REVIEW PAPER
SEVENOAKS DISTRICT
STRATEGIC HOUSING LAND AVAILABILITY ASSESSMENT
UPDATE 2009
Prepared in support of representations to the Sevenoaks District Council
Core Strategy Submission Document and Site Allocations DPD (options)
(January 2010)
(March 2010)
EXECUTIVE SUMMARY
i. This paper has been prepared in support of representations which have been submitted in respect of the pre-submission Sevenoaks Core Strategy 2010 and Site Allocations DPD (options).
ii. A number of the key policies and the overall strategy set out in the Core Strategy (CS) and which in turn inform the Site Allocations (SA) are based on the assumptions made in and the conclusions drawn by the SHLAA. It is therefore a key part of the evidence that underpins the CS. PPS12 advises at paragraph 4.36 that the CS must be founded on a robust and credible evidence base.
iii. The SHLAA is not ‘robust and credible’ and as a result important elements of the CS and SA which rely upon its findings are unsound. In particular the SHLAA has overestimated the housing supply achievable on previously developed land (PDL) sites within the urban areas of the main settlements.
iv. Our key objections are:
· Insufficient allowance for lapse rates in existing planning permissions.
· Unrealistic and too high densities have been assumed on identified urban sites contrary to the SEP and proposed Policy SP7 of the CS.
· The density assumptions for identified sites will inherently fail to deliver an appropriate mix of dwelling types and size as sought by the SEP and proposed CS Policy SP5.
· No lapse rate has been allowed for identified sites.
· The allowance for small site windfalls after year 10 is contrary to Government policy[1] as it is possible to identify specific sites for this period.
· The proposed small site windfall rate erroneously assumes that windfalls will continue at the same rate as historically (during a period of economic boom and when such development came forward at very high rates post-publication of PPG3).
· The over reliance on urban sites within two towns (Sevenoaks and Swanley) will not achieve balanced delivery of affordable housing across the District as a whole and where it is needed; including in and around Edenbridge.
v. We conclude that a more realistic and robust assessment of the SHLAA is that there is not a surplus of 261 dwellings but a significant deficit of 502 dwellings against the South East Plan (SEP) requirement if no additional land is allocated for development in the period to 2026.
vi. We conclude that the previously safeguarded SG1 land at Edenbridge, now proposed to be allocated under Policy LO6 of the CS as ‘Reserve Land’ should be included as a general housing allocation or in the alternative (and without prejudice) there should be no timing constraint to its potential release within the CS period in keeping with the proposed Reserve Land allocation.
1.0 Introduction
1.1 This paper has been prepared in support of representations pursuant to the Sevenoaks District Council Draft Submission Core Strategy (‘the CS’) and Site Allocations DPD (options) (‘the SA’).
1.2 It reviews the various sections of the SHLAA, the assumptions made and the conclusions drawn.
1.3 It is set out as follows:
2.0 Extant Planning Permissions
3.0 Historic Local Plan Allocations
4.0 Identified Sites Potential
5.0 Windfall Allowance
6.0 Affordable Housing
7.0 Spatial Strategy
8.0 Conclusions
2.0 Extant Planning Permissions
2.1 The SHLAA identifies a housing contribution of some 557 dwellings from large sites with planning permission and 278 from small sites with planning permission giving a total of 835 new dwellings from this source.
2.2 In an effort to be robust the SHLAA has considered the conversion rate of permissions into actual dwelling completions and assumes a lapse rate of 4% on sites over 0.2 hectares and 6% on sites under 0.2 hectares. These lapse rates are based on historic trends in the late 1990’s and early 2000’s.
2.3 Whilst the principle of adopting a lapse rate is necessary and supported, the SHLAA and Core Strategy into which it feeds must be as robust and flexible as possible. The use of the 4% and 6% lapse rates as proposed assumes that there will be absolutely no change in previous lapse rates i.e. no flexibility is built in at all.
2.4 Further, the late 1990’s early 2000’s covers a period of economic growth where rates of housing development and house prices were rising strongly. As a result lapse rates on permissions are likely to have been fairly low as evidenced by the 4% and 6% Council figures.
2.5 In contrast, in the current economic situation many urban sites have become far less viable. Developers and landowners are unable or unwilling for economic reasons to bring these sites forward. As a result more permissions are lapsing than was the case historically.
2.6 This has been compounded by two Government initiatives in 2005. First to reduce the standard time period for implementation of permissions from 5 to 3 years and second to remove the opportunity to extend time limit conditions under Section 73. These were seen (then) as mechanisms to encourage housing delivery sooner rather than later but have been frustrated by the (then) unknown and unforeseen current economic conditions and slowdown in the housing development industry.
2.7 Extant residential permissions granted under this regime are now coinciding with the economic downturn. There is uncertainty that these permissions can be implemented as rapidly as Government envisaged or intended, or as developers and landowners would wish. In turn, anticipated housing delivery has been compromised. This is evidenced by Government’s decision earlier this year to intervene by introducing new streamlined planning application procedures for ‘replacement planning permissions’. However, while this provides an opportunity, effectively, to renew an extant permission it does not guarantee implementation; in fact in the current and foreseeable market conditions it will provide opportunity and increased propensity for permissions to remain extant for longer, but nonetheless still not implemented. This will not assist housing delivery at all, let alone “continuous” delivery as Government demands[2].
2.8 In the final quarter of 2008 the Department for Communities & Local Government reported on house building starts and completion monitoring. DCLG advised that this quarter had seen the lowest level of starts since monitoring began in the 1980’s. In the same period the Council of Mortgage Lenders announced a 44% reduction in mortgage lending compared with the same period in 2007.
