Wyre Strategic Housing Land Availability Assessment 2010 · Wyre Strategic Housing Land Availability Assessment 2010 Annexe 1: Draft Methodology, Consultation Responses and Amendments

Wyre Strategic Housing Land Availability Assessment 2010Annexe 1: Draft Methodology, Consultation Responses and Amendments

July 2010

ContentsPart 1 Introduction

Comments on Draft Methodology

Amendments to Draft Methodology

Part 2 Wyre SHLAA Draft Methodology

Part 3 SHLAA Newspaper Advert

Part 4 Schedule of Consultees on Draft Methodology

Part 5 Schedule of Comments and Responses on Draft Methodology

Part 1: Introduction

Part 1.1

Introduction

The Council published a draft SHLAA methodology (see Appendix 1) for consultation on its web site and made copies available at the Council’s main office and all libraries throughout the District on 21st August 2009. An advert was also placed in local newspapers (see Appendix 2). The Council invited the submission of comments on the draft methodology and sites for consideration (“call for Sites”) for a six week period between 21st August and 2nd October. At the same time the Council emailed or sent letters to over 250 organisations and individuals with a possible interest in housing provision in the Borough (see Appendix3).

Comments on Draft Methodology

The Council received 15 comments on the Draft Methodology The comments received, together with the Council’s response to them, and required amendments to the methodology are set out in Appendix 3)

Amendments to Draft Methodology

As a result of the comments received the methodology was revised following discussion with the Wyre SHLAA Forum on 27th October 2009. The key changes were as follows:

Suggested introduction of a 6 week consultation at Draft Report stage; ( Subsequently ɶɶamended in agreement with the Wyre SHLAA Forum to include Forum and Parish Councils only. Final Document to be made available on Web site as part of LDF Evidence Base)Suggested specific consultation with Highways Agency on impacts on Strategic ɶɶHighway Network;Suggested further consultation/discussion on flooding issues;ɶɶ

Agreement requirement on proposed approach towards “Greenbelt” and “Open ɶɶCountryside”

Subsequently, on consideration of further guidance produced by the Planning Advisory Service, it was decided that it would be inappropriate to use a scoring system as part of the “suitable, available, deliverable assessment”. This decision was noted by the Wyre SHLAA Forum at its meeting on 21st April 2010.

Part 2: Wyre SHLAA Draft Methodology

Part 2.1

Part 2.2

Part 2.3

Part 2.4

Part 2.5

Part 2.6

Part 2.7

Part 2.9

Part 2.10

Part 2.11

Part 2.12

Part 2.13

Part 2.14

Part 3: SHLAA Newspaper Advert

Part 3.1

Part 3.2

Part 4: Schedule of Consultees on Draft Methodology

Part 4.1

Category Name Position Organisation DetailsAdjoining Authority Tony Donnelly Head of Planning (Policy) Fylde Borough CouncilAdjoining Authority Head of Planning (Policy) Barrow Borough CouncilAdjoining Authority Graham Page Devlopment Pans and Projects Blackpool Borough CouncilAdjoining Authority Mike Kirby Chief Planning Officer Lancashire County CouncilAdjoining Authority John Whittaker JSP Group Head Lancashire County CouncilAdjoining Authority Phil Megson Lancashire County Council, Environment DirectorateAdjoining Authority Head of Planning (Policy) Lancaster City CouncilAdjoining Authority Head of Planning (Policy) Preston City CouncilAdjoining Authority Guy Kenyon Manager Remade Lancashire County Council, Environment DirectorateAdjoining Authority Colin Hirst Local Plans Ribble Valley Borough CouncilAdjoining PC L E Hargreaves Clerk Ellel Parish CouncilAdjoining PC Mr Alan Blakeley Clerk Staining Parish CouncilAdjoining PC Mr J R Coulston Clerk Barton Parish CouncilAdjoining PC Mrs R Carr Clerk Bowland Forest High Parish CouncilAdjoining PC Clerk Chipping Parish CouncilAdjoining PC Mrs D Kellett Clerk Cockerham Parish CouncilAdjoining PC Mr R Eckton Clerk Elswick Parish CouncilAdjoining PC Mrs J Ward Clerk Goosnargh Parish CouncilAdjoining PC W G Kelsall Clerk Over Wyresdale Parish CouncilAdjoining PC Mr D Clarke Clerk Overton Parish CouncilAdjoining PC Mrs Gill Mason Clerk Singleton Parish CouncilAdjoining PC Mr J C Wright Clerk Thurnham Parish Counci;Adjoining PC Mrs S Barnes Clerk Treales, Roseacre & Wharles Parish CouncilAdjoining PC Mrs Julie Buttle Clerk Woodplumpton Parish Councilagent Laurie Lane Planning & Development CB Richard Ellis Ltdagent Mr Andrew Johnston Planning Consultant DTZAgent Mr Graham Lamb Assistant Planner GL Hearnagent Mr Mark Graham Planning Consultant Halcrow Group LimitedAgent Mr Andy Frost Director Jones Lang LaSalle LimitedAgent Carolyn Wilson Senior Planner Mono ConsultantsAgent Mr Nicholas Thompson Director Nathaniel Lichfield and PartnersAgent Martyn Nicholson Managing Director Russell Armer Limitedagent Mr Anthony Atkinson Acorus Rural Property ServicesAgent Mr Guy Evans Associate Planneragent Director Atis Real Weatherallsagent John Dunshea AtisrealAgent Mr Paul Forshaw Atisreal UKagent Ailie Savage Atkins Globalagent Director Atkins Planning ConsultantsAgent Director Ballard Properties Limited

