HARROGATE DISTRICT SITES & POLCIES DPD

HOUSING BACKGROUND PAPER

October 2013

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CONTENTS

1.0 Introduction

2.0 Policy Context

National Policy

Regional Policy (now revoked)

Local Policy: Adopted Harrogate District Core Strategy

3.0 Harrogate District Housing requirement

The Housing Figure

Household Projections

Environmental and infrastructure constraints

4.0 Meeting the requirement: Housing Implementation Strategy

Plan period requirement

Homes delivered

Providing a buffer

Windfalls

Site allocations

Bringing the evidence together

Delivery of housing

5 year housing supply

Managing risks to delivery

Contingency within the SPDPD

5.0 Conclusion

Appendices:

Appendix 1: Leeds City Region Interim Strategy

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1.0 INTRODUCTION

1.1 The Harrogate District Sites and Policies DPD (SPDPD) seeks to deliver the strategic planning

policies set out in the adopted Harrogate District Core Strategy. Adopted in 2009, the Core

Strategy sets out a vision for what the District should be like by 2021 and provides strategic

policies for the development and conservation of the District. In order to ensure a

continuous delivery of housing, for at least 15 years from adoption, the Core Strategy plans

for new housing up to 2023/24.

1.2 Notwithstanding the fact that the agreed level of annual housing growth has been set out in

the adopted Core Strategy, this paper provides further information on the District’s housing

requirement and growth strategy in order to demonstrate why this approach is appropriate

within the context of Harrogate District and in light of the NPPF.

1.3 Section two of the paper provides an overview of the policy context, whilst section three

sets out how the figure was derived. The final part of the paper looks at how the identified

requirement will be met both through allocations within the SPDPD and windfalls and

provides justification for the approach to the windfall allowance and percentage buffer.

2.0 POLICY CONTEXT

National Policy

2.1 In March 2012, the National Planning Policy Framework (NPPF) was published, superseding

the numerous planning policy statements. At the heart of the NPPF is a ‘presumption in

favour of sustainable development’ [para.14]. For plan making this means that:

Local planning authorities should positively seek opportunities to meet the development

needs of their area;

Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to

rapid change, unless:

o Any adverse impacts of doing so would significantly and demonstrably outweigh

the benefits, when assessed against the policies in [the NPPF] taken as a whole;

or

o Specific policies in [the NPPF] indicate that development should be restricted.

2.2 Paragraphs 47-55 of the NPPF sets out the approach that local planning authorities are

expected to take in order to deliver a wide choice of high quality homes. Specifically it

requires that local planning authorities should:

boost significantly the supply of housing, ensuring that the Local Plan meets the full

objectively assessed need for market and affordable housing in the housing market area.

identify and update annually a five year supply of specific deliverable sites, providing

either a 5 % or 20% buffer (dependent on past records of delivery) to ensure choice and

competition. A windfall allowance can be made within the 5 year supply.

identify a supply of specific developable sites or broad locations for years 6-10 and

where possible for years 11- 15

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plan for a mix of housing based on current and future demographic trends, market

trends and the needs of different groups within the community

identify the size, type and tenure of housing that is required

set policies for meeting affordable housing needs where these have been identified.

2.3 In order to plan for and deliver new housing, local planning authorities should have a clear

understanding of the housing needs within their area. This should be informed by the

preparation of a Strategic Housing Market Assessment (SHMA). The SHMA should identify

the scale, mix and tenure of housing required over the plan period. In order to meet the

identified need for housing local planning authorities should prepare a Strategic Housing

Land Availability Assessment (SHLAA) to establish realistic assumptions about the

availability, suitability and the likely economic viability of land for housing.

Regional Policy

2.4 The Regional Spatial Strategy (RSS) for Yorkshire and the Humber (the Yorkshire and Humber

Plan) was published in May 2008 and was revoked, in part, in February 20131. Whilst now

revoked, the approach to housing growth for Harrogate in the RSS as a general approach is

still pertinent.

