EL2.018 - Issue 3 statement per Emery Planning representor 182

Blackburn Site Allocations DPD
Issue 3 – Housing Delivery
Click here to enter text.
for Mr and Mrs Gee ID182
Emery Planning
2-4 South Park Court, Hobson Street
Macclesfield, SK11 8BS
Tel: 01625 433 881
www.emeryplanning.com
Project
Site address
Client
: 14-336
: Land west of Gib Lane,
Blackburn, Lancashire,
BB2 5BP
: Mr and Mrs Gee ID182
Date
Author
: 14 November 2014
: Stephen Harris
This report has been prepared for the
client by Emery Planning with all
reasonable skill, care and diligence.
No part of this document may be
reproduced without the prior written
approval of Emery Planning.
Emery Planning Partnership Limited
trading as Emery Planning.
Contents:
1.
Introduction
1
2.
Questions 3.1 to 3.7
2
3.
Question 3.8
2
Planning Statement
Land west of Gib Lane, Blackburn, Lancashire, BB2 5BP
November 2014
1.
Introduction
1.1
Emery Planning is instructed by Mr & Mrs Richard Gee to attend the Examination with particular
regard to their land which forms part of the allocated site land of west of Gib Lane, Blackburn
(Site 16/9). Their land is shown in Appendix EP1.
Background
1.2
Our client submitted representations to the Publication Plan and their representor ID is 182.
Those representations were submitted by McAteer Associates Ltd. Our client has been invited to
attend Issue 3 (Housing Delivery). Emery Planning will attend on their behalf.
1.3
Since the submission of the representations to the Publication Draft, Mr and Mrs Gee have
agreed an option with Wainhomes North West Ltd to bring forward their site. Wainhomes is one
of the main developers in the region and are seeking to bring forward the site via a planning
application early next year.
Summary of our Position
1.4
The original representation supported the allocation of the land west of Gib Lane, although
objected on the basis that the delivery of our client’s land should not be held back by a
masterplan to be approved by the Council.
1.5
Since those submissions were made, the Council has progressed with a masterplan for the Gib
Lane allocation and this was consulted on in August and September this year. Therefore the
current position is that a masterplan is to be approved by the Council in December which
would then be used for the determination of planning applications. However that is a related
but importantly a separate process to the Examination of this Plan and the policies contained
therein.
1.6
We therefore set out our response to the specific questions set out by the Inspector in the Issues
and Questions dated October 2014.
1
Planning Statement
Land west of Gib Lane, Blackburn, Lancashire, BB2 5BP
November 2014
2.
Questions 3.1 to 3.7
2.1
These questions specifically relate to releases in the Green Belt and safeguarded land. As our
clients land is neither Green Belt nor safeguarded land we do not intend to provide a response
to these specific questions. However we do support the Council’s position that land is required
to be released from the Green Belt to meet its objectively assessed housing need.
3.
Question 3.8
3.1
Question 3.8 asks two specific questions.
3.2
The first is whether the proposed housing allocations, set out under Policy 16, are based on a
sound assessment of land availability and deliverability?
3.3
The second is whether there is any evidence that any of the housing sites proposed by the
Council are not viable or deliverable?
Land Availability and Deliverability
3.4
The housing requirement that the Allocations Plan should be seeking to meet is set out in Policy
CS6 (Housing Targets) of the Core Strategy. However the figures set out in paragraph 4.5 of the
Allocations Plan is some 335 dwellings less than the 9,365 dwellings set out in Policy CS6. A further
change is that the phasing of the housing requirement has been altered in paragraph 4.5 to
that set out in CS6. The changes are not significant but it is noted that they are lower. Therefore
in light of the Wokingham judgment it is not open for the Allocations Plan to reassess the
objectively assessed need and the housing requirement. This issue was recently debated at the
Preston Local Plan Examination where the requirement in the Core Strategy could not be
altered. The debate on this issue will take place on Issue 2.
3.5
The latest Housing Position Statement is dated June 2014. That assumes, even on the lower
housing requirement in the Allocations Plan, that the supply is 5.1 years. Part of that 5 year
supply of 3,536 dwellings is 120 dwellings from the land west of Gib Lane. Therefore it is clear that
even if all the Council’s assumptions on their deliverable supply are correct in order to meet
paragraph 47 of the Framework, sites allocated in the draft Allocations Plan are required
immediately. Therefore the delivery of sites, such as our clients, is integral to the soundness of the
plan.
2
Planning Statement
Land west of Gib Lane, Blackburn, Lancashire, BB2 5BP
November 2014
3.6
We now assess their land specifically but also in the context of the wider allocation.
