Report of the Director (Governance) bringing Members the results of the Housing and Employment Land Availability Assessment (HELAA), to consider any policy implications associated with sites which are considered to be technically ‘suitable’ coming forward and the cumulative impact associated with combinations of sites and to consider which sites should be included in the Local Plan.
The report of the Director (Governance) brought to the attention of Members the results of the Housing and Employment Land Availability Assessment (HELAA), and considered any policy implications associated with sites which were considered to be technically ‘suitable’ coming forward as well as the cumulative impact associated with combinations of sites and to consider which sites should be included in the Local Plan.
Appendix A (Employment Sites Selection – Background Paper 2016) and Appendix B (Housing Sites Selection - Background Paper 2016) to the report considered the results of the Green Belt Sites Review, the implications for defining a new Green Belt boundary, the conclusions of the HELAA, infrastructure issues, the sequential test, the extent to which the site would help to deliver strategic objectives, and the interim sustainability appraisal of the site.
The Panel then received a presentation from Colin Haigh (Head of Planning) and noted that the Council had a duty to prepare a Local Plan and to co-operate with adjoining authorities and other bodies. The Local Plan would cover the period 2013-2032 and would contain a strategic vision, strategic policies, site allocations and development management policies plus a Policies Map which would show allocations and designations. Once adopted, planning applications would have to be determined in accordance with Local Plan policies (unless material considerations indicate otherwise).
The Panel was informed that the National Planning Policy Framework (NPPF) expected Local Plans to deliver sustainable pattern of development and it stated that “Local Plans should meet objectively assessed need for development, unless any adverse impacts would significantly and demonstrably outweigh benefits, when assessed against policies in the Framework as a whole or specific policies indicate development should be restricted”. Consultation responses to Emerging Core Strategy (2012) favoured that growth be more fairly distributed to towns and villages around the Borough while consultation responses to Draft Local Plan (2015) had raised concerns about the impact of growth on green belt and infrastructure, and had warned against the risk of settlements merging and suggested the potential for a new settlement should be considered for inclusion in the Local Plan.
An assessment of the need for additional employment land and the potential for jobs growth had been made in the Economy Study which had been conducted by independent consultants. This assessment results in the need for an additional 5.4 hectares of Class B (office, general industry, warehousing) employment land over the plan period, as well as protection of all existing designated employment land. A Strategic Housing Market Assessment (SHMA) had also been conducted by independent consultants taking into account the results of the Economy Study and had concluded an Objective Assessment of Housing Need of 12,616 - 13,433 new homesover the plan period. It was considered that a target at the lower end of the OAN range would best meet the needs of the borough taking account of evidence and consultation responses but would represent a considerable increase in housing supply.
Table 4 in the report identified that completions, sites under construction, permissions and windfall sites could deliver 3,905 homes which would leave 8,711 homes to find against the lower OAN and 9,528 against the upper OAN.
The Housing and Employment Land Availability Assessment (HELAA) was an objective analysis of the suitability, availability and achievability of all promoted urban and green belt sites, using methodology that followed national best practice guidance. The analysis divided the sites into 3 categories –
· Stage 1 Fail = site is unsuitable because: subject to policy constraint or environmental designation, in flood zone 3, there is significant physical barrier to development, not contiguous with urban settlement boundary
· Stage 2 Fail = site is not suitable, available, achievable for development
· Stage 2 Pass = site is suitable, available, achievable for development
All sites were shown on maps in Appendices A-K of the report and all sites big enough to be allocated in Local Plan were accompanied by an appraisal table.
The HELAA had identified suitable sites with potential for 11,789 dwellings and they could be considered as a “menu of options.”
The Housing Sites Selection Background Paper set out at Appendix C to the report was a subjective review of “menu of options” sites which weighed up impact on green belt purposes, green belt boundaries, transport issues, flood risk, infrastructure capacity, school provision, sustainability appraisal, any strategic advantages or disadvantages and cumulative impacts. It was estimated that current sources of supply together with suitable urban sites after a subjective weighing up exercise and suitable safeguarded land after subjective weighing up exercise could total 6,554 which would leave 6,062 to find against the lower OAN and 6,879 to find against the upper OAN.
