Representations on Joint Core Strategy Gloucester, Cheltenham & Tewkesbury Draft for Consultation December 2013
On behalf of
Gleeson Developments Limited
Joint Core Strategy Gloucester, Cheltenham & Tewkesbury representations
Prepared by Gleeson Developments Ltd
1.0 Introduction
1.1 These representations have been prepared by Gleeson Developments Limited (Gleeson) as part of our promotion of the land between Hill Lane and Gravel Pit Lane, Prestbury for residential development with associated open space and infrastructure. The land promoted within these representations is controlled by Gleeson through a Legal Agreement and is considered to be a suitable and deliverable location for development and is considered to be available for residential development if allocated as part of the Local Development Framework process.
1.2 The land being promoted by Gleeson extends to 9 hectares and is located to the north of Prestbury which benefits from accessible links to the highway network and Cheltenham town centre. We feel this site benefits from not having the constraints that affect other sites in the area primarily not being in the green belt and not being in an Area of Outstanding National Beauty (AONB) thereby easing the three local authorities pressure to release green belt land.
1.3 Gleeson support the continued progress and planned submission of the Gloucester, Cheltenham and TewkesburyJoint Core Strategy (JCS), and acknowledges that the three local authorities have recognised that housing growth is required across the JCS area to meet housing demand.Within these representations we discuss our concern on the housing need projection the JCS intends to provide in the plan period and in allocating a disproportionate share of residential growth to North West Cheltenham and Gloucester, where we have concerns over delivery
1.4 Gleeson has considered the ‘vision’ for the JCS area as set out within Chapter 2, specifically Strategic Objective 8 of Ambition 3. We believe that this forms an important and focused brief for development in the JCSareawhich our site at Prestbury meets.
2.0 Policy SP 1 – Scale of New Development
2.1 Gleeson support the identification of new land outside the existing urban boundaries for long term development. We agree with paragraph 3.6 which confirms thatthe advice sought from Nathaniel Lichfield and Partners (NLP) on housing need that Scenario A, 810 per year, is considered unsound in examination. However we are concerned that Scenario B, provision of 1,660, used as the housing delivery target in Policy SP1,also provides an insufficient projection of meeting housing need over the plan period to accommodate growth. NLPs assessment found that a total requirement of housing need annually is between 1,625 and 2,175. We believe that JCS housing projection should be averaging at 1,900 units per annum rather than at the lower end of range provided by NLPs assessment.
2.2 Paragraph 3.7of the JCS states that planning for less housing than the assessed need may result in the JCS being found unsound and therefore is likely to lead to ad-hoc development to be approved outside the plan led approach.Furthermore a lower allocation could cause a deficiency in housing delivery if suitable land is not identified and deliveredearly. We believe that this statement demonstrates the three local authorities’ acceptance of the consequences of lower housing delivery. In addition we are concerned that an over provision of large scale allocations at North West Cheltenham, Gloucester and Ashchurch could result in a delay in delivery in the short term, as large scale strategic sites have longer lead in times.
2.3 The JCS area has seen a changing demographic over recent decades with an aging population and an increase in household formations all contributing to a shortage of housing stock in both the private and affordable market place. The requirement for a greater stock of housing units has become particularly acute in recent years with the decline in new housing completions and also with increasing demand for homes associated with economic migration, the changing format of family units and lifestyle choices with people choosing to live alone, and with people living longer. The combination of factors contributing to increased household formations has resulted in the demand for alternative and a diversity of accommodation formats, mix and locations in order to address the current imbalance in supply and demand.Gleeson appreciate the difficulty in planning for a 20 year period however, as stated in paragraph 3.12, the reasoning of a partial recovery of the economy in line with mortgage lending improvements provides little justification for Policy SP1 to be based on the lower end of the assessed housing need in the JCS area. We are concerned that Policy SP1 will not meet housing demand and housing need across the JCS areaduring the plan period and therefore find this policy unsound.
