north tyneside strategic housing land … · on behalf of sjs potts ltd 5-year housing land supply...

NORTH TYNESIDE

STRATEGIC HOUSING LAND AVAILABILITY ASSESSMENT

2016

APPENDIX 4:

Consultation Response Schedule

September 2016

North Tyneside SHLAA Report September 2016

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North Tyneside Council

SHLAA Update 2016 – Consultation Response Summary

Ref Company / Organisation

Point/Site for Comment

Comment (summarised) NTC Officer Response

1 Big Tree Planning on behalf of SJS Potts Ltd

Part Site 115 and Part Site 306

The site’s landowners and covenant beneficiaries have entered into a single option agreement – there are now no legal ownership impediments to delivery. Taylor Wimpey no longer has any legal interest in site – it is requested that this is amended. The site is suitable for a residential development comprising approximately 120 dwellings – with at least 15% affordable housing.

Comments and update with regard to landownership, interests and site options noted. The site schedule has been updated accordingly. However the Council consider that the location of the site within the setting of Killingworth Open Break (or designated Local Green Space in the LPSD 2015) renders the site unsuitable for development.


5-Year housing land supply methodology

The Council are claiming a 5% buffer is appropriate. This is despite severe under-delivery every year since 2008/09 – 1,678 dwellings against the emerging Local Plan target (applied since 2011/12) and previous RSS target (until 2010/11). Over the emerging local plan period this represents a 51% shortfall i.e. less than half the required target since 2011/12. This under delivery is as persistent as it is significant. The Council’s reasoning for the under-delivery revolves around wider economic and housing market conditions. However, economic circumstances form no part of national policy under paragraph 47 of the NPPF. Persistence is merely something which has continued over time and it is a matter of degree. It is considered that 7 years’ under-delivery is persistent in that

Comments noted with regard to the shortfall in housing delivery against the requirement. It is acknowledged that, when compared to the requirement as set out in the Local Plan, there has been under-delivery over the last 5 years. However, it is important to consider this issue on a long-term cumulative basis and in light of the recent positive trend with regard to both house-building and the grant of new planning permissions for residential development. Delivery over the previous two years has been accelerated as additional sites have been brought forward for consideration and approved. Added to this, the delivery that will be achieved following adoption of


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regard and as such a 20% buffer must be applied. However, even with the 5% buffer the Council cannot demonstrate an adequate supply (963 dwelling shortfall), with it rising to 1,879 when the correct 20% buffer is applied. It is clear that the Council must identify significantly more land to meet its 5-year requirement.

the Local Plan will enable this acceleration to continue and ensure further house-building to meet the new higher targets identified. The shortfall in housing delivery over recent years has to be considered in light of a significantly increased requirement: from 400dpa under RSS (relevant up to 2011) to 828dpa based upon latest evidence. This increase in requirements took place over a period when wider economic recession led to a slowdown in housing delivery generally, previous allocations within the UDP (2002) have been exhausted and preparation of a revised Core Strategy/Local Plan to release appropriate new housing land allocations has been underway. In this land availability and market context, housing land supply has not met relevant targets. However, when taking overall delivery into account from 2004/05 it is worth noting that overall cumulative delivery did not fall below target until 2013. The Council considers that the use of a 5% buffer is most appropriate in the local circumstances and the most effective strategy of addressing housing land supply issues and delivering the housing requirement for the borough. An adopted Local Plan will then allow the allocated sites to come forward for development. The more positive recent context is reinforced through the 5-year housing land supply assessment; the 2014 SHLAA identified a deliverable supply from all potential


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sources of 3.04 years from all potential sources, rising to 3.40 years in 2015 and to 4.32 years in 2016. However, clear and transparent evidence is provided through the 2016 SHLAA that discusses the implications of both a 5% and a 20% buffer and also the use of both Sedgefield and Liverpool methodologies in determining residual need. This sets out a range of potential scenarios and subsequent conclusions for the housing land supply position over the next five years and beyond.


5-Year housing land supply position

The SHLAA suggests 4,091 units are deliverable between 1st April 2015 and 31st March 2020. The OAN for the same period (with 20% buffer) is 7,332 dwellings – representing approximately 56% of the total requirement. Even when a 5% buffer is applied, the requirement is 6,416 dwellings – 64% of requirement. The Council must look to identify significantly more land to ensure supply is sufficient to meet the requirement.

Comments noted. The Local Plan Pre-Submission Draft (2015) and the Council’s Proposed Minor Modifications (June 2016), identify the preferred allocations to meet identified need. It is considered that the allocations are deliverable and/or developable over the plan period and, along with robust evidence-based allowances for windfall and small sites, that the full OAN for the borough through to 2032 will be met, without the need for further allocations. The monitoring process will be crucial in assessing both overall delivery and that of additional windfall. The Local Plan I&M Framework sets out contingencies needed in the result of a failure to deliver against the OAN. This will enable a flexible, proactive approach to the release of land for development to meet identified need.


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Incorporating Site 115 and Site 306 as part of Site 074 Killingworth Moor (strategic allocation)

The site is suitable for approximately 120 dwellings: ownership/covenant issues now resolved; available –actively promoted by the option holder; greenfield – no known physical constraints; and achievable within the short-term. The site forms part of the Killingworth Open Break (UDP, 2002) but the current local plan review is considered an appropriate time to amend boundaries. The site has no other designations within the existing or emerging plan and is not within the Green Belt. Recent planning permission (14/00730/FUL) granted on land to east was granted for 125 dwellings – forms part of the Killingworth Moor Strategic Allocation for approximately 2,000 homes. The LPSD Concept Plan (Policy S4.4(b)) includes the site as part of a ‘Development Zone’ with a ‘Wildlife Corridor Principle Location’ to the south. Drawing a straight line between the southern boundary of that site and existing development at Killingworth Village, a logical extension is formed which comprises this site. The Concept Plan should be amended to include the site and the wildlife corridor extended to the south. This would still maintain a significant open break to whilst facilitating development. Expansion would also facilitate two additional access points; one to the north and one to the west (proposed alteration to the Concept Plan previously submitted as an LP representation).

Comments noted. The site is situated in the UDP designated Killingworth Open Break. This now proposed as designated Local Green Space (LGS) in the Local Plan Pre-Submission Draft (2015) – the site is considered unsuitable for residential development. The evidence for this preferred position is provided by the Local Green Space Designation report. Further context and thought with regard to strategic allocation at Killingworth Moor noted. This issue will be considered through the Local Plan examination process. At the current time it is not considered necessary for the boundary of the strategic allocation to be amended in the SHLAA. Comments noted – this issue will be considered through the Local Plan examination process, it is not the role of the SHLAA to allocate land for development.

5 The Coal Authority

Site assessment process

The Coal Authority is pleased that the SHLAA Report (October 2015) confirms that sites will be considered against relevant

Comments noted.


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constraints, including coal mining legacy. The Coal Authority would also expect criteria relating to mineral sterilisation to form part of the site selection process. The Coal Authority has provided GIS layers to the LPA comprising both the surface coal resource and the defined Development High Risk area. We would expect these to be utilised to inform the site assessment process on criteria relating to mineral sterilisation and unstable land respectively.

