Examination of the Central

Examination of the Central Lincolnshire Local Plan Matter 2 - Objectively Assessed Need, the Housing Requirement and Affordable Housing Statement submitted on behalf of Cyden Homes October 2016   Examination of the Central Lincolnshire Local Plan Matter 2 - Objectively Assessed Need, the Housing Requirement and Affordable Housing Statement submitted on behalf of Cyden Homes Project Ref: 26678/P4a/A5 Status: Final Issue/Rev: 01 Date: 10 th October 2016 Prepared by: Michael Knott Checked by: Michael Knott Authorised by: Michael Knott The Blade, Abbey Square, Reading, Berkshire. RG1 3BE Tel: 0118 943 0000 Fax: 0118 943 0001 Email: planning@bartonwillmore.co.uk Ref: 26678/P4a/A5/MK/dw Date: 10 th October 2016 COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP. All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks.   CONTENTS 1.0 Introduction 2.0 Issues 2b - Objectively Assessed Need for Housing (‘OAN’) 3.0 Issue 2c - Housing Requirement 4.0 Issue 2d - Affordable Housing 5.0 Issue 2e - Conclusion on Local Plan Housing Requirement APPENDICES 1 - Site Boundary Plan 2 - Borough Council of Kings Lynn and West Norfolk v Secretary of State for CLG, ELM Park Holdings Ltd) [2015] EWHC 2462 (Admin)   Examination of the Central Lincolnshire Local Plan: Matter 2 - Cyden Homes Introduction 1.0 INTRODUCTION 1.1 This statement has been prepared by Barton Willmore LLP on behalf of Cyden Homes Limited, which controls land to the south of Hawthorn Road, Cherry Willingham, identified by the South East Lincolnshire Joint Planning Unit (JPU) as land at Bleak House Farm (site reference CL4363), hereafter referred to as ‘the site’. A site boundary plan is provided at Appendix 1. 1.2 Cyden Homes is committed to the delivery of new housing development from the site. AN outline planning application was submitted to West Lindsey District Council (WLDC) in March 2016, for the development of up to 300 homes. The application was reported to WLDC’s Planning Committee in July 2016, with officer recommendation to grant planning permission. A copy of the planning officer’s report is provided with our written statement in response to Matter 5. 1.3 Planning permission was refused by WLDC, principally due to conflict with policy LP2 of the Submission Central Lincolnshire Local Plan (‘the Local Plan’). 1.4 The site is promoted as an omission site, for allocation for the development of 300 homes. The site could make a contribution to housing delivery in the first five years of the Local Plan, in a sustainable location and with high quality new homes, including the provision of affordable housing. 1.5 For the reasons set out in our statements responding to Matters 2, 3 and 5, on behalf of our client, the Local Plan is unsound. Where possible, we have recommended modifications to the Local Plan to rectify the parts of the Local Plan which are deemed unsound. We trust our submissions will assist the Inspectors appointed to examine the Local Plan and in arriving at a positive outcome for the Examination. 26678/P4a/A5/MK/dw Page 1 October 2016  Examination of the Central Lincolnshire Local Plan: Matter 2 - Cyden Homes Issue 2b - Objectively Assessed Need for Housing (‘OAN’) 2.0 ISSUE 2B - OBJECTIVELY ASSESSED NEED FOR HOUSING (‘OAN’) Q12. The Local Plan states (paragraph 3.5.10) that baseline job growth will result in a requirement for around 23 ha of new employment land over the plan period. However, the Local Plan allocates significantly more – some 153 ha (111ha through Policy LP5 and 42ha through the SUEs). Given that the housing land requirement is based on baseline economic growth, will the supply of housing land be sufficient to ensure that there are enough workers in relation to the amount of allocated employment land? 2.1 Whilst this is principally a matter for the JPU, this strongly suggests that insufficient housing provision is made through the Local Plan. 2.2 We will seek to address this point in more detail through the Hearing once we have had the opportunity to review the JPU’s response. 26678/P4a/A5/MK/dw Page 2 October 2016  Examination of the Central Lincolnshire Local Plan: Matter 2 - Cyden Homes Issue 2c - Housing Requirement 3.0 ISSUE 2C - HOUSING REQUIREMENT Q16. The conclusions of the SHMA identifies an OAN of between 34,368 - 42,720 (or 1,432 - 1,780 dpa), but confirms that the bottom end of the range only represents a modest ‘boost’ to long-term housing supply. With this in mind, why was the housing requirement for Central Lincolnshire established as 1,540 (baseline economic growth), which sits towards the lower end as identified by the SHMA? 3.1 The JPU’s justification for the proposed housing requirement is set out in the supporting text at section 3.3 of the Local Plan. The explanation of the balanced judgement reached is based upon the consideration of economic needs; no reference is made to the need for an uplift to meet the affordable housing needs of the area, including the substantial backlog of households currently on the housing register. 3.2 The position set out in paragraph 3.3.5 of the Local Plan is inconsistent with the conclusion expressed in the ENA (paragraph 11.3) which states that the High Growth Adjusted Scenario “is deemed realistic, yet ambitious based on the areas’ historic growth trends.” 3.3 Whilst we address the issue of affordable housing in response to Issue 2d, below, it is important to note that no uplift for meeting affordable housing need is included in the OAN range. The OAN range expressed in the SHMA does not adequately reflect the requirements of the NPPF and PPG. 3.4 We also note the representations submitted by other parties (see, for example, HBF) at the Regulation 19 Proposed Submission stage which note that, where a OAN range is identified, that the selection of a housing requirement at the bottom end of the range is not in the spirit of positive planning and the national objective to boost significantly the supply of new housing. 3.5 The proposed housing requirement in the Local Plan does not therefore meet the tests being positively prepared, is not justified and is inconsistent with national policy. Q17. Will the housing requirement in the Local Plan significantly boost the supply of housing as sought by paragraph 47 of the Framework? Does it reflect the Vision of the Local Plan which states that Central Lincolnshire will be a location of ‘positive growth’? 26678/P4a/A5/MK/dw Page 3 October 2016