3.0 Policy SP 2 – Distribution of New Development
3.1 Policy SP2 identifies the broad distribution of new development across the area and recognises that development requirements cannot wholly be met by district capacity therefore a collaborative approach across boundaries to identify urban extension capacity is necessary. As previously stated we are concerned that the overall housing supply proposed does not addressed housing demand and housing need within the JCS area. Accordingly, housing allocations across the settlements should be increased to ensure adequate delivery across the plan period.
3.2 Table SP 2a setting out the amount and distribution of development identifies 33,449 dwellings in the JCS area for the plan period; we strongly dispute the soundness of the distribution figure set out. We feel that a greater proportion of the requirement for new development has been placed in Gloucester, 7,654 at district capacity. District capacity has been based on past delivery, commitments, windfalls and potential allocations on smaller sites which we believe some of these to be unreliable factors due to their levels of uncertainty. Furthermore a significant proportion of the total supply of housing for Cheltenham and Tewkesbury has been placed on urban extension capacity primarily located in Tewkesbury Borough Council, as stated in paragraph 3.22.
3.3 Table SP 2b shows that half of the total number of proposed new dwellings falls within Cheltenham of which almost a third is projected for North West Cheltenham. Gleeson appreciate that Cheltenham is the principle settlement within the JCS area however we do not believe that delivery of 4,647 homes is achievable over the plan period. The guiding principle for this policy as stated in paragraph 3.23 is: ‘need is met where it arises’ which seems to have largely been ignored, as strategic sites such as those around Cheltenham, specifically at as Prestbury, have been disregarded in the draft JCS.
3.4 Gleeson appreciate the methods used in the JCS to identify potential sources of housing supply, as stated in paragraph 3.24,however we do have some areas of concern, firstly the use of housingbuilt between 2011 and 2013 does not suggest meeting the need for future growth. Secondly, sites that have been granted planning permission do not necessarily constitute housing completions. Thirdly, Gleeson support the inclusion of sites identified in the SHLAA however the issues of constraints that prevent sites coming forward, needs to be addressed to bring potential sites forward efficiently. Furthermore we strongly dispute the assumption on the number of windfall sites that will be granted planning permission as there is great uncertainty on how many will come to fruition.Finally, Gleeson is concerned that as the district plans for Gloucester, Cheltenham and Tewkesbury are all in the preparation process the reliance of housing need and delivery being based on them is unsound. This is concerning as in total this equates to 18,634 which is 55% of the projected housing need.
3.5 Gleeson agree that there is insufficient land inside the existing urban boundaries of Gloucester and Cheltenham to accommodate housing needs and therefore urban extensions have been considered most suitable locations for new development. We do however feel that not all sites have been considered when urban extensions were identified within the sustainability appraisal. Furthermore the urban extensions boundary study shows that in fact 2,820 dwellings per annum would be required for the JCS to adequately address overall regional housing figures and the economic aspirations of the area, of which 205 would be delivered in Tewkesbury.
3.6 Gleeson believe the Broad Locations Report used to assess the land surrounding the three main centres ignores our site at Prestbury. We feel Prestbury, unlike other strategic sites identified in the JCS area, benefits from not being in the green belt and therefore would not have a diverse impact on the countryside.
3.7 Finally the policy is flawed as paragraph 3.29 states:
“…it is anticipated that not all of the site may be delivered within the plan period to 2031. It is estimated that a further 1,092 dwellings will be delivered post 2031 and form part of the overall supply”
This emphasises that there will be a shortfall of housing delivery in the JCSarea and despite a proportion being delivered after the plan period the JCS intend to include it as overall supply for the plan period. This cannot be acceptable.
4.0 Policy SP 3 – Delivery and review
4.1 Gleeson support the three Councils decision to review the JCS at regular intervals to meet the needs of the area through monitoring, releasing safeguarded area early, identification of sites and undertaking green belt review. We support the JCS view that a contingency supply of homes will come from unallocated sites to provide a buffer for slippage of large sites being delivered, however we remain concerned that not enough housing is being proposed in the plan period.
