Taylor Wimpey UK Ltd and Bethell Group. Heathfield Farm, Wilmslow

Transcription

1 Taylor Wimpey UK Ltd and Bethell Group Heathfield Farm, Wilmslow Shaping Our Future: A Development Strategy for Jobs and Sustainable Communities February 2013 Ref: a

2 Taylor Wimpey UK Ltd and Bethell Group Heathfield Farm, Wilmslow Shaping Our Future: A Development Strategy for Jobs and Sustainable Communities February 2013 Ref: a Authorised for and on behalf NJL Consulting LLP Nick Lee Partner This report takes into account the particular instructions and requirements of our client. It is not intended for and should not be relied upon by any third party. Any such party relies on this report at their own risk. Report copyright of NJL Consulting LLP Adamson House Towers Business Park Wilmslow Road Manchester M20 2YY Tel: Fax: info@njlconsulting.co.uk

3 Contents 1.0 Introduction Housing Target East Handforth Wilmslow Site Allocations A Housing Strategy for Wilmslow Heathfield Farm Summary Appendix 1 Wilmslow Vision Consultation Response Appendix 2 Heathfield Farm Development Statement a

4 1.0 Introduction 1.1 This submission has been prepared by NJL Consulting LLP (NJL) on behalf of Taylor Wimpey UK Ltd (TW) and the Bethell Group in response to the draft Development Strategy (Shaping Our Future: A Development Strategy for Jobs and Sustainable Communities) produced by Cheshire East Council. 1.2 This report is intended to focus on the issues arising from the draft Development Strategy as they specifically relate to Wilmslow, with reference to the Heathfield Farm site. It will cover: The adequacy of the proposed housing target for Wilmslow. The inappropriateness of the proposed Handforth East strategic site. The prospect of the proposed strategy delivering Wilmslow s housing target. The important role that Heathfield Farm could play in achieving these objectives. 1.3 A separate submission has also been prepared for TW by Nathaniel Lichfield Partnership (NLP) which deals with issues relating to the Policy Principles document and the Cheshire East position more generally a Page 1

5 2.0 Housing Target Introduction 2.1 The National Planning Policy Framework (NPPF) clearly sets out that in order to boost significantly the supply of housing Local Plans should ensure that they meet the full, objectively assessed needs for market and affordable housing The importance that the Government places on setting appropriate housing targets is well demonstrated through the comments of Inspectors examining Local Plans. As recently as September, the Inspector considering the Salford City Council Core Strategy concluded that in my judgement, the Core Strategy is unsound in its present form in that it does not demonstrate an adequate and realistically deliverable supply of housing land. 2.3 In justifying this statement the Inspector commented that: The ministerial Statement of March 2012 refers to the pressing need to ensure that the planning system does everything it can to help secure a swift return to economic growth and urges local planning authorities to make every effort to identify and meet the housing, business and other development needs of their areas As has been accepted at the Hearings, house building is a driver of the local economy besides providing homes for local people. The evidence presented to me supports an annual housing requirement of at least 1,600 dwellings instead of the current proposed annual provision of at least 1,300 dwellings. In addition to reflecting an objective assessment of need in accordance with the Framework requirement, this would be likely to bring forward more affordable and aspirational homes to which reference has been made at the Hearings, a considerable benefit. 2.4 Furthermore, in May last year, the Inspector considering the Core Strategy submitted by Wigan Metropolitan Borough Council commented that as it stands I consider the submitted Core Strategy to be unsound in that it fails to demonstrate an adequate and realistically deliverable supply of housing land. 2.5 It is readily apparent that the Government sees both the provision of an appropriate housing target and an effective plan for its delivery as being critical to whether or not a plan is considered sound a Page 2

6 2.6 Having reviewed the information contained within the Core Strategy, along with the supporting evidence base documents, we do not believe that these aims have been met for either Cheshire East as a whole or for Wilmslow specifically. Cheshire East 2.7 NLP have made a separate submission on behalf of TW covering a range of policy issues as well as providing detailed commentary on the proposed borough-wide housing target of 27,000 dwellings. This in turn draws upon analysis work carried out by Barton Willmore on behalf of a consortium of home builders. 2.8 It is not proposed to repeat the analysis provided by these reports here, however it is worthwhile noting the key conclusion that, in order to meet housing need, aspirations for economic growth, and anticipated demographic changes, the housing target for Cheshire East as a whole should be set at 1,800 dwellings per annum (dpa). In order to accommodate this additional growth, additional development sites should be identified in the Key Service Centres, as these represent the most sustainable locations for growth. Wilmslow 2.1 The analysis of the borough-wide housing target provides important context to a discussion of the position in Wilmslow. However, of equal importance is the evidence base and the proposed housing target as it relates specifically to Wilmslow. The draft Development Strategy identifies Wilmslow as being required to accommodate an additional 400 homes, and the justification for this level of housing growth needs careful consideration. 2.2 It is important that the level of housing need for Wilmslow and Handforth is assessed separately. Although they may be geographically close, they are demographically very different and have very different characters. While Wilmslow is one of the wealthiest towns in the borough, Handforth has one of the lowest rates of economic activity. With two such different sets of conditions, different strategies will be needed for each. 2.3 The draft Development Strategy, however, is confused as to whether or not the two settlements are treated separately or collectively. The structure of the plan, with separate policy sections and separate housing requirements for each, suggests that they have been treated separately. The housing targets however, and in particular with regards to Handforth East, indicated that the two settlements have been treated a Page 3