As acknowledged, constraints with regard to mining are fully taken into consideration through the site assessment process and will continue to take account of the latest evidence. Mineral Safeguarding Areas (MSA), identified through the Local Plan (Policy DM5.17 and Policies Map), have been introduced as a new constraint in the 2016 SHLAA.

6 Owen Pugh Site 095 – Grieves Row

We have reviewed the above draft and note that it indicates that the site at Grieves Row will deliver 90 units in the next 5 years. We can confirm that the site will be delivered for the full allocation of 90 units within the next 5 years and more likely within the next 2 years, as delivery of the site shall take place upon the company’s relocation to new headquarters premises which are required to accommodate the continued operational needs of the business and desired growth.

Confirmation of and support for the conclusion from 2016 SHLAA noted and positive approach to future development of the site is encouraged. This is confirmed through the Council’s identification of the site as a preferred allocation for residential development through the Local Plan Pre-Submission Draft (2015). Development expected through wider development with Site 422.

7 Owen Pugh Site 422 – Former Dudley Miners Welfare

Additionally, having reviewed the draft and note it indicates that the site at the former Miners Welfare will deliver 10 units in the next 5 years. We can confirm that this site will be delivered and developed at the same time and alongside the Grieves Row site and therefore will be delivered well within the next 5 years due to the company intended relocation. We also note that the draft now indicates that the site is ‘100% brownfield’ and ‘is available’ for development in the forecast delivery. We welcome these changes to reflect the size and status of the site.

As above, confirmation and support for conclusions noted. Development expected through wider development with Site 095.

8 Northumberland Estates

5-Year Housing Land Supply Position

We note Table B regarding housing delivery in the previous 5 years, with every year significantly underperforming. Considered that this is evidence of “persistent under delivery” and

Comments noted with regard to the shortfall in housing delivery against the requirement.


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recommends that the buffer is increased to 20%. As recommended in the report the situation can be monitored and revised on an annual basis, but as a starting point the 5% buffer is currently inappropriate based on the evidence.

It is acknowledged that, when compared to the requirement as set out in the Local Plan, there has been under-delivery over the last 5 years. However, it is important to consider this issue on a long-term cumulative basis and in light of the recent positive trend with regard to both house-building and the grant of new planning permissions for residential development. The Council considers that the use of a 5% buffer is most appropriate in the local circumstances and the most effective strategy of addressing housing land supply issues and delivering the housing requirement for the borough. An adopted Local Plan will then allow the allocated sites to come forward for development. The more positive recent context is reinforced through the 5-year housing land supply assessment; the 2014 SHLAA identified a deliverable supply from all potential sources of 3.04 years from all potential sources, rising to 3.40 years in 2015 and to 4.32 years in the 2016 SHLAA. However, clear and transparent evidence is provided through the 2016 SHLAA that discusses the implications of both a 5% and a 20% buffer and also the use of both Sedgefield and Liverpool methodologies in determining residual need. This sets out a range of potential scenarios and subsequent conclusions for the housing land supply position over


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the next five years and beyond.


Site 065a – Shiremoor West (Phase A)

Story Homes is the house builder for this site and has started construction on site.

Comment noted and reflected in site assessment.


Site 065b – Shiremoor West (Phase B)

Miller Homes is the house builder for this site and has started construction on site.



Site 065c – Shiremoor West (Phase C)

This site for approximately 50 houses has outline planning permission (13/00781/OUT). This site could come forward in the next 5 years as infrastructure will be in place to allow delivery and adjoining housing sites commenced on site in 2015. 30 houses could be delivered in 2018/19 and 20 houses in 2019/20.

Support for delivery and conclusions noted and reflected in site assessment.


Site 065d – Shiremoor West (Phase D)

This site for approximately 160 houses has outline planning permission (13/00781/OUT). Northumberland Estates considers that this site could come forward in years 6-10 as infrastructure will be in place to allow delivery and adjoining housing sites commenced on site in 2015. Housing delivery forecasts would be 30 houses in 2021-22, 30 houses in 2022-23, 30 houses in 2023-24, 30 houses in 2024-25 and 40 houses in 2025-26. The Northumberland Estates supports development of houses on this site, although Northumberland Estates is also currently reviewing part of this site for other mixed-uses including employment/retail.

Forecast of housing delivery amended from draft – now to start in 2021/22 rather than 2020/21. The consideration of alternative land uses for part of site acknowledged.


Site 065e – Shiremoor West (Phase E)

This site is proposed for the replacement Backworth Park Primary School.



Site 065f – Shiremoor West (Parcel F)

This site is the existing balancing pond. Comment noted and reflected in site assessment.


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Site 065g – Shiremoor West (Parcel G)

This site is now being promoted for housing development and could deliver around 50 houses in years 6-10. The ‘North East Sites’ plan colour for this site allocation should be yellow (years 6-10). The Northumberland Estates supports development of houses on this site.

The update with regard to the preferred future use of the site is acknowledged. Given that the landowner now confirms that the site is available for residential development, the assessment has been updated to show theoretical delivery in years 6-10. However, this land remains as one of the Council’s preferred employment land allocation through the Local Plan Pre-Submission Draft (2015).


Site 066 – Backworth Business Park and Cottages

Site owned by The Northumberland Estates. Holywell Engineering own land relating to the cottages (not included in this submission). Planning application 12/00637/FUL was refused on noise impact grounds only – currently at Appeal. A larger development proposal is currently being prepared and could deliver around 150 houses combined with improvements to open space/landscaping. The site could come forward in years 6-10 delivering 30 houses per year. The SHLAA identifies the wrong site boundaries.

Comments noted – appeal has now been determined and dismissed. In this context, it is considered there are obstacles to delivery, including due to the conflicting operations of existing businesses and ecological matters. This wider site is identified as a mixed-use allocation in the Local Plan Pre-Submission Draft (2015) with the indicative yield (65 dwellings) reflecting that an element of residential development could be appropriate, alongside existing and new industrial/employment uses. The boundary in the SHLAA (and Local Plan) echoes the fact that this site should be considered as a wider strategic site, rather than individual parcels of land. This will help a satisfactory resolution to be reached. Proposals for development will have to provide evidence of how impacts on surrounding businesses will be mitigated, providing an acceptable solution for


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both proposed land-uses. Development will only be considered acceptable on satisfactory resolution of issues of potential conflict. Dividing the site up into smaller parcels would dilute this principle/objective. Based on the yield identified and overall scale of the site it is considered that a satisfactory solution can be achieved. Accordingly, the site yield will remain at 65 dwellings, in line with the Local Plan, with delivery forecast for years 6-10.


Site 074 – Killingworth Moor (Strategic Site)

The Northumberland Estates supports this strategic site allocation for at least 2,000 homes.

Support for conclusion noted.


Site 076 – Murton (Strategic Site)

The Northumberland Estates supports this strategic site allocation for at least 3,000 homes.



Site 107 – Scaffold Hill Farm

This site is now owned by Taylor Wimpey and Bellway and construction has started on site.

The details of landownership have been updated accordingly in the site assessment. To reflect site progress, delivery for 2016/17 has been increased to 30 dwellings.


