For and on behalf of Redrow Homes Ltd Sheffield Additional Site Allocations Document Local Development Framework Consultation Representations Prepared by DLP Planning Ltd February 2012
Contents Page 1.0 Introduction 4 The General Approach to Housing Provision 4 2.0 Housing Requirement and Distribution 7 3.0 Questions 11 Question 1: 11 Question 2: 14 Question 3: 14 Question 4: 15 Question 5: 16 4.0 Conclusions 17 3
1.0 Introduction The General Approach to Housing Provision 1.1 This representation to the Sheffield Local Development Framework Additional Site Allocations Consultation has been prepared by DLP Planning Ltd on behalf of Redrow Homes Ltd in relation to the site off Platts Lane in Oughtibridge Sheffield (site ref: P00505 in the Additional Sites Document). 1.2 The Council are seeking the views of residents, landowners and developers about which sites would be additionally identified for housing development in the plan period. It is stated that recent changes in the housing market mean that the City Council is having to identify potential additional sites and is asking for views on additional sites for new homes. 1.3 The issue of housing sites was highlighted at the Core Strategy but dismissed by the Council. It is further suggested that more recent evidence of housing demand together with the requirements of the Localism Act mean that the housing required in the Core Strategy is out of date. This is because it is no longer based on credible evidence. The impact of the Localism Act therefore requires a different approach to site allocation and the level of undersupply is considerably more than can be met by the 1,000 or so dwellings identified in this further consultation. 1.4 The consultation document sets out a range of potential additional sites to those already put forward in the City Sites and Policies Document in 2010. 1.5 The Consultation Report identifies the requirement for enough land for future housing in the City while striking a balance with the protection of green space. While paragraph 1.2 of the statement refers to the need to identify more Greenfield sites while retaining a 90% proportion of the city s new housing being on brownfield land and no review of potential sites in the Green Belt. This is not considered to be a sustainable position as it raises difficulties in respect of the following: Delivery rates will not be improved if the 90% brownfield objective is used to inform a covert phasing policy The 40% affordable housing requirement results in many sites being unviable (60% of all sites according to the Council s evidence at the Core Strategy Examination) Failure to review the Green Belt will result in less sustainable forms of development with parks and recreation grounds coming under pressure rather than more suitable land on the edge of the urban areas currently within the Green Belt. There remains no substantive evidence put forward by the Council as to the expected delivery of housing to meet the Core Strategy policies There is a lack of evidence in respect of the current deliverable housing land supply. It is understood there is not in place a five year supply of land given the evidence in the Appeal Case APP/J4423/A/11/2153926 but there is nothing 4
further in respect of the Additional Sites Consultation to advise in respect of the number of years worth of deliverable sites in place. 1.6 In light of the above the proposed sites in this consultation will only provide a partial relief to meeting the City Council s future housing requirements. 1.7 This representation directly comments on matters raised in the consultation paper with respect to the site at Platts Lane in Oughtibridge and in particular considers the allocation of the site for housing in the context of the admission by the Council that further land is required. 1.8 This representation seeks to: Support the proposed housing allocation on the site at P00505 Identify that the site is deliverable within the next 5 years Represents a sustainable location for residential development which should be confirmed in the emerging Site Allocations Document. Map 1: Map of Site ref: P00505 Land off Platts Lane, Oughtibridge, - site hatched in red 1.9 The site at Platts Lane has been assessed by the Strategic Housing Land Availability Assessment (SHLAA) as being an Other Suitable Identified Site and within the Additional Sites Allocation Consultation as a potential housing allocation. It is considered that the site is a location for development and is required to come forward in 5
the shorter term (i.e. within the first five years of the plan) to meet the delivery targets and address the shortfall in housing land within the city. 1.10 The allocation of this site will: Remove an undeveloped and vacant site currently in Fringe Industry and Business allocation which has never been considered appropriate for development by the market Locate residential development within an established community close to public transport networks and accessible to a number of local services and facilities. Deliver much needed housing to meet that required in the adopted Core Strategy 6
