Questions for Clarification Liskeard NDP

Questions for Clarification Liskeard NDP

I am Deborah McCann, the independent examiner of the LiskeardNeighbourhood Development Plan. I seek clarification on the following policies, my questions relating to those policies is in blue following each policy. These questions are directed to the Neighbourhood Plan Group.

POLICY NP1

Development Boundary

The neighbourhood plan designates a Liskeard Development Boundary, as shown on the proposals map within which development will be permitted according to the following policies.

QUESTION

Please clarify how the development boundary has been established and the evidence base supporting it.

How does the development boundary as chosen relate to the strategic policies of the Cornwall Local Plan in relation to housing delivery? How will the housing need identified be delivered across the plan period?

The Development Boundary was drawn up following an appreciation of the value that such a tool would bring to our NDP strategy. (see separate notes explaining the criteria used, and the links with CLP). Liskeard NDP group took, as a starting point, the development boundary set by Caradon District Council, and applied by Cornwall Planners until the Local Plan was adopted in Nov 2016. Utilising previous data and studies, such as information from the unfinished Town Framework, the Housing Working Group assessed sites on a range of detailed criteria, to establish a sustainable hierarchy of potential sites around the town that would more than deliver our housing need and apportionment set by CLP to 2030. During the process of creating the Neighbourhood Plan which started in 2014, there was a large development that had just commenced buildingplus some other viable sites already in the planning system, and further sustainable developments that we had included in our assessment also came forward as the NP progressed, so together these provided us with the basis for forming a new development boundary that would accommodate the sustainable growthand evolving infrastructure,as well as include all our other community aspirations and policies in a holistic way to meet the towns needs to 2030. In producing this we have used the same methodology on determining development boundaries as advocated by Cornwall in its Neighbourhood Planning guidance.

We feel the NDP is fully supporting the CLP strategic policies relating to housing delivery “providing homes in a proportional manner where they can best meet need and sustain the role and function of local communities and that of their catchment [policy 2a]”. Our Neighbourhood Development Plan allows for the key targets in policy 2 and 3 to be met, especially in relation to the apportionment figures outlined by CLP, and their deliverability within the plan period.

For clarity, as explained in the section of the Housing Working Group report on Matching Housing Supply and Demand, and detailed delivery trajectory, the planning permission granted on the Tencreek site, for 275 dwellings (& on top of that figure an additional 60 units for older person provision), is outside our development boundary, because although it is on the very edge of Liskeard, it falls within Menheniot parish. But it was made quite clear by Cornwall from the start, that the housing numbers would be included in the total for Liskeard, and this has been fully endorsed in the CLP, para 1.55 – “in some cases housing allocations and/or planning permissions for a town will cross parish and community network boundaries, or abut such boundaries, where this best meets the growth needs of that place. Where this is the case, development in those locations will be counted against the allocation for that town”.

So our figures as detailed in the Housing Report and NDP, show that a surplus over the apportionment is deliverable (most with planning permission already in place). This is evidenced in the Housing Report, shown in extract here:

As the CLP states (policy 2), there is a requirement to take account of the rate at which houses are actually built to ensure “delivery of the target in the plan period”. The methodology for this is set out in the ‘Cornwall Local Plan Housing Implementation Strategy’ (Jan 2016), which includes figures for the lead-in time from planning permission to commencement ofbuilding, and the subsequent rate at which houses will be built. These depend on whether the planning permission is ‘outline’ or ‘full’, and on the size of the site.

Housing target and delivery in Liskeard: From Cornwall Local Plan Housing Implementation Strategy Chart, and Parish level data Allocations spreadsheet, updated to April 2016, with additional permissions granted up till Oct 2016 and identified ‘urban capacity’ sites factored in, the following table details the position :

supply / demand
Target 2010-2030 / 1400
Completions to Apr 2016 / 280
Permissions to Apr 2016 / 554
Additions Apr – Oct 2016 / 315
Net windfall prediction / 86
= current supply of : / 1235
Residual Target / 165
Net additional urban capacity identified in NDP less 30% for non-delivery / 90
Residual target to be met / 75
Charter Way/Pengover Rd urban extension (now with permission) / 207
Residual demand / Surplus of 132

N.B. the above chart does not include the extra 60 units for older person provision.

Cornwall Council has forecast an allowance for ‘windfall’ of 6 units per year up to 2030 (86 in total). Our historic record indicates positive evidence that we will cover this requirement.

Additional note: Housing figures given in CLP ‘Housing Implementation Strategy report’ (Aug 2017) only include data on completions/permissions up to April 2017 – however as indicated above, since then a further 207 houses have been granted permission on the site allocated in policy H4.

Liskeard has to demonstrate that it can not only provide sufficient land, and permissions to meet the Cornwall Local Plan target of 1400 dwellings, but also these have to be ‘deliverable’ i.e. built, within the plan period up to 2030. To demonstrate that this is the case, a delivery trajectory has been calculated using the Housing Implementation Strategy methodology, and is presented as a bar chart, and year by year completion schedule below :

The chart below shows that sites in Liskeard, in progress (Addington), with permission (Tencreek and Woodgate Road), and now allocated with permission (Charter Way/Pengover Rd), together with discounted urban capacity and windfall allowance, provide both deliverable land and completed houses to meet the target within the plan period to 2030. The over provision and notional surplus provides a buffer to ensure full delivery.

