UPSVLP 0410
The UPSVLP seeks to pursue the minimum housing requirement derived from the Standard Method but pays little regard to the need to boost the supply of housing, tackling the affordability issues, aligning the housing requirement with the Plan?s economic aspirations or seeking to boost the supply of affordable housing to meet existing needs.
To align the proposed economic growth with the housing requirement would derive a housing requirement of at least 1,015 dpa and it is considered that this would address realistic economic growth targets and help to deliver over 70% of the identified affordable housing need.
Plan Period - Inconsistencies in the UPSVLP?s policies and its own evidence base: these are manifold, but one of the most relevant is the fact that the Council?s own housing evidence (the 2021 LHNAU) and the UPSVLP have different timeframes. The Local Plan is working to an 18-year timeframe (2021/22 to 2038/39), and therefore should arguably be running from 2021 to 2039, not 2038. In contrast, GL Hearn?s housing need assessment is over a 17-year timeframe, running from 2021 to 2038. This error is indicative of the extent to which the Local Plan and its own evidence base are fundamentally flawed, unjustified and unsound as a result.
The Council has unjustifiably and arbitrarily sought to reduce their housing requirement in the first 5 years.
The solution to address this concern and for the Plan to be found sound is to frontload housing delivery as required by the NPPF.
There is no rationale reason for reducing the requirement in the first 5 years aside from arbitrarily seeking to manipulate the figures to be able to demonstrate a 5-year supply upon adoption. The Council seeks to justify the approach due to the number of strategic sites taking longer to deliver units. However, the Council is also advocating that 535 dwellings will be delivered from these sites in the first 5 years. Not only that, there are considerable housing issues in Warrington which will be further exacerbated by the Council?s approach which is the antithesis of positive plan preparation.
Urban Capacity Assessment
The Council evidence to justify their housing trajectory is flawed and insufficient
The Consortium is of the opinion that at least 2,448 dwellings needs to be removed and replaced by alternative sources of supply.
The Consortium has sought to undertake a detailed and thorough assessment of a significant proportion of the Council?s housing land supply focusing primarily on the larger sites with capacity to deliver 50 or more units. In total, there were 44 sites with capacity to deliver 50 or more units which we assessed in this housing land supply analysis paper and the combined capacity of the 44 sites was 7, 152 (43% of the overall supply). Having reviewed the Plan and the evidence base in considerable detail, the Consortium is very surprised and disappointed with the lack of detail and information being provided to justify the significant levels of development being envisaged on some sites particularly those sites without planning permission. The Council has delayed the publication of this version of the Plan for almost 2 years and has had ample time to update and provide sufficient evidence to substantiate its claimed housing land supply. In particular, the Consortium is incredibly disappointed with the lack of an up to date SHLAA being released and the figures contained in the plan differing significantly from those presented in the Plan. Furthermore, the Council has indicated that it will be releasing a new SHLAA immediately post conclusion of this consultation exercise. This is a fundamentally flawed approach which the Council has taken and represents poor practice in preparing a new Local Plan. It undermines the credibility of the process and the transparency of the Council?s evidence base. Where sites have no extant permission or live planning application, little if any information is provided on the willingness of the landowner to bring forward their land, the suitability of the site to accommodate development, justification for the claimed site capacity and the likely viability of the site bearing in mind future policy aspirations and infrastructure requirements. Whilst the Consortium commend the Council?s ambition to redevelop the Town Centre of Warrington, the delivery trajectory must be grounded in reality particularly relating to the viability of delivering high density development in a town centre. The delivery of high-density apartment schemes in Manchester and Liverpool is not comparable to Warrington for a host of reasons. Not only that but the delivery of high-density developments will not delivery sufficient proportions of affordable housing as is currently being experienced in Warrington?s recently approved schemes or deliver sufficient levels of larger 3 & 4 bed family homes to meet housing needs identified in the Council?s evidence.
Failure to provide an appropriate mix, size and type of housing. The proposed supply pays no regard to the Council?s evidence on housing need which advocated that 65% of the supply needs to deliver 3 & 4 bedroomed properties.