5.0 Policy S 1 – Presumption in favour of sustainable development
5.1 Gleeson support the JCS recognition in favour of sustainable development and that economic, social and environmental gains should be sought jointly. We understand the view that planning applications that accord with the JCS and those without policies or out of date policies will be granted permission unless material considerations state otherwise. Gleeson acknowledge that policies will become dated therefore evidence must be submitted to demonstrate benefits of any proposals.
6.0 Policy S 3 – Sustainable design and construction
6.1 Gleeson support the JCS commitment to the provision of sustainable buildings and assessing BREEAM standards within new development. However we do feel that some of the requirements stated in the policy are too restrictive, and will therefore impact on the viability of developments, which we believe should be flexible to meet the housing demand within the plan period.
7.0 Policy S 5 – Green belt
7.1 Gleeson understand the JCS function to preserve the green belt due to the constrained nature of the JCS area. Gleeson support the three Councils intention to release land from the green belt to provide for adequate land for current and future development across the JCS however we believe the JCSfails to properly consider sites outside the green belt such as the Gleeson site at Prestbury which would prevent amendments to the green belt boundary.In addition we find the previous green belt review (2011) took place before changes to national planning policy commenced and therefore needs to be updated.
8.0 Policy C 1 – Residential development
8.1 Gleeson support the JCS ambition for new housing developments to be sustainable and accessible whilst addressing local needs, offering a range of different housing types, tenures and sizes. We disagree with the JCS point to only permit housing developments on greenfield sites solely for the provision of offsite affordable housing, infill development and on the basis that a site is brought forward through Neighbourhood Planning process. Gleeson believe each site should be assessed on its own merits and assessed individually by case and on the status of planning policy and need to achieve housing delivery.
9.0 Policy C 2 – Housing mix and standards
9.1 Gleeson support the JCS view to create mixed and balanced communities to aim for sustainable developments that meet the needs of the community. We understand this is achieved by supporting infrastructure, sense of space and greater community cohesion. Gleeson has concerns with the JCS on the provision of 25% of homes on sites providing 50 or more dwellings to be built to meet Lifetime Homes standards. It is unnecessary to be so restrictive within the JCS, especially when standards change on such a regular basis. Gleeson agree that housing provision is responsive to local market changeand should be reviewed and updated in line with changing demographics.
10.0 Policy C 3 – Affordable housing
10.1 Gleeson support the provision of affordable housing, although we believe that the policy should allow a degree of flexibility to ensure that site specific matters such as site conditions can be taken into account during the application process and also so that the policy framework can be varied in order to take account of wider market conditions and housing demand within the locality of the scheme.
11.0 Policy SA 1 – Requirements for strategic allocations
11.1 Gleeson aresupportive of the requirements set out in Policy SA 1 for Strategic Allocations however there are some issues with specific requirements. We believe the average density of housing to be provided (40 dwellings per hectare) is too high for some areas and therefore the quality of housing, outside space and townscape and landscape would need to be compromised, which incidentally challenges other landscape features required in the policy. It is also unnecessary to be so specific in this regard and would therefore request re-consideration of this restrictive policy.
12.0 Policy A 5 – A 7
12.1 Gleeson believe strategic allocations stated in Policy A 5 to A 7 around the Cheltenham area are particularly large strategic allocations and will therefore take a number of years to complete negotiations and for units to be completed on these schemes. All three policies provide for a significant number of dwellings.In addition, these involve major changes to the landscape, the provision of new road infrastructure and junctions, the majority of which will be required to be delivered in the early phases of development, which will push back the delivery of units on this scheme. It is almost certain that the development, especially A5, will not be completed within the JCS period thus the JCS will not meet housing need that has been identified for the plan period. In light of the assumptions made, Gleeson believe that smaller sites will need to be released from the green belt and meet provisions in the short term to meet annual housing need, such as that at Prestbury.
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