Part 4.2

Category Name Position Organisation DetailsAgent Brian Barden Barden Planning Consultantsagent Mr Stephen Locke Associate Berrysagent Bill Atkinson Bill Atkinson AssociatesAgent Sheila Wright Broadway Malyan Planningagent Bromley Parker Architectsagent C A PlanningAgent Mr Daniel Hamer Cass Associatesagent unknown Cassidy & Ashtonagent Charles F Jones & Sonagent Chris Hewitt Architects LtdAgent Andy Brown Colliers CREAgent Mr Adam Pyrke Colliers CREagent Jackie Dibley Community Planner NW Planning Aidagent Croft Goode Partnershipagent Roger Beck David Hill Property Consultantsagent unknown De Pol Associated LimitedAgent unknown De Pol AssociatesAgent Stewart Ross DesplanAgent Katy Lightbody Development Planning Partnershipagent Jennifer Asquith Dickinson Deesagent unknown Dickinson DeesAgent Louise Dowd Dowd Town PlanningAgent Cara Heekin DPPagent Miss Catherine Honeywell Assistant Planner DPPagent Mr Jonathan Burns DPPagent Joel Firth Firth Associates (RIBA Architects)agent unknown Fletcher Smith ArchitectsAgent Jeremy Hinds FPD Savills, International Property ConsultantsAgent Director Futurama Ltdagent unknown Fylde Architects & Surveyorsagent unknown Fylde Design Associatesagent Emma Wilcock G L Hearnagent unknown Graham Anthony Associatesagent unknown Higham & Coagent Mr Richard Woodford How Commercial Planning Advisersagent unknown J Alan WrightAgent Jonathan Parsons JMP ConsultingAgent Suzanne Asher Jones Lang Lasalleagent Mr Michael Gordon Jones Lang LaSalleagent Director Kensington Developments Ltd

Part 4.3

Category Name Position Organisation Detailsagent Keystone Design Associates LtdAgent Frazer Sandwith King Sturge LLPAgent Emma Latimer Knight Frankagent Claire Norris Lambert Smith Hamptonagent Steve Norwood Lancashire Double Glazingagent MacKeith Dickinsonagent Adam Smith Malcolm Judd & Partnersagent Director Maple Timber FrameAgent Mr Stephen Watson MB Hodgson & SonAgent Messrs Bamber, Cubbins & Stansfieldagent Midgley Drawing Servicesagent Mono Consultants LimitedAgent Mr Trevor E Mortimer Mortimer Surveying Services Ltdagent unknown NTJ Designagent Paul Dickinson & Associates SIBCagent Ed Kemsley Peacock & SmithAgent Mr Nigel Robinson Planning Problems Solvedagent PlantasiaAgent Robert Taylor Plot of Gold Limitedagent unknown PRDSagent Philip Rothwell PRDSagent Mr Peter Thornton PT Designsagent unknown Robert Lobellagent unknown RPSagent Michael Jones Sanderson Wetherallagent Rachel Pierce Sanderson Wetherallagent unknown Smiths GoreAgent Harry Tonge Steven Abbott AssociatesAgent Mr Neil Culkin Head of Planning Strutt & Parkeragent unknown T.S.D. Jonesagent D.W. Short The Emerson GroupAgent Alexander J Bateman The Planning Bureau Limitedagent Thompson Developmentsagent unknown Tom Mellor & Partnersagent Felicity Wye Tribal MJPagent unknown Turley Associatesagent Jeni Hall Turley AssociatesAgent unknown Walton & Coagent Wilkinson Developments Ltdagent Melanie Lawrenson

Part 4.4

Category Name Position Organisation Detailsagent David Pearson agent Mr Roger Cross agent Mr Gerald Senior agent Lisa Bennett agent Mr B J Lea FRICS agent Pandav agent Leo Morgan agent John Rowe agent E Forster agent Jim Baines agent Dave Garlick agent Peter Howorth agent K Johnstone agent Roy Bancroft agent Alan Jones Chartered Surveyors agent Stephen Greenhalgh agent Ian Standige agent D Turnbull agent R Newman agent P Ibbison agent R V Hooper agent C N Sinkinson agent Bill Atkinson agent Geoff Attwater agent Jonathan Burns builder Mr Andrew R Thompson Senior Land Director Morris Homes (North) Limitedbuilder Property & Dev Division Wm Morrison Supermarkets PLCbuilder unknown Barratt Manchesterbuilder Director Baxter Homes Ltdbuilder David Miller Bovis Homes Limitedbuilder Chris Edge David McLean Homes Limitedbuilder unknown David Wilson Homes North Westbuilder unknown Miller Homesbuilder Gina Bourne Regional Planner - Northern Regions Home Builders Federation Ltdbuilder Mr Steven Lancaster Land Director Persimmon Homes Lancashirebuilder Mr Simon Artiss Planning Manager Bellway Homes Ltdbuilder Mr Robin Buckley Redrow Homes North Ltdbuilder Mr Andrew Thorley Strategic Land Manager Taylor Wimpey UK Limitedbuilder Director Turner Builders Ltd

Part 4.5

Category Name Position Organisation Detailshousing group unknown Accertgroup Housing Associationhousing group unknown Muir Housing Associationhousing group unknown New Era Housing Associationhousing group unknown New Fylde Housinghousing group unknown North British Housing Associationhousing group Sam Pope Places for Peoplehousing group Mr Andrei Szatkowski Wyre Housing AssociationInfrastructure Associated UtilitiesInfrastructure Centrica PLCInfrastructure Catherine Lowe Head of Planning National Grid Company plcInfrastructure Tracy Ward Business Services Assistant National Grid Property LimitedInfrastructure unknown NpowerInfrastructure Robert Stockford Npower RenewablesInfrastructure PowergenInfrastructure Powergen/E.ON UK PLCInfrastructure Adam Smith The National Grid CompanyInfrastructure David Hardman United UtilitiesInfrastructure Centrica PLCInfrastructure NpowerInfrastructure PowergenInfrastructure Rob Greaves TranscoInfrastructure David Hardman United UtilitiesInfrastructure Rob Greaves Asset Protection offcier National Grid UK TransmissionInfrastructure Lancashire County HighwaysInfrastructure Andrew Leyssens Property Manager United UtilitiesInfrastructure Brian Green Land & Development Policy Department National Grid TranscoInfrastructure Property Manager BT PLCmajor landowner John Sunter Diocesan Surveyor Diocesan Board of Financemajor landowner Mr Eric Taylor Chief Executive NPL Estates Limitedmajor landowner unknown Airport Operators Associationmajor landowner Callum Cooper Port Manager Associated British Portsmajor landowner Property Manager Associated British Ports (ABP)major landowner Property Manager Dransfield Properties Limitedmajor landowner William Lee Esq Duchy of Lancastermajor landowner J Spence Duchy of Lancastermajor landowner unknown Estates Department ICI Chemicals & Polymers Ltdmajor landowner Heidi Mottram Northern Rail Limitedmajor landowner unknown Wyresdale Park Estatesmajor land owner Jennifer Asquith Poulton Consortium c/o Dickinson Dees national Mr Nigel Stirrup Senior Transport Planning Manager Government Office for the North West