The solution to this concern and for the Plan to be found sound is to provide more greenfield sites capable of delivering the larger property types set out in the Council?s own housing need assessment.
Lichfields? analysis indicates that there is an overall need for 34% 1-bed and 2-bed properties over the period 2021-2038, and a 66% need for larger 3-bed+ properties. This broadly aligns with the need for larger properties identified in the LHNA, which has been taken forward in the emerging UPSVLP. However, The Consortium is concerned that the supply of sites in Warrington will not deliver the mix of homes identified in the emerging UPSVLP. Given the extremely high density being advocated in the Town Centre Masterplan document (240 dph), it is impossible to understand how any larger 3 and 4 bedroomed family homes will be delivered of the 8,000 homes identified in this area to 2040. The members of this Consortium are very experienced developers and housebuilders yet they have never seen town houses or family homes being delivered at an average density of 240dph. As such, this Plan as drafted will fail to deliver 65% of dwellings as larger properties. The Consortium considers that providing larger houses is vital as they can act as a mechanism for people to move around within the market and free up housing along the housing ladder.
The evidence which justifies the Fiddlers Ferry allocation is technically flawed and not legally sound. There are some significant omissions in the evidence, and it is the consortiums view that they have deliberately over exaggerated the sustainability merits of the site and hidden its technical failings to avoid allocating more suitable and sustainable. We consider on the basis of the evidence available that the Council has not met its duty to cooperate which is in conflict with the relevant provisions of Section 20 of the Planning and Compulsory Purchase Act 2004. greenfield releases.
To ensure the Local Plan is sound and legally compliant, it is considered that the Council: 1 Needs to provide additional evidence to justify the inclusion of the Fiddlers Ferry Site, including viability evidence. 2 Needs to re-assess the incorrect and underplayed impacts it will have in the SA and use this to inform the Local Plan strategy. 3 Provide robust evidence to counter the delivery concerns we have identified. 4 Reconsider the Green Belt evidence prepared for the site. 5 Should ensure that sufficient land is provided in alternative locations to account for any shortfall in provision at Fiddlers Ferry and ensure the housing requirement is met.
The Council has introduced a new mixed-use allocation into the Plan at the latest stage and the Consortium has considerable concerns in relation to the principle of the site?s inclusion. Not only that, the timescales for the delivery of the site as set out in the Plan are fanciful and are not grounded in any sense of reality. It is the consortiums view that the SA in relation to the assumptions made on Fiddlers Ferry is fundamentally flawed, results in an unstainable approach to development, it is not sound, and it is not legally compliant. The identification and delivery of a brownfield site which over exaggerates its impact in the SA should not surpass the allocation of other more sustainable greenfield releases where it is clearly not justified. Not only that, Fiddlers Ferry is wholly unviable and as a consequence it is highly questionable whether the development could ever be delivered without significant intervention. We also have concerns with the loss of Green Belt land in this location and the lack of evidence to justify that this is the most appropriate site for Green Belt release. It is not clear why the Green Belt element of this site is required to come forward. Given the significant number and complexity of the issues raised in relation to the developability of this site, it is consider that the Council?s delivery trajectory is completely at odds with the reality of delivering complex strategic sites and the Council need to identify alternative sites to plug the gap in the supply trajectory. Not only that but the Consortium considers that the Council has not followed a logical approach in terms of identifying the most appropriate sites for release from the Green Belt and the loss of this proposed allocation would result in the erosion of the strategic gap between Warrington and Widnes.
The Consortium has significant concerns in relation to the viability of a large proportion of the Council?s claimed supply, and the subsequent ability of the emerging Local Plan to deliver the required number of affordable dwellings over the plan period. No regard has been paid to the viability of delivering a significant quantum of housing in Warrington Town Centre and the impact this will have on the delivery of much needed affordable housing and social infrastructure such as schools and medical centres to cater for future resident?s needs.
Identifying a greater quantum of greenfield sites in higher value areas will also help to ensure that the required social and physical infrastructure provision can be delivered, and ensure the needs of residents in new developments are met.