With regard to the identification of employment sites (Appendix A), independent consultants had recommended a need for additional 5.4 hectares of employment land, equivalent to about 138,000 square metres (sqm) of floor space and the Panel was informed that the sites listed below could deliver the following levels of floorspace:
Net Total 116,400 sqm
This represented a slight shortfall against the OAN, but projections were subject to uncertainty and there was no direct correlation between floor space and jobs.
The position with regard to infrastructure could be summarised as follows –
School provision had been an important factor in the subjective weighing up exercise with the following conclusions -
§ Welwyn Garden City and northern villages required two new schools and expansion of existing schools by 1 form of entry each
The risks facing the Council were that the Government had threatened to intervene where Councils had not submitted their Local Plans by early 2017. That duty to co-operate bodies would object to a Local Plan which did not meet the Objective Assessment of Need. Also, a risk of Local Plan being found unsound if it did not meet the Objective Assessment of Need. The Examination Inspector might require that modifications be made to Local Plan by adding additional sites in order to achieve Objective Assessment of Need and the risk of planning applications for rejected/refused green belt sites being won on appeal.
The timetable for the next stages of the Local Plan consideration were -
CHPP Proposed Submission Local Plan 20 July 2016
Cabinet Proposed Submission Local Plan 2 August 2016
Public consultation for 8 weeks August - October 2016
Analyse consultation responses Late 2016
Submission Local Plan Early 2017
Public Examination Mid 2017
Inspector’s Report Late 2017
Adoption Late 2017
The Chairman thanked Colin Haigh for the presentation and officers for the work they had carried out to date on the Local Plan.
Members of the Panel and, with the consent of the Chairman, other Councillors then asked questions and commented on the report during which the following points were made –
Councillor Perkins (as Executive Member for Planning, Housing and Community) pointed out that the Council had a responsibility to prepare a Local Plan, so that planning decisions about the future of the Borough and where development would occur, was not taken out of the Council’s hands. Planning officers had done an enormous amount of work to ensure that sites had been properly assessed and that infrastructure issues associated with each site were understood, as has been explained to the Panel by the Head of Planning.
However, the need to take into account the views of residents was acknowledged while still having regard to the number of houses and amount of employment land that had been objectively assessed as being needed. Also, developers and landowners needed to be sure that this process has been carried out in a transparent way, in accordance with the National Planning Policy Framework and Guidelines.
The Panel’s attention was drawn to the Risk Management Implications on pages 18 and 19 of the report of the Director (Governance), in particular the need to have prepared a Local Plan by early 2017. With regard to the various sites the following comments were made -
Welwyn Garden City and the northern villages
The idea of a criteria-based policy for the selection of an additional secondary school site to serve growth in Welwyn Garden City and the northern villages should be supported. This would be a pragmatic way of progressing the Plan, rather than pausing the process and waiting for a suitable site to be identified, as the Government had threatened to intervene if we do not submit our Local Plan by early 2017.
As far back as 1993, Panshanger Aerodrome had been identified by an Inspector as safeguarded for future potential growth needs, and it was released from the Green Belt for this purpose.
With regard to the continuance of the Aerodrome, business cases from third parties had not been conclusive in demonstrating that rent and capital investment could be paid back within a reasonable number of years. There had to be severe reservations about delaying the Local Plan to investigate the very late proposal by Mr Fitch, when that proposal relied on a number of landowners being willing to redevelop their land. Indeed, the Council had previously decided that it did not want Panshanger golf course to be redeveloped for housing as it was a well-used community facility.
The need for housing and the importance of preparing a sound Local Plan outweighed the desire of some residents to see the airfield retained and it was acknowledged too that there were many people living in Digswell who were pleased that planes no longer flew over their community.