Part 4.6

Category Name Position Organisation Detailsnational Samantha Turner Principal Planning Officer, Implementation & Monitoring 4NWnational Steven Broomhead Chief Executive North West Regional Development AgencyNational Ian Southworth Planning Liaison Officer Environment AgencyNational Civil Aviation Authoritynational Commission for Architecture & Built Environmentnational Mrs Rupinder Dhillon-Downey Conservation Advisor Natural Englandnational Carol Davenport Countryside Agencynational Rosemary Leach English Sports Councilnational Mr Gordon Jones Food & Rural Affairs Government Office for the NWnational B K Jones Forestry Authoritynational Mrs Phil Smith Government Office for the North Westnational Mr Christopher Bamber Senior Spatial Development Manager Government Office for the North Westnational Sandra Fleming Highways Agencynational Mr Steve Fife Local Planning Team Leader Government Office for the North

WestNational Don Earley Deputy CEO National Playing Fields Association (Fields in Trust)national Mr Steven Hedley Natural Englandnational Rosie Baynes Natural EnglandNational Martin Reynolds North West Development Agencynational Janet Belfield Planning Specialist Planning and Advocacy, Regional Advoccacy and Partnerships

(North West) Natural EnglandNational Peter Foster Sustransnational Miss Rachael Bust Planning & Local Authority Liaison The Coal AuthorityNational Mr Brian Green Sport England (North West Region) Cathy Tuck English HeritagePublic Landowner Jill Stephenson Senior Town Planner Network RailPublic Landowner Mr Tim Ellams Principle Estates Offcier Lancashire PolicePublic Landowner J R Stanyon Blackpool, Wyre & Fylde Health Services NHS TrustPublic Landowner Alison Truman British WaterwaysPublic Landowner Mr Ian Sprott British Waterways Board NW RegionPublic Landowner Property Manager Business Environments Ministry of DefencePublic Landowner Property Manager Church Commissioners for EnglandPublic Landowner Property Manager Crown EstatesPublic Landowner Jones Peckover Crown Marine EstatesPublic Landowner Angie McMahon DWP EstatesPublic Landowner David Wild Land Use Planning Manager Highways AgencyPublic Landowner Property manager Lancashire Care NHS TrustPublic Landowner Property manager Lancashire Fire & Rescue ServicesPublic Landowner Nicola Holmes Town Planning Network RailPublic Landowner unknown North West Strategic Health Authority

Part 4.7

Category Name Position Organisation DetailsPublic Landowner James Lough Strategic Rail AuthorityPublic Landowner unknown The Chief Fire Officer Fire BrigadePublic Landowner Doug Soper Wyre NHS Primary CarePublic Landowner Sue Higgins Programme Director, Post Office Ltd Network Change Programme OfficePublic Landowner Kate Grimshaw Planning & Review Officer Lancashire County Council, Property GroupPublic Landowner Colette Taylor Business Development Manager Lancashire County Developments LimitedPublic Landowner Deborah McLaughlin Regional Director - North West Housing and Communities AgencyPublic Landowner Property and Asset Manager Nort West Ambulance Service 449-451 Garstang RoadPublic Landowner Lynn MacDonald Lancashire County Council, Education & CulturalPublic Landowner Kate Grimshaw Planning & Review Officer Lancashire County Council, Property GroupPublic Landowner Julie Armitage Primary Care TrustSpecial Interest Group Mr Lawrence Cox CPRE Wyre District GroupSpecial Interest Group Mrs Irene Moore Lancashire Archaeological SocietyW PC Ms Nicky Mason Clerk Barnacre with Bonds Parish CouncilW PC Mrs J. Berry Clerk Bleasdale Parish CouncilW PC Mrs B Greenwood Clerk Cabus Parish CouncilW PC Mrs Gillian Benson Clerk Catterall Parish CouncilW PC Mr J Hallas Clerk Claughton Parish CouncilW PC Mr Ron Allen Chairman Fleetwood Parish CouncilW PC Mrs Jill Speak Clerk Forton Parish CouncilW PC Mrs Edwina Parry Clerk Garstang Town CouncilW PC Mrs Gill Mason Clerk Great Eccleston Parish CouncilW PC Mrs L Squires Clerk Hambleton Parish CouncilW PC D Porteous Clerk Inskip with Sowerby Parish CouncilW PC Mrs Gillian Benson Clerk Kirkland Parish CouncilW PC Mr R W Bassnett Clerk Myerscough & Bilsborrow Parish CouncilW PC Mr S R Handley Clerk Nateby Parish CouncilW PC Mrs M J Harben Clerk Nether Wyresdale Parish CouncilW PC Mr J Slee Clerk Out Rawcliffe Parish CouncilW PC Mrs Gillian Benson Clerk Pilling Parish CouncilW PC Mr L Marr Clerk Preesall Town CouncilW PC Peter Swarbrick Clerk Stalmine with Staynall Parish CouncilW PC Mr J E Slee Clerk Upper Rawcliffe with Tarnacre Parish Council

Part 4.8

Part 5: Schedule of Comments and Responses on Draft Methodology

Part 5.1

Name Summary of Comment ResponseChange Required to Final Methodology

M01Judith Nelson, Regional Planner, English Heritage

Stage 2 of the process sets out which sources of sites should be included within the assessment. Here it will be necessary to consider filtering out certain sites, such as Scheduled Ancient Monuments and Historic Parks and Gardens, where housing development within their boundaries is likely to be unacceptable in principle.

Noted. SAM’s included in the constraints mapping exercise.

None required.