2.5 Harrogate sits within the Leeds City region but is also part of the North Yorkshire grouping of

authorities. The RSS identified that over the period 2004-2026, 390 new homes should be

provided annually within Harrogate. In concluding on the appropriate level of growth for

Harrogate the report of the Examination in Public (EIP) noted that across the North Yorkshire

Sub-Regions there is an annual difference in the RSS growth target and the figures based on

household projections of the time, with the greatest difference being within Harrogate

where the 2004 ONS projections resulted in a figure of 650-800 new dwellings for Harrogate.

The EIP report went on to note that the figures for North Yorkshire were reviewed to

support strategic restraint in rural areas but also to support urban regeneration and the

roles of service centres.

2.6 In relation to Harrogate specifically, urban capacity and highway capacity were considered to

be constraints to increased levels of growth within the District. To increase growth would

result in more development being diverted to Knaresborough and Ripon. The EIP report

concluded that these settlements were unlikely to witness additional employment growth

and to increase housing provision would not result in a sustainable pattern of growth. At

the RSS EIP Harrogate Borough Council supported the proposed annual housing target for

Harrogate.

2.7 The approach to settlement growth set out in RSS embodied a long standing strategy (since

the 1980’s) to restrain growth in North Yorkshire in order to protect the County’s high

quality environment and assist in housing market regeneration in parts of West Yorkshire.

1 The RSS York Green Belt policies remain extant.

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2.8 Whilst the RSS has largely been revoked the authorities within the Leeds City Region

continue to support the broad policy thrust of the RSS and the principles of urban

transformation and to this end have carried forward a suite of policies from the RSS that

address spatial principles in a City Region Strategy Statement (Appendix 1). Similarly Local

Government Yorkshire and York produced a North Yorkshire and York Strategy, 2011 in

which they note: ‘The area to the north of Leeds and Bradford has a high demand for

housing which results in high house prices, and is part of the Golden Triangle. Highly valued

landscapes restrict opportunities for further development outside of the main towns which

means it should be an area of housing restraint, other than for affordable housing to meet

the needs of local settlements’.

Local Policy: Adopted Harrogate District Core Strategy

2.9 In February 2009 the Harrogate District Core Strategy was adopted. Core Strategy Policy

SG1: Settlement Growth: Housing Distribution sets out that the Council will make provision

for 390 homes per annum (net annual average) over the period to 2023/24. The Explanation

to the policy notes that the housing requirement over this period was determined at the

regional planning level and that the figure in the Core Strategy matches that set out in the

RSS.

2.10 The approach to the spatial distribution of this annual growth is based on a hierarchy of

settlements; ensuring that the majority of all future growth is well related to the existing or

extended key bus/rail network and broadly reflects the level of affordable housing need

within particular settlements. Core Strategy Policy SG2 sets out the settlement hierarchy:

Group A settlements are defined as Harrogate Knaresborough and Ripon and are the

main urban centres of the District offering a wide range of jobs, shops and services.

These settlements are the focus for growth, accommodating around 70% of the total

growth proposed.

Group B settlements comprise of the District’s market towns (Boroughbridge,

Masham and Pateley Bridge) and the District’s villages that have the best access to

jobs, shops and services. These settlements are the focus of growth for the District’s

rural areas.

Group C settlements are smaller villages offering more limited access to jobs shops

and services and as such are only suitable for limited open market housing.

Beyond these defined settlement limits, land is classified as open countryside where strict

control over new development is applied (Core Strategy Policy SG3)

3.0 HARROGATE DISTRICT HOUSING REQUIREMENT

The housing figure

3.1 As noted above the District housing requirement is set out in the adopted Core Strategy and

was a direct reflection of the figure set out in the now revoked RSS. This housing

requirement has been open to scrutiny at two public examinations; the RSS EIP (2006) and

the Harrogate District Core Strategy Public Examination (2008) where the figure was found

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sound and as such this now forms part of the development plan for the District. The figure

arrived at was not derived directly from a single mathematical model or set of projections.