7 collectively. This latter approach is not appropriate and therefore the position needs reconsidering and clarifying by the Council. 2.4 The background to the proposed housing target is provided in a background paper titled Population Projections and Forecasts issued by the Council in January Although this deals with Cheshire East as a whole, there are some references to individual settlements. In particular, the summary of the Natural Change Forecast, which sets out the amount by which a population could be expected to change simply as a consequence of births and deaths, identifies Wilmslow as one of only four settlements which will see population increases under this scenario. Table 3 of Population Projections and Forecasts confirms a population increase of around 1% would occur in this scenario with a consequential requirement for an additional 740 new homes to be provided. This figure is approximately double the proposed housing target. 2.5 This need for new homes in Wilmslow was recognised by the Council in the Issues and Options consultation document, released in November This set out a range of growth scenarios for Cheshire East as a whole, with a range of methods for distributing that number across the borough. Figure 1 summarises the number of new homes that Wilmslow was expected to accommodate based on each of the proposed spatial options (options 1 to 3, plus rural dispersal ) and each of the three growth scenarios. Figure 1: Housing targets for Wilmslow under various growth options (from Issues and Options Paper, 2010) a Page 4

8 2.6 The number of new homes required ranged from 575 to some 2,400, with an average requirement of 1,025 new homes. The proposed target of 400 dwellings is therefore some 30% below the bottom end of that range, and 40% below the average requirement. 2.7 In response to this consultation, some 59% of respondents were in favour of the high growth option for development, although this does not seem to have been reflected in the following revisions to the plan. 2.8 These various options helped inform the draft Wilmslow Vision, which was published in March This document stated that Cheshire East Council and its partners will aim to deliver in the order of 1,500 new homes by This target, of course, is almost four times higher than the current draft housing target. 2.9 The need for an adequate number of new homes to be delivered was well understood, with the Wilmslow Vision stating that: Across Cheshire, housing demand outstrips supply. However, the position is particularly acute in Wilmslow across all types of housing and tenure Furthermore, the Vision goes on to state that: It is estimated that Wilmslow needs to deliver around 30 new affordable homes per annum to meet current and future needs. This would equate to around 600 homes over twenty years So even the requirement for affordable homes is 50% higher than the proposed target for housing of all kinds in Wilmslow Furthermore, on page 18 of the original Wilmslow Vision consultation document, it is observed that if the number of households in Wilmslow were to increase at the same rate as the whole of Cheshire (24%) then around 2,300 new homes would need to be provided over the same period (2006 and 2031) The reason why the need for new homes in Wilmslow is of this scale is clear; it is the fourth largest settlement in the borough, and a successful town which is considered a desirable place to live Despite being the borough s fourth largest settlement, of the nine Key Service Centres identified in the draft Development Strategy, only two (Handforth and Poynton) have lower housing targets than Wilmslow. Yet of these nine Key Service Centres only one, Congleton, is larger a Page 5

9 2.15 Both the NPPF and the draft Development Strategy identify the importance of new homes in delivering sustainable communities and vibrant town centres. This is exactly one of the aspirations of the final Wilmslow Town Strategy, which aims for Wilmslow to flourish as a dynamic and sustainable town which provides for the needs of the whole community and has a thriving town centre. Put simply, these aims cannot be achieved with the artificially low housing target currently proposed When compared with the assessed evidence of need and the status of the town within the borough, Wilmslow s housing target begins to look, at best, irrational. The Council s evidence base, gathered from a variety of sources, unequivocally demonstrates the need for significantly more than 400 new homes over the plan period The only justification given for this lower target is the statement that the proposal for a new settlement to the east of Handforth will meet some of the needs of Wilmslow and justifies a lower housing figure. This does not seem to represent a robust, considered case; certainly, no evidence is advanced as to how that dynamic would work in practice, or to the implications for sustainable development and the economic needs of Wilmslow Notwithstanding that, in our opinion, Handforth East is not deliverable as currently envisaged (which is covered in detail later in the submission) this approach is also flawed. As the Wilmslow housing target itself is below the level of provision required simply to accommodate natural change, the proposed strategy is one that will force existing residents of Wilmslow to move out of the town. This is completely contrary to the stated aim of the Wilmslow Town Strategy to meet the needs of the whole community No commentary is provided on what alternatives to Handforth East have been considered, nor what their impacts would be on sustainable development objectives. It is our considered view that there our significantly better alternatives to the option currently proposed, which should be investigated via a comprehensive review of the Green Belt in both Wilmslow and Handforth to determine how best they can each deliver their individual housing needs The Population Projections and Forecasts report also acknowledges that, due to demographic change in the borough, if the population remains static then the number of jobs will fall. Failing to plan to meet even the needs of Wilmslow arising from natural change will inevitably lead to an erosion of the town s economic base and a Page 6

10 undermine the viability of the town centre. This is also completely contrary to the stated aim of the Wilmslow Town Strategy to deliver a thriving town centre It is therefore self-evident that the proposed housing target for Wilmslow is too low, and will only serve to exacerbate the already acknowledged acute housing issues in the town. Based on the current proposed housing target for the borough would therefore necessitate a return to the housing target set out in the Wilmslow Vision of 1,500 homes over the plan period as a minimum, with additional sites being identified to meet this need Compounding this requirement for additional development sites to be identified in Wilmslow is the observation, clearly demonstrated by both NLP and Barton Willmore, that the correct housing target for the borough would be 1,800dpa, rather than the 1,350dpa currently proposed. In order to achieve that level of delivery, further development sites will need to be identified in Wilmslow We would therefore advocate a housing target for Wilmslow of 2,300 homes in order to accommodate the anticipated population growth; to help deal with the existing housing shortage in the town; and to support the viability of the town centre. This is the same figure as we proposed as part of our response to the Wilmslow Vision consultation exercise; no evidence has been presented to suggest an alternative figure would be acceptable. Summary 2.24 Various evidence sources advanced by the Council show that the housing need for Wilmslow is significantly higher than the 400 homes currently proposed. The proposed target will fail to meet the requirements of natural change, fail to satisfy the need for affordable homes, and fail to prevent the town s workforce from shrinking. It is therefore clearly contrary to the requirements of the NPPF Attempting to shift the housing supply to Handforth East does not represent an appropriate solution. No evidence has been presented to demonstrate how this would be a sustainable solution for Wilmslow, even if the site were capable of being delivered in the form envisaged Taking into account the under-estimate of the borough-wide housing target, we would therefore proposed a housing target for Wilmslow of 2,300 homes over the plan period a Page 7