Site 110 – A19 Corridor 3

‘Backworth Park North’ site has outline planning permission (14/01687/OUT) for 290 houses. This site could come forward in the next 5 years – 20 houses delivered in 2017/18 then 30 houses per year for the next 9 years. Infrastructure will be in place up to the site in 2017 to allow delivery and adjoining housing sites commenced on site in 2015.

Support for conclusion noted and additional information regarding site infrastructure acknowledged.


Site 111 – A19 Corridor 4

This site is suitable, available and deliverable/developable. The Northumberland Estates again proposes to divide site 111 into two sites as noted below.

Request for amendment is noted; however the position and conclusion reached in the 2015 SHLAA remain relevant. It is considered that splitting this site into two separate parcels will not have any impact on


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the assessment of suitability. This area of land is considered unsuitable for residential development and therefore will remain undevelopable. This conclusion is due to the site being the location of a 'category 1 designation'. It is considered that any development would harm the fundamental character of the Backworth Medieval Village Scheduled Ancient Monument (SAM) and that it would not be possible to deliver a development that could appropriately mitigate these impacts.


New Site 111a – West Backworth (South)

The Northumberland Estates owns this approximate 9ha site and considers that approximately 210 houses could be delivered in years 6-10, with 30 houses per year delivered from 2021-22 for 7 years. Previously the site was discounted due to limited integration with existing housing/restricted access to services. It was also considered that West Backworth medieval settlement Scheduled Ancient Monument (SAM) rendered the site unsuitable. However, residential planning permissions 13/00781/OUT and 14/01687/OUT will deliver housing and infrastructure to the south and will promote appropriate integration of this site with new housing areas and allow direct access to local services at Northumberland Park, including a new roundabout for direct access (14/01687/OUT) will allow direct access to this site. The housing site area is outside of the SAM boundary, provides a natural extension to already approved strategic housing sites and is outside of the Green Belt.

Request for amendment is noted; however the position and conclusion reached in the 2015 SHLAA remain relevant. This site is not considered suitable for residential development, whether as a single site or divided into two parcels (see above).


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The ‘North East Sites’ plan should be yellow (6-10 years). The Northumberland Estates supports the development of housing on this site.


New Site 111b – West Backworth (North)

The Northumberland Estates owns this approximate 6.7ha site and considers that approximately 150 houses could be delivered in years 11-15, with 30 houses per year delivered from 2026-27 for 5 years. Previously the site was discounted due to limited integration with existing housing/restricted access to services. It was also considered that West Backworth medieval settlement Scheduled Ancient Monument (SAM) rendered the site unsuitable. However, residential planning permissions 13/00781/OUT and 14/01687/OUT will deliver housing and infrastructure to the south and will promote appropriate integration of this site with new housing areas and allow direct access to local services at Northumberland Park, including a new roundabout for direct access (14/01687/OUT) will allow direct access to this site. The housing site area is outside of the SAM boundary, provides a natural extension to already approved strategic housing sites and is outside of the Green Belt. The ‘North East Sites’ plan should be orange (11-15 years). The Northumberland Estates supports the development of housing on this site.

Request for amendment is noted; however the position and conclusion reached in the 2015 SHLAA remain relevant. This site is not considered suitable for residential development, whether as a single site or divided into two parcels (see above).


Site 112 – Fenwick’s Pit

Planning application (15/01307/FUL) now submitted for redevelopment into 18 houses (recommended for approval by Officers at the 12th July 2016 Planning Committee).

Comments noted and the site has now been granted planning permission following decision in July 2016. To reflect this, the estimate of site yield has amended


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The site is suitable, available and deliverable/developable. Although in the Green Belt, the site is brownfield (PDL). In terms of NPPF, the complete redevelopment of the site for residential dwellings is appropriate, subject to satisfying other relevant policies. This site can come forward in the next 5 years with all 18 houses being delivered in 2018-19. The ‘North East Sites’ plan should be amended to blue (next 5 years).

to 18 dwellings with delivery forecast for 2018/19.


Site 244 – Land south of Metro Line, Northumberland Park

The Northumberland Estates agrees with North Tyneside Council that this retail park is no longer available for housing.



Site 252 – East Farm, Backworth

This site has been completed. Update with regard to site noted – as at 31 March 2016, there remained one dwelling remaining to be completed. Completion of the site will be reflected when the schedule of ‘outstanding housing commitments’ is rolled-forward for 2017/18.


Site 288 – Dock Road Industrial Estate

The Northumberland Estates supports the development of this site for housing.



Site 352 – land at Backworth Metro, Northumberland Park

This site has planning permission for retail development and is not available for housing.

The assessment confirms that this site is not currently available due to the intention of the owner to implement the planning permission for retail development. However, in the context of the SHLAA is site is still considered to be theoretically developable until this alternative development is commenced and as a result the ‘developable in years 6 to 10’ conclusion is reiterated in the final SHLAA. However, the preferred


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use for retail development is supported by identification in the Local Plan Pre-Submission Draft (2015).


Site 358 – St. Edmund’s Building

This site has been completed. Site completion is reflected in 2016 SHLAA.


New Site – Pier Works and Car Park, Pier Road, Tynemouth

The Northumberland Estates owns this approximate 1.07ha site and considers that approximately 40 houses could be delivered in years 6-10, with 20 houses per year delivered from 2021-22 for 2 years. This is a new site where the opportunity for development has just recently been identified following changes in tenants etc. The ‘South East Sites’ plan should be yellow (6-10 years). The Northumberland Estates supports the development of housing on this site.

Submission of new site welcomed. This has been included in the final 2016 SHLAA and assessed in the context of the evidence provided.


Various sites Northumberland Estates also have interest in the following sites but have no further comments to make:

Site 67 – Foxhunters Industrial Estate;

Site 102a – Ice Rink, Football Ground and Surroundings (West);

Site 102b – Ice Rink, Football Ground and Surroundings (East);

Site 103 – Tynemouth Golf Course;

Site 104 – Mariners Lane, Tynemouth;

Site 105 – St. John’s Green, Percy Main;

Site 106 – Whitehouse Lane (Monks Wood), North Shields;

Site 443 – West Farm, Earsdon; and,

Site 542 – Holystone.

Interest in additional sites noted.