2.0 Housing Requirement and Distribution 2.1 The Sheffield Core Strategy sets the overall number of new homes needed in the city over the period 2004 to 2026 as being 29,750 net (Policy CS22). In gross total terms a further 4,800 replacement units were required for those properties to be demolished meaning a total gross figure of 34,550 is needed over this period (Table 8.1 of the CS). 2.2 The Consultation Report identifies that 13,100 new homes were built between 2004 and 2010 (an annual rate of 2,183 over this 6 year period) meaning that the future delivery rate of 1,369 per annum is needed to deliver the outstanding 21,900 new homes between 2010 and 2026 (16 year period). 2.3 The identification of 22,500 new homes leaves a headroom of 600 dwellings which is not suitably flexible (being 0.5 years supply) to provide a robust plan and that is before even taking into account the Council s own delivery failure estimates for the 2026 end date of the plan. As the Council are aware windfall sites are not allowed to be taken account of in the first 10 years of the plan and indeed it is not considered appropriate for a metropolitan area such as Sheffield to be relying on an anticipated windfall level as high as 4,000 homes in the period between 2010 and 2026 as is suggested in para 2.7 of the Consultation Report. 2.4 It is unfortunate indeed that while the Council admit to not having a five year supply of housing land they do not provide an estimate of what the supply is, therefore making it very difficult to establish how many additional sites and capacity need to be identified to address this particularly in the context of the Draft National Planning Policy Framework (NPPF) that 20% headroom should be provided in the five year supply of housing land. If this is not taken into account in the further allocations then yet again the allocations will have been drawn too tightly. 2.5 In this consultation the Council have failed to address the changes to planning legislation and emerging draft Policy. Importantly in determining the level of houses to be developed in an area Councils are required to co-operate by the Localism act. The decision by Rotherham Council to move away from the RSS evidence base and the figure derived from it has serious implications for Sheffield, as Rotherham s housing figure was integral to the overall approach of meeting the Sub Regions housing requirement and, according to the evidence at the E.P. of the RSS, was reached by political consensus between the South Yorkshire authorities. 2.6 The housing requirement increase identified within para 2.1 of the Consultation Document is agreed with by DLP Planning. Indeed DLP Planning have made representations to previous consultations and Development Plan Documents outlining the concerns that the city was not planning properly to meet the future housing needs of the city. 2.7 Significantly more houses need to be built to address the shortfall in delivery that has occurred. It is not appropriate for Sheffield to continue to rely on Rotherham to take up a substantial proportion of the housing delivery that must be met. Without meeting these needs the housing market will continue to overheat with properties becoming more 7
unaffordable than even at present as demand inflates the cost of property at a time when first time mortgages require higher than ever initial deposits to secure a loan. This leads to difficulties in accommodating first time buyers and new workers to the city but also increased demand in the private rental market which will escalate costs of living for that tenure. This will generate an environment which can have severe consequences in respect of increased homelessness, overcrowding and concealment of households. 2.8 For the Site Allocations plan to be found sound it must be based on evidence. The rejection of the Stevenage Core Strategy was on the basis that North Hertfordshire had clearly indicated that it was unwilling to accommodate the city s growth. The situation in Sheffield is very similar. Rotherham has clearly indicated it is unwilling to accommodate housing growth generated by Sheffield City. In light of this significant change to the evidence base, proceeding to a Sites and Allocations document without reviewing the required level of housing would lead to potential challenges. To do so would raise the serious issue of Judicial Review or finding the Sites and Allocations DPD unsound. 2.9 The Sites and Allocations plan will need to demonstrate that it has complied with the duty to co-operate. In this case where Rotherham and Sheffield share borders that are within the urban area, or for the regeneration at Waverley; the creation of a new community linked directly back into the city, then direct co-operation will need to be demonstrated. 2.10 The second element of the evidence base, which is being used by Rotherham to justify their departure from the RSS figure, is the household projections. Released in 2010 these suggest that rather than the 35,000 new homes (gross) 2004 to 2026, the net requirement would be 65,400 (219,000 households at 2004, compared to 284,400 at 2026). This equates to 67,360 dwellings allowing for vacancy in stock at the end of the period, or just over 3,000 dwellings (net) over the period. Even excluding the historic changes these projections suggest some 60,000 households 2008 to 2028, again confirming an average net dwelling requirement of almost 3,100 dwellings a year. 2.11 It is imperative the Local Authority plan for at least 15 years of housing growth and secure and maintain a DELIVERABLE five year supply of housing land in accordance with national guidance. The test of being available, deliverable and viable has no doubt resulted in the discounting of numerous city centre apartment schemes. One reason for this is that banks will not lend on apartment schemes. The fall in land value and the increased build costs as well as affordable housing and sustainability requirements have all adversely affected site viability. 2.12 The demand for traditional family housing needs to be met by the provision of dwelling houses. The demand for apartments was clearly limited in terms of market appeal and the over reliance of the City Council on the delivery of niche city centre 1 and 2 bedroom apartments to meet the needs of the city s population was previously criticized as failing to deliver housing for families. The reasons for failure outlined in para 2.6 of the Consultation Report need to be addressed. The concern is that these failures may be about to be repeated: 8
