PERSIMMON/439830/3283/P30/M1 3, PERSIMMON /439830/3346/P30/M1 3, PERSIMMON/439830/3450/P30/M1 3, PERSIMMON/439830/3508/P30/M13, PERSIMMON/439830/3512/P30/M1 3, PERSIMMON/439830/3583/P30/M1 3, PERSIMMON/439830/3660/P30/M1 3, PERSIMMON/439830/3708/P30/M1 3, DURHAM LOC PERSIMMON/439830/3918/P30/M13, PERSIMMON/439830/431 5/P30/M1 3, EXAMINATION PERSIMMON/439830/3609/ P31 /M1 3 Response to Inspector’s Matters, Issues and Questions Made on Behalf of Persimmon Homes North East & Charles Church Matter 13: HOUSING (Policy 29-34) Preamble 13.1 On behalf of our client Persimmon Homes and Charles Church, we write to provide comments in response to the Submitted Durham Local Plan, following our previous representations on the consultation for the Proposed Pre-Submission Draft in October 2013. 13.2 Our client is one of the UK’s leading house builders, committed to the highest standards of design, construction and service. They have a large number of site interests across Durham and therefore are very keen to engage with the Council and assist in preparing a sound plan which is positively prepared, justified, effective and consistent. Persimmon Homes and Charles Church Site Interests in Durham 13.3 This is a list of our client’s site interests upon which we will be commenting individually in statements either now or at stage 2 of the EIP: 1. Site H8 — Merryoaks, Durham; 2. Site H19 — South of Drum, Chester-le-Street; 3. Site H28 — South Knitsley Lane, Consett; 4. Site H33 — West House Farm, Sacriston; 5. Site H37 — West of Woodstone Village, Fencehouses; 6. Site H39 — Brooms Public House, Urpeth; 23034/AS/ME/Matter 13 1 August 2014 BARTON WILLMORE 7. Site H41 — Canney Hill, Bishop Auckland; 8. Site H44 — Rear of High West Road, Crook; g• Site H49 — Eldon Whins, Newton Aycliffe; 10. Site H71 — Former Easington Council Offices; 11. Site H72 — West of Fennel Grove, Easington Colliery; 12. Site H75 — Dunelm Stables; 13. Site at Coundon (3/CO/2, 3/CO/S & 3/CO/25); 14. Site at Bournmoor (2/60/06 & 2/60/10); and 15. Site at Aykley Heads — Adjacent to Police Headquarters; Skid Pan 16. Site at Burnhope (1/BR/09) 17. Site adjacent to land south of Site Ml — Sniperley Park. 13.4 These written representations set out our client’s comments on the Submission Draft Local Plan which we trust will assist in the adoption of a ‘sound’ Plan. 13.5 On behalf of our clients, Persimmon Homes and Charles Church, we would like to make comment on the following matter. In order for ease we have repeated the questions of the inspector and sought to respond directly. Key issue Does the plan provide an appropriate, effective and soundly based framework for suppofling stronger communities, including the provision of deliverable and achievable housing sites, providing a mix of dwellings, including affordable housing, provision for older people, houses in multiple occupation, student accommodation and provision for travellers, which is justified with evidence and consistent with national policy? Q 13.1 Existing Housing Commitments (Policy 29) a) The NPPF requires sites to be deliverable and achievable. Sites with permission can easily move from one period into another due to market and other constraints. Sites may have gained permission purely as a valuation exercise with no intention of being built. In an adverse market there can be redesigns on sites to improve their viability. Is it reasonable to allow for a 10% discount on such sites to deal with the inevitable impacts on completions that will occur in respect of these sites? Policy 29 does not mention this but DCC are now required to consider the reasonableness of allowing a 10% discount. 23034/A5IME/Matter 13 2 August 2014 BARTON WILLMORE 13.6 It should be noted that within Table 2 Components of the Housing Requirement within Policy 3 states that current commitments within Durham equate to 13,547 units, however at Paragraph 7.4 under Existing Housing Commitments, this figure is measured as 13,459, with the figure for houses completed since 1st April 2012 standing the same in both references as 2,252. 13.7 This therefore leaves a shortfall of some 88 units which have not been accounted Lr within the overall housing target and more importantly within the residual target of 15,583. 13.8 It is also noted that within Policy 30; Housing Land Allocations when combining the housing allocation figures it results in a figure of 15,573; this is therefore a 10 unit shortfall on the residual target identified above. 13.9 This results in an overall shortfall when combining shortfall in commitments and shortfall in allocations of 98 units. Table 2 assumes a rounding up of the target to account for the overall target of 31,400. However this means that either a mistake has been made within the reference between Table 2 and Paragraph 7.4 or a resulting shortfall of 80 units exists. 