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33 George F White on behalf of Mr Oliver

333 - Land west of Camperdown Industrial Estate,

Greenfield site (8.14ha) of relatively level agricultural land and identified in the UDP as ‘safeguarded land’. The UDP is now, with specifically regard to the housing policies and the provision and delivery of new homes, out of date. In this context Site 333 could, subject to other relevant material considerations be brought forward for development. The NPPF is clear that local planning policies are out of date if: policies have been prepared pre-2004 and are not in accordance with the Planning and Compulsory Purchase Act 2004 (paragraph 214); and if an LPA cannot demonstrate a five year housing land supply (paragraph 49). Both of these points are applicable in North Tyneside. Where no up-to-date Local Plan is in place and there is any doubt over whether housing numbers have been adequately provided for (NPPF para.47/49) then the presumption in favour of sustainable development will take precedent (para.17). This is a strong material consideration (para.187) which should be taken into account when determining planning applications. North Tyneside cannot identify a five year supply of deliverable housing land for the period 2015/16 to 2019/20, the current document demonstrates that the maximum supply would equate to 3.4 years, realistically this is likely to be considerable less as the deliverable supply total includes a number of sites which do not benefit from a current planning permission so actual supply amounts to only 2.4 years. The SHLAA identifies Site 333 as suitable, available and

Support for SHLAA conclusion noted and the Council considers that the site is ‘developable in years 6 to 10’ on mitigating the identified issues and overcoming constraints. It is acknowledged that the housing policies in the UDP are now out of date. The appropriateness of a specific proposal will be judged through the development management process with any planning application determined on merit. It is acknowledged that the Council cannot identify a 5-year supply of housing land – the conclusion of the 2016 SHLAA is that a 4.32 year supply is deliverable from all potential sources. Additional context with regard to delivery of site and


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developable in years 6-10 for approximately 183 dwellings. The Site is under Option with a willing developer seeking to bring the site forward. There are a number of constraints which are currently being investigated including access and highways, ecology, archaeology and noise. It is anticipated that an application will be forthcoming in the short term, which subject to approval, could see the delivery of much needed residential development potentially comprising 2, 3, and 4 bedroomed dwellings from 2019. The SHLAA Assessment is supported.

support for the site assessment in the SHLAA is noted.


334 - Land east of Killingworth Way

Description - ‘land to the east of Killingworth Way’ – is incorrect, the site lies to the north of Killingworth Way, north of Edge Mount – consider amending. Site currently assesses as not suitable. Little information is provided on the assessment and it is assumed that unsuitability is due to the site being within designated Green Belt rather than any other known site constraints which would prevent development. The site lies within a sustainable location. It is available in that there is a willing landowner. The site is known, subject to material considerations to be an attractive site to the development industry, the site would, subject to deletion from the Green Belt be developable and achievable, it is anticipated that development of the Site could be forthcoming in the medium to long term. The Site assessment should be reviewed in a policy neutral context identifying the potential of the site subject to a robust and justified review of the Green Belt.

Suggestion noted – it is acknowledged that current description is misleading and the site name has been updated to ‘Land to the north of Killingworth Way’. In line with the SHLAA methodology, sites within the Green Belt are assessed as unsuitable for residential development, being subject to a ‘category 1’ designation. However, the monitoring process will be crucial in assessing both overall delivery and that of additional windfall. The Local Plan I&M Framework sets out contingencies needed in the result of a failure to deliver against the OAN. This will enable a flexible, proactive approach to the release of land for development to meet identified need. Further detail with regard to suitability and use of site is acknowledged but it is the Council’s continued position that Green Belt sites are considered unsuitable for residential development through the SHLAA and the site assessment will continue to conclude that it is undevelopable.


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Site 075w – Land west of Hillheads Poultry Farm

Site 075(w) is identified as a suitable, available, developable and achievable site. The site is the subject of a planning application for 30 dwellings (amended to 28) a decision is anticipated in August 2016. The assessment of this site is supported and subject to planning consent the Site is expected to commence delivery of new housing units in 2017 completing in 2018. Please note that the Site is not identified on the Draft North West Map, Site 075(W) should be identified (Green) until such time as development is complete.

Support for deliverability conclusion noted. The forecast yield from the site has been changed to 28 dwellings, reflecting the latest proposals and the planning application awaiting determination. The error with regard to the draft North West Sites Map is acknowledged – this has been amended to reflect the site assessment and outlined as ‘blue’ in-line with being deliverable in the next 5 years.



The Council proposes to use the Sedgefield method of calculation for the five year housing land supply. This is in accordance with PPG and is welcomed. The Council propose that a 5% buffer reflecting NPPF para.47 is added to the housing requirement. However, in light of the NPPF (para.47) and NPPG (para.035), it is clear from the Council’s data at Table B that net housing delivery has failed to meet the net housing requirement in every year of the past five years, a longer term view and reasonable period of time. The Council has persistently year on year since 2011 not met the housing requirement. The degree of under delivery is also significant; it ranges from under delivery against the housing requirement of between 35% and 54%. From this data it is clear that there is a significant and persistent under delivery of housing and the failure to meet the net housing requirement is not temporary or a minor trend. The data demonstrates that looking forward there is not a five year housing land supply and as such it is

Support for use of Sedgefield methodology noted. Comments noted with regard to the shortfall in housing delivery against the requirement. It is acknowledged that, when compared to the requirement as set out in the Local Plan, there has been under-delivery over the last 5 years. However, it is important to consider this issue on a long-term cumulative basis and in light of the recent positive trend with regard to both house-building and the grant of new planning permissions for residential development. The Council considers that the use of a 5% buffer is most appropriate in the local circumstances and the most effective strategy of addressing housing land


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unlikely that the backlog will be met in the next five years. In this regard the Council should be applying a 20% buffer to the housing requirement. It is noted in the conclusion that North Tyneside cannot identify a five year supply of deliverable housing land (2016/17 to 2020/21). The supply is identified as 4.25 years (using a 5% buffer) this includes all of the potential sources of supply outlined as coming forward in the next five years. As set out above the application of a 5% buffer is challenged and the methodology should apply a 20% buffer to reflect persistent under delivery. It is also unrealistic to include all of the potential sources of supply coming forward in full, an element of discounting must be applied in the methodology to account for a percentage of sites which will not come forward from the identified supply. This is a commonly accepted practice which ranges from between 5% and 10% discount being applied to the delivery of identified supply based on historical data.

supply issues and delivering the housing requirement for the borough. An adopted Local Plan will then allow the allocated sites to come forward for development. The more positive recent context is reinforced through the 5-year housing land supply assessment; the 2014 SHLAA identified a deliverable supply from all potential sources of 3.04 years from all potential sources, rising to 3.40 years in 2015 and to 4.32 years in the 2016 SHLAA. Comments noted with regard to need for a discount rate. This issue has been considered through the final 2016 SHLAA, with further evidence being collated and analysed. This work has been undertaken to determine how significant this matter is in North Tyneside and whether there is need to incorporate this into the forecast of future delivery. A number of scenarios are outlined and further detail is available in the final 2016 SHLAA Report and supporting Appendix 1. However, clear and transparent evidence is provided through the 2016 SHLAA that discusses the implications of both a 5% and a 20% buffer and also the use of both Sedgefield and Liverpool methodologies in determining residual need. This sets out a range of potential scenarios and subsequent conclusions for the housing land supply position over the next five years and beyond.