The anticipated supply of apartments in the city centre will not be delivered as the demand is limited for that form of accommodation. Simply put, loans cannot be secured at this time in any case for those sites which even have planning permission. There needs to be sites brought forward that can provide suitable family accommodation in more traditional dwelling types Platts Lane at Oughtibridge can accommodate such a scheme. Large sites in regeneration areas will require substantial lead in times and potentially multiple house builders on site to deliver the overall scheme. The long term nature of such a project offers little opportunity to make up the shortfall of housing in the five year supply of housing land now. Medium size sites such as Platts Lane can make a contribution of the right tenure and type within this shorter term. The 90% brownfield objective has been used in the past to frustrate development of Greenfield sites and if Core Strategy Policy CS24 (seeking 88% of housing on brownfield sites) is applied in a similar manner the city will continue to fail to deliver the required housing for its population. Joined up thinking between Development Control and Forward and Area Planning should promote those sites which are sustainable and can come forward in the short term to address the housing needs of the city which include sites such as Platts Lane. House and land values have fallen and it will require the market to find innovative ways to reduce costs while bringing forward attractive, sustainable and well designed properties. A pro-active approach between the house builders by the Local Authority to encourage development can foster this collaborative success and a more flexible approach to the contributions (affordable housing etc) from each site combined with a better understanding of the needs of an area (through use of the Strategic Housing Market Assessment). Whilst banks have restricted lending to developers and house buyers, it is imperative that the right type of accommodation is provided in the right area. There should be an increase in the delivery of family homes which will mean more development sites coming forward to balance against the loss of higher density city centre apartment proposals in meeting the needs of the city s housing demand and sites well related to existing neighbourhoods such as Platts Lane in Oughtibridge can deliver this. 2.13 Whilst it is not the objective of these representations to secure a Green Belt review, the difficulties in addressing the housing supply in Sheffield suggest that there are in fact exceptional circumstances to justify changes to the Green Belt at this time. The argument in paragraph 2.14 of the Consultation Report appears to be that this cannot take place without a review of the new housing forecasts and cross boundary cooperation is also needed. DLP Planning Ltd are of the strongly held view that in fact reference to up-to-date housing projections and the duty to co-operate is essential now and would serve to confirm the need for a Green Belt review at this time. 9
2.14 It is our view that for the sites document to be found sound it will have to address the change of circumstances since the approval of the Core Strategy, namely:- The Localism Act and the need to co-operate, and hence address, the lower level of housing provision now being proposed by Rotherham. The requirement for development plans to be based upon the latest information including the CLG Household Forecasts in this case the 2008 based forecasts (Draft NPPF) 2.15 It is clear that the exceptional circumstances set out in paragraph 2.14 have now occurred and the work subsequently described needs to be undertaken. 10
3.0 Questions Question 1: Do you think the site should be used as suggested e.g. for new homes? Why? 3.1 Yes the site should be developed for new homes. 3.2 The site is identified within the UDP as a Fringe Industry and Business Area as shown in the extract of the proposals map at Map 2 below. This is in spite of the site being a Greenfield portion of land which had not been put to an employment use as indicated in the aerial photograph at Map 3 below. Map 2: UDP Extract 11
Map 3: Aerial Photo of Site 3.3 The 2010 City Sites and Policies plan identified the site as an area of open space (see Map 4 below) though this is not appropriate with the site being within private ownership and surrounded by urban features and a combination of commercial and residential built form. 3.4 The surrounding policy allocations of P00442 and P00267 seek to provide housing development on the proposed residential allocations of the former Silica Brickworks and Farrar Precision Engineering site. As noted in the 2010 draft Site Allocations DPD, Core Strategy Policy CS23 supports housing development on sustainable sites within the built up area of Oughtibridge. As noted above, the site at Platts Lane is surrounded by built form. 3.5 In allocating P00442 for housing the draft DPD identified that residential development is the most compatible use with surrounding land. The draft DPD suggested the need to provide pedestrian access to and from local services which meant either using the steep Station Lane/Oughtibridge Lane with its narrow bridge (without a pavement) over the railway or a more direct and less steep route and unauthorised crossing of the track and 12