13.10 Irrespective of this, the Council’s current approach (summarised in Policy 3 and its explanatory text) outlines that the sources of supply comprise solely of completions (2011 — 2013), commitments and allocations. There is no allowance for factors such as demolitions, windfall or non-implementation of commitments or allocations. As such it would only take a small alteration to any of the sources of supply that the Council has assumed as a result of these other factors to create a scenario where the Council’s housing requirements can no longer be met. We would therefore advocate the consideration of expanded allocations or additional sites to ensure that a suitable buffer exists so that the Council can continue to identify enough housing land to meet its requirements. Inspector’s Questions Housing Land Allocations (Policy 30) a) Do the sites allocated in the Plan, together with the housing commitments, provide a range and choice of sites capable of meeting objectively assessed need and delivering the Spatial Approach for the future development of County Durham? 23034/AS/ME/Matter 13 3 August 2014 BARTON WILLMORE b) What is the current and future 5, tO & 15-year housing land supply position, in terms of existing commitments, future proposed provision, allowance for windfalls, and provision identified in the latest SHLAA? Are there exceptional circumstances to justify removal of sites from the Green Belt? 13.11 Our client supports the general direction of Policy 30, with the distribution of development across the county but focus given to Durham City and other conurbations with the ability to achieve sustainability development, being a suitable methodology. 13.12 However our client objects to the policy on the basis of the overall target for the plan period being too low, the council should be looking to increase the target and as a result should have consideration for further land proposal to be allocated within the plan. Detailed comments on the Council’s housing requirement are provided in our response to Matter 4 of this examination. 13.13 Our client supports the inclusion of the following housing sites: 1. Site Hi — Sniperley Park, Durham (with a modified boundary to include our client’s land) 2. Site H8— Merryoaks, Durham; 3. Site H19 — South of Drum, Chester-le-Street; 4. Site H28 — South Knitsley Lane, Consett; 5. Site H33 — West House Farm, Sacriston; 6. Site H37 — West of Woodstone Village, Fencehouses; 7. Site H39 — Brooms Public House, Urpeth; 8. Site H41 — Canney Hill, Bishop Auckland; 9. Site H44 — Rear of High West Road, Crook; 10. Site H49 — Eldon Whins, Newton Aycliffe; 11. Site H71 — Former Easington Council Offices; 12. Site H72 — West of Fennel Grove, Easington Colliery; 13. Site H75 — Dunelm Stables; 13.14 Our client also respectfully requests the addition of the following sites to the housing allocations: 14. Site at Coundon (3/CO/2, 3/CO/S & 3/CO/25); 23034/A5/ME/Matter 13 4 August 2014 BARTON WILLMORE 15. Site at Bournmoor (2/BO/06 & 2/BO/lO); and 16. Site at Aykley Heads — Adjacent to Police Headquarters; Skid Pan 17. Site at Burnhope 13.15 We will be providing separate representations on each of these sites under Stage 2 of the EIP, however specific sites have the potential to make additional contributions to the identified shortfall and we therefore have highlighted the details below. Hi Sn4oerley Park - BOUNDARY OBJECTION 13.16 Whilst our client supports the allocation as a strategic site we strongly object to the currently defined boundary. We request that the boundary is revised as a main modification of the proposed plan to include our client’s interest. The proposal forms a logical infill as considered within the Deliverability Statement included with this statement. 13.17 As identified within our statement regarding Matter 7; Durham City the proposed site lies within the both the same landscape character area and the same broad landscape type as the current allocation. There is no distinction between the physical boundaries of the allocation site and that of our client’s site, indeed features such as field boundaries and woodland tree and hedge patterns following the same irregular patterns, with varying condition, size and shape. 13.18 The Landscape Statement submitted in support of these representations explores the historical context of the Sniperley Farm parkland. It concludes that the ‘parkiand’ reference relates in a historical context to a far tighter boundary surrounding Sniperley Farm and as such the designation based on a wider usage should not restrict development. 13.19 The strong physical boundary of the A691 to the west will resist coalescence with any neighbouring community and therefore ensure that the plan maintains adherence to the NPPF which stipulates at Paragraph 85 (final bullet point) that ‘When defining boundaries, local planning author/ties should define boundaries c/early, using physical features that are readily recognisable and likely to be permanent Clarity can be achieved with the definition of the western boundary of 23O34lASlMElMatter 13 5 August 2014 BARTON WILLMORE the allocation being identified as the A691 rather than the debated landscape character typology boundary.