Hat2 West of Hatfield
Officers had advised that Hat2 was considered suitable for development, but only beyond the plan period. Herts CC, as the mineral authority, had received a planning application for the extraction of minerals along St Albans Road West and it could take up to 30 years before the land could be fully remediated.
However, the development of Hat2 would result in the loss of country park land that was master planned as part of Hatfield Business Park and it would not be right to take this valuable asset away from local residents until new country park provision had been made. Because of the uncertainty of how long it would take for minerals to be extracted and the land to be remediated as a country park, it was suggested that Hat2 should not be considered suitable at this stage, not even beyond the Plan period. This view was further compounded by Herts CC advice that the cumulative selection of Hat1, Hat2 and Hat15 would make local congestion worse, even with mitigation, such that one site might be rejected at this stage to provide more time to consider the transport constraints and improvement options.
Hat5 and Hat19
Officers advise that Hat5 and Hat19 could be considered to help achieve the Objective Assessment of Need, but they would impact on Green Belt purposes and narrow the gap between Hatfield and Smallford in St Albans and should not be included.
It was noted that Officers' advice was that Hat11 was in a fragile gap between Hatfield and Welham Green, but were of the view that it could be reconsidered as suitable for housing.
The gap between Hatfield and Welham Green was already partly compromised by existing employment development along Travellers Lane and by the presence of the New Barnfield site. The understanding of the NPPF was that New Barnfield was a brown field site that could be suitable for redevelopment even if it was not allocated for a particular use/activity and would be considered as "windfall".
The promoters of Hat11 had identified scope to expand the Lawn cemetery on Southway and the Borough needed to find new land for this purpose, so the opportunity for extra cemetery space was a strategic advantage that should be given more weight. Consequently, Hat11 should be added to the list of suitable sites for 120 dwellings, with an assumption that its master planning included a strong landscape belt to separate it from Welham Green.
It was suggested that the officer’s opinion that the level of growth in Welham Green should be limited to match the capacity of the existing primary school be endorsed. The level of growth needed to justify a new primary school would be far greater than the proportionate amount for Welham Green and would put enormous stress on its road network and other community facilities.
The level of growth in Brookmans Park should be limited to match the capacity of the existing primary school to expand by ½ form of entry, as this was Herts CC’s preference as education authority, and this had been well articulated in the report of the Director (Governance).
However, further consideration should be given to the weighing-up exercise as development of the site BrP12 would reduce the gap between Brookmans Park and Welham Green and residents had made it very clear in their consultation responses that they did not wish to see settlements merge. There would also be concerns about traffic volumes along Bradmore Way if BrP12 if it were to accommodate 110 dwellings and a 2 FE primary school.
There was no question that Cuf4 and Cuf5 would represent a significantly disproportionate increase to the size of Cuffley which would place a great deal of stress on its road network and community facilities.
In summary there was disappointment that it had not been able to identify enough suitable sites for housing to meet the Objective Assessment of Need, as there was a risk that the Local Plan would not be found sound or the Inspector would ask the Council to consider the inclusion of additional sites. However, as elected Councillors there was a responsibility to listen to the views of residents, who had repeatedly told Members that they were concerned about too much development taking place on Green Belt land, about the merging of distinct settlements and the loss of identity as a consequence, as well as concerns about the pressure of growth on the road network and vital community facilities such as schools and GP surgeries.
The fact that sites for some 12,000 new homes had been identified should be recognised as this would represent a 26% increase on the current housing stock over the next 15 years. It was also important to note that the selection and release of Green Belt sites for about 5,400 new homes, although something the Council would not choose to do, equated to a loss of only 4% of the Green Belt land in the borough. Even with these difficult decisions, over 75% of the borough would continue to be designated as Green Belt land, where development would only be able to take place in very special circumstances.
The Panel having thanked Officers for their work over many months in getting to this stage in the process it was
That having considered all of the information provided that the sites proposed by Officers be approved with the addition of site Hat11 and the deletion of any reference to site Hat2 and that the Head of Planning now draft the proposed submission Local Plan on the basis of these sites.