Draft Local Plan - Supplementary Consultation

Object

Representation ID: 9771

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

No clear justification for taking an alternative approach to the standard methodology. Using 2014 household projections proposed by the methodology the minimum annual housing figure of 767 omitting any contribution to the HMA shortfall is well in excess of the OAN for the Borough of 689 identified in the SHMA. Consultation does not seek to revise contribution SMBC is making towards shortfall in housing market area. Para 27 acknowledges that there is no clear justification why the figure of 2,000 was chosen and there is an opportunity to make a greater contribution. We support this, in that there ia an underestimation in the contribution that the Borough could make towards meeting the unmet needs of the HMA. Essential to acknowledge that local housing needs figure is a minimum and a starting point for SMBC to identify the full housing needs that can be met within the Borough. Should be a comprehensive review of SMBC contribution to meeting the HMA shortfall.

Object

Representation ID: 9772

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

Strongly object to application of two stage site selection methodology. A more detailed assessment of the step 2 assessment specifically in relation to sites identified within Hampton in Arden clearly indicates that the planning judgement has not been applied consistently, on a like-for-like basis, across sites within a single settlement or that are comparable in character and/or size. Does not object to the methodology but does object to the inconsistency of its application.

Object

Representation ID: 9774

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

Consultation document indicates that the settlement could support more development noting the range of existing facilities and high level of accessibility. On this basis do not agree with the inference in para 169 that development should be restricted so as not to overwhelm existing infrastructure due to additional demand generated from it. Development and infrastructure planning are integral to each other the purpose of the Local Plan being that development is delivered in conjunction with the appropriate level of infrastructure. It is clear that Hampton in Arden is a highly accessible settlement and contains a number of core facilities, and can support additional development that will itself secure the necessary infrastructure required to support new and existing residents and existing services and
facilities.

Comment

Representation ID: 9776

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

Site is adjacent to the existing allocation in the SLP (site 24) and effectively forms an extension to that allocation. Despite anticipated release of allocated SLP site by April 2023 no planning applications have come forward on the site. Boundary changes have effectively omitted the area of brownfield land, the majority of the allocation is therefore greenfield. Arden Wood Shavings Limited currently operates within part of DLP Site 6 and it is understood that the company has no plans to vacate the site. Previous representations by the company have highlighted ongoing use of the depot and a desire to implement recent planning permissions. This is a significant consideration in terms of deliverability. In addition as indicated in the 2012 SHLAA there are also a number of other physical constraints and limitations to the development of SLP Site 24 that require consideration, including access and local infrastructure, lack of suitable routes to key local services and facilities, poor relationship to existing development, creation of an indefensible Green Belt boundary. Do not object to the two sites within the settlement however given the proposed comprehensive approach to the development of SLP 24 and proposed site 6 there is considerable uncertainty in terms of the overall deliverability of both Meriden Road sites.

Object

Representation ID: 9780

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

WDL strongly objects to the omission of their site at 'Land off Old Station Road, Hampton in Arden' (Assessment Site Ref. 6). Site selection methodology has been inconsistently applied and as a result DLPSC has unfairly discounted this site. Evidence within the site assessment document confirms the site to be highly achieving against a number of the matrices, the site performs better than proposed allocations of a similar size and location within settlements of the same Settlement Hierarchy class. Attached appendix A comparison table compares the application of the methodology and associated evidence base in relation to the site (Land off Old Station Road)and comparable sites. It shows a lack of consistency in the justification and associated decision-making set again that same evidence base, resulting in Land off Old Station Road being identified as unsuitable and excluded from further consideration. The sites used for comparison are of similar size and character; having a similar capacity, being wholly or predominantly greenfield, lying within the Green Belt, and lying within a settlement that is within a settlement of the same hierarchy as Hampton in Arden. The table demonstrates that the findings contained with the site assessment document and associated evidence base reinforce that Land off Old Station Road continually performs highly when assessed against the key criteria; including in relation to the spatial vision, site constraints, deliverability, accessibility, impact on Green Belt performance, and sensitivity of landscape character. Significantly, the site adheres to the DLP's spatial vision, reaching a 'Yellow' score of 5 overall in Step 1 of the Site Selection process. Notably, the site scores more favourably than Land South of School Road, Hockley Heath, which is proposed for allocation as DLP Site 25.
Evidence in stage 2 of the site assessment also confirms the site is suitable for development particularly when compared with sites proposed for allocation. Suitability was also demonstrated in the 2016 SHELAA where it was assessed as a category 1 which could commence within 5 years but by comparison the southern parcel of the DLP proposed site 10 was assessed as category 2 and DLP site 6 is identified as category 3 as not currently developable. Site also performs extremely well within the accessibility study. Again findings are inconsistent when compared to other sites. Site also performs to a similar standard or better than comparable sites that have been proposed for allocation within the greenbelt assessment. Despite all of this the site is designated as a red site. Site lies within landscape character parcel which only has medium sensitivity and is more favourable when compared to proposed allocations within Meriden and Hockley Heath. The Sustainability appraisal is also favourable to the site having fewer negative and more positive impacts than other sites proposed for allocation.
The issues of 'indefensible boundaries' and 'visual intrusion' are given a considerable amount of weight in the site assessment process despite the site being assessed favourably in other areas. This is unfounded as this can be readily mitigated and is not permanent. In fact, the advice given by SMBC within the DLPSC (para 75) states that "sites that would use or create a strong defensible boundary to define the extent of land to be removed from the Green Belt" would be considered favourably. It is clear that SMBC have shown inconsistency in the application of site assessment methodology notably this is reflected in the lack of a robust definition for clearly defined boundaries. The DLPSC gives conflicting views on the definition and approach to this, in some instances placing significant emphasis on defensible boundaries as permanent and physical boundaries.

Object

Representation ID: 9782

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

WDL does not consider there to be any evidence to demonstrate that such an approach would incentivize developers in this way. Indeed, seeking affordable housing contributions based on the total square meterage or habitable rooms / floorspace would not comply with the affordable housing site thresholds set out by the Government in the Written Ministerial Statement dated 28th November 2014
and NPPF 2019 (para 64).

Object

Representation ID: 9783

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

WDL does not consider the calculation of affordable housing contributions based on bedroom numbers, habitable rooms, or habitable square meterage to be an effective approach to delivering affordable homes. Indeed, such an approach is considered likely to create uncertainty as to the number of affordable units required, resulting in prolonged negotiations and a slowing of the planning application process. Moreover, it is standard practice for affordable housing contributions to be calculated on the basis of the numbers of units proposed in conjunction with development and, as such, WDL continues to fully support this approach.

Object

Representation ID: 9852

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

WDL considers this to be an inappropriate approach irrespective of the way used to measure developable space.

Object

Representation ID: 9853

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

WDL propose that all households should have access to different types of dwellings to meet their housing needs and that market signals are an important factor in determining the size and type of homes needed. Furthermore, the Council should focus on ensuring that there are appropriate sites (providing a wide range of types across a wide range of locations) allocated to meet the needs of specifically identified groups of households, such as families, older people and / or self-build, rather than setting a specific housing mix on individual sites.