In detail:

Addington- Construction commenced and c. 100 dwellings completed. 35 per year build out would result in completion by end of Jul 2026

Tencreek- Outline permission by October 2016: Lead time to construction = 24 + 19 = 33 months, so could commence building by June 2019; 275 dwellings at 35/year would take 8 years to complete, so possibly finished by beginning of April 2028

Charter Way/Pengover Rd – detailed planning permission now granted May 2017 – Lead time to construction = 19 months so could commence building Nov 2019; 207 dwellings at 35/year would take 6 years to build, so completion by Nov 2025

Woodgate Road – Full planning permission 1st august 2016 – lead time 30 months, so may commence by 1stJanuary 2019. 40 dwellings at 39 per year would take until Mar 2020 (Note : this has now already commenced). [When this received planning permission, the report from the LPA commented that Liskeards “housing requirement is likely to be met over the plan period, and this is given some weight in considering the sustainability of this development”]

site / houses / permission / date / Lead-in months / Extra Lead-in months / Build rate per year / Build time years / Total years to deliver / Delivery date
Addington / 360 / In progress / As at Apr 2016 / 35 / 10.29 / 10.29 / Jul 2026
Woodgate Rd / 40 / full / Aug 2016 / 30 / 0 / 39 / 1.03 / 3.53 / Feb 2020
Tencreek / 275 / outline / Oct 2016 / 19 / 24 / 35 / 7.86 / 11.44 / Apr 2028
Charter Way/Pengover Rd / 207 / full / May 2017 / 19 / 0 / 35 / 5.91 / 7.5 / Nov 2025

NB The Implementation Strategy explains that: “ The evidence to obtain these assumptions is based on activity in the development industry during a period of recession. It is likely therefore that particularly delivery rates and to a lesser extent, lead in times may be on the conservative side.”

As the above information shows, with planning permission on most of our sites Liskeard is well able to deliver its apportionment within the period to 2030 as well as contributing positively to the maintenance of a 5-year supply for Cornwall.

However our Housing Policy H5 allows for regular monitoring of building rate and if a shortfall were to occur relative to the Delivery Trajectory, there is a clear mechanism whereby additional permissions could be allowed, using the criterion-based assessment of sustainable sites.

POLICY EM1

Employment and Housing Balance

In order to relate the delivery of employment land to the expansion of housing provision, all new larger housing schemes (30 or more dwellings) must contribute towards the need (as defined in the Cornwall Local Plan) for employment land, or servicing and development of such sites to facilitate the delivery of viable workplaces, through a process of cross-subsidy. Where a developer can demonstrate that the site is not suitable for inclusion of employment (e.g. because of topography, environmental impact, poor transport links etc.) then an ‘off-site’ contribution will be sought to cross-subsidise the release/development of employment land elsewhere in the NDP/CNA area.

QUESTION

What evidence is there to justify the 30 housing threshold and how does this policy fit with existing national and local policy and meet the Basic Conditions?

In the absence of clear definitions around what is meant by small, medium, and large developments, the aim was toprovide a figure above which developments would beconsidered sufficiently viable to either accommodate some employment/mixed use, or trigger cross-subsidyfor off-site provision.

One of the strongest messages to come out of our Neighbourhood Plan engagement and consultation with our community was the desire to provide more employment, jobs and training in our local area, (and that Liskeard should not just be a dormitory town for Plymouth), thus supporting sustainable development as outlined in both national and local policies and referenced in our Basic Conditions Statement -“contributing to building a strong responsive and competitive economy” promoting “mixed use development” whilst trying to be “genuinely plan led, empowering local people to shape their surroundings” (NPPF core principles), with CLP “supporting economic development in SE Cornwall that meets the areas own needs”(spatial strategy policy 2)

Furthermore we are meeting CLP’s required target figures for providing employment space as outlined in CLP p36 Table 3, and our approach is supported by CLP’s explanation that “where there is a clear need for employment facilities but building them is not viable, we will consider proposals that include mixed use schemes where the ‘other’ uses can provide cross-subsidy.” (In the Business and Tourism section supporting policy 5)

Historically, Liskeard Business Park at Charter Way, which was developed by Caradon District Council, had plans, with funding in place, for further phases in the vicinity, but after the setting up of Cornwall Unitary Authority, the funding was removed, and since then, following the economic recession, no further public sector intervention funding has been allocated to the area, with little or no employment development. However, during the process of producing the Neighbourhood Plan we have been pro-active in trying to address this problem and carry out the wishes of our community, by achieving some mixed use, where appropriate, through engagement with developers on two major sustainable developments that have come forward and now have planning permission (one of them mentioned below in reference to EM2A).

