LDC and SDNPA/Issue 4/v/Housing Scale and Distribution (Policies SP1/SP2)
Lewes District Local Plan Part 1: Joint Core Strategy Examination
Lewes District Council and South Downs National Park Authority
Response to Inspector’s Questions and Participants’ Written Statements
Issue 4 (v) Housing Scale and Distribution (Policies SP1/SP2)
January 2015
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LDC and SDNPA/Issue 4/v/Housing Scale and Distribution (Policies SP1/SP2)
Issue 4 – Housing Scale and Distribution (Policies SP1/SP2)
1.
Inspector’s Question
4 v)
Should the LP address contingencies/alternatives, including in relation
to the strategic sites, in the event that completions do not come forward
as expected?
2.
LDC and SDNPA Response
2.1
LDC and SDNPA consider that this question and response are closely related
to our statements to Issue 4 iv (managing delivery); Issues 5, 6, 7 and 8
(policies SP3 to SP6); Issues 4ii and 4iii (particularly concerning the
distribution of growth to settlements in the district) and Issue 16
(implementation / flexibility / delivery / monitoring). This statement considers
whether contingencies or alternatives would be reasonable and realistic in the
event of housing completions not coming forward as expected. However, we
consider that this is inseparable from the spatial strategy as a whole,
particularly the overall implementation and management of the strategy. This
question also relates closely to Issues 1/2 and the potential impact of any
alternatives/contingencies on the objectives of the plan and sustainable
development. We therefore ask that this is considered in the round with our
other relevant responses.
2.2
In accordance with NPPF paragraph 14 the JCS has been prepared positively
and with in-built flexibility to respond to changing circumstances, within the
framework as a whole. This includes taking into consideration where the
NPPF indicates that development should be restricted, in the overall pursuit of
sustainable development in the district. Such flexibility provides a degree of
in-built contingency for changing circumstances.
2.3
The JCS includes one strategic site (SP5) identified as a contingency
allocation in the event that the Ringmer Neighbourhood Plan1 is not made
before the adoption of the JCS or that it does not allocate sufficient land to
secure the delivery of 110 net additional dwellings as required in the early
plan period (our response to Issue 7 - SP5 sets out more detail).
2.4
A wider contingency/alternatives approach in the JCS is not considered
practical, realistic or appropriate in the context of NPPF paragraph 14. To do
so would divert from the strategy identified, which has evolved as a result of
significant supporting evidence, public engagement, and sustainability
appraisal, including consideration of reasonable alternatives. To divert from
the submitted strategy could undermine the benefits for the district sought by
the JCS as a whole, including the ability to achieve the objectives set out.
1
The Ringmer Neighbourhood Plan is at Examination at the time of writing (December 2014) with the
Examiner’s report and recommendations expected imminently.
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LDC and SDNPA/Issue 4/v/Housing Scale and Distribution (Policies SP1/SP2)
2.5
The plan includes significant scope for flexibility and for management and
monitoring, including actions to be taken as required and as proportionate.
Potential triggers for review and revision have been highlighted and LDC and
SDNPA are ready to implement such actions in the unlikely event that barriers
to delivery of the plan arise.
2.6
Deliverability of the strategic sites in the early plan period has been
demonstrated in other statements and we consider that there is very
reasonable certainty that these will come forward. Other sources of supply,
including smaller sites and windfall also have a good track record for delivery.
The future adoption of Local Plan Part 2, the SDNPA Local Plan and
Neighbourhood Plans with further site allocations will also secure further
deliverable supply. Again, we have reasonable certainty that at least the
minimum target will be met, with the expectation that this target will in practice
be exceeded over the plan period.
2.7
A number of Neighbourhood Plans are advancing around the district, which
are expected to include housing allocations to meet at least the minimum
settlement target. However, as contingency for the event that these plans are
not made in a timely manner, or ultimately do not include any/enough housing
allocations, we will allocate contingency sites in the Local Plan Part 2 /
SDNPA Local Plan as appropriate to ensure a back-up position for housing
land supply in those areas. Suitable triggers for the release of such
contingency sites will vary by parish for reasons including: the scope and
intentions of the emerging Neighbourhood Plan; the degree of advancement
in preparation of the Neighbourhood Plan; and the significance of delivery of
the settlement’s housing target at a given time to the overall strategy and
maintenance of a five-year supply of housing land (which will be informed by
the regularly updated housing trajectory).
2.8
While a contingency/alternative strategy is not considered appropriate for the
JCS, the flexibility within it would allow for some limited increase in capacity at
the strategic allocations. For example, the recent detailed pre-application
design and layout work for the North Street Quarter (SP3) indicates that the
eventual number of homes delivered is likely to exceed the 390 units indicated
in SP3 (approximately 410 units is now considered more likely on the North
Street part of the strategic allocation). All numbers of homes indicated for the
strategic allocations have been given as ‘approximately X’ as a precautionary
approach to avoid a scenario whereby the numbers cannot be met and we
incur a shortfall against the site’s housing target and to allow suitable
flexibility, including for any appropriate increase in the delivered numbers of
homes once detailed proposals are prepared. Albeit, any additional capacity
on these sites will be limited as the numbers set out in the policies reflect the
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LDC and SDNPA/Issue 4/v/Housing Scale and Distribution (Policies SP1/SP2)
site context and the evidence base, including the SA, to be the level
realistically achievable on those sites in the context of the overall strategy and
the NPPF taken as a whole. This is explained in detail in the Justification for
the Housing Strategy background paper [CD/045].