Other designations, such as listed buildings and conservation areas, may not prevent development altogether depending on the scale and proximity of development, but need to be a key part of this filtering process.

Noted the presence of listed buildings and conservation areas within or adjacent to sites will be picked up as part of the detailed desk top constraint assessment of potential sites as part of stages 3 and 4.

None required.

The setting of designated heritage features, from SAMs to listed buildings, is a key component of their character and importance and needs to be considered as part of the site identification process. The development of a site near to a designated feature may have a considerable negative impact on its setting and may exclude the site at an early stage in the SHLAA process. There is also a need to consider the wider historic environment has described above.

The possible impact of potential housing sites on such sites and features will be addressed both during stage 3 and 4, but also in detail during the site survey stage 5. Where necessary appropriate specialist advice from the Council’s Conservation Officer will be obtained.

None required.

By the proper consideration of a site/areas historic environment and contextual features (at stage 5 and 6 of the SHLAA (CLG practice guide, 2007)), where character and physical constraints are assessed, greater certainty of housing supply and more reasonably accurate capacity assumptions will be established. This will also help ensure places, spaces and places are created that maintain and improve local character (PPS3 Housing).

Noted None required.

Also at stage 7a of the SHLAA and with reference to paragraph 38 of the CLG practice guide, it is clear that one needs to consider the historic environment as a determining factor in the process of establishing when and whether sites are likely to be developed i.e. their suitability.

Noted. The historic character of the site and its surroundings will be taken into account when determining the suitability of a site for development.

None required.

The extent to which the historic environment affects the principle of deliverability will depend on the particular characteristic of the site/area in question e.g. a modest appropriate infill development in a conservation area may have greater potential (deliverability) than a suggested development within a designated historic park and garden. Therefore our advice should not necessarily be seen as a constraint on the delivery of more homes but as means to provide greater certainty, clearly identifying at an early stage the likely deliverability of the estimations you may suggest.

Noted. Where potential sites have potential to affect potential heritage resources the Council’s Conservation Officer will be requested to assist assessment of development potential.

None required.

Part 5.2


All designated historic assets should be considered together with non designated features of local historic or architectural interest and value since these can make an important contribution to creating a sense of place and local identity. This covers buildings, and other structures and features, archaeological remains, historic open spaces and the historic character of the Districts’ rural landscapes and townscapes. Key features will include: significant known, likely archaeology including Scheduled Monuments; Historic Parks and Gardens; Conservation Areas; Listed Buildings; local listings; World Heritage Sites; rural landscapes and urban townscapes.

Noted. Non designated features of local significance will be considered.

None required.

Environmental analysis should look beyond specific designations and consider their wider setting, along with a general assessment of the landscape and townscape impact of housing development.

Noted. None required.

We strongly advise that you engage conservation, archaeology and urban design colleagues at the local and or county level to ensure you are aware of all the relevant features of the historic environment and that the historic environment is effectively and efficiently considered as part of the SHLAA. They will be able to provide you with the Historic Environment Records for the area including any ‘characterisation’ study, and ensure a joined-up and robust approach is undertaken (Para 12 CLG practice guide, July 2007).

This will be done where appropriate, and is already noted in para 4.8 of the methodology.

None required.

M02 Natural England

We ask that you give full consideration to all of our interests in assessing land with potential to be developed for housing. These interests include biodiversity and geodiversity, landscape character and quality, greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management.

Noted. These concerns are reflected in the methodology.

None required.

We would also recommend that you consider proposals which show both adaptation to and reduction in the contribution to climate change.


While we would not wish to suggest sites for development we would again, of course, wish our interests to be fully considered in the process of selecting and assessing sites for development and in protecting sites from development. ‘Environmental Quality in Spatial Planning’, jointly published by the (then) Countryside Agency and English Nature, English Heritage and the Environment Agency offers guidance on incorporating the natural, built and historic environment and rural issues in Local Development Frameworks. It is available to access and download (together with the Supplementary Files which support it) from our web site at www.naturalengland.org.uk

Part 5.3


Habitats Regulations AssessmentAmendments are being made to the Habitats Regulations to reflect recent clarification of the status of land-use plans as ‘plans or projects’ under Article 6(3) & 4 of the Habitats Directive. Natural England is awaiting further guidance on how Habitats Regulations assessment procedures will need to be applied specifically in the case of Local Development Frameworks. In general terms, this means that if a landuse plan is likely to have a significant effect, alone or in combination, on one or more European sites (SACs, SPAs) it must be subject to an ‘appropriate assessment’.


While we acknowledge that the SHLAA report is unlikely to require Habitats Regulations Assessment we recommend that consideration of the requirements of the Habitats Regulations be included as part of the assessment of suitability of sites and land in terms of the impacts of development on European sites, indeed this is of particular importance to you due to the proximity and links with European sites.

Noted. Whilst we do not consider it appropriate to undertake HRA of potential sites eventually included in the SHLAA which is a process to be undertaken by subsequent DPD’s we will have regard to the potential impacts on European Sites as part of Stage 3 the desk top assessment. We will also ensure that NE are consulted on potential SHLAA sites at the Draft Report Stage.

None required.

NERC Act - Duty in Relation to BiodiversityWe would like to draw attention to the duty in relation to biodiversity introduced in the Natural Environment and Rural Communities Act (NERC) Act, 2006. Section 40 of the Act states that: “Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity”. Advice on implementing this duty is available from the Defra website, and we would of course also be pleased to help.

Noted. The protection of biodiversity is implicitly covered in Paras. 4.16 to 4.19 of the draft methodology which deals with initial sifting of sites. Nevertheless the Site Survey Form will be designed to ensure that potential impacts on biodiversity conservation are adequately addressed

Ensure NE are consulted on proposed SHLAA sites at Draft Report Stage.

M03Mrs Lindsay Alder LDF Manager, Highways Agency

The Strategic Road Network in WyreThe Strategic Road Network (SRN) within Wyre comprises of the A585(T) and the M6 in the east of Wyre. The A585(T) provides a north south link through Wyre joining the M55 at junction 3. The M6 is categorised as being of national and international importance and the A585(T) is categorised as being of national importance. In having this national role and international role, the Agency has the responsibility for the operation of these routes and is responsible for funding improvements to the route. The Agency is interested in the safety of these routes and their junctions with the local road network and would be concerned if, through land use planning policy, the development or intensification of land would increase levels of traffic on the network such to create capacity problems in the future.