Instead it was based on a range of evidence and debate and included:

Household projections (DCLG 2003 and 2004 based)

The needs of the regional economy

Evidence about land availability

Evidence about housing affordability

Evidence about low demand and vacancy rates and recent rates of housebuilding

The findings of the Sustainability Appraisal, Appropriate Assessment and other

information about environmental capacity

Evidence about transport and other infrastructure

3.2 At the Examination into the Core Strategy the Council, in its evidence, confirmed that the

housing figure proposed in the Core Strategy was appropriate for the district, having taken

into account sustainable patterns of growth, likely levels of employment development in the

District and infrastructure capacity.

Household Projections

3.3 Working collaboratively with authorities within North Yorkshire, the Council published the

North Yorkshire Strategic Housing Market Assessment (SHMA) in 2011 together with the

Harrogate Appendix. Based on the 2008 ONS population projections, as with the 2004

projections, these indicate a significantly higher housing figure for Harrogate District than

the 390 new dwellings per annum, ranging from 376 per year under natural change, 862

under sub-national population projections and 1, 086 under an employment led scenario.

3.4 The figures set out in the SHMA were not intended to be directly translated into housing

targets within local plan policy. It was recognised that further detailed analysis of individual

factors influencing supply and demand would be required, including environmental and

wider infrastructure constraints. As the Council already had an adopted housing figure for

the plan period no further work was undertaken. However, the following summarises some

of the issues raised in the SHMA in respect of the data.

3.5 The mid-year ONS estimates of population provide the base historical data for the sub-

national population projections (SNPP)which in turn provide the basis for the sub-national

household projections. A key driver of these trend projections is recent historical evidence.

This means that any error in the mid-year estimates is magnified over the 25 year period.

3.6 Under SNPP a substantial growth in population is projected for Harrogate with it set to

increase by 20,000 over the period 2008-2026. During the period 2001-2009 net internal

and international migration were important drivers for growth. SNPP being trend based,

models these assumptions forward such that both internal and international migration

having a consistently positive impact on population growth over the period. The SHMA also

includes a natural change scenario, whereby the impacts of migration on population growth

are stripped out. Under this scenario the growth of the population is substantially smaller,

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amounting to some 600 over the period 2008-20026. This highlights the impact of

assumptions around sustained high net migration levels into an area. Clearly a nil migration

rate is a hypothetical scenario.

3.7 As noted above the scenarios set out in the SHMA are trend based and as such included a

buoyant economic period. The SHMA goes on to look at a number of key aspects that have

shaped the housing market over recent years in order to provide an understanding of the

impact of projecting forward these historical trends.

3.8 Between 2001 and 2009, net international migration has been the main driver of population

change, accounting for 60% of the growth in population in Harrogate during this period.

Within the Mid-year estimates, calculating international migration is the most difficult.

When compared against GP registrations by foreign nationals and national insurance

number registrations to foreign nationals, the ONS estimates of immigration is significantly

in excess of data recorded in these administrative sources. The SHMA used York and

Richmondshire as case studies but concluded that applying this correction to other

authorities would result in a reduction in projected household growth noting that this would

be particularly true of Harrogate and Ryedale which also have in built high assumptions

around the projected level of growth driven by net international migration.

3.9 The Household Survey provides useful data on the short term picture of newly forming

households, both within and outside of the authority and provides a useful comparator to

the SNPP projections. Using this information the annual number of newly forming

households is 401 for Harrogate when compared against 862 under the SNPP scenario.

3.10 In April 2013, DCLG issued Household Interim Projections 2011 to 2021. For Harrogate this

indicated that over the ten year period the number of households would rise from 68,000 to

73,000; the equivalent of 500 per year. This is in marked contrast to the 2008 based

estimates for the same period which showed that households would rise from 69,000 in

2011 to 78,000 in 2021; the equivalent of 900 per year. The 2011 figures are much closer to

the annual housing requirement set out in the Core Strategy.