37 George F White Requirement to It is evident that North Tyneside does not have a 5-year supply The Local Plan identifies the housing requirement for


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on behalf of Mr Oliver

identify additional sites

of deliverable housing land and there is significant uncertainty surrounding the proposed sites in the emerging Local Plan specifically the reliance on large scale strategic sites at Murton and Killingworth Moor which have a number of constraints. In order to provide a full, justified and robust assessment of housing as an evidence base for the emerging local plan, the Council will need to review the extent of the Green Belt and consider the necessity for Green Belt deletions to identify sites with the potential to come forward within the Plan Period or to provide land for future housing delivery as safeguarded sites beyond the plan period. The methodology for the calculation of the 5 year housing land supply should be amended to include a 20% buffer and an element of discounting.

the plan period and a range of suggested allocations to meet this need. The preferred allocations are considered the most sustainable and appropriate locations to accommodate the levels of growth and are deliverable and/or developable over the plan period to ensure a rolling and continuous supply of housing land. This includes the strategic allocations at Killingworth Moor and Murton, which are considered deliverable and developable within the plan period, with robust evidence available from the key landowners, developers, agents and other interested parties. A Green Belt Review has been undertaken to support the Local Plan and this concludes that there are currently no exceptional circumstances evident, as required by NPPF, to support any change to the current Green Belt boundaries. The boundaries identified are considered to be permanent and able to endure beyond the plan period. Principally, there remains sufficient suitable, sustainable and deliverable land outwith the Green Belt to meet the identified need for new homes. It is the Council’s continued position that Green Belt sites are considered unsuitable for residential development through the SHLAA (as a ‘category 1’ designation) and the site assessment will continue to conclude that it is undevelopable.

38 Viridis Commercial on

Site 116 – Bird Street

The site remains suitable for high density residential development. The site is cleared and ready for development to

Comments with regard to delivery, yield and future proposals are noted. The Council agrees that the site is


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behalf of P North Developments Ltd

commence and has the benefit of a current outline approval (12/01185/OUT) for a 70 bed residential care facility and 32 ancillary residential units. The site is currently assessed in the SHLAA for 32 units however recent discussions have taken place with North Tyneside Council which anticipated the site could comfortably yield 35 units whilst meeting Local Planning Authority requirements for design and access, parking and sustainability. There is no possibility of the site returning to employment use. It is considered, subject to the reconfiguration of layout/units that the site could accommodate up to 40 residential dwellings. The site should, as an absolute minimum, be considered as capable of providing 35 units.

suitable and available for development and this is supported by the conclusion of deliverability in the SHLAA. The additional context with regard to site delivery is noted; however, whilst it is acknowledged that the site may be suitable for a slightly higher yield, to reflect the latest permitted scheme, it has been maintained at 32 units. This position maintains the necessary consistency across the evidence base, particularly the total dwellings with an outstanding planning permission at 31 March 2016. This figure will be updated if/when a new planning permission comes forward but the site context will be updated to reflect a potential new scheme.

39 Viridis Commercial on behalf of P North Developments Ltd

Site 411 – Coleman NE

The site is suitable for high density residential development over a number of storeys. The site has been cleared since the last consultation period and is capable of development. There is no possibility of the site returning to employment use or any alternative use other than residential Terms have been agreed with the Local Authority for release of a restrictive covenant restricting the use of the site. A full planning application proposing the development of 27 units on the site has been submitted (15/01172/FUL) and is currently subject to appeal (16/00005/S78TPA). As part of wider discussions with the planning case officer, the LPA provided a clear statement that the site was capable of providing in excess of 14 units for which it is currently allocated on the SHLAA, this statement made by

Comments with regard to delivery, yield and future proposals are noted. The Council agrees that the site is suitable for development over the plan period and this is supported by the conclusion of deliverability in the SHLAA. The additional context with regard to site delivery is noted; however, as the current application is subject to appeal following refusal, it is considered that there is uncertainty regarding deliverability in the immediate term. Therefore, until the outcome of this appeal is known, the site will continue to be identified as ‘developable in years 6 to 10’ and the map and site schedule will reflect this status.


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the LPA should be reviewed as part of the consultation process. The site is identified on the South East Area Action Plan map as being deliverable within the next five years, however, the wording on the schedule states that development is anticipated in years 6-10. This is clearly an error and given that the site is cleared and available for development this should therefore be amended to reflect that the site is deliverable within 0-5 years.

40 Viridis Commercial on behalf of P North Developments


As set out within the SHLAA North Tyneside cannot identify a five year supply of deliverable housing land for the period 2016/17 to 2020/21, therefore sites 116 and 411 should be given thorough consideration for review of the unit numbers and the proposed uplifted numbers applied to the sites.

It is acknowledged that the Council cannot identify a 5-year supply of housing land – the conclusion of the 2016 SHLAA is that a 4.32 year supply is deliverable from all potential sources. However, as outlined above, the 2016 SHLAA will continue reflect the site-specific conclusions previously set out until more substantive evidence is available.

41 White Young Green on behalf of Landowners

Site 059 – Swales Industrial Estate

Swales Industrial Estate occupies approximately 2.5ha – mix of uses, predominantly B2 with an additional B8. The site is in a highly sustainable location with Howdon metro station adjoining the site to the north, the national cycle network, good local bus and a good level of facilities and services in the immediate vicinity. Area is predominantly residential in nature, with this being reinforced by the large Bellway residential development built over recent years to the west of Howdon Lane. Whilst the updated employment land demand/supply position is awaited within the Submission Draft Local Plan, it is significant to note that the ELR was updated in October 2015. This continues to confirm that the Swales Industrial Estate could ‘potentially be developed for uses other than employment’. Indeed, the fact that the updated SHLAA retains the site as deliverable in years 6

Comments with regard to the site and surroundings are noted. The Council assesses the site as ‘developable in years 6 to 10’ through the SHLAA. There is agreement with landowner that the site could be theoretically suitable for residential use but it is considered that there is need for site clearance/preparation before development could commence. However, following


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to 10 for housing confirms both the site owner’s and the Council’s position that the site is suitable for housing. Where the site owner and the Council disagree is, first, the site’s deliverability within years 6 to 10 and, secondly, notwithstanding recognition and acknowledgement of the site’s suitability for housing, with a suggested quantum of 58 dwellings, the Council are puzzlingly seeking to retain the original employment allocation across the site. Multiple ownership/tenants continue to be raised by the Council as a potential obstruction to the deliverability of the site for housing in the short term. However, the land owner has previously emphasised that those tenants remaining on the site are all on short term leases and, as a consequence, the site could be made immediately available for development. Indeed, the landowners have a Joint Venture Agreement in place to demonstrate their stance on the reallocation of the site for residential development. Further comments – in terms of the provision of para.47 of the NPPF, it is considered that the site is deliverable. Residential development on the site would represent the efficient reuse of brownfield land within the urban area, in accordance with one of the core principles of NPPF (para.17). SHLAA Site 037 (Howdon Tip) has been identified in the SHLAA as a potential housing site. However, development on this site is dependent on access through Swales Industrial Estate. As such, whilst the latter is capable of a standalone residential development, its development could also unlock to residential

further consideration it is identified as a preferred location for employment development through the Local Plan Pre-Submission Draft (2015), a position confirmed through the Council’s Proposed Minor Modifications (June 2016). Further context with regard to the site acknowledged, including ownership/lease details. Comments noted – the redevelopment of brownfield land is prioritised through the Local Plan, however, notwithstanding the SHLAA conclusion, the Council considers that the most appropriate allocation for future land use is that of employment development. Comments noted – Site 037 has not been identified as a preferred allocation for residential development through the Local Plan process.


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potential of this adjoining site.