Part 5.4


Wyre SHLAA Methodology 2009The Agency recognises that the document intends to set out the methodology that Wyre propose to use to review and update the previous SHLAA undertaken in 2008. The completed study will form a key part of the council’s Local Development Framework (LDF) evidence base and will assist with the identification of suitable and deliverable sites with the potential for housing.


Stage 1: Planning the AssessmentA Housing Market Assessment (SHMA) has been prepared for the Fylde Coast through a partnership arrangement between Blackpool, Fylde and Wyre Council’s. Each of the council’s will be preparing an individual SHLAA for each of their specific areas. It should be noted that the Agency has not been consulted on the Fylde Coast SHMA. We would welcome being involved in the consultation of this document.

Noted Wyre BC to add HA to list of consultees on all LDF evidence base studies.

ConsultationThe council’s established LDF and 2008 SHLAA database will be used to ensure that consultation is as comprehensive as possible. As stated previously the Agency welcomes the opportunity to comment on the draft methodology for the Wyre SHLAA. As part of the consultation the Council is calling for sites which could be identified as being potential for housing. Whilst the Agency would not specifically suggest sites it should be noted that the Agency would prefer housing sites to be located in the most sustainable locations in terms of access to modes other than the private car.

Noted None required

Resources for Undertaking the Assessment The council has engaged consultants to advise and oversee the preparation of the SHLAA as well as internal resources for key elements such as site surveys etc. The Agency has worked with Wyre Borough Council with regard to development control and in the preparation of the Thornton and Fleetwood Area Action Plan (AAP) and is therefore confident that the development control officers at Wyre BC fully understand the role of the Agency in the planning process. It is noted that Lancashire County Council has been included as a specialist with regard to Highways in the additional advice that may be sought by Wyre Borough Council. However it should also be noted that the A585(T) and M6 are major routes through Wyre and the Agency would expect to be consulted on any site that may have an impact on these routes.

Noted. The HA will be consulted on the Draft Report and specific sites as appropriate.

None required.

Part 5.5


Stage 2: Determining which Sources of Sites will be Included in the AssessmentThe Agency has no particular comment relating to the sources of sites given that these are set out in PPS3, however would reiterate that the Agency supports development in sustainable locations which reduce the need for travel by private car. The Agency would wish to be consulted on any site that may have a detrimental impact on the SRN. The Agency would request the opportunity to comment on the sites that are included within the SHLAA when it is published.

Noted. The HA will be consulted on the Draft Report and specific sites as appropriate

None required.

Stage 3: Desktop Review of Existing Information Wyre BC will use existing sources of information to help give reason for the inclusion of sites within the SHLAA. The Agency notes the inclusion of the sites identified within the AAP area and would welcome the opportunity to comment on other sites that may impact on the SRN. The methodology states that Government Guidance recommends that the SHLAA assessment should not be narrowed down by existing policies which are designed to constrain development but certain national policies must be taken into consideration to ensure that time is not wasted on sites which are not suitable for development. Examples of the likely sites to be excluded are described below: • Nationally or internationally important conservation sites (RAMSAR,

SSSI);• Flood Risk Zone 3b unless water compatible use; and• Greenbelt or open countryside.


Stage 4: Determining which Sites and Areas will be SurveyedIt is stated that all sites will be visited to ensure that information is consistent and up to date and remove any duplicate sites. The site size to be included with the SHLAA assessment has been set at sites above 0.1ha. In combination with the size of the site area, the Agency is particularly interested with the density of housing proposed on a site. These two factors combined will provide the potential housing yield for each site, which could be utilised to determine the likely trips to and from the proposed development and would help the Agency to understand the likely impact of the proposals on the SRN. It is however recognised that stage 6 of the assessment will determine the potential yield.

Noted None required

Part 5.6


The inclusion of rural settlements has been determined by Wyre BC on the basis that they are sustainable rural settlements using set criteria. Although sustainability is mentioned here, there is no mention of sustainability in terms of transport. The Agency would be keen to see sites that are served by existing public transport infrastructure and services, which are usually located within existing centres and on brownfield land. Rural areas tend to increase the reliance on private car usage which in turn could increase the impact on the SRN.

Access to public transport will be taken into account when assessing the suitability of sites where possible.

None required.

Stage 5: Carrying out the Survey The council’s own staff, as part of the project team, will undertake the survey on each of the sites identified.The Agency agrees with the proposed survey approach and would hope that as part of investigating the ‘character of the surrounding area’ that it would be identified whether the site was in a sustainable location that would reduce the need to travel. Sites located close to SRN junctions should also be highlighted as these have the potential to have the greatest impact on the SRN.


Stage 6: Estimating the Housing Potential of each SiteThe Agency has no particular comment to make with regard to the development density assumptions.


Stage 7: Assessing when and whether sites are likely to be developedThe Agency would wish to be consulted on any development that may have an impact on the SRN. However sites that are likely to come forward within the next 5 years would be of particular interest to the Agency.

Noted. The HA will be consulted on the Draft Report and specific sites as appropriate

None required.

Stage 8: Review of the Assessment All the information collated will be entered into the SHLAA database and this will be used to produce a housing trajectory that sets out how much housing can be provided and at what point in the future.The SHLAA will be assessed against the aspirations as set out in the Council’s emerging Core Strategy and Regional Spatial Strategy requirements.Following the above, if there are insufficient sites it will be necessary to plan for the shortfall which will include Stage 9 below.

None required.

Stage 9: Identifying and assessing the housing potential of broad locations (where necessary) The Agency would wish to see any sites (and any identified broad locations) brought forward to make up the shortfall to also be in sustainable locations.

Noted None required

Part 5.7


Stage 10: Determining the Housing Potential of WindfallDue to a typographical error, it is not clear whether Wyre intend on using windfall sites and within what timescale, however as with any other site allocation, the Agency would wish to see them located in the most sustainable locations and the Agency would wish to be consulted to determine if they may impact on the SRN.

