Publication Draft

Object

Representation ID: 65710

Received: 27/06/2014

Respondent: Trustees of the Haseley Settlement

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Council has failed to ensure the permanence of the Green Belt to ensure beyond the Plan period as required by the NPPF. The Council has not provided for its objectively assessed need nor made satisfactory provision for the level of housing generated from the Gateway site. The level to which the Green Belt has been amended is insufficient to meet the needs of the District and Sub-Region. There is no formal commitment to undertake a strategic review of the Green Belt despite committing to reviewing housing numbers by 2015 within the CWLEP Strategic Growth Plan. The SHLAA identifies a number of village sites suitable for development subject to green belt boundaries being amended. However the plan fails to take the SHLAA into account when drawing the settlement boundaries of the villages within the Green Belt. For example despite the SHLAA identifying site R39 at Hatton Green as suitable and available the proposed village boundary excludes the site. No housing sites are identified at Hatton Green despite it being a sustainable location with a primary school, nursery school and community facilities. In direct contrast 80 dwellings are proposed at Hatton Park which has no facilities and is considered to extend the built form beyond clearly identifiable and defensible limits of green belt.

Object

Representation ID: 66776

Received: 27/06/2014

Respondent: Trustees of the Haseley Settlement

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Council has failed to identify an objective assessment of objectively assessed need for housing. In line with government guidance and recent case law RPS sets out that establishing OAN requires four key components; demographic analysis, economic analysis, affordability and market signals. The Council's SHMA used 2011 interim population projections up until 2021 and extended these to 2031. There is concern over the use of headship rates from 2008 and 2011 to extend the forecasts. Affordability is a key component of establishing need for housing, the SHMA identifies a requirement for 268 dwellings per annum to be affordable. The Council sets a target of 40% which would appear to provide the policy context however based on Council's track record providing an average of 86 affordable homes per year over the last five years the ability to achieve triple the historic level of provision is doubtful.

Object

Representation ID: 66777

Received: 27/06/2014

Respondent: Trustees of the Haseley Settlement

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

RPS is of the opinion that the Housing Trajectory is unsound
The Housing Trajectory contains substantial over estimations of housing delivery, particularly in the early
period of the plan. The rate of development in the early period is insufficient from the sites identified and an over reliance is being placed on a small number of sites delivering high rates of dwellings. This is not going to be experienced as proposed and the only way to maintain high levels of delivery is from a broader range of sites.
RPS also objects to the identification of confidential sites in the Housing Trajectory amounting to 207
dwellíngs. lt is not appropriate to identify confidential sites and withhold information on the location of such
sites from a public examination of the evidence. lf the Council cannot identify those sites publically, if
cannot rely on them during scrutiny of the public examination as it does not permit transparency in the
evidence. The 207 dwellings should be removed.

Object

Representation ID: 66780

Received: 27/06/2014

Respondent: Trustees of the Haseley Settlement

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing trajectory is unsound in respect of its reference to windfall allowances. The allowance is overestimated and unrealistic in respect of windfall developments particularly in the rural area where the settlement limits proposed are overly restrictive. The allowance makes provision for student accommodation and therefore will not meet the identified housing needs of the district. The authority should only include student accommodation based on accommodation it realises from the housing market. This requires the dwelling unit to have first been occupied by students then alternative accommodation be provided to release the dwelling unit back.