42 White Young Green on behalf of Landowners

5 Year Housing Land Supply Position

Whilst the land owner is in agreement that the approach to identifying a 5 year housing land supply within North Tyneside is correct, particularly the use of the ‘Sedgefield method’ to meet previous under delivery, the land owner disputes the Council’s preference for a 5% and not a 20% buffer to reflect this under delivery. It is acknowledged that the Council had a record of delivering its housing delivery requirement up to 2008 (as set by the former RSS). However, since 2008 it is considered that the Council has missed its housing target for 8 of the last 10 years. In this regard, HBF identify an under delivery of 1,970 dwellings against the currently proposed Plan requirement (828 dpa) which is considered to comprise ‘a persistent under delivery’ and therefore should trigger the application of a 20% rather than a 5% buffer. Whilst the application of a 5% buffer still results in a shortfall in terms of a 5 year housing land supply, the use of 20% buffer naturally exacerbates this shortfall further. In light of this, it is even more important that the Council can seek to address this shortfall immediately which emphasises the role of Swales Industrial Estate in contributing to this shortfall.

Comments noted and support for Sedgefield methodology noted. It is acknowledged that, when compared to the requirement as set out in the Local Plan, there has been under-delivery over the last 5 years. However, it is important to consider this issue on a long-term cumulative basis and in light of the recent positive trend with regard to both house-building and the grant of new planning permissions for residential development. The Council considers that the use of a 5% buffer is most appropriate in the local circumstances and the most effective strategy of addressing housing land supply issues and delivering the housing requirement for the borough. An adopted Local Plan will then allow the allocated sites to come forward for development. The more positive recent context is reinforced through the 5-year housing land supply assessment; the 2014 SHLAA identified a deliverable supply from all potential sources of 3.04 years from all potential sources, rising to 3.40 years in 2015 and to 4.32 years in the 2016 SHLAA. However, clear and transparent evidence is provided through the 2016 SHLAA that discusses the implications of both a 5% and a 20% buffer and also


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the use of both Sedgefield and Liverpool methodologies in determining residual need. This sets out a range of potential scenarios and subsequent conclusions for the housing land supply position over the next five years and beyond.

43 Persimmon Homes

Site 071 – Station Road West

This can be brought forward to commencing and delivering units in years 1-5, it is our intention to submit a planning application in the next 6 months.

Update with regard to site programme noted and delivery forecast amended. First completions now outlined for 2019/20.

44 Persimmon Homes

Site 072 – Station Road East

Development has commenced on this site, so start mid 2016 rather than late 2016.

Update with regard to site programme noted and delivery forecast amended. Construction has now commenced, with first completions now outlined for 2016/17.

45 Persimmon Homes

Site 073b – East Benton Farm South

This is owned by Persimmon Homes and will come forward as part of a comprehensive development with East Benton Farm North, completed with access rights. Therefore, the comment in relation to access should be removed as there are no impediments to residential development.

Further context with regard to landownership and access issues acknowledged. The SHLAA continues to conclude that this site is developable in the longer-term and is likely to follow development in the wider Station /East Benton Farm area.

46 Persimmon Homes

Site 076 – Murton (strategic site)

This seems sensible to merge all of the previous SHLAA sites into one. The information appears accurate and is based on the feedback from the Consortium in relation to phasing.

Support for consideration of the Murton site as one strategic entity supported and the conclusions with regard to delivery and phasing are noted.

47 Persimmon Homes

Site 087 – Rosehill Road

This should be moved into years 1-5 for development as a planning application is in preparation.

Update with regard to site programme noted and delivery forecast amended. First completions now outlined for 2020/21.

48 Persimmon Homes

Various sites Persimmon Homes also have interest in the following sites but have no further comments to make:

073a – East Benton Farm North;

086 – Greenhouse Farm, Dudley;

088 – Dairy Farm, Dudley.

Interest in additional sites noted.

49 Barratt David Site 417 – Means Development of the site would perform the logical extension to Comments with regard to site suitability, context of


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Wilson Homes Drive, Burradon the Burradon urban area. The site’s Green Belt designation performs poorly against NPPF paragraph 80:

Criteria 1) The site is surrounded by development on all 4 sides. Phased delivery of a comprehensive sustainable scheme will meet the needs of the locality’s existing and future residents for the emerging plan period and beyond.

Criteria 2) Development of the scheme would not lead to or encourage the future agglomeration of any two neighbouring settlements, namely Burradon with Dudley and Annitsford.

Criteria 3) Development of the site would not represent encroachment into open countryside nor would it encourage any future ‘ribbon development’.

Criteria 4) Development of the site will not harm the setting or character of any settlement. Indeed the development of high quality new homes will improve the overall housing offer in Burradon in Camperdown.

Criteria 5) Development of the site would have substantial economic and social benefits for the local area. BDW does not consider that the scale or distribution of development proposed by the emerging Local Plan supports the Council’s regeneration of Burradon/ Camperdown as a ‘priority investment area’.

In the context of Policy S1.1, the emerging Local Plan identifies only one residential development over the plan period in Burradon and Camperdown combined (Camperdown Social Club, 9 dwellings are already completed). Given the priority for the regeneration of villages in the North West failure to identify

NPPF Green Belt criteria and wider Local Plan strategy for distribution of development are noted. In line with the SHLAA methodology, sites within the Green Belt are assessed as unsuitable for residential development, being subject to a ‘category 1’ designation. However, the monitoring process will be crucial in assessing both overall delivery and that of additional windfall. The Local Plan I&M Framework sets out contingencies needed in the result of a failure to deliver against the OAN. This will enable a flexible, proactive approach to the release of land for development to meet identified need. A Green Belt Review has been undertaken to support the Local Plan and this concludes that there are currently no exceptional circumstances evident, as required by NPPF, to support any change to the current Green Belt boundaries. The boundaries identified are considered to be permanent and able to endure beyond the plan period. Principally, there remains sufficient suitable, sustainable and deliverable land outwith the Green Belt to meet the identified need for new homes and, therefore, there is no need to consider this land for development and the Local Plan confirms that this land will remain designated Green Belt over the plan period. Further detail with regard to suitability and use of site is acknowledged but it is the Council’s continued position that Green


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any new land for residential development within the plan period is considered unsound against the Local Plan’s own objectives and the NPPF. At the very least, NTC should seek make provision for the long term sustainable expansion of the settlement. The SHLAA should provide a variety of suitable sites to allow the emerging local plan to be flexible, ensuring choice within the plan period.

Belt sites are considered unsuitable for residential development through the SHLAA and the site assessment will continue to conclude that it is undevelopable. Comments with regard to allocation noted, however the SHLAA does not allocate sites for development, it simply provides evidence for the next stage of site-selection, undertaken through the Local Plan process.

50 Barratt David Wilson Homes


The LPA cannot demonstrate a five year housing land supply, having significantly under delivered over the past five years, creating a large minimum target going forward, which is unlikely to be met. The five year housing land supply is based on a 5% buffer in line with the NPPF para.47, however due to the significant under delivery we would suggest that this should be amended to a 20% buffer (NPPF/NPPG guidance). Further, the assessment has included all of the available and identified sites (identified to come forward in years 1 – 5) for delivery within the next five years but the assessment has not included for any discounting, which is normally 5% - 10% as some of the sites will not come forward or be delivered at the proposed rates. The LPA cannot demonstrate a five year housing land supply with a 5% buffer, however once discounting and a 20% buffer are applied this will further impact on the amount of dwellings required within the next five years.