Para 4.50 should read: ‘Windfall allowances should not be used for the first 10 years unless there are clearly justified local circumstances’.

Amend para 4.50

Future Monitoring and Review The Agency supports an annual review of the SHLAA so that any future sites can be identified early in the planning process and would wish to be involved in such reviews to ensure that any site updates / new sites are considered in relation their potential impact on the SRN.


The Wyre SHLAA ForumAlthough the Agency is not part of the SHLAA forum, it is recommended that consultation should take place with the Agency on any development that may have an impact on the SRN.

The HA will be included in circulation lists etc relating to Forum activities.

None required.

M04Miss Rachael A. BustDeputy Head of Planning and Local Authority Liaison, Coal Board

Having reviewed your document, I confirm that we have no specific comments to make on this document at this stage.


M05Diane ClarkeTown Planning Technician LNW, Network Rail

Welcomes opportunity to comment on SHLAA methodology but no substantive comment.


M06Mr David ShortGroup Planning Divisional Director, The Emerson Group

Stakeholder involvement is an important factor in the evolution and checking process of the SHLAA. Appropriate representation from professions involved locally in the development industry is needed to complement and supplement the input from Officers and the Councils consultants.

Noted. The Council intends to establish a SHLAA Forum to establish this stakeholder approach. Nominations from the house building industry were requested in parallel with comments on the methodology.

None required.

Do you agree with the initial desk top assessment to reduce the number of SHLAA sites?There should be no automatic rejection of sites in the greenbelt or open countryside. They could be better located to provide for local needs than some brownfield sites.

Agreed – Para 4.19 to be amended as follows: Sites both within the greenbelt and ‘open countryside’ will be considered as part of the SHLAA and it is not the intention to restrict the process based on existing local policy.

revise para 4.19

Part 5.8


Do you agree with the proposed criteria for defining’sustainable rural settlements’?However those settlements with only around 20 dwellings with two of the necessary facilities are likely to be small nuclei developments serving a much wider rural area.


Do you agree with the proposed survey approach?Stakeholder involvement should also take place at this stage.

Disagree. The surveys will be undertaken by specialist council staff. The outcome of the site surveys will be made available to the SHLAA Forum Members and then more widely at the Draft Report stage.

None required.

Do you agree with the proposed approach for estimating the development potential of sites?Broadly this seems acceptable but site characteristics may require deviations from this. To an extent each site has to be considered on its own merits and the density table used only as a guideline.

Noted. Given the large number of potential sites the density table will be used and where possible local knowledge via the Forum and planning application information will be used to ensure the density figures are robust. It is not practical at this stage to analyse each site individually.

None required.

Do you have any comments regarding the intended approach to assessing deliverability and developability of sites?Some care needs to be taken with the scoring system because it can be biased against larger sites. Taking a central location on a larger site will almost always depress the score in relation to distance to facilities and neglect to account for new facilities that may be provided as part of the development of that site. Deliverability is key to the phasing of sites coming forward.


Do you have any comments regarding the use of a windfall allowance?Should not be used for first 10 years, misprint in document.

Para 4.50 should read: ‘Windfall allowances should not be used for the first 10 years unless there are clearly justified local circumstances’.

Amend para 4.50

Do you have any questions on the proposed make up of the SHLAA Forum?A manageable number should be more than two or three. The contribution to be made to validation of assessments from a range of expertise should not be ignored.


Part 5.9


M07 Ian SouthworthPlanning Liaison Officer, Environment Agency

We are generally in agreement with your methodology but have comments on paragraph 4.18 (question 5). This states that land identified within flood zone 3b will be excluded. Flood Zone 3b (Functional Flood Plain) is defined in Table D.1 of PPS 25 (development and Flood Risk as being “land where water has to flow or be stored in times of flood. SFRAs should identify this Flood Zone (land which would flood with an annual probability of 1 in 20 (5%) or greater in any year or is designed to flood in an extreme (0.1%) flood, or at another probability to be agreed between the LPA and the Environment Agency, including water conveyance routes). Paragraph 4.80 of the PPS 25 Practice Guide (published in June 2008) reemphasises this.Unfortunately your SFRA (published in April 2007) only looked at the area of the Borough to the west of the River Wyre. In order for you to apply this criteria in your SHLAA, it will be necessary for you to undertake a revised SFRA for the whole of the Council’s area in order to identify any areas of Flood Zone 3b.

Comments by Carl Green, Principal Engineer, Wyre BC: It isn’t quite true that the SFRA only considered the area west of the River Wyre, it considered this area in more detail but looked at the whole of the borough in the initial assessment.There is no developable land within the functional flood plain zone 3b (undefended land) and we would never recommend any development except for recreation (boats/mariners etc) within this zone.The majority of the developable area is within zone 3a in the definition of PPS25. The only acceptable area within this is the Thornton corridor. There may be windfall [additional] sites outside of this area and I support the stance that these areas should come from zones 1 and 2 in the first instance and zone 3a should only be considered should these opportunities not yield the desired development.

reword para 4.18 to take into account comments received

I must also point out that residential development is classified as more vulnerable in Table D.2 of PPS 25 (Development and Flood Risk) and Annex D of the PPS points out that a sequential approach needs to be applied to such development in order that it is first steered to those areas at lowest risk of flooding. Any site which falls within flood zone 3a (High probability having a 1 in 100 or greater annual probability of river flooding (>1%) or a 1 in 200 or greater annual probability of flooding from the sea (>0.5%) in any year), also, needs to satisfy the exemption test set out in Annex D.