11 3.0 East Handforth Introduction 3.1 The draft Development Strategy identifies a new settlement at Handforth East and presents this as being a silver-bullet for development need in this part of the borough. 3.2 Amounting to approximately 126ha, it is intended that the site will deliver 2,300 homes (1,800 of which will be delivered in the current plan period), 5 hectares of employment land, 2 new primary schools and 3,500m2 of retail floor space, amongst other uses. 3.3 The site is separated from the existing settlement of Handforth by the A34 link road and the Handforth Dean Retail Park, and is currently designated as Green Belt. Green Belt Function 3.4 The first step in assessing the suitability of the site for development is to consider how well it performs the function of Green Belt land. This should be done as part of a comprehensive Green Belt review of both the Wilmslow and Handforth areas to ensure that the most appropriate sites for release are identified in order to ensure that both settlements can satisfy their individual housing needs. This has not yet been carried out by the Council and the requirement for a Green Belt review set out in NLP s companion submission is re-iterated here. 3.5 Notwithstanding that shortfall, the performance of this proposed development site against the role of the Green Belt can be considered in isolation. 3.6 The NPPF sets out that the five roles of the Green Belt are as follows: To check the unrestricted sprawl of large built-up areas; To prevent neighbouring towns merging into one another; To assist in safeguarding the countryside from encroachment; To preserve the setting and special character of historic towns; and To assist in urban regeneration, by encouraging the recycling of derelict and other urban land a Page 8

12 3.7 It is therefore necessary to assess the performance of the site against each of those criteria in turn. Check Unrestricted Sprawl 3.8 The existing boundary of Handforth in this area is provided by the A34 Handforth Bypass. This is a busy, dual carriageway road and forms a strong, defensible boundary for the settlement. Although there is a small amount of development within the area already (primarily a Total Fitness gym) the over-riding visual character of this area is one of green fields Should this site be released for development the new boundary would be weak, with no strong defining feature or boundaries. Indeed, the only justification for the location of the boundary would appear to be that it forms the administrative boundary with Stockport MBC Notwithstanding that the site is branded as a new settlement it is to all intents and purposes a new suburb for Handforth, This is acknowledged in the Sustainability Appraisal published alongside the draft Development Strategy which states in the site s favour that it should seek to enhance Handforth. Yet it is a new suburb which is self-evidently poorly related to the existing built form of the town and remote from the town centre (as opposed to the retail park). The Spatial Portrait of Handforth in the 2010 Issues and Options paper underlines this, stating that There is no direct road access between the settlement of Handforth and Handforth Dean. The development is therefore likely to be heavily dependent on the car. This meets neither national nor local objectives for delivering sustainable settlements and is instead the worst kind of American-style sprawl around high capacity road networks The landscape and visual impact of the proposed development also need to be considered in this regard, although the evidence base provided by the Council suggests this exercise has not yet taken place The Cheshire Landscape Character Assessment identifies the site as falling within the Higher Farms and Woods (HFW) character area. This landscape type has a rural nature defined by a higher than average density of woodland than Cheshire as a whole, while land use is a mix of arable and pasture, and settlement largely retains its dispersed low density pattern. Handforth East falls within the sub-category HFW3, which consists of a triangular-shaped area from Macclesfield in the south to Handforth and Poynton in the north. It is recognised in the Cheshire Landscape a Page 9

13 Character Assessment that this particular character type is under threat from development The key elements that contribute to this type of landscape are small areas of woodland, hedgerows, streams and ponds. All of these are present within the proposed Handforth East site. The landform of the site is relatively flat and has an open nature to the adjoining countryside. The site also allows extensive views from Handforth and Cheadle Hulme, as well as those travelling on the A34 and A555, into the large expanse of countryside of the same landscape character that is present in the direction of Macclesfield and Woodford. The site is therefore considered to have Medium landscape sensitivity, with a landscape quality assessed as Ordinary (on a scale ranging from Very Poor to Exceptional) which is defined as a locally recognised landscape without a specific designation. Higher ratings of landscape quality are only likely to be found in national parks The magnitude of change would, however, be assessed as being Large which can be defined as development that would result in a prominent change to the landscape character, would substantially decrease the landscape value and quality and would materially reduce the area of this particular landscape type in the borough which is already acknowledged to be under threat. On the basis of these landscape impacts alone, development of the site would be inappropriate It is therefore considered that the Handforth East site does perform a Green Belt function in preventing unrestricted sprawl. Prevent Neighbouring Towns Merging 3.16 To the south of Handforth, the nearest settlement is Wilmslow. Although the two towns already merge into one another, they maintain distinct characters and identities. The proposed area of the Handforth East allocation extends south as far as far as Handforth Road in the Dean Row area of Wilmslow reinforcing the connection between the two settlements. The perception of the coalescence of the two settlements will be even worse, as those driving along the A34 will be presented with development on both sides of the road inevitably resulting in the sense that the area is one single settlement The north and eastern boundaries of the site are marked by the administrative boundary between Cheshire East Council and Stockport MBC. To the north of the proposed allocation, the nearest settlement is Cheadle Hulme. Currently, the distance between Cheadle Hulme and Handforth is 1km, however with the proposed a Page 10

