figure 1) a site that is generally flat and therefore physically well suited to larger floor plan commercial and community developments. 6. We consider that as part of any strategic mixed use development an element of retail development would be entirely appropriate. It is apparent from a review of retail provision in Brotton and the other East Cleveland villages that the quantity and quality of both convenience and comparison goods floorspace available is well below what one might expect is necessary to adequately meet the needs of the resident population of this area. As a result there is a substantial outflow of expenditure to the larger supermarkets in Redcar and the conurbation. This pattern is clearly demonstrated in the Council’s 2006 Strategic Retail, Leisure and Office Study. Table 3.1 of this Study indicates that 73% of residents of the ‘Rural East’ undertake their main food shop at supermarkets outside of the Rural East area with 42% travelling to Morrisons in Redcar. 7. The 2006 study also shows that the local shops in Brotton, Loftus and Skelton are used primarily for top-up shopping and that 82% of residents undertake their non-food shopping outside the Rural east area. 8. This means that residents of this area have to travel considerable distances to meet their main shopping needs. This situation is unsustainable because most of these journeys will be undertaken by private car and this leads to increased and potentially avoidable CO2 emissions. It also results in the substantial leakage of expenditure from this area that might otherwise be used to create jobs and promote the vitality and viability of settlements such as Brotton. Residents of this area currently have no choice in this matter because the quantity and quality of provision simply does not exist. There is for example no large supermarket in East Cleveland 9. There is therefore a clear need for additional retail provision in East Cleveland. Unfortunately there are no opportunities within or on the edge of existing local centres that are realistically available, suitable and viable, and capable of satisfying this requirement. The only option therefore is an out of centre location that is highly accessible to all residents. The land at Kilton Lane provides the best location for any new provision as it is centrally located within the East Cleveland area and because it is adjacent the A174 By-Pass. It is therefore highly accessible to all residents and will reduce travel distances and times. Page 2 of 11 England & Lyle 10. The development of a modest 20,000 – 30,000sq ft supermarket in this location would not impact unacceptably on stores within existing centres as it would largely derive its turnover from clawing back expenditure that currently leaks to supermarkets Redcar and beyond . Shops in the existing centres will continue to perform their current ‘neighbourhood’ role as predominantly top-up shopping destinations. 11. The development of a medium sized supermarket on the land at Kilton Lane could also act as a catalyst for the development of a range of other services and facilities and deliver a truly mixed use scheme that will promote job creation and regeneration in East Cleveland. The exact scale, mix of uses and phasing of delivery will need to be agreed with the Borough Council through the DPD. 12. The allocation of a Strategic Mixed Use regeneration site in East Cleveland would be in line with the adopted spatial and locational strategy of the Council and would represent a sound long term plan led approach to meeting the needs of residents in this part of Redcar & Cleveland. The land at Kilton Lane, Brotton provides the best opportunity to make such an allocation. 13. In the light of the above we would request that Policy CM1 is amended to identify the land at Kilton Lane, Brotton as a Strategic Mixed Use Regeneration Site CM1c and that consequential amendments are made to other relevant policies in the DPD. Figure 1 Page 3 of 11 England & Lyle Redcar & Cleveland Local Development Framework Preferred Options Communities DPD Land at Kilton Lane , Brotton Representations on Behalf of George Wimpey (North Yorkshire) Ltd. Chapter 3 – Delivering New Housing Paragraphs 3.4 and 3.5 1. RSS Policy sets out the net dwelling requirement for Redcar and Cleveland Borough to 2021 and the formula for calculating the minimum net additional housing requirement for the years post 2021. It is noted however that in RSS Paragraph 3.89 it states: “ It is emphasised that the gross and net dwelling provisions set out in Policy 28 are guideline figures and do not represent a ceiling. LDF’s may make the case for higher figures as appropriate.” As a result the net additional housing figures in Policy 28 and paragraph 3.5 on the Communities DPD should be seen as being the minimum housing requirements that Redcar & Cleveland Borough should seek to ensure it delivers through the LDF. The text of the DPD should be amended to reflect this approach Paragraph 3.13 - Small Windfall Completions 2. It is accepted that windfall completions over recent years have contributed towards the overall supply of new dwellings in the Borough. However the supply from this source has been variable and cannot be relied upon. Paragraph 59 of PPS3 states “Allowances for windfalls should not be included in the first 10 years of land supply unless local planning Authorities can provide robust evidence of genuine local circumstances that prevent specific sites from being identified.” Contrary to this guidance however the Council does not provide any evidence as to why it is unable to identify further specific sites for housing development and instead justifies the windfall allowance on the basis of past trends. 3. It is clear from the Preferred Options Communities DPD and the SHLAA that the Council is able to identify more than enough sites, as potential housing allocations to meet the RSS net additional housing requirement. There is no reason therefore why the council could not allocate additional sites to meet the full RSS net housing requirement without the need to include a windfall allowance within its calculations. Page 4 of 11 England & Lyle 4. This approach of course will not preclude windfalls coming forward over the plan period which will add marginally to the housing land supply and make up for the non-delivery of allocated sites . Such an arrangement would ensure, in line with the plan-led approach, that the LDF contains sufficient allocations to satisfy the minimum net additional housing requirement identified in RSS whilst at the same time introduces an element of flexibility into the housing land supply. It also accords with the guidance that the RSS net housing requirements are ‘guideline’ and not ceiling figures. The delivery of on average 35 windfall dwellings per annum is equivalent to less than 8% of the overall requirement, and would not impact on overall spatial strategy for the Borough. Paragraph 3.14 - Net Housing Requirement 5. In the light of comments in relation on Windfall Allowances the net housing requirements shown in the table in 3.14 should be amended by the removal of the ‘small windfall allowance’ element – at least for the next 10 years of the plan – in line with PPS3.