Comments noted and support for Sedgefield methodology noted. It is acknowledged that, when compared to the requirement as set out in the Local Plan, there has been under-delivery over the last 5 years. However, it is important to consider this issue on a long-term cumulative basis and in light of the recent positive trend with regard to both house-building and the grant of new planning permissions for residential development. The Council considers that the use of a 5% buffer is most appropriate in the local circumstances and the most effective strategy of addressing housing land supply issues and delivering the housing requirement for the borough. An adopted Local Plan will then allow the allocated sites to come forward for development. The more positive recent context is reinforced through the 5-year housing land supply assessment; the 2014


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SHLAA identified a deliverable supply from all potential sources of 3.04 years from all potential sources, rising to 3.40 years in 2015 and to 4.32 years in the 2016 SHLAA. Comments noted with regard to need for a discount rate. This issue has been considered through the final 2016 SHLAA, with further evidence being collated and analysed. This work has been undertaken to determine how significant this matter is in North Tyneside and whether there is need to incorporate this into the forecast of future delivery. A number of scenarios are outlined and further detail is available in the final 2016 SHLAA Report and supporting Appendix 1. However, clear and transparent evidence is provided through the 2016 SHLAA that discusses the implications of both a 5% and a 20% buffer and also the use of both Sedgefield and Liverpool methodologies in determining residual need. This sets out a range of potential scenarios and subsequent conclusions for the housing land supply position over the next five years and beyond.

51 Barratt David Wilson Homes

Requirement to identify additional sites

As a result further sites are required to come forward. To achieve a five year housing supply further deliverable sites need to be identified. Due to the limited amount of land available in North Tyneside a Green Belt review, which should form part of the emerging Local Plan process, should be carried out to bring forward suitable sites for development by identifying sites which

A Green Belt Review has been undertaken to support the Local Plan and this concludes that there are currently no exceptional circumstances evident, as required by NPPF, to support any change to the current Green Belt boundaries.


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could form part of a strategic Green Belt release. Other LPA’s in surrounding Local Authorities have carried out this assessment and this process is suggested to be adopted by the LPA as part of their emerging Local Plan. Further, the LPA have a substantial reliance on the two strategic sites at Murton and Killingworth. If the strategic sites do not deliver at the proposed growth rates there will be a need for other sites with the potential to deliver in the medium and longer term of the emerging plan period to come forward. Given the shortfall in residential sites, and the large target for delivery over the next five years, sites which can deliver within the short term should be brought forward for residential development to help meet the five year housing land supply and prevent further significant under-delivery. Our proposal at Means Drive provides an opportunity to implement a logical extension and comprehensively planned development that could contribute significantly toward the regeneration of a key priority investment area and help towards providing a five year housing land supply.

The Local Plan identifies the housing requirement for the plan period and a range of suggested allocations to meet this need. The preferred allocations are considered the most sustainable and appropriate locations to accommodate the levels of growth and are deliverable and/or developable over the plan period to ensure a rolling and continuous supply of housing land. This includes the strategic allocations at Killingworth Moor and Murton, which are considered deliverable and developable within the plan period, with robust evidence available from the key landowners, developers, agents and other interested parties. Further context with regard to availability and achievability of site is acknowledged but, at this time, it is the Council’s continued position that Green Belt sites are considered unsuitable for residential development through the SHLAA and the site assessment will continue to conclude that it is undevelopable.

52 Checkley Planning on behalf of Keenan’s

Site 066 – Backworth Business Park & Cottages

Site 66 is shown again in the updated Draft SHLAA as a housing site for 65 units, developable in years 6-10, and listed as a Local Plan mixed use allocation). I simply wish to confirm on behalf of my client, Keenan Processing Ltd of Backworth Business Park, that we object to the inclusion of the site as one that is suitable for housing when it

Comments noted – the appeal has now been determined and dismissed. In this context, it is considered there are obstacles to delivery, including due to the conflicting operations of existing businesses and ecological matters. This wider site is identified as a mixed-use allocation in


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lies next to existing noisy industry. The full reasons are set out in our previous representations to earlier versions of the SHLAA and Local Plan. Housing application (12/00637/FUL) is subject to an appeal against refusal of permission by the Council and a decision is expected shortly. If the appeal is dismissed, we would expect the site to be removed from future updates of the SHLAA and proposals for any housing on the site in the Local Plan to be deleted.

the Local Plan Pre-Submission Draft (2015) with the indicative yield (65 dwellings) reflecting that an element of residential development could be appropriate, alongside existing and new industrial/employment uses. The boundary in the SHLAA (and Local Plan) echoes the fact that this site should be considered as a wider strategic site, rather than individual parcels of land. This will help a satisfactory resolution to be reached. Proposals for development will have to provide evidence of how impacts on surrounding businesses will be mitigated, providing an acceptable solution for both proposed land-uses. Development will only be considered acceptable on satisfactory resolution of issues of potential conflict. Based on the yield identified and overall scale of the site it is considered that a satisfactory solution can be achieved. Accordingly, the site yield will remain at 65 dwellings, in line with the Local Plan, with delivery forecast for years 6-10.

53 Home Builders Federation

Draft Site Assessment Schedule

It is important that in determining the delivery of sites realistic lead-in times and build out rates should be applied. These will need to take account of factors such as ownership, developer interest, planning status (inclusive of pre-commencement conditions and Section 106), site preparation, number of outlets and the strength of the local market.

Comments noted. The assessment of deliverability in the SHLAA is undertaken on a site-specific basis for all sites of 5 dwellings and above across the borough. The lead-in times, delivery rates and timescales are fully informed by developers, landowners, agents and other key


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The Council will be aware that lead-in times and build out rates can vary considerably between sites. The HBF therefore recommend that wherever possible these should be directly informed by discussions with the land owner, site promoter or ideally the developer. The HBF is therefore supportive of the current consultation and our members will assist wherever possible. It is also pleasing to note that the trajectory for some sites is based upon previous discussions. Where generic assumptions are used it is important that they are not artificially raised in an attempt to identify a greater supply.

stakeholders responsible for the delivery of development and therefore comply with the advice as set out by the HBF. It is considered that the conclusions of the SHLAA reflect realistic and appropriate programmes for site development.