14 development this will reduce to a little less than 300m. In fact, parts of the proposed strategic site will be closer to the centre of Bramhall than to the centre of Handforth This was acknowledged in the draft Handforth Town Strategy which observes that it would close the open space between Handforth and Cheadle Hulme Moving to the east, the next closest settlement is the village of Woodford. Currently, the distance between Handforth and Woodford is approximately 2.5km, although the proposed allocation will see this reduce my more than half to around 1.1km Although only a small settlement, Woodford is the location of the former BAE Woodford facility. This is referred to as an Opportunity Site within the adopted Stockport Core Strategy, and is also the subject of a Supplementary Planning Document adopted in January This calls for the redevelopment of the site for a mix of uses, including a large quantum of new homes. The site is currently being progressed by Harrow Estates, part of home builder Redrow, and therefore there can be few doubts as to the ability of the site to deliver. Despite being a previously developed site, the redevelopment proposals will result in the gap between Woodford and Handforth narrowing. The proposed Handforth East strategic site will simply serve to exacerbate this problem It is therefore considered that the site clearly performs this Green Belt function. Safeguard the Countryside from Encroachment 3.22 As previously referred to, the A34 forms the effective eastern boundary of Handforth, while the A555 is the effective southern boundary of Cheadle Hulme. The proposed site therefore represents the north-western quadrant of a large expense of countryside, which provides a visual connection between the conurbations of Cheadle Hulme, Handforth and Wilmslow and the Cheshire countryside, making a significant contribution to their unique characters Much of the land is covered with a network of informal footpath links while one formal Public Right of Way crosses the site indicating that the site performs a social function. This is acknowledged in the draft Development Strategy which identifies a range of leisure uses to which the site is currently put The Green Belt in this area clearly serves an important role in protecting the countryside from encroachment a Page 11

15 Preserve the setting and character of historic towns 3.25 Despite the obvious attractions of both Handforth and Wilmslow, neither can be considered historic towns. The Green Belt does not, therefore, perform this function. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land 3.26 Urban regeneration is about both bringing derelict sites back into use and providing sufficient levels of development to support vibrant, sustainable town centres As will be set out in section five of this report, the existing Strategic Housing Land Availability Assessment (SHLAA) confirms that there are an inadequate number of previously developed sites within Wilmslow to accommodate the identified housing need. Far from obstructing urban regeneration, the release of the right Green Belt sites in the wider Wilmslow and Handforth area will actually support those objectives However, as has been previously identified, the proposed Handforth East site represents the worst kind of car dependent, urban sprawl development and will therefore serve to undermine any attempts to improve and support existing centres It is considered that this area of Green Belt does, therefore, perform this function. Green Belt Conclusion 3.30 Of the five functions of Green Belt, the Handforth East site demonstrably performs four. The only function it does not perform is the protection of a historic town, but the nature of the settlements in this area means that no areas of Green Belt will perform this function The site is also considered to be important from a landscape and visual perspective, and that impacts from development would be unacceptable in this regard Before determining which sites to release for development, there should therefore be a full Green Belt review of the Wilmslow and Handforth area. This would seek to identify those sites which do not perform a Green Belt role and which are therefore most suitable for release, before moving on to consider issues of deliverability Without such an exercise having been carried out and made available for comment, TW must therefore object to the apparently arbitrary proposal to release the Handforth East site from the Green Belt a Page 12

16 Deliverability 3.34 Notwithstanding that the release of this site from the Green Belt has not been justified, consideration needs to be given as to whether the site is deliverable in the manner envisaged The following analysis considers the major portion of the site located to the east of the Handforth Bypass. It does not consider the existing safeguarded site at Handforth Hall, as this would require development as a separate entity from the main site. Density 3.36 No evidence has been presented to show that the site can accommodate the number of homes proposed. So crucial would Handforth East be for the draft Development Strategy being delivered that its yield should not be determined from nothing more than a series of assumptions. Furthermore, many of these assumptions would appear to be flawed. This section outlines the number of assumptions that need to be made to assess whether the quantum of development proposed can actually be delivered The approximate size of the main site as identified in the draft Development Strategy is 126ha. Even if the whole site area could be developed in its entirety with new homes, this would result in a density of approximately 18 dwellings per hectare (dph). This is a higher density than the one proposed for the Adlington Road site in Wilmslow (225 homes on 13.5ha equating to circa 16.5dph) despite Adlington Road being required to provide none of the extensive list of non-residential uses proposed for Handforth East. It is therefore doubtful from the outset as to whether this density can be delivered Indeed, the draft Development Strategy recognises that the net area is likely to be significantly lower than the gross area. Not only is there a requirement for the new homes, but also for a variety of other land uses including retail, employment land and a range of community services and facilities. To determine whether the density is deliverable or not, it is necessary to identify the impact on the area of the site of accommodating these other land uses The draft Development Strategy includes an illustrative masterplan identifying how these various uses can all be accommodated within the scheme. In addition to the a Page 13

17 areas of residential development, the following uses have been incorporated which explicitly exclude residential development: District Centre (amounting to c. 3.78ha). Environmental Mitigation area (amounting to c. 3.03ha) Green Buffers and open space (amounting to c ha) 3.40 From the information provided, these areas can again only be estimated. However, taking these estimates into account, the net area of the site reduces to 88.45ha. The resultant density of development to deliver 2,250 homes would therefore be 25.4dph However, these are not the only parts of the site that would need to be set aside for non-residential uses. Even assuming that the proposed green buffers and open space are sufficient to accommodate the sports and leisure facilities, the formal sports pitches, the country park, allotments and community orchard, the proposed policy also includes the following uses: 2 new primary schools 5ha of employment land Mixed-use local centre 3.42 A new primary school and associated playing fields would typically be expected to occupy around 2ha of land. Providing two such schools would therefore result in 4ha of land being required, which has not yet been identified on the plan The proposed mixed-use area, measuring circa 5.69ha, is stated as providing 100 homes as well as employment uses. At 30dph, 3.3ha of this designation will be required for housing, leaving just 2.36ha available for employment uses. A further 2.64ha of employment land therefore remains to be identified Although these are yet further estimates, taking them into account the net area of the site available for residential development would decrease to approximately 79.45ha, requiring a density of 28.3dph This 79.45ha of residential development would not, however, all be expected to deliver new homes. As well as local areas of open space being required, such as LAPs and LEAPs, areas of land will need to be set aside for Sustainable Urban Drainage Systems (SUDS) acoustic buffers to the both the A34 and A555 and the additional highway width required of the main link road. These are just a few a Page 14