2.9
The JCS (as considered in our response to Issue 4 iv) provides appropriate
mechanisms to monitor and manage the implementation of the plan. LDC
and SDNPA have suitable options and actions at our disposal to review
sources of housing land supply and delivery against the housing trajectory/
trajectories. The strategy has evolved as the most appropriate for Lewes
district, based on appropriate up to date evidence and the SA. Therefore it is
not considered that alternative strategic allocations for delivery in the early
part of the plan period would be appropriate or realistic to include in the JCS.
In developing the spatial strategy we have explored all reasonable avenues
currently available for potential housing delivery to 2030 as we have strived to
meet as much of our Objectively Assessed Need for Housing as is sustainably
possible during the plan period. The deliverability evidence shows that the
likelihood of a strategic allocation not being delivered in the plan period is very
low.
2.10
Alternative strategic allocations put forward lack the robust evidence to show
that they would be suitable and, in some cases, deliverable in the early part of
the plan period. It is acknowledged that there will be some potentially
significant allocations made in Local Plan Part 2 (conceivably including sites
capable of delivering more than 100 homes). However the JCS only includes
sites as strategic allocations that are capable of both delivering 100+ homes,
are deliverable in the early plan period; and are key to delivering some of the
objectives of the JCS. This generally means that they are deliverable in the
first five years and so will be integral to the five-year supply of housing from
adoption of the JCS.
2.11
It would not be justified or effective for the JCS to consider alternative options
for growth that would significantly depart from the submitted spatial strategy.
The concentration of development in the towns and distribution among the
smaller settlements, in accordance with their order of sustainability as
evidenced by the Rural Settlement Study, is considered the most effective
option for meeting the objectives of the plan and delivering sustainable
development as set out in the NPPF as a whole. This strategy has evolved
through the pragmatic balancing of the district’s potential housing land supply
with the significant constraints and needs faced and this has been aligned
with realistic prospects for delivery. To now include an alternative strategy (or
partial strategy) to the identified distribution, even as a contingency, would
undermine the overall policy framework and is not supported by the JCS
evidence base, from which the submitted strategy is devised.
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LDC and SDNPA/Issue 4/v/Housing Scale and Distribution (Policies SP1/SP2)
2.12
Consideration of sites for the purposes of alternative/contingency strategic
allocations would require a review of the evidence base and would result in a
substantial delay to the implementation of the JCS. This course of action
would carry no certainty of additional delivery and meanwhile additional
shortfall in housing delivery would accrue, which would be a serious concern
in a district with high levels of existing housing need – any additional delay in
boosting housing delivery (which can be expected with the adoption of the
JCS) would simply exacerbate the identified issues of affordability and high
house prices. It would also mean the overall time taken between now and
finding a solution to and delivering housing to meet our needs (of which the
JCS spatial strategy will be the mainstay) would be increased.
2.13
While LDC and SDNPA are committed to additional sub-regional work to seek
to identify a solution to meeting the housing needs of the wider Housing
Market Area (including the consideration of options for a new settlement in
meeting that need, whether that is in this district or elsewhere in the subregion), we are strongly of the view that to add such alternative/contingency
options to the JCS without robust evidence or to delay the JCS for
consideration of such significant alternative/contingency options would be
false progress. Experience nationwide is that strategic allocations take many
years to plan and implement, particularly when they are on the scale of a
strategic urban extension or a new settlement. Therefore a significant new
strategic allocation instigated from a ‘standing start’ would be unlikely to
deliver significant levels of housing within the plan period. This approach
would also not deliver any more new homes during the plan period than the
implementation/management and review mechanisms set out in the JCS and
HIS [CD/046]. To delay the JCS would only result in a delay in implementing
the identified housing strategy that will begin to meet the objectively assessed
need for housing.
2.14
We conclude that the submitted housing strategy, with associated
infrastructure requirements, is appropriate, realistic and deliverable. Our
proposals for monitoring and managing housing supply are proportionate and
appropriate and will be effective in ensuring the overall delivery of the housing
scale and distribution set out in the JCS. It would not be appropriate, realistic
or effective to identify an alternative/contingency strategy or
alternative/contingency strategic allocations beyond that set out in the
submitted plan.
3.0
Proposed Modifications
3.1
None.
4.0
Other Participant’s Written Statements
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LDC and SDNPA/Issue 4/v/Housing Scale and Distribution (Policies SP1/SP2)
4.1
Town and Country Planning Solutions (for Gleesons) [REP-273-001] contend
that Bishop’s Lane ‘contingency’ allocation should be released for immediate
delivery. We have addressed this in our response to Issue 4iv (paragraphs
4.1 – 4.2)
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