2.9 The latest 2009 figures for annual housing starts in England (DCLG November 2009) totalled 83,080 in the 12 months to September 2009. This was down 35% compared with the previous 12 months to September 2008 and some 55% below the 2005 – 2006 peak. The early signs in 2010 are that limited confidence is returning but mainly only to those developers/landowners that can prove a track record of fiscal low risk to lenders; the fact remains that house building levels are still well below the historic highs and are expected to remain so for the immediate future.
2.10 PPS12 requires that the Core Strategy (which is informed by the SHLAA) is responsive, builds in flexibility and has contingencies. It is considered that simply applying a lapse rate identical to that achieved during a boom period does not build in such flexibility. Account should be taken of the current economic situation and the potential for a higher percentage of permissions to lapse.
2.11 It should be a matter of agreed common ground with the Council that in the past robustness was achieved in assumptions made in preparing local plans by including non implementation allowances of 10%. This was commonplace and generally accepted by Inspectors as providing reasonable flexibility.
2.12 Although completion figures in Sevenoaks District have been traditionally strong, given the state of the market we submit that achieving only a 10% lapse rate on permissions over the next 5 years would represent a very impressive performance for the local market.
2.13 If a 10% rate is applied to the 835 dwellings this would reduce the contribution from this source to 789.
3.0 Existing Local Plan Allocations
3.1 The existing local plan was adopted in March 2000, ten years ago.
3.2 The preparation of the plan was begun in the early to mid 1990’s. The majority of the sites which were eventually allocated by the Plan were known to the Council and have been recognised as having development potential for at least 15 years.
3.3 The local plan allocated 17 housing sites that it anticipated would deliver 610 dwellings between 1996 and 2006.
3.4 Of the 17 sites allocated, 4 sites (nearly a quarter, or 24%) have failed to come forward and deliver any completions to date.
3.5 The four sites which have failed to deliver were expected to contribute 90 dwellings (15% of anticipated housing supply during the plan period).
3.6 The SHLAA lists these sites in its table 5.3. The SHLAA advises that one site (Cray Road) will not come forward because the owner has indicated that there is no intention to develop.
3.7 However, the SHLAA still indicates the other three sites coming forward within the CS period to deliver 58 units.
3.8 There must be a substantial doubt and uncertainty that these sites will now come forward given that they have failed to be developed over the past 10 – 15 years, during a buoyant economic period and despite being allocated in the local plan.
4.0 Identified Sites
Application of a Sequential Approach:
4.1 The SHLAA has identified 32 sites which it considers suitable for housing development within existing urban areas. If delivered in full, as the SHLAA assumes, this could bring forward 1,421 dwellings over the CS period to 2026.
4.2 Of these, 93% (1324 dwellings) are expected to be delivered on previously developed land (PDL) sites and only 7% (97 dwelling) on Greenfield land. This grossly exceeds even Government’s “at least” aspiration of 60% of housing delivery on PDL[3]. The CS provides no apparent justification or even explanation for such an imbalance and excessive over-reliance.
4.3 The SHLAA has instead deployed a sequential approach as was advocated in PPG3. The SHLAA slavishly seeks to exhaust all PDL potential to the exclusion of Greenfield sites; whereas PPS3 advocates a more balanced approach with the delivery of sustainable communities and meeting the varied housing needs of all in the community confirmed as important objectives, as well as the need to consider a variety of alternatives. The sequential approach was specifically removed from PPS3.
4.4 As a result the SHLAA (and in turn CS and SA) is imbalanced and does not give sufficient weight to the potential and benefits which non PDL sites could deliver.
Delivery of identified sites
4.5 The SHLAA (and so CS and SA) does not explain how each of the identified sites are considered deliverable having regard to PPS3, paragraph 54. For example very few of the sites identified in the 0-5 year period appear to have made any progress through the planning system[4] and approval of reserved matters for the West Kent Cold Store could potentially delay implementation of around 50% of dwellings into the 6-10 year period.
Density Assumptions / Dwelling Mix
4.6 The West Kent Cold Store (500 dwellings) is by far the largest identified site. There is only one other site large enough to accommodate over 100 dwellings. The majority are small scale sites of 50 or fewer dwellings.
4.7 13 of these 32 sites (40%) propose densities between 50 and 100 dph. When the dwelling numbers for these 13 higher density sites are totalled this reveals 1,224 dwellings, leaving just 197 (or 14% of dwellings) expected to come forward at a density below 50dph.
4.8 To place this in context the South East Plan seeks an average density of 40dph across the region. Draft CS Policy SP7 advises that within the urban areas of Sevenoaks, Swanley and Edenbridge new residential development will be expected to achieve a density of 40 dph. Delivery of 1,224 dwellings above 50 dph relies on a far higher level of dense development than is envisaged by Government and regionally.
4.9 The CS and SA strategy adopted appears to be seeking to ‘cram’ very dense development onto a small number of urban sites in an effort to avoid the need to utilise available Greenfield land. This is in conflict with Government policy as it does not strike the right balance with other interests of acknowledged importance, such as character and appearance of an area[5].
4.10 It is our experience and generally accepted urban design best practice that in order to develop sites with (i) a good mix of dwellings i.e. 1, 2, 3, and 4 bedroom properties, (ii) provide a mix of houses and flats, and (iii) provide gardens and adequate parking then 45 dph is approximately the maximum density which can achieve all of this.
4.11 At a density of 50 dph mixed development is still possible but normal and expected amenity standards, garden sizes, parking and space around dwellings is compromised.
4.12 Minimum garden sizes cannot be achieved and parking would be below appropriate levels. At 60 dph and above the majority of dwellings will be 1 and 2 bedroom flats. The SHLAA suggests that 912 dwellings can be accommodated on urban sites at a density above 60 dph.