54 Home Builders Federation

5-Year Housing Land Supply Summary

The HBF is largely supportive of the methodology employed in determining whether a five year housing land supply exists within North Tyneside. In particular we support the use of the ‘Sedgefield Method’ to meet previous under-delivery and the addition of this under-delivery prior to the buffer, as advised by the Planning Advisory Service. The only area of contention is the application of a 5% or 20% buffer. It is noted that the Council’s preference is a 5% buffer. Whilst the HBF recognise the Council regularly delivered its housing requirement, as set by the former Regional Spatial Strategy, prior to 2008 it has not provided sufficient delivery since this time. The following table identifies that the Council has missed its target for 8 of the last 10 years. This has led to an under-delivery of 1,970 dwellings against the currently proposed plan requirement (828dpa). The HBF consider this to be persistent under-delivery and therefore recommend that a 20%

Support for methodology noted. Comments noted with regard to the shortfall in housing delivery against the requirement. It is acknowledged that, when compared to the requirement as set out in the Local Plan, there has been under-delivery over the last 5 years. However, it is important to consider this issue on a long-term cumulative basis and in light of the recent positive trend with regard to both house-building and the grant of new planning permissions for residential development. Delivery over the previous two years has been accelerated as additional sites have been brought forward for consideration and approved. Added to this, the delivery that will be achieved following adoption of the Local Plan will enable this acceleration to continue and ensure further house-building to meet the new


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buffer is applied. Whichever buffer is applied the conclusions are clear that the Council cannot currently demonstrate a five year housing land supply. To ensure that this situation does not continue indefinitely the HBF recommend the Council engage with our members in order to identify if and how existing sites could be accelerated through the process as well as the identification of additional sites which could delivery early in the plan period. It is important that the Council undertake this work as soon as possible to ensure that the plan is found sound at examination and that the policies relating to housing are not immediately out of date upon adoption.

higher targets identified. The shortfall in housing delivery over recent years has to be considered in light of a significantly increased requirement: from 400dpa under RSS (relevant up to 2011) to 828dpa based upon latest evidence. This increase in requirements took place over a period when wider economic recession led to a slowdown in housing delivery generally, previous allocations within the UDP (2002) have been exhausted and preparation of a revised Core Strategy/Local Plan to release appropriate new housing land allocations has been underway. In this land availability and market context, housing land supply has not met relevant targets. However, when taking overall delivery into account from 2004/05 it is worth noting that overall cumulative delivery did not fall below target until 2013. The Council considers that the use of a 5% buffer is most appropriate in the local circumstances and the most effective strategy of addressing housing land supply issues and delivering the housing requirement for the borough. An adopted Local Plan will then allow the allocated sites to come forward for development. The more positive recent context is reinforced through the 5-year housing land supply assessment; the 2014 SHLAA identified a deliverable supply from all potential sources of 3.04 years from all potential sources, rising to 3.40 years in 2015 and to 4.32 years in the 2016


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SHLAA. However, clear and transparent evidence is provided through the 2016 SHLAA that discusses the implications of both a 5% and a 20% buffer and also the use of both Sedgefield and Liverpool methodologies in determining residual need. This sets out a range of potential scenarios and subsequent conclusions for the housing land supply position over the next five years and beyond. The monitoring process will be crucial in assessing both overall delivery and that of additional windfall. The Local Plan I&M Framework sets out contingencies needed in the result of a failure to deliver against the OAN. This will enable a flexible, proactive approach to the release of land for development to meet identified need.

55 Sport England Numerous sites We are disappointed to note that the assessment contains a number of playing fields, including: Site refs 27, 28, 35, 36,102a, 413, and 551.

Comments noted. The role of the SHLAA is to make a theoretical assessment as to whether a site is deliverable or developable for housing development in the future. Whilst a number of sites that provide existing playing fields are identified as developable in the longer term, the SHLAA conclusion does not represent planning policy or mean that an application for development would be considered favourably. The Council will continue to work with Sport England, as a key stakeholder, to ensure that development is


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appropriate and that any proposal for loss of existing facilities would be mitigated by provision of new examples to an equivalent or higher standard. In order to consider such a proposal as acceptable, substantive evidence would be required from applicants and agreement reached with Sport England.

56 Sport England Site 551 – Land to the north of Backworth Hall

Whilst a number of the sites are recognised as being playing field, with the need to work with Sport England to satisfy playing field policy before development might be acceptable, no such recognition is made in respect of site ref 551 (land north of Backworth Hall, Backworth). Sport England would request that this omission be rectified.

Comment noted. The omission with regard to Site 551 has been rectified in the final 2016 SHLAA.

57 White Young Green on behalf of Taylor Wimpey

Site 105 – Land north of Beaumont Drive

The site is located within the Green Belt and sits to the north of existing residential development and is set within clearly defined field boundaries. It is not considered that the development of the site would compromise the safeguarding of the countryside from encroachment and significant distances could be maintained between settlements. We do not therefore consider that development of the site would in any way compromise the purposes of the Green Belt as set down in the NPPF. The site is considered to be in a highly sustainable location due to its proximity to a wide variety of services and facilities – including transport, schools, health, retail and leisure. It is considered that there are no significant constraints to the development of the site. Any constraints that do exist could be dealt with through appropriate mitigation measures.

Comments noted with regard to site suitability and context of NPPF Green Belt criteria. In line with the SHLAA methodology, sites within the Green Belt are assessed as unsuitable for residential development, being subject to a ‘category 1’ designation. However, the monitoring process will be crucial in assessing both overall delivery and that of additional windfall. The Local Plan I&M Framework sets out contingencies needed in the result of a failure to deliver against the OAN. This will enable a flexible, proactive approach to the release of land for development to meet identified need. A Green Belt Review has been undertaken to support the Local Plan and this concludes that there are currently no exceptional circumstances evident, as


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required by NPPF, to support any change to the current Green Belt boundaries. The boundaries identified are considered to be permanent and able to endure beyond the plan period. Principally, there remains sufficient suitable, sustainable and deliverable land outwith the Green Belt to meet the identified need for new homes and, therefore, there is no need to consider this land for development and the Local Plan confirms that this land will remain designated Green Belt over the plan period. Further detail with regard to suitability and use of site is acknowledged by it is the Council’s continued position that Green Belt sites are considered unsuitable for residential development through the SHLAA and the site assessment will continue to conclude that it is undevelopable.

58 Northumbrian Water Limited

All SHLAA sites Site-specific comments provided on all sites. Comments noted – these are used to inform the site-specific assessment, providing vital information on infrastructure capacity.

59 Historic England SHLAA 2016 The information collected as part of the SHLAA database is very comprehensive, and includes recording the presence of designated heritage assets as a potential constraint. There does not appear to be any appraisal of the likely impact of proposed development upon their significance, or the potential for mitigation, although the SHLAA indicates that this more detailed analysis would take place at a later stage. However, it is unclear how the presence of undesignated

Comments noted – the SHLAA does not allocate sites for development, it simply provides evidence for the next stage of site-selection. The Local Plan allocations process has included extensive consideration of heritage impacts in selecting the most appropriate sites for future development. The impact on heritage assets, and any mitigation


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heritage assets, or the impact of development upon the setting of a heritage asset, would be recorded. Para.5.24 of the SHLAA Report refers to the range of additional issues which may be considered during a site visit, so it is quite possible that these aspects would be properly covered in the assessment, but it might be helpful to state this explicitly. The NPPF is very clear that heritage assets are an “irreplaceable resource and should be conserved in a manner appropriate to their significance” (para.126). It goes on to state that “as heritage assets are irreplaceable, any harm or loss should require clear and convincing justification” (para.132). In pursuing a housing site, the local planning authority should therefore ensure that it has sufficient information and evidence to demonstrate that the public benefits would outweigh any harm or loss to the significance of heritage assets, including any contribution made by their setting, and that the benefit cannot be met by any other means in any other location.

measures required to address these, will be fully considered through the development management and wider Local Plan process, meeting the requirements of NPPF.

north tyneside strategic housing land … · on behalf of sjs potts ltd 5-year housing land supply...

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