Residential use is categorised as “more vulnerable” in Annex D1 of PPS25, requiring the exception test to be completed to justify development within Zones 3a “High Probability and 3b “The Functional Floodplain”.Sites known to be lying within flood risk zones 3b will be excluded from the SHLAA.Sites known to be lying within flood risk zones 3b will be excluded from the SHLAA. The majority of the developable area is within zone 3a in the definition of PPS25. The only acceptable area within this is the Thornton corridor. There may be sites outside of this area and these areas should come from zones 1 and 2 in the first instance. Zone 3a should only be considered should these opportunities not yield the required housing supply.

reword para 4.18 to take into account comments received

Part 5.10


M08Mrs Gillian Benson Clerk to Pilling Parish Council

Do you agree with the proposed list of settlements to be surveyed as part of the SHLAA?Don’t agree with Pilling - Smallwood Hey. Should read Pilling Village - includes Smallwood Hey, School Lane, Fluke Hall Lane & St John’s Avenue

The list of settlement will be used as a guide. Your definition will be forwarded to the team working on the Core Strategy and will help in their work as they define the settlement strategy for the Borough.

None required.

Do you agree with the proposed criteria for defining’ sustainable rural settlements’?Smallwood Hey does not meet this criteria. Pilling Village would include Primary School, Public House, Church, New Community Hall, Post Office & 2 shops.

as above None required.

Please refer to Parish Plan which indicates land unsuitable for development Noted None required.Consider foul sewerage constraints and require separate foul and surface water drainage on any new development


Can anything be done to lower speed limit of traffic associated with new development

your comments will be forwarded to the Highway engineers.

None required.

M09 Mrs Gillian Benson Clerk to Catterall Parish Council

Do you agree with the proposed list of settlements to be surveyed as part of the SHLAA?Catterall is not a Market Town but a Rural Settlement

The inclusion of Garstang/Catterall as a market town, reflects the hierarchy set out in the Replacement Local Plan 1st Deposit Draft. The emerging Wyre Core Strategy is likely to propose the identification of Catterall/Garstang as a Key Service Centre under Policy RDF2 of the Adopted North West RSS.

None required.

M10 Mr Mike Gee, Janet Dixon Town Planners Ltd

Does the proposed list of sources provide a robust basis for identifying the type of sites with potential for housingTable 4.1, should include an additional section (or section 7 should be amended) to specifically include all sites that were put forward during the previous 2008 SHLAA ‘call for sites’.

The information from both the 2008 and 2009 ‘call for sites’ is included.

None required.

Part 5.11


Do you agree with the initial desk top assessment to reduce the number of SHLAA sites?Sites within open countryside should not be excluded as a matter of principle. Much of Wyre’s land area is open countryside, including a considerable number of ‘washed over’ settlements (such as Preesall). Indeed, the exclusion of open countryside sites would conflict with consideration of many sites within and adjoining the list of sustainable rural settlements in Table 4.3. Thus, as it stands, the proposed methodology is inherently inconsistent. To exclude sites within open countryside would unduly constrain the SHLAA exercise. It would prejudice a proper evaluation of development options. Indeed, there may be opportunities through new housing development within and adjoining sustainable rural settlements (eg such as Preesall) to secure the improved viability and vitality of those rural settlements and the range and quality of services that support those communities.

Sites located within both Greenbelt (National Policy) and Open Countryside (Local policy) will be considered at the early stages when sites are being sourced including the call for sites. Sites will be surveyed taking into account a large range of criteria. Sites located in the greenbelt, covered by national policy would not be considered ‘available’ at present.The list of settlement in table 4.3 will be used as a guide and does not preclude sites in other smaller rural settlements being put forward for consideration. Further work on the proposed Rural Housing Needs Study (RHNS) will assist with the definition of what constitutes a sustainable settlement.

Revised note added after table 4.3: Note: Sites within or contiguous to all existing rural settlements will be considered in the early stages of the SHLAA. In the absence of an approved Settlement Strategy as part of the Core Strategy, the SHLAA will not narrow down the areas of search.

The evaluation of appropriate sites for development should properly take place through the formulation of the Core Strategy and any subsequent Development Management Policies and Allocations DPD, alongside the range of other considerations that support place-shaping. In short, to adopt such a restrictive approach would run counter to Government guidance and, potentially, render unsound any subsequent plan-making and policy formulation work.


Given the extensive areas of potential flood risk within the Wyre area, it is important not to unreasonably exclude sites from assessment. In particular, sites which are already protected by defences from 1 in 100 year river floods and 1 in 200 year floods from the sea should not be excluded from the SHLAA.

Comments by Carl Green, Principal Engineer, Wyre BC: The EA’s flood risk maps which are to be used for PPS25 do not recognise defences in place and although the council aims to provide high levels of protection to existing properties, where economics allow it would not be in the spirit of PPS25 to increase flood risk by allowing further development within these flood zones. Any development site coming forward would need to satisfy the exemption test and certainly would require additional modelling work to demonstrate that mitigation measures could be taken to reduce the overall flood risk.

None required.

Part 5.12


Do you agree with the proposed list of settlements to be surveyed as part of the SHLAA?The list of settlements is agreed. However, it would be entirely inappropriate to define the extent of those settlements (and thus, in turn, the sites to be assessed) by reference to the definition referred to in the note to Table 4.3. Indeed, Government guidance states that the assessment should not be narrowed down by existing policies which are designed to constrain development. Rather, our suggested approach is that all sites put forward that adjoin or are in the general vicinity of the listed sustainable rural settlements should be included in the SHLAA.

Noted, and note amended. Revised note added after table 4.3: Note: Sites within or contiguous to all existing rural settlements will be considered in the early stages of the SHLAA. In the absence of an approved Settlement Strategy as part of the Core Strategy, the SHLAA will not narrow down the areas of search.

M11 Mr and Mrs Stansfield

No substantive comments-wish to be kept informed of progress. Noted None required.

M12Ms Victoria Shorrock, Graham Anthony Associates

No substantive comments-wish to be kept informed of progress.Refers to separate call for sites submissions in response to question 3 relating to additional sources of sites to be considered.


M13 Simon Artiss, Planning Manager, Bellway Homes (NW) Ltd

Commitments – clearly market conditions require the discounting of your committed sites. Our experience in Sefton, for example, has shown that re-planning to remove apartments and change the mix etc in response to market conditions has meant a discount on yield of 34%. You should therefore assume a reduction in yield from sites with an extant consent in the order of one third.

Noted. Lambert Smith Hampton have been engaged to look at the local market conditions taking into account the current approach to apartments. Additionally input from the SHLAA Forum will help to test the robustness of the density assumptions applied.