stated that this had to be addressed. The housing allocation site was stated as being a prime site for family housing so long as a safe and direct route into the village was provided and the site to the south of P00442 subject of these representations can equally contribute to this. 3.6 The planning permission for the redevelopment of the Farrar Precision Engineering site for residential development will give further weight to the residential context of the proposed allocation. It makes little sense in this context to leave an isolated area of land unallocated when there is such demonstrable need for residential allocations to come forward. 3.7 As the Farah Precision site was granted consent without changes to the highway network we would suggest that the site at Platts Lane may come forward without the need for major infrastructure provision. Map 4: LDF Draft Proposals Map Extract 3.8 The need for additional housing sites means the identification of the land off Platts Lane under P00505 would enable this site to be comprehensively developed for housing and provide an appropriate urban form on the east side of Oughtibridge. 13
3.9 Overall the site is considered to score highly as a potential housing allocation. There are no site constraints that cannot be overcome and when taken in combination with the wider redevelopment opportunities for the former Silica Brickworks the need to deliver additional benefits in terms of pedestrian links over the railway line are more likely to be delivered. 3.10 The site is considered suitable for residential development. Question 2: Are there any relevant local factors that we ve not taken into account in the reasons for suggesting housing here? 3.11 There is a concern, outlined elsewhere in these representations, that the costs of developing the site have not been taken into account properly by the local authority. The conditions being suggested for the development of the site are extensive and include significant infrastructure works, open space provision and affordable housing. 3.12 The potential limitations on the developable area of the site combined with the other conditions set out, means the viability of this site itself could be undermined. It is unlikely that a scheme with 40% affordable housing and open space could fund any meaningful infrastructured provision. As such it would be appropriate for this document to set out the precise requirements for the site so that these may be independently tested in terms of their reliability. 3.13 It is worth noting that the development of this site would be more closely related to the established residential community of Oughtibridge than the Silica Brickwork Site or Farrar Engineering. The phasing of the development should be for this to come forward at the same time as those sites in order to maximise the comprehensive approach to development of this land. 3.14 It is worth noting that the Farrar site has recently been granted a renewal of planning permission under 11/00480/OUTR for 9 units. This means the eastern edge of the residential area will be established by a development which already has a planning permission secured in place. It makes for a logical development form for this site off Platts Lane to come forward alongside this. Question 3: If the site were to be allocated for new housing, how would you want to see its impact reduced or its possible benefits guaranteed, (e.g. how should it be laid out or designed or what conditions would you like to see placed on it)? 3.15 The development of the site can bring forward much needed family housing. 3.16 The need to deliver a range of additional features and for this to be funded by the values realised by the housing development means a careful balance of those features needs to be taken into account and it is unlikely that the provision of 40% affordable 14
housing across the site would realise sufficient value to provide a pedestrian footpath alongside Oughtibridge Road and a bridleway to cross over the railway. 3.17 The land slopes significantly across the site and it is important to take into account that change of level when considering the developable area of the site and the associated build costs on sites with such a varying topography. 3.18 The desire for open space provision on site could be provided by greening the western boundary with the railway line but it is also important to provide an attractive setting for the public footpath and pedestrian way to cross the freight railway line. With this in mind an imaginative approach to the open space provision to create a green boulevard for the bridleway would be more appropriate than a pocket park or consolidated area of open space within the site. 3.19 The provision of a bridleway bridge over the railway line and inclusion of safety measures alongside the railway line as well as the 5 metre easement inside the western boundary of the site and an adoptable footway adjacent to Oughtibridge Lane will all serve to reduce the developable area of the site and the value to be gleaned from development. 