It is clear that the emerging Local Plan in its current form will not deliver on the required quantum of affordable housing or infrastructure provision across the Borough without significant alternative public sector funding being secured, or identifying a number of strategic Green Belt allocations with the ability of delivering reasonable proportions of affordable dwellings. The Consortium is strongly of the opinion that the failure to identify a sufficient level of housing allocations in the Plan, which have been tested as being viable, will result in the UPSVLP being found unsound at Examination.
The Consortium has significant concerns in relation to the viability of a large proportion of the Council?s claimed supply, and the subsequent ability of the emerging Local Plan to deliver the required number of affordable dwellings over the plan period. No regard has been paid to the viability of delivering a significant quantum of housing in Warrington Town Centre and the impact this will have on the delivery of much needed affordable housing and social infrastructure such as schools and medical centres to cater for future resident?s needs.
Identifying a greater quantum of greenfield sites in higher value areas will also help to ensure that the required social and physical infrastructure provision can be delivered, and ensure the needs of residents in new developments are met.
It is clear that the emerging Local Plan in its current form will not deliver on the required quantum of affordable housing or infrastructure provision across the Borough without significant alternative public sector funding being secured, or identifying a number of strategic Green Belt allocations with the ability of delivering reasonable proportions of affordable dwellings. The Consortium is therefore very concerned that the required infrastructure to support new developments may not be deliverable, particularly when viability has been identified as a significant issue in the Town Centre and in low value locations across the Borough. The Consortium is strongly of the opinion that the failure to identify a sufficient level of housing allocations in the Plan, which have been tested as being viable, will result in the UPSVLP being found unsound at Examination.
The Consortium are strongly of the opinion that the current version of the Warrington Local Plan does not meet the requirements of the Framework as it does not identify sufficient proportions of land to meet needs post 2038 or identify safeguarded land which could act as a failsafe in the event that one of the key strategic allocations does not come forward as envisaged.
The Consortium is of the opinion that sufficient land is required to meet the future needs for at least 6,499 dwellings or 8,693 dwellings should the Inspector agree with the Consortium that a higher housing requirement is warranted. This land should be identified now and safeguarded to meet the needs beyond the Plan period and ensure that the Green Belt boundaries endure beyond the Plan period too. The Consortium is of the opinion that the land to be identified as Safeguarded should be varied in size and be capable of coming forward in the short terms should the need arise at any point in the plan period. This would allow any future Local Plan Review to allocate the safeguarded sites for development and ensure they are capable of delivering units in the first 5 years post adoption of the Review.
Despite this Plan undertaking a Green Belt Review, no sites have been identified as safeguarded land to meet needs beyond the Plan period. The consortium disagrees with the Council's methodology for establishing housing need beyond the Plan period and its assessment of potential development capacity. The Local Plan is effectively seeking to claim that some of the larger allocations which will deliver units beyond the plan period are effectively Safeguarded Land but this does not represent a robust or justified approach. The purpose of safeguarding land is to ensure the long term permanence of Green Belt boundaries beyond the plan period and to offer an alternative source of land in the event of there being an insufficient supply of available housing sites. Within the Plan, this fall back position has not been included and further undermines the soundness of the Plan. The identification of a number of safeguarded sites of varying sizes across the district would offer the potential to quickly address shortfalls in the supply of units through a Local Plan Review. In most cases, smaller sites with the capacity to deliver up to 500 units would come forward sooner and could contribute towards completions in the first 5 years and a policy trigger should be included within the Plan which allows Safeguarded Land to come forward when housing land supply issues are experienced (i.e. not being able to demonstrate a deliverable 5 year supply).
The LHN target derived from the standard methodology only represents the minimum starting point. There are compelling arguments to increase the overall housing need which have been totally ignored and frankly misinterpreted by WBC and its housing consultants. These include the misalignment with the Plan?s very high employment land target; and the very high levels of affordable housing need across the Borough. The solution to address this concern and to be found sound is to increase the housing requirement so that it aligns more closely with the Council?s economic growth proposals. Our modelling indicates that the Council should be planning for at least 1,015 dpa, which is more closely aligned with the Council?s previous 2019 target, would address realistic economic growth targets and help to deliver over 70% of its affordable housing need.