None required.

Market Conditions – your base year is probably 2008 and therefore the current recession will have a significant detrimental impact on the SHLAA 0-5 year period at least. The SHLAA must therefore take a precautious approach in terms of the market in this period. We will continue to look for opportunities in Wyre in these circumstances.


Development Viability – this is a key determinant in delivery and therefore an important aspect to the SHLAA methodology. Many Councils are using external consultants to assess site viability from a commercial perspective, combined with comments such as this letter. We welcome a robust assessment and seek an LDF policy position that takes a realistic approach to this matter ( in terms of S106 – affordable homes, renewables, Code, POS, etc). Where other benefits can be delivered (such as regeneration) these other requirements could be reduced.

Noted. The council is using the services of Lambert Smith Hampton to advise on viability.

None required.

Part 5.13


SHLAA Assessment Criteria – the greater the detail and the lesser the assumptions the better the assessment. All site proformas to be published and all assumptions / methodology to be made clear. The use of external consultants would be supported to do this work.


Density Assumptions – due to market conditions and credit restrictions densities are dropping. Most house builders, including ourselves, are not prepared to build apartment schemes and are re-planning accordingly. Lower density (30-40 dph) family housing is most likely to be built in the 0-5 year SHLAA period, if not beyond.


Monitoring of delivery remains key to future reviews of the SHLAA, which should be made annually.

Noted, the Council intend to review the completed SHLAA on an annual basis.

None required.

Greenfield / Greenbelt considerations: the assessment of these should be included rather than excluded, as it remains the role of the SHLAA to inform any future policy considerations of these matters. The assessment of these sites should not be overly-constrained by existing policy as housing supply is a future policy matter.

Agreed – Para 4.19 to be amended as follows: Sites both within the greenbelt and ‘open countryside’ will be considered as part of the SHLAA and it is not the intention to restrict the process based on existing local policy.

revise para 4.19

Larger sites – these can potentially deliver non-residential uses and therefore their distance to existing facilities, whilst a consideration, is not a determining factor.


The delivery of RSS (minimum) targets remains a key objective and the SHLAA as Evidence Base is an important resource to enable these to be met over the plan period (being at least 15 years). The SHLAA methodology and LDF policies must not prejudice this delivery, and we look forward to our continued involvement in this partnership process.


M14 David Hardman, United Utilities

Question 1: Paragraph 4.8 (Page 7): United Utilities Water is very pleased to help with the SHLAA process. You should be aware that we sold our electricity distribution network to ‘Electricity North West’ in December 2007 and United Utilities Water plc does not provide them with a planning liaison service. They can be contacted through 0800 195 1452.


Part 5.14


Question 11: Paragraph 4.44 (Page 15): United Utilities Water will be pleased to give ‘high level’ advice on our current capacity to serve potential sites and if there is underground public water/wastewater utility infrastructure. We do find it particularly convenient if a spreadsheet is supplied with the consultation indicating site reference numbers and description. We will add ‘one-liner’ high level comments. Also, we require indications of potential development site boundaries and if this can be supplied on area based maps rather than individual site maps with site reference numbers clearly marked this will make the SHLAA utility assessment more efficient. We are very pleased to discuss this with the person responsible for preparing the consultation documents.

Noted. Thank you for agreeing to help with high level advice. We will provide you with a spreadsheet together with an area based map.

Note UU consultation requirements.

Call for SitesUnited Utilities Water has no site suggestions but I have alerted my colleagues in United Utilities Property Services who may respond separately.


M15Ms E Chatham, house owner

Do you have any comments on the intended approach to partnership working...?Housing industry involvement is questionable, possible bias

Involvement of building industry is considered essential to ensure that appropriate sites are included in the SHLAA. Potential bias will be mitigated by requirement for declaration of interest in particular sites by members of the Forum. Also, allocation of sites for development will take place through the DPD process, which will be open to consultation with the public.

None required.

Does the Proposed list of sources provide a robust basis for identifying the type of sites with potential for housing?Greenfield sites should not be considered until all Brownfield sites are exhausted.

Emphasis will be placed on Brownfield sites. Greenfield sites will only be considered where insufficient Brownfield sites are available, having regard to issues of deliverability and developability.

None required.

Are there any additional sources of potential sites that should be considered?Any unfinished developments finished first

Sites under development but not yet complete will be taken into account as potential sources of housing.

None required.

Do you agree with the initial desktop assessment to reduce the number of potential SHLAA sites?Yes – No Zone 3 to be considered

See response to M07 from Wyre BC’s Principal Engineer.

None required.

Do you agree with the proposed list of settlements to be surveyed as part of the SHLAA?Comment not understood

None required.

Do you agree with the proposed criteria for defining “sustainable rural settlements”Avoid Congestion

Potential traffic impacts will be considered as part of consultation with the Highways Agency and Lancs CC Highways

None required.

Part 5.15


Do you have any comments regarding the intended approach to assessing deliverability and developability of sites?Particular attention paid to flooding and overcrowding

Flood risk is a key criteria for selection of SHLAA sites. The detailed density of sites will be determined at the subsequent site allocation DPD stage of the Local development Framework.

None required.

Do you have any comments regarding the use of a windfall allowance Need to establish real need.

Windfall sites will not be taken into account in housing supply numbers for the first 10 years.

None required.

M16 Mr Peter Foster, Sustrans

The only comment we have relates to the transport and traffic implications arising from the choice of sites for house building. We suggest there ought to be a further point for consideration on Table 4.1 stressing the following:The location of sites is important in relation to existing facilities (shops, schools, library, places of work) so that for some short journeys walking/ cycling are real choices.The layout of sites is important so that walking/ cycling is encouraged within and that linkages can be made to established residential area.

It is intended to incorporate sustainability criteria in the detailed site assessment proforma, and this will be reflected in the list at para 4.28.Detailed layout issues will need to considered at DPD site allocations and planning application stages.

None required.

Part 5.16

Documents

Wyre Strategic Housing Land Availability Assessment 2010 · Wyre Strategic Housing Land Availability Assessment 2010 Annexe 1: Draft Methodology, Consultation Responses and Amendments