3.20 A tree survey can be undertaken as part of the detailed submissions for a residential planning application. However there seems an inherent conflict between the need to provide a footpath link across the railway line and the retention of the trees on the western boundary. While the majority of mature and quality specimens could be retained, elements will likely have to be removed along that area where the public bridleway crossing is to be put in. 3.21 Reference is made in the conditions for development to a requirement for increased sewer pipe capacity. There is no such requirement as for the allocations on Silica Brickworks or Farrar Precision Engineering. The reasons for this is that the current sewage treatment works is under capacity as is the sewer pipe so it is not understood why this is an issue. Surface water run-off to watercourse is also possible via easement as noted in the assessment so it is unclear why further investment in respect of the sewer infrastructure is needed to be identified at this time in the allocation. Should there be such a requirement this needs to be included into the viability assessment of the site. 3.22 The need for a contribution to be in respect of the capacity at Oughtibridge Primary School also needs to be identified for the viability assessment. Question 4: In your view, what further action would be needed to bring about the development of the site, and which other organisations or agencies, if any, would need to be involved? 3.23 The conditions on development set out in the assessment of the site for residential development need to be costed by the Council to determine if the site will remain viable. The allocation of the site is supported and the developer who owns the site wishes to bring it forward for development, however the wide range of requirements placed on the 15
site mean that the site may remain unviable for at least the first part of the Plan period. The Council need to assess the likely costs of their policy requirements together with all the infrastructure requirements in order to demonstrate that the site is viable in the suggested policy context. 3.24 If the site is unviable due to the implication of the policy the Council should review the policy context and be specific with regard as to what is required to be developed on this site and at what levels. The implications of these requirements should be costed to demonstrate that the site remains viable in the Council s policy context. 3.25 A collaborative approach with the Local Planning Authority and landowners / developers of the adjoining sites is required. The City Council will also have a key role to play in respect of the needs of the Local Education Authority to provide more school capacity and consider the design of the highway works in its role as the Highways Authority. 3.26 Discussions as to the necessity to provide the public bridleway bridge link from the east to the west side of the freight line will also be required with the City Council as the Transport Authority if the site is to come forward on its own. Question 5: When, if at all, would you expect the site to be marketed/ developed? 3.27 The site is currently owned by Redrow Homes Ltd, a major national house builder. 3.28 Redrow Homes would wish to deliver the majority of the houses on the site within the first 5 years of the adoption plan. There is a significant caveat to this statement which is the current level of affordable housing and the development costs such as infrastructure, including the bridleway over the railway make this site presently unviable. 3.29 The dilemma facing the Council is that although this is a suitable and deliverable site, the Council s own policies are acting as a brake to bringing this site forward. 16
4.0 Conclusions 4.1 This representation has been submitted on behalf of Redrow Homes Ltd in relation to the site off Platts Lane, Oughtibridge in Sheffield. 4.2 We are in support of the allocation of the site for residential development in accordance with the assessment under P00505. 4.3 The site has substantive benefits in respect of the following: a. It constitutes undeveloped and underused land identified for Fringe Industry and Business b. It could provide a comprehensive development associated with the Silica Brickworks and Farrar Precision Engineering sites although it has the advantage of being able to be brought forward early given the appropriate policy context c. The development could help fund the delivery of the bridleway link over the freight railway line and extended pavement along Oughtibridge Lane 4.4 Approximately 40 dwellings could be provided on site in accordance with the advice on density guidance within the Core Strategy. As important though is the potential to provide access to the adjoining housing sites of the former Silica Brickworks and Farrar Precision Engineering which can assist in delivering a more sustainable residential environment for the anticipated 123 units available from those sites. 4.5 The allocation of this site is then one to improve the residential sustainability of these other proposed allocated previously developed sites. 4.6 We therefore support the proposed residential allocation of land off Platts Lane to the east of Oughtibridge and consider that this site can be brought forward in the shorter term rather than the proposed 2021 2026 timescale suggested in the SHLAA. 4.7 The major constraint to the development of this site is the policy context which renders the site undeliverable in the short term. The policy context clearly needs reviewing. 4.8 In conclusion this representation seeks to: Secure the allocation of residential development on site P00505 The phasing of the development of this site should be in the shorter term given the involvement of a major house builder and its development will assist delivery of the adjoining land. 17