18 examples, but demonstrate that the actual net area will be significantly below even the 79.45ha figure. The actual density of delivery required will therefore inevitably be in excess of the 30dph figure envisaged by the draft Development Strategy It is already readily apparent therefore, that the density proposed can only be tested by layering estimates on top of estimates. This does not represent a robust basis for plan making To provide assistance in making such estimates, the Local Housing Delivery Group (LHDG) publication Viability Testing Local Plans provides guidance on the likely ratio of gross to net developable areas, stating that: The net area can account for less than 50% and sometimes as little as 30% on larger sites, of the site to acquired (i.e. the size of the site with planning permission). Failure to take account of this difference can result in flawed assumptions Taking the best case scenario as set out by the LHDG of 50 % ratio, this would result in a net area for the site of 63ha. This illustrates the potential impact of all those issues identified previously. Were this (generous) assessment of the net developable area to prove correct, this would result in a residential development density of almost 36dph. This is already 20% higher than the figure quoted in the draft Development Strategy Given the wide range of non-residential land uses proposed, a ratio of gross to net areas nearer the bottom end of the LHDG figures is much more likely to represent reality. Should the net area account for just 30% of the gross area, the resultant density required would be just under 60dph. This is clearly unachievable The information that has currently been made available in respect of the proposed allocation does not make it possible to identify the actual areas of the site which will accommodate residential development without making a significant number of estimates and assumptions. It is therefore not possible to definitively identify the likely density of development. However, assessing the likely outcome based on the currently available information identifies that, at best, the draft Development Strategy significantly underestimates the density of development required. At worst, the density would be so great as to render the allocation undeliverable in their proposed form. This does not represent a robust basis for plan making a Page 15

19 Accessibility and Highways 3.51 The location of the proposed development would also result in a heavy dependence on the car. The road network in this area is already acknowledged to be heavily congested, with the South East Manchester Multi Modal Study having identified the need for additional highways capacity. Handforth East would compound those existing issues The Sustainability Appraisal acknowledges the likely car dependence of the site stating that the majority of amenities and services are outside the maximum recommended distance to the site. There is no existing road link connecting the Handforth Dean Retail Park with Handforth itself, meaning the only option for those leaving the site to visit Handforth would be to use either the A34 or A555. The draft Handforth Town Strategy underlined this concern pointing out that Given the distance from and physical barriers between existing residential areas and this area of land, development here would effectively form a standalone community The site physically adjoins Handforth Dean Retail Park and, in plan form at least, appears to form an extension of the settlement. The only reason for the site to be considered a standalone community is precisely its unsustainable nature. The physical barriers between the site and Handforth, presented by the A34, Handforth Dean Retail Park and the railway line, mean residents of any development of Handforth East would not easily be able to use the facilities provided by the town. There are only two pedestrian routes across the A34, which is clearly inadequate for a development intended to ultimately accommodate 2,300 homes. There are no cycling facilities on the A34, eliminating this as a potential alternative mode of transport As a consequence, the town centre of Handforth is not easily accessible. Existing primary schools are not easily accessible (and although new schools are proposed on site, these will not be available immediately while access to additional schools is important for parental choice). Existing employment opportunities are not easily accessible The development would therefore add significantly to the level of traffic on this portion of the highway network, which already suffers from capacity issues. It would also fail to support existing facilities in Handforth. The proposed development site is clearly in an inaccessible, unsustainable location a Page 16

20 Ecology 3.56 According to the Sustainability Appraisal the site contains designated flora including Biodiversity Action Plan priority species as well as a number of ponds. It is recognised that the ponds support an assemblage of dragonflies species which meets the criteria for selection as a Local Wildlife Site. However, no further information is provided, suggesting a detailed ecological assessment has yet to be carried out Before determining how much of the site, if any, is developable a full ecological survey would need to be carried out. This should identify the location of protected species, in particular any European Protected Species (such as Great Crested Newts), and identify suitable mitigation measures. These mitigation measures may result in the area of the site that is available for development significantly decreasing from that currently proposed It is especially likely that the presence of the ponds will result in a decrease in the net developable area of the site. A number of these ponds are located within areas identified for residential development despite the acknowledgement that they represent Local Wildlife Sites. At the very least, therefore, these ponds are likely to require retention along with significant green buffers and links to other habitat areas in order to maintain their ecological value Without carrying out this work it cannot be said that the site is deliverable. Services 3.60 Delivering a new development of this size will but significant pressure on the existing network of gas, electric, water and sewerage systems. However, no reference is made in either the Sustainability Appraisal or the draft Development Strategy to any investigations having been carried out in this regard At worst, this could result in the site being found to be undevelopable. At best, it is likely that new service infrastructure will be required that will have either a significant cost (or consequential viability impacts) or require significant areas of the site to accommodate it (for example, if a primary substation is required) Without detailed investigations being carried out in this regard, it cannot be said that the site is deliverable a Page 17