Environmental and infrastructure constraints

3.11 In setting the housing figure a consistent theme running through both the RSS EIP and Core

Strategy Examination was that environmental and infrastructure constraints restrict the

amount of growth that can be accommodated to create a sustainable pattern of growth in

the District without causing demonstrable harm. The District’s environmental and

infrastructure constraints have not materially changed since the housing requirement for the

District was determined at the earlier examinations. The quality of the local environment

throughout the District remains very high with many international, national and locally

important heritage, landscape and ecological designations, and the statutory green belt

forming critical assets of the District’s local distinctiveness. There have been no major

improvements in the capacity of the public and private transport network, which of itself

places limits on development.

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Environmental Constraints

3.12 The District is characterised by its high quality environment. The western half of the District

lies within the Nidderdale Area of Outstanding Natural Beauty (AONB). Designated in 1994,

this affords the area the highest status of protection in relation to landscape and scenic

beauty. Moreover, most of the AONB’s moorlands are internationally important and form

part of the North Pennine Moor Special Protection Area (SPA) and North Pennine Moor

Special Area of Conservation (SAC).

3.13 Whilst generally sparsely populated, the AONB includes the market town of Pateley Bridge

and a number of Group B settlements (Summerbridge, Darley, Kirkby Malzeard and

Birstwith). As noted above the market towns and Group B villages are the focus for growth

in the District’s rural areas. However, the AONB designation acts as a constraint on the

amount of housing that can be accommodated in these settlements. This is most noticeable

in Pateley Bridge itself where the Council has been unable to identify sufficient land to meet

that settlement’s requirements without causing demonstrable harm to the character of that

settlement.

3.14 As well as the Nidderdale AONB the District contains the World Heritage Site at Fountains

Abbey and Studley Royal, 53 Conservation Areas, some 3,000 listed buildings, 130 Scheduled

Ancient Monuments and 12 registered parks and gardens. These all act as constraints to

development across the District. Reflecting the high quality and scarce landscape resource

around the District’s main settlements of Harrogate, Knaresborough and Ripon, the Council

has identified Special Landscape Areas (SLAs). These landscapes are important to the setting

of the three towns and are highly valued by the local community, as demonstrated by

consultation responses where strong support is offered for their continued protection. The

Council carried out a formal review of these areas in 2011 which in the large part confirmed

their importance. Nevertheless, the Council has had to make revisions to some of these

boundaries, particularly around Harrogate, in order to provide for the housing number.

3.15 Outside of these formal designations the quality of local landscapes is generally high,

reflecting the rural nature of much of the district. This is reflected in the landscape and

historic environment assessments undertaken to identify suitable housing and employment

sites. The limited amount of brownfield land within the District means that the majority of

new development is on greenfield sites on the edge of settlements, the development of

which can have a demonstrable impact on the character of the district’s settlements.

3.16 The District is also rich in important ecological sites. In addition to the 2 SPA’s and SAC’s to

the west of the district there is a further SAC to the east at Kirk Deighton together with

numerous Sites of Special Scientific Interest (SSSIs). Locally, the Council has designated a

number of nature reserves (LNRs) and Sites of Importance for Nature Conservation (SINCs).

The Council is committed to the protection and enhancement of biodiversity as evidenced by

its production of the Harrogate Biodiversity Action Plan.

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3.17 The West Yorkshire Green Belt wraps tightly around the main settlements of Harrogate and

Knaresborough, and effectively prevents the merging of the two towns. The Green Belt here

is in parts only 0.6 miles wide. In line with advice set out in NPPF, and PPG2 that preceded it

in respect of national Green Belt policy, the Council’s Core Strategy confirms that no changes

are to be made to the Green Belt; the SPDPD confirms the boundary (Policy EQ3). The Green

Belt effectively acts as a barrier to significant increases in the number of homes that can be

planned around these two settlements. At the eastern edge of the district lies the outer

edge of the York Green Belt.

Infrastructure constraints

3.18 In drawing up its proposals for growth, the Council has worked closely with infrastructure

providers to ensure that development is supported by necessary infrastructure. Further

details can be found in the Council’s Infrastructure Delivery Plan.