We see the essence of the above policy as having regard to both national and local policies and as a practical solution to supporting enhanced employment prospects for people in the Liskeard area.

EM2A

The development of the land north of Pengover Road must:

a) Be for use classes B1, B2, B8, A1 and A3 only;

and

b) Be commenced in advance of/ concurrently with any development of adjoining land for residential development;

and

c) Ensure that the main vehicular access to the site operates safely in conjunction with the Clemo Road Industrial Estate Rd.

QUESTION

What is the justification for this policy and how does it fit with existing national and local policy?

QUESTION

This policy refers to the hybrid application PA 17/04823 – outline for 0.93 Ha employment space, and detailed for 207 houses (also referred to in NDP policy H4). The history of this site was that the NDP group engaged with the developer, in accord with policies EM1/H3, to incorporate employment land as part of the overall site, which lies adjacent to the hospital and associated health services(so could allow for expansion of these facilities or other appropriate employment opportunities). It is also situated within a ‘neighbourhood node’ with pedestrian and cycle routes, good accessibility to local services, bus routes and ring road - in compliance with NPPF and CLP around building a strong competitive economy, healthy communities and sustainable development, and as indicated in our basic conditions statement (for instance on pages 8, 13, 18, and 19).

Subsequent to the publication of the draft Neighbourhood Plan, this site has received planning permission from Cornwall, taking into account the provision for employment, and with enhanced access to the main road network.

EM3

Allocation of Employment Land Outside but Abutting the LiskeardNeighbourhood Plan Designated Area

Menheniot Parish Council has agreed to support, in its forthcoming Neighbourhood Plan:

1. The use of 12.72 ha of land at Bolitho Farm for the following purposes:

a) A grouping of related industries – for example related to agricultural technology and processing

b) A development related to the growth hub initiative of the Plymouth and South West Peninsula City deal

c) The development is for use class B1 only, or mixed B1/B2 uses

QUESTION

What is the justification for including a policy which relates to land outside the NP area?

Recognising that this is outside the NDP area, it has been put forward in the Draft LiskeardNeighbourhood Plan, as a suggestion, not a policy. However we appreciate now that this could perhaps be clearer in the plan document if the background colour was a paler shade to avoid confusion.

This has been included because provision of employment land is a CLP requirement of the whole Community Network Area (Liskeard and LooeCNA), so therefore does cross boundaries (this site is very close to the Liskeard/Menheniot parish boundary on the SE outskirts of the town), and helps to support an overview for the area. During the preparation of the plan there has been close liaison with Menheniot Parish Council, who are fully supportive of this suggestion for use of land at Bolitho Farm for an ‘agri-hub’, and there is a feasibility study now in progress which has been endorsed by both Menheniot and Liskeard Councils.

Historically, this site, along with others in the vicinity, have been proposed as suitable employment sites linked to Liskeard, (e.g. Cornwall Development Company study 2012/13) because of their sustainable locations with good access to the main A 38 transport network, as well as landowner deliverability.

POLICY H2

Brownfield Land First

Further releases of land for housing beyond the development boundary established in POLICY NP1 will not be permitted until 90 dwellings have commenced development on a combination of the urban capacity sites identified in Table 1, and smaller unidentified and windfall sites within the urban area (using the base date for measurement of 1st April 2016), and the conditions in policy H5 apply.

QUESTION

What is the justification of this policy? How does it meet the Basic Conditions?

We believe that the reasoned justification already included in the NDP on pages 39 and 40 provide a cogent argument. There is nothing in the NPPF that says such an approach cannot be adopted and therefore it meets Basic Conditions. Furthermore, the Housing White Paper 2017, ‘Fixing our broken housing market’ suggests a number of changes to NPPF are forthcoming that support this position, including:

A presumption that brownfield land is suitable for housing unless clear and specific reasons to the contrary and a change to indicate that great weight should be attached to the value of using suitable brownfield land within settlements for homes.

Support for the development of small ‘windfall’ sites and indicate that great weight should be given to using small undeveloped sites within settlements for homes, where they are suitable for residential development
A requirement that on top of the allowance made for windfall sites, at least 10% of the sites allocated for residential development in local plans should be sites of half a hectare or less.

Given the absence of an NPPF or CLP restriction on the approach suggested, and recognizing the direction of travel in national policy, we feel that the policy as stated is sound.

To date, delivery on brownfield sites in Liskeard has been maintained at a rate that is consistent with realistically achieving 90 plus starts within the plan period. (potential sites outlined in the NDP Housing Working Group report). Thus showing that this is a realistic, workable policy that is actually achieving what national and local policies are propounding, as well as supporting the strong opinion voiced during our community engagement.

Apart from brownfield sites noted in the NDP as already having planning permission (nearly half the requirement), there are further sites going through the application process at present – as well as landowner submission and acceptance onto the C.C. Brownfield register; and in addition there are sites owned by Cornwall Council that are surplus to requirements now, and have the potential for housing/employment well within the plan period (e.g. Westbourne, Graylands, the Cattle Market site).

POLICY H3

Employment and Housing Balance