21 Ground Conditions 3.63 Although the draft Development Strategy identifies potential contamination issues at the site, no further investigation work appears to have been carried out. Consequently, it is not possible to identify either the potential costs of remediating the site or of providing an appropriate foundation solution. Without carrying out this work it is not possible to identify the costs of delivering the site (and therefore its viability). Nor is it possible to accurately estimate the lead in time for the development and therefore the number of homes that the site can realistically deliver over the plan period. Delivery 3.64 The draft Development Strategy sets out the intention for the site to deliver 1,800 homes across the plan period. On a site in a single location such as this, it is likely that the market could sustain a maximum of three developers at a time. The average build rate per developer is recognised to be 30dpa. This equates to a build rate of 90 dpa, resulting in a build out period of exactly 20 years The start date for the Core Strategy is 2010, with the plan intended to run until This means there are 17 years left in the plan period For a site of the scale of Handforth East, significant infrastructure works will be required before development commences. These include: any required improvements to the A34; installation of SUDS; treatment of any contamination from the previous Ministry of Defence use; construction of service and access roads within the site; and enhancement to the wider service network (in particular drainage). These works could be reasonably expected to take 18 months Before these works could commence, Outline Planning Permission needs to be secured. As the majority of the site is owned by Cheshire East Council, it would presumably be necessary to dispose of a first phase of development to a home builder. The developer would then need to secure a Reserved Matters Consent. From commencement of the first home, it would be three months before the first occupation. This stage of the process would conservatively take 2 years Consequently, it is likely to be at least three and half years before development of homes commences on site. At that stage, there would be 14 years left in the plan period. At the maximum realistic delivery rate of 90dpa, the site could therefore only a Page 18

22 be expected to deliver 1,260 homes over the plan period. This is some 540 dwellings below the draft Development Strategy target We do not, therefore, believe that 1,800 homes can be delivered from the site during the plan period. Public Response 3.70 This view of the inability of the Handforth East site to deliver and the inappropriateness of attempting to deliver this number of new homes in the area is one that is shared by local residents Handforth residents views are clearly stated in the Summary Report of Consultation regarding the initial draft Handforth Town Strategy. 48.1% of residents disagreed with the alternative development option of creating a new unsustainable community to the east of the Handforth Bypass. However, although parts of the site were identified in the draft Town Strategy the entirety of the site as proposed was not. Furthermore, those parts of the site which were consulted on were identified as two separate options. This site has not, therefore, been subject to public consultation prior to appearing in the draft Development Strategy as a preferred option At the outset, we observed that the different characters of Wilmslow and Handforth demand that their housing needs also be considered separately. Our perception that this hasn t taken place is one that is shared by members of the public. At a public meeting in February, former Parish Councillor Patricia Page stated that: Handforth should not be up for sale. We do not need these homes in Handforth, you are robbing our green belt to serve other areas. All we're saying is people of Handforth only want and need their quota, we shouldn't have to be blackmailed by saying we can't fight off developers, it is supposed to be a consultation at the moment you are telling us it is already a done deal It is worth noting that Ms Page resigned her post as Parish Councillor in protest at the perception that the Development Strategy process was being progressed in an undemocratic way This same opinion was further expounded by local resident Pauline Keen who stated at the same meeting that: I met with you [Council Leader Mike Jones] on 29th September. Nothing s changed except its got worse, horrendously worse. You told us that the village of Handforth a Page 19

23 would really improve by these 500 houses we were going to have. Since that time 500 houses, and people in Handforth have voted on that number, we find ourselves at 2,500 houses. We know how much you protect Cheshire East, we know how much you protect Wilmslow. Wilmslow was having 1,500 houses but Wilmslow being Wilmslow said oh no we don't want 1,500 we'll have 400. So Wilmslow have 400 so let s dump the other 1,100 plus on the scrubland in Handforth and Poynton The perception remains that the driving force behind the proposed allocation of the site is to avoid political tensions in Wilmslow and as a consequence of the majority of the site already being owned by the Council. Summary 3.76 This assessment of the Handforth East site makes it obvious that the site is: Not suitable for release from the Green Belt. Unlikely to be capable of accommodating the number of homes required in total. Not able to deliver the number of homes anticipated over the plan period. Not proven to be deliverable or sustainable. An attempt to shift Wilmslow s housing target to other areas, seemingly for political rather than planning reasons On that basis, Taylor Wimpey therefore objects to the proposed allocation of the site for development a Page 20

24 4.0 Wilmslow Site Allocations Introduction 4.1 The draft Development Strategy specifically identities two development sites to help deliver the 400 new homes over the plan period. These are the Adlington Road and Royal London sites. A further site, also owned by Royal London, is safeguarded for delivery beyond the current plan period. This section provides a brief overview of the sites and discusses their suitability for contributing to the delivery of the housing allocation within Wilmslow. Adlington Road 4.1 An exhaustive analysis of the Adlington Road site, particularly in comparison to the Heathfield Farm site, has previously been submitted to the Council for consideration. Royal London 4.2 Royal London is a Greenfield site, to the east of Royal London's office campus. The site is bounded to the east by the West Coast mainline and the A34 Bypass. The site can provide approximately 75 new homes (at approximately 30dph) and around 2ha of B1 employment land. Surrounding land uses include playing fields for Wilmslow High School and a small number of residential properties. 4.3 Although the site would represent a logical rounding off of the settlement with strong defensible boundaries, it is not readily apparent that the site is deliverable. Access to the site would presumably need to be provided through the existing office complex, which would require a significant re-design to bring the roads to an adoptable standard and to separate them from the existing private road network. The costs of these works could render the project unviable. 4.4 Approximately 4ha of land to the west of Royal London, across Alderley Road, is proposed to be safeguarded for future development, although the type of development that this site is suitable for has not been stated. 4.5 The proposed safeguarded site also appears to be a natural infill development despite its current Green Belt designation. However the consultation draft of the Wilmslow Vision noted that the site performed an important role in providing a a Page 21

25 Summary perceived green gap between Wilmslow and Alderley Edge which does not seem to have been considered. 4.6 The two sites proposed for allocation in Wilmslow can accommodate just 300 homes compared to the 400 home target. Even if both these sites deliver as anticipated by the Council, additional sites will therefore need to be found. 4.7 The appropriateness of safeguarding the Alderley Road site has also not been demonstrated. 4.8 Choosing which sites to release from Green Belt should be carried out via a full Green Belt study to identify first of all which sites do not perform the functions of Green Belt. This does not appear to have been carried out and therefore it cannot be determined that these sites are the most appropriate for release. 4.9 It is also our considered opinion that the housing target is too low, and that a figure of 2,300 homes would be more appropriate. On that basis, a significant number of new sites would need to be allocated for development a Page 22