3.19 The western extremities of the District which comprise the AONB experience problems of

accessibility due to their remote rural location. This, combined with generally limited

employment opportunities, precludes significant levels of development in this part of the

district. More generally the rural nature of the District results in significant levels of

commuting both into the main towns in the district and outside the district, principally to

Leeds and York.

3.20 Transport, and in particular the existing road network, places a significant constraint on the

amount of new growth that can be planned within the main settlements of Harrogate and

Knaresborough in line with the Core Strategy settlement hierarchy. Working with the

County Council, Harrogate Borough Council has commissioned a series of traffic modelling

reports to look at the impact of growth on Harrogate and Knaresborough. These two towns

already experience congestion at peak times and the modelling work shows that at the end

of plan period, even without the growth being planned for, a number of key junctions will be

over capacity. Full details of this modelling work can be found in the Strategic Traffic

Assessment of Development Growth in Harrogate and Knaresborough, 2009-2024.

3.21 During the preparation of the SPDPD the Council has also worked with the Highways Agency

who raised concerns as to the cumulative impact of planned growth on Junction 47 of the

A1(M). Modelling work indicated that whilst the level of growth being planned for would

have a material impact on this junction they considered that the impact would not be

considered to be severe. However, it is clear that levels of growth above that being planned

for would have material impacts that would need to be mitigated.

4.0 MEETING THE REQUIREMENT: HOUSING IMPLEMENTATION STRATEGY

4.1 This part of the paper looks at how the identified requirement will be met both through

allocations within the SPDPD and windfalls and provides justification for the approach to

windfall allowance and percentage buffer. This section represents the Council’s Housing

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Implementation Strategy in line with guidance set out in NPPF (para. 47) which advises that

local planning authorities should:

‘for market and affordable housing, illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their housing target’.

Plan Period Requirement

4.2 As noted above the Core Strategy makes an annual provision of 390 new homes (net) per

year over the period 2004 to 2024. Over this twenty year period this equates to 7,800 new homes. Policy SG1 of the Core Strategy sets out the broad distribution of that growth as follows:

Homes delivered

4.3 Since the start of the plan period in 2004, 4519 new homes have either been built or have

planning permission. A 5% reduction of the gross figure is applied to take account of indicative annual clearance rates.2 This equates to a net figure of 4293 new homes.

Table 1: Housing Completions 2004-2013 (30 September 2013)

Providing a buffer

4.4 The NPPF requires local planning authorities to include:

‘an additional buffer of 5% (moved forward from later in the plan period) to ensure choice and competition in the market for land. Where there has been a record of persistent under delivery of housing, local planning authorities should increase the buffer to 20% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market for land’.

4.5 No guidance has been produced defining what ‘persistent under delivery’ means. In

considering whether persistent under delivery has occurred it is appropriate to consider data that is representative of the economic cycle. Since the start of the plan period the average

2 This reflects the figure set out in the now revoked RSS for the District (410 gross, 390 net)

3 Sites with extant permission

4 1 April- 30 September 2013

Settlement Distribution

Harrogate (including Pannal) 48% Knaresborough (including Scriven) 14% Ripon 8% Boroughbridge (including Langthorpe) 3.5% Masham 2% Pateley Bridge (including Bridgehousegate) 3% Villages and countryside 21.5%

Housing Completions With PP

3

Total

04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 12/13 13/144 Total

420 432 351 510 395 335 203 152 130 50 2978 1814 4792

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house building rate per annum over the first 5 years of the plan period was 415 dwellings, exceeding the annual requirement of 390 dwellings. This time period represented more buoyant times. Since then, matching the wider economic downturn, the number of completions has fallen. However, past trends indicate that when the economy does pick up Harrogate is well placed to see a return to higher levels of development activity.

4.6 Looking further back, prior to the start of the plan period, housing completions in the District

were consistently over the requirement for the District, peaking at 930 dwellings in 2000/01, set against a then Structure Plan target of 470 dwellings. This ‘over provision’ led to the introduction of Policy HX in the Harrogate District Local Plan Selective Alteration (May 2004). This was a policy to manage housing site release and applied severe restrictions to the release of greenfield and large previously developed sites in order to manage the rate of growth.