Site 16/9 Land west of Gib Lane
3.7
In the Submitted Plan (1.01A) the land west of Gib Lane (16/9) is allocated for 440 dwellings.
Pages 57 and 58 of the Plan set out the site boundary and the Key Development
Considerations. Our client’s land is in the north eastern corner of the site and adjoins the existing
urban area. As a standalone site it is a sustainable urban extension. However we recognise that
the site is part of a wider allocation and it can deliver vehicular and pedestrian links as a first
phase for that wider site.
3.8
Whilst we note that there are objections to the allocation of the wider land we are confident
that the site is deliverable and particularly now in that our client now has a contract with
Wainhomes. The evidence base to date and the more detailed work that Wainhomes is
undertaking in preparation for a planning application, for example landscape and visual
assessment, highways and drainage demonstrates that the site is deliverable. We would expect
a planning application to be submitted early next year.
3.9
We now assess the criteria in the policy.
3.10 Criterion 1 states that the site is to be brought forward in line with the masterplan and that the
masterplan must be agreed by the council prior to the granting of planning permission for any
part of the site. Whilst we understand that the council intends to adopt the masterplan in
December, we would not maintain our objection to this criterion provided that master plan is in
accordance with the key development considerations in 16/9 and particularly how the
development is to be accessed.
3.11 Nevertheless, we consider that to be effective criteria 1 should be amended so that
applications can come forward which would not prejudice the wider development of the site
particularly if that application was not contrary to the Key Development Considerations in 16/9.
This is because the Key Development Considerations are part of the Allocations DPD and
therefore form part of the statutory development plan. The masterplan will not have the weight
of a statutory development plan and therefore provided any application is in accordance with
the Key Development Considerations, it should be granted in advance of the masterplan. This
would be in accordance with paragraph 14 of the Framework as it would be in accordance
with an up to date development plan.
3
Planning Statement
Land west of Gib Lane, Blackburn, Lancashire, BB2 5BP
November 2014
3.12 Criterion 4 refers to the SFRA and that the site is not at risk of surface water flooding. However it
does note that the site has a high water table and sloping ground therefore development
would be required to incorporate SUDS and soft measures to control surface water run-off.
Whilst we support the use of such measures, from our own investigations, alternative methods
should be included within the policy due to the underlying ground conditions. However what is
clear is that the site can come forward and can be drained in order to deliver the required
housing development.
3.13 Criterion 5 refers to this site being accessed off Livesey Branch Road, Broken Stones Road and
GIb Lane. The masterplan, which was consulted upon, shows two potential highway access
points off Gib Lane. The northernmost access point is into our clients land and we note that two
pedestrian access routes are also proposed in the masterplan. Again pedestrian access onto
Gib Lane forms an integral part of the sustainability and permeability of the wider allocation.
Therefore vehicular and pedestrian access onto Gib Lane is a fundamental part of the delivery
of the site and criterion 5 should remain as drafted.
3.14 Enclosed as Appendix EP2 is a draft layout showing that the land within the control of our client
can deliver some 95 dwellings whilst ensuring the pedestrian and vehicular routes as identified
on the master plan can be secured. Enclosed as Appendix EP3 is a site access drawing showing
the proposed vehicular access into the site from Gib Lane. Discussions have taken place with
the council and the local highway authority on their requirements. Therefore the Inspector can
be assured that delivery of this part of the wider Gib Lane allocation can be achieved which
would be an integral part of phase 1 of the wider development to provide the necessary
vehicular and pedestrian links through to the existing urban area and the local facilities such as
the primary school.
3.15 This concludes our statement and we can provide further clarification at the Examination on 3rd
December.
4
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QUAY WEST at MediaCity UK
TRAFFORD WHARF ROAD
TRAFFORD PARK
MANCHESTER
M17 1HH
TEL:
+44 (0)161 872 3223
FAX:
+44 (0)161 872 3193
e-mail: manchester@wyg.com
Project:
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Drawing Title:
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FILENAME : J:\2014\A087996 GIB LANE, BLACKBURN\CAD\WYG DRAWINGS\A087996-P001 REV C.DWG | PLOTTED BY : LUKASZ.BARAN | PLOTTED DATE : 23 October 2014 12:33:02
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Scale @ A2
1:250
Project No.
A087996
Drawn
Date
Date Approved Date
Checked
SH
16.06.14
AK
16.06.14
AK
16.06.14
Revision
Office Type Drawing No.
27
T
A087996-P001
C
C WYG Group Ltd.