26 5.0 A Housing Strategy for Wilmslow Introduction 5.1 It is clear that even the currently low housing target for Wilmslow cannot be delivered from the proposed allocations and that additional sites need to be found. Consideration therefore needs to be given as to where these sites may come from. Previously Developed Sites 5.2 Wilmslow is a constrained settlement surrounded by Green Belt with limited capacity to accommodate future housing growth within the existing urban boundary. This is clearly demonstrated by the 2011 SHLAA which identifies just 20 homes with planning permission on brownfield sites within Wilmslow, and a further 205 homes that may be developable on brownfield sites over the remainder of the plan period. 5.3 None of these 205 dwellings considered developable currently benefit from planning permission. Nor is it known whether the sites will become available for development or if there are any technical constraints that will prevent their delivery. It is therefore extremely unlikely that all these dwellings will actually be delivered. 5.4 Consequently, Previously Developed Sites are unlikely to offer a solution to achieving even the proposed, artificially low housing target for Wilmslow. Other sites will need to be identified. Green Belt Sites 5.5 The Green Belt is tightly drawn around Wilmslow and therefore the release of suitably located Green Belt will be required in order to ensure that an adequate supply of homes is delivered. This should be done via a full Green Belt review, to assess which sites currently serve the purposes of Green Belt. 5.6 The NPPF is clear that, as part of the plan making process, Green Belt boundaries can be reviewed in exceptional circumstances. The inability of the borough to meet its housing need clearly represents such an exceptional circumstance; the willingness of the Council to consider Green Belt release in some locations is recognition that this is the case a Page 23

27 5.7 At the very least, given the concerns over the ability of both the proposed allocations in Wilmslow and the Handforth East site to deliver, additional land should be safeguarded for development. This will provide alternative options in the probable circumstances of the housing target failing to come forward as envisaged. This will provide a robust strategy to enable the Development Plan to be found sound by the Inspector at an Examination in Public. This approach is supported by the NPPF and is similar to approaches being taken by other Councils, for example West Lancashire. Summary 5.8 The existing housing allocations seem unlikely to deliver Wilmslow s housing need, while the shortage of previously developed sites means that such windfall developments are unlikely to offer a solution. 5.9 Consequently, in order to ensure that Wilmslow s housing needs are met, additional Green Belt sites must be allocated for development or, at the very least, safeguarded to provide a contingency position should the allocated sites ultimately fail to deliver a Page 24

28 Heathfield Farm, Wilmslow 6.0 Heathfield Farm Introduction 6.1 The site,, identified in figure 2, is approximately 14ha in size with the capacity to accommodate approximately 360 dwellings and is located just south of the B5358 Dean Row Road which is located directly off the A34 Handforth bypass. The site can be accessed directly via an existing roundabout and has good public transport connections on Dean Row Road, the A34, and Wilmslow W Road. Figure 2: Approximate site location 6.2 The settlements of Wilmslow and Handforth are surrounded surrounded by the North Cheshire Green Belt which is allocated under Policy GC1 of the the Macclesfield Local Plan (adopted January 2004). This site lies directly adjacent to the eastern edge of Wilmslow s settlement boundary and within the North Cheshire Green Belt designation. It is currently in use as agricultural land for low intensity uses such as grazing and pasture. It is bordered to the north by Dean Row Road, Ro Cross Lane to the south east and Browns Lane to the west. 6.3 The site sits within a semi-urbanised semi urbanised location surrounded by housing to the north nor and west with linear forms of lower density housing to the south and east making this site a logical infill area a for housing in close proximity to Summerfields Local Lo Centre and Dean Oaks Primary School a Page 25

29 6.4 This section will look at the proposed site of Heathfield Farm in relation to its sustainability and how it is more suited to housing than other sites in Wilmslow, including the safeguarded site at Adlington Road. In doing so this section will demonstrate that the Heathfield Farm site is suitable, achievable and available for development and can therefore be considered to be deliverable. 6.5 In previous submissions to the Council, we have carried out a full, comparative assessment of the deliverability and appropriateness of all those potential sites in Wilmslow identified in the draft Wilmslow Vision, including Green Belt function. This exercise identified Heathfield Farm as being the most appropriate site for allocation for development, and we would refer the Council to those submissions. A copy of that analysis has been appended to this submission. Suitable 6.6 This section will consider the suitability of the site in light of the weight the NPPF attaches to sustainable development. Green Belt Function 6.7 As with the Handforth East site, it is informative to assess Heathfield Farm against the functions of Green Belt. 6.8 The site is provided with strong boundaries by the existing roads of Dean Row Road, Cross Lane and Browns Lane; this ensures that should the site be developed, the new Green Belt boundary would be robust and defensible. 6.9 The boundary of the Green Belt is currently provided by Brown Lane and Dean Row Road. However, this has been breached in a number of locations, in particular on Cross Lane. This area already feels like part of the town of Wilmslow, with the perceived start of the countryside being to the east of Dean Row Road The presence of built development on the northern and western boundaries of the site would result in any development of the site being a rounding off of this part of Wilmslow The nearest settlement to Heathfield Farm will be the redeveloped BAE Woodford site to the east. This is some 2.4km away however and considerably further from Heathfield Farm than it is from the Handforth East strategic site a Page 26