Table 2: Housing Completions 1997-2004

4.7 Taken together, information from the last 9 years covering both sides of the recession

alongside more historical evidence demonstrates that Harrogate is not an authority where persistent under delivery is an issue and therefore a 5% buffer has been applied.

Windfalls

4.8 Paragraph 48 of the NPPF states that ‘local planning authorities may make an allowance for

windfall sites in the five-year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply. Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected future trends, and should not include residential gardens.’

4.9 Historically, windfalls have made a significant contribution to the overall supply of housing

within Harrogate district. With adopted Local Plan sites largely built out, housing completions on non-allocated sites have in fact represented the bulk of supply over the period 2004-2013 with some 94% of new housing completed on windfall sites over this period. The only completions on sites allocated in the Local Plan have been at St George’s Road, Harrogate, the former Royal Bath Hospital, Cornwall Road, Harrogate, Halfpenny Lane in Knaresborough, the Abattoir, Hampsthwaite and Back Lane, Kirkby Malzeard.

4.10 The NPPF defines windfall sites as ‘sites which have not been specifically identified as

available in the Local Plan process. They normally comprise previously-developed sites that have unexpectedly become available.’ The Local Plan process includes the Strategic Housing Land Availability Assessment therefore windfall sites are considered to be those not identified within the SHLAA.

4.11 The SHLAA Practice Guidance (paragraph 51) advises that ‘one way to determine a realistic

windfall allowance is to estimate the housing potential from each likely source of land for housing, as the rate will be different between them. One method to estimate potential from each source is by calculating the average annual completion rate from the source.’

1997/98 98/99 99/2000 2000/01 01/02 02/03 03/04

520 548 659 930 512 572 476

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4.12 To establish an appropriate windfall allowance a detailed analysis of historic permissions has been undertaken in order to identify those sites that have not been specifically identified as available in the local plans process. The analysis looked at planning permissions granted for new residential development for the five-year period between 1st April 2005 and 31st March 2010. This period was chosen as it covers both pre-recessionary and recessionary conditions and therefore reflects different points within the economic cycle. This analysis identified three important sources of windfalls:

previously developed sites (brownfield sites)

conversions (including barn conversions) / sub-division of existing buildings; and

infill /intensification of sites.

4.13 Once sites had been identified the analysis then, for each source of potential supply:

identified the number of additional dwellings permitted;

identified how many of these planning permissions have been implemented;

combined these two pieces of information to determine the expected annual rate from;

considered the expected future delivery.

Brownfield sites: Historic delivery 4.14 This includes previously developed sites that were not in residential use including

employment sites and community uses. The table below shows the additional dwellings on such sites that have been granted planning permission in the 5 year period from 1st April 2005 to 31st March 2010.

Table 3: Number of dwellings permitted on brownfield sites 4.15 To understand how many of these permissions have been delivered it is necessary to work

out the implementation rate of these permissions. All permissions granted between 1 April 2007 and 31 March 2010 have been looked at. This time frame was selected to cover the most recent period of the years analysed and to ensure that all permissions are beyond their expiry date. The table below shows the implementation rate for brownfield sites. This indicates that nearly half of the permissions granted are translated into dwellings. Table 4: Brownfield Sites – Implementation Rate

4.16 Combining these two pieces of information provides an indication of the additional dwelling

gain from brownfield sites. Table 5: Average dwelling gain from Brownfield sites

Dwellings permitted (1st April 2005 to 31st March 2010)

Dwellings permitted Average dwellings per annum 532 106.4

Implementation of permissions (1 April 2007 to 31 March 2010)

Dwellings permitted Dwellings implemented Dwelling implementation rate

217 102 47%

Dwellings permitted Dwelling gain at 47% Average dwellings per annum

532 250 50

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Brownfield sites: Future trends 4.17 As noted above brownfield sites can include land in employment or community use. Policies

within the saved Harrogate District Local Plan, adopted Core Strategy and emerging Sites & Policies DPD include policies to retain and protect these types of land uses. Nevertheless, there may be instances where it is appropriate to consider alternative land uses and this is reflected in the various clauses of these policies. It is likely therefore that there will be a continued supply of new dwellings from these sources. Conversions/sub-division of existing buildings: Historic Delivery

4.18 This type of windfall development occurs as a result of existing units or buildings being

divided into two or more buildings and is usually achieved within the existing building envelope or it may include an element of new extensions and includes residential conversions from offices, flats above shops, holiday cottages and barns and the subdivision of existing housing into flats. The table below shows the additional dwellings on such sites.

