Wyre Forest District Council Engagement Statement for Five Year Housing Land Supply at April 2020 1. National planning policy (NPPF para.73) requires that in demonstrating a five year housing land supply, the supply consists of specific deliverable sites. Annex 2 of the NPPF gives a definition of deliverable : To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within 5 years. In particular: a) Sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within 5 years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans). b) Where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of planning permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within 5 years. 2. Sites can be placed into 2 distinct categories regarding their deliverability, based on their size and planning status; with one presumed to be deliverable unless proven otherwise, and the other requiring clear evidence in order to be considered deliverable. 3. On this basis, the following sites are considered to be deliverable in principle: All major sites with detailed planning permission for housing; and All sites with planning permission for housing which do not involve major development sites 4. Clear evidence will be required in order for the following sites to be considered deliverable: Major sites with outline permission Sites allocated in the Local Plan with no detailed permission Sites with a resolution to grant planning permission Sites with permission in principle Sites which are identified on a Brownfield Land Register 5. Planning Practice Guidance Para. 007 (68-007-20190722) provides further advice on what evidence may be appropriate to substantiate the deliverability of a site, noting that such evidence, to demonstrate deliverability, may include: Current planning status – for example, on larger scale sites with outline or hybrid permission how much progress has been made towards approving reserved matters, or whether these link to a planning performance agreement that sets out the timescale for approval of reserved matters applications and discharge of conditions; Firm progress being made towards the submission of an application – for example, a written agreement between the local planning authority and the site developer which confirms the developer’s delivery intentions and anticipated start and build- out rates; Firm progress with site assessment work; or Clear relevant information about site viability, ownership constraints or infrastructure provision, such as successful participation in bids for large-scale infrastructure funding or other similar projects. 6. The use of ‘may’ implies that the list is not exhaustive. 7. The Local Planning Authority has sought to establish a comprehensive housing trajectory that is underpinned by individual delivery timetables for all of the specific sites that make up the housing supply in Wyre Forest District, together with evidence of windfall rates. 8. The Council has undertaken a programme of engagement with landowners, agents and developers of individual sites that have the potential to contribute to the five year housing land supply or the wider housing supply over the plan period 2016 to 2036. 9. The process focussed on obtaining relevant information about sites that needed clear evidence to demonstrate deliverability and in particular targeted all site allocations, non- strategic housing sites, sites with outline permission or those with a resolution to grant (subject to Section 106 agreement). The engagement process also targeted major sites with detailed planning permission in order to inform the delivery programme and therefore ensure that the housing trajectory and supply is robust and as realistic as possible. The Council did not target any sites on the basis that they are included on the Brownfield Land Register (BLR). The reason for this is that the majority of sites on the Register already have planning permission in place and so have already been included in the housing supply. Many of the BLR sites without planning permission in place have been proposed as allocations in this Local Plan or are existing allocations being carried forward. 10. Engagement was carried out by email with targeted distribution to those known to be involved with individual sites. Statements of Common Ground were prepared for the two large strategic sites at Lea Castle and the Kidderminster Eastern Extension (Taylor Wimpey). A response form asking for specific information was sent out along with a covering letter explaining why the information was required. These can be found at Appendix 1. This process was also undertaken in summer 2019 where a good response was received and previously in May 2018 which had a very poor response. The April 2019 five year housing land supply report included a copy of the letter and response form sent out to developers/agents but the individual responses were not published. For completeness, those received can be found at Appendix 3. The delivery data was used to inform the updated housing trajectory included in the July 2019 Local Plan Amendments document. 11. Where a response was obtained, it was assessed to ensure that the information provided appeared to be reasonable, realistic and achievable, reflecting upon existing knowledge about a site. Where a response suggested that more confidence may be given to site deliverability, this was factored into the conclusions and delivery programmes for that site. The Council has not tried to be more optimistic about delivery rates than those given by those involved in bringing a site forward for development. 12. Where insufficient information or no response has been received from a site interest, the Council has applied realistic assumptions on the appropriate lead-in times and delivery rates. This was after the agents/developers were given further chances to provide information and still did not respond. Although the forms stated that the delivery data related to financial years (1st April to 31st March) a number of respondents evidently referred to calendar years and also referred to starts rather than completions of units. Therefore, officers have used their knowledge to tweak data based on start on site dates and total length of time required for site development. Actual responses have not been amended by officers but the data feeding into the housing trajectory has been slightly amended where there were obvious errors on the forms. In such cases, the agents/developers were contacted to discuss the perceived errors. The completed forms are included at appendix 2. 13. Where no response was forthcoming by the requested date, follow up emails were sent. In a few cases, information was gleaned from emails or phone calls or from other sources such as street naming and numbering request forms or from case officers involved with pre- application discussions. 14. Since 2016, officers from the Local Plans team have held a number of meetings with agents and landowners and interested developers for eight of the larger proposed allocations. For the largest sites, these meetings have also involved officers from Worcestershire County Council (highways, education, landscape and ecology, historic environment) together with NHS, Sport England, Worcestershire Wildlife Trust and North Worcestershire Water Management. 15. The following tables give a summary of the progress made on bringing each of the proposed allocated sites forward for development. Kidderminster Sites Site Ref Location Plannin Complet- Under Not yet Comments g Ref ions at construct started at 1/4/2020 -ion at 1/4/2020 1/4/2020 AS/1 Comberton 17/0268 15 8 0 Site expected to complete autumn Place /full 2020. Affordable rent (The Community Housing Group) AS/3 Chester Road 17/0617 0 0 15 Revised application for 15 South Service /outl (including 4 affordable flats) Station expected to be recommended for 20/0289 approval at October planning /full committee subject to site levels being agreed AS/5 Victoria 19/0727 0 18 30 Site expected to be complete by Carpets Sports /full late March 2021. 100% affordable Ground – 30 affordable rent, 18 shared ownership (Stonewater) AS/6 Lea Street - 0 0 24 Buildings due to be vacated by School September 2022. Victorian buildings on Local Heritage List AS/20 North of 0 0 9 Various pre-applications. Unlikely Bernie to come forward in next five years Crossland Walk BHS/2 Bromsgrove 0 0 35 Part of large scale mixed use Street (Lion regeneration scheme in town Fields) centre. Mostly in WFDC ownership. Awaiting outcome of Future High Streets Fund bids. Residential numbers expected to be much higher. See details in appendix 4 BHS/16 Timber Yard 0 0 55 Timber yard vacated. Local development company still trying to progress site purchase. Part of wider site in WFDC ownership BHS/18 Blakebrook 17/0780 22 10 8 Expect to complete late 2020. 18 School /full affordable rent, 16 shared ownership and 6 outright sales to those on housing register. BHS/38 Kidderminster 0 0 20 Site vacated 2019/20 and being Fire Station marketed. Front building is on Local Heritage List and within Conservation Area. BHS/39 Boucher 10 Vacant building in ownership of Building Morrison’s. Being marketed by Halls. Within Conservation Area BW/1 Churchfields 18/0285 0 0 246 Outline approval for up to 240 /outl dwellings. Reserved Matters application received July 2020. Full 20/0469 application for additional 6 /dem dwellings.