30 6.12 It is therefore considered that Heathfield Farm performs none of the five functions of Green Belt and should not be prevented from being allocated for development on that basis. Accessibility 6.13 Existing bus services run along Dean Row Road, adjacent to the northern boundary of the Heathfield Farm site. The nearest bus stop to the Heathfield Farm site is located along the northern boundary of the site on Dean Row Road In terms of pedestrian accessibility the Heathfield Farm site has direct access to an extensive footway network along Dean Row Road where footways are on both sides of the carriageway along with formal crossing facilities adjacent to the site boundary One of the more important elements of the non-car accessibility of a site is the access to local amenities, specifically schools and local retail facilities. The nearest school to the site is the Dean Oaks Primary School which is located on the opposite side of Dean Row Road to the Heathfield Farm site. It can be reached directly from the Heathfield Farm site using the existing pedestrian controlled crossing over Dean Row Road The Summerfields Village centre provides this area with local retail and leisure facilities. The centre includes two supermarkets, a travel agent, veterinary surgery, pharmacy and various places to dine. There is also a leisure club located on the site with a gymnasium and swimming pool. It is located around 450 metres from the Heathfield Farm site on the northern side of Dean Row Road. Site Access 6.17 Vehicular access to the Heathfield Farm site can be taken in a number of locations given the extensive frontage of the site along Dean Row Road and off the Handforth Road roundabout. Summary 6.18 The Heathfield Farm site is clearly suitable for development, and can be considered more suitable than even the Adlington Road site. The Sustainability Appraisal shows both sites as having an identical rating as each other, as identified in figure As the Council have already chosen to identify Adlington Road as a proposed development allocation, there is no reason why the Heathfield Farm site should not a Page 27

31 also be allocated. On the Council s own assessment, if Adlington Road is suitable for development, then so too must Heathfield Farm. Sustainability Objectives Heathfield Farm (site 4 Land off Dean Road western parcel) Adlington Road (site 1 Adlington Road) Quantity & Quality of housing. + + Sustainable access to jobs, services & facilities. + + Equality & social inclusion. + + Healthy & Active lifestyles. + + Vibrant rural communities. + + Crime & the fear of crime.?? Infrastructure, services & facilities. + + Cause & effect of climate change Water quality, quantity & flood risk Pollution Biodiversity & Geodiversity. - - Heritage, landscapes & townscapes. - - Energy efficiency & renewable energy. + + Waste management.?? Minerals provision. / / Natural resources, green infrastructure & previously developed land. Sustainable, competitive & low-carbon economy. Vitality, viability & diversity of town & village centres Rural economy. + + Education, training, jobs & employment opportunities. + + Figure 3: Cheshire East Council Sustainability Appraisal for the draft Development Strategy In summary, the Heathfield Farm site can be demonstrated as suitable due to its lack of a Green Belt function, the proximity of amenities, accessibility, and sustainable transport links. Therefore the site offers a suitable location for development now and would contribute to the creation of sustainable communities a Page 28

32 Achievable 6.21 Heathfield Farm is considered to be achievable now as there are no technical or environmental constraints which would affect the overall economic viability or deliverability of housing on the site A Development Statement has previously been submitted to the Council which sets out the extensive technical due diligence which has already been carried out in relation to the site. A copy of that Statement is appended to this submission. This has demonstrated that there are no constraints relating to highways, ecology, flood risk, surface water drainage, services, archaeology, agricultural land value, contamination or landscape impacts that would prevent development. Available 6.23 Heathfield Farm is under control of TW and Bethell Group and is considered to be available for development now as it does not rely on the involvement of additional third party land acquisition or land required for access It is therefore clear that the site is available. Summary 6.25 Heathfield Farm has been consistently demonstrated to be suitable, achievable and available for development. It can therefore be considered to be a deliverable site, as defined in the NPPF The site does not perform any of the five functions of Green Belt and is therefore the most appropriate site to be allocated for development in Wilmslow. This would be the case even with the currently proposed housing target, which is insufficient to meet the town s needs. The need to allocate the site for development would be exacerbated by the Council adopting the more appropriate housing target of 2,300 homes a Page 29

33 7.0 Summary 7.1 This submission has shown that not only is the housing target proposed for Cheshire East as a whole inappropriate, but that the housing target for Wilmslow is particularly under-estimated. With a target of just 400 dwellings, the town will not even come close to meeting the housing need generated from natural change, let alone to sustain the present level of economic activity. 7.2 In response to the housing crisis in this part of the borough, the Council have proposed to allocate a strategic site for development at Handforth East. However, this site performs an important Green Belt role and is therefore not suitable for allocation. Furthermore, there are real concerns over the site s ability to deliver, its ability to accommodate the number of homes proposed, and its ability to achieve the level of development required over the plan period. It is not, therefore, the answer to the problems faced in Wilmslow. 7.3 Although two sites have been allocated for development in Wilmslow, there remain concerns over the ability of both to deliver. It is therefore unlikely that these sites will deliver the 300 homes anticipated over the plan period. 7.4 With such doubts over delivery, it is important that the Council not only review their choice of allocations sites, but also ensure there is an adequate Plan B by identifying additional sites to come forward in the event that the initially identified sites do not deliver. This is an approach that has been taken by other Councils, such as West Lancashire. 7.5 Previously developed sites are not an alternative option. The 2011 SHLAA only identifies 205 potential homes from such sites, and there is no guarantee that any will actually be delivered. The reality is that no more than a small proportion of homes will come forward from such sites. 7.6 There is therefore an urgent need to identify additional residential development sites in Wilmslow and, at the very least, additional safeguarded sites. This should be via a full Green Belt review to identify which parts of the current Green Belt fail to perform the five required functions. 7.7 This submission has demonstrated that Heathfield Farm does not perform any of the functions of Green Belt land, and is suitable, achievable and available for development. It is already acknowledged by the Council as being equally suitable for a Page 30

34 development as the Adlington Road site, and therefore Heathfield Farm is the most obvious option for allocation for development a Page 31

35 Appendix 1 Wilmslow Vision Consultation Response a Page 32