Name: Bob Woollard
Organisation Representing: McCann and Co (Nottm) Ltd
Response to Matter 2: The Spatial Strategy and Housing Policy
Question 5
Subject to our submissions in respect of the strategic sites at Toton and Fields
Farm, please refer to our previous submission on Policy 2
Question 6
Please refer to our previous submissions on Policy 2
Question 7
Please refer to our previous submissions to the Consultation on ‘Land in the
vicinity of the HS2 station at Toton as a Strategic Location for growth’
The identification of the site as a strategic growth location is unsound in that it
purports to be justified solely in relation to the potential HS2 hub station. It is
notable that no modifications proposed to the justification of Policy 2 to explain
why, having been withdrawn from earlier iterations of the plan, it has now been
put back in.
Background paper CD/BACK/15 confirms that the HS2 announcement is the sole
reason for re-inclusion of the site, justified on the basis of ‘enhanced accessibility
and sustainability associated with HS2’ No details are given as to what this
enhanced accessibility and sustainability is and would make the point that
collocation with a nationally, strategic high speed rail network does not
necessarily make it easier to get to work in Long Eaton, or to get a pint of milk
within walking distance.
Given that the HS2 announcement is the acknowledged sole justification for the
inclusion of Toton as a Strategic site, the most recent debates around HS2 are
entirely germane to the debate about how it is treated at a Policy level.
Particularly in view of the fact that delivery will take place outside of the plan
period.
While it is far beyond my abilities to question the cost benefit case put by those
either in favour, or against HS2, it is fact to say that there is intense debate at a
national level about the rights and wrongs of HS2, with some senior politicians
calling the economic case into question. While the Government announcement
may be a material consideration, until the public consultation and debate has
concluded, we are still a very long way from confirming that HS2 will happen or
that it will happen in the timeframes set out.
Currently, the ACS is seeking to plan for something beyond the plan period,
which might not happen at all. We would question the need for the plan to do this
when it will be reviewed well before HS2 starts on site. If Phase 2 of HS2 is
confirmed, the Government will no doubt issues safeguarding directions (as they
recently have for Phase 1) which can be accommodated in future iterations of the
local plan.
The NPPF is clear, that ‘the plan should be deliverable over its period’ in order to
be effective. This strategic allocation, which is justified only by delivery of the
HS2 hub beyond the plan period, will therefore not be delivered over the plan
period.
If the site is justified because of the ‘enhanced accessibility and sustainability
associated with HS2’, delivery cannot be justified in advance of the hub
development. What happens if HS2 is cancelled or a decision is postponed?
Clearly, the HS2 hub is potentially of strategic importance and needs to be
considered. However, as set out in our previous submissions, the re-identification
of the site is a reaction to the Government’s announcement and is not justified
within this context. The nature of the strategic site is left vague and ambiguous
and there is no link to demonstrate how the policy connects to meeting the vision
set out in the modifications.
Our previous submission provides a way of acknowledging the importance of
HS2 within the ACS and provides a suitable form of words to make the plan
sound through early review, when and if the HS2 hub at Toton is confirmed and
public consultation has been completed. We consider that this strikes the correct
balance between the Council’s previously expressed concerns about this area as
a growth location and the need to factor in the potential of the HS2 project.
Questions 8 and 9
The Councils propose a skewed housing trajectory where delivery is increased
significantly later in the plan period in order to meet overall growth needs. In
calculating a deliverable five year housing supply for the purposes of paragraph
47 of the NPPF, the accepted methodologies adopt an even distribution across
the plan period. As such, I would agree with the suggestion that the tables imply
a shortfall in the 5 year supply of specific deliverable sites.
Notably, Broxtowe’s Cabinet Report of 12/3/131 considered five year supply on
the basis of an even distribution methodology
1
http://www.broxtowe.gov.uk/CHttpHandler.ashx?id=26878&p=0 viewed 19-09-13
It reported that if Fields Farm had planning permission it would have 4.83 years
supply against the ACS requirement with a 5% buffer. Without permission at
Fields Farm, the supply is considerably less than 5 years.
A recent appeal decision APP/H1033/A/11/2159038 provides some guidance on
the interpretation of paragraph 47 of the National Planning Policy. The inspector
notes that ‘para 47 requires that local planning authorities should … identify and
update annually a supply of specific deliverable sites sufficient to provide 5 years’
worth of housing against their housing requirements with an additional buffer of
5% (moved forward from later in the Plan period) to ensure choice and
competition in the market for land. Footnote 11 to para 47 explains that to be
considered deliverable, sites should be available now… and be achievable with a
realistic prospect that housing will be delivered on the site within 5 years ….
Footnote 11 states that sites with planning permission should be considered
deliverable until permission expires, unless there is clear evidence that schemes
will not be implemented within 5 years, for example they will not be viable…. The
inclusion of the phrase ‘until permission expires’ strongly implies that a site which
no longer has – or, significantly, has not yet received – planning permission for
housing is not to be considered deliverable in the terms of the Framework.’
Table 10 in Appendix 1 of the March Cabinet report identifies that of the Council’s
identified 5 year housing supply sites, there are over 200 dwellings that do not
yet have planning permission (about 20% of overall 5 year supply). While it is
acknowledged that some of these sites may now have planning permission
granted it is by no means clear that the 2013 SHLAA will assist if sites identified
as deliverable do not meet the definition set out at footnote 11 of the NPPF
Questions 23 to 25
Please refer to our previous submissions on the Fields Farm site.