Table 6: Number of dwellings permitted as part of conversion schemes 4.19 The table below shows the implementation rate for conversion / sub-division of existing

buildings. This indicates that nearly three quarters of the permissions granted are translated into dwellings.

Table 7: Conversion/sub-division of existing building - Implementation Rate

Implementation of permissions (1 April 2007 and 31 March 2010)

Dwellings permitted Dwellings implemented Dwelling implementation rate

455 334 73%

4.20 Combining these two pieces of information shows that an average of 133 dwellings per year

is gained from this source. Table 8: Average dwelling gain from conversion schemes

Dwellings permitted Dwelling gain at 73% Average dwellings per annum

910 664 133

Conversions/sub-division of existing buildings: Future trends

4.21 The conversion/sub-division of existing buildings generally present a cost-effective and

viable option for delivering additional housing and contribute towards meeting the demand for dwellings from small households. The information above shows that this is an important source of new housing. Opportunities remain for this source to continue to make a contribution to housing supply in the future.

Dwellings permitted (1st April 2005 to 31st March 2010)

Dwellings permitted Average dwellings per annum 910 182

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Infill/intensification: Historic Delivery 4.22 This occurs where the existing dwelling is retained on the site and the plot sub-divided to

create additional residential plots or through the demolition of a dwelling to enable redevelopment at a higher density. Residential intensification has also contributed to housing supply in the District in terms of overall numbers and delivery. During the period 1st April 2005 to 31st March 2010 an annual average of 25 dwellings have been delivered from this source.

Infill/Intensification: Future trends

4.23 The NPPF specifically precludes the inclusion of residential gardens in the windfall allowance

and in general terms suggests that local authorities should consider the case for a more restrictive approach to the development of residential gardens. The justification to draft policy SG8 (para 3.42) notes that development within gardens of larger properties will not be appropriate, bringing about the steady erosion of the character and appearance of the area. On this basis whilst such schemes may still come forward this type of development has not been included in the calculation of the windfall allowance.

Windfall allowance

4.24 The above analysis demonstrates that windfall development has made a significant

contribution to housing supply in the District and that there are genuine local circumstances to justify making an allowance. The nature of settlements within the Borough mean that small scale developments are likely to continue to form an important supply of new housing in the future as demonstrated by the assessment of the implementation rates of permissions.

4.25 To ensure no double counting of sites already with permission (which have a 3 year life) an

estimate for windfalls is made only for the last two years of the five year supply period. Consequently a windfall allowance of 183 dwellings per annum has been included in years 4 and 5 only and reflects:

brownfield sites at 50 dwellings per annum; and

conversions/sub-division of existing buildings at 133 dwellings per annum.

4.26 This allowance is based on a robust analysis of windfall development over a five-year period carried out in accordance with guidance contained in the SHLAA Practice Guidance. This detailed analysis has looked in depth at the number of windfalls together and implementation rates to enable the calculation of anticipated future trends. This is considered to provide a realistic contribution for windfalls. It replaces, and is higher than, the windfall allowance included in the Publication Draft where a figure of 128 per year was used. This earlier figure was calculated using only small brownfield sites and conversions and was based on an annual average rather than looking at an implementation rate.

Site Allocations in the SPDPD 4.27 Policy SG6 of the SPDPD allocates a range of urban extension sites and smaller urban and

rural housing sites for a mix of market and affordable housing to meet the plan requirement. In addition policy HLP6 allocates rural exception sites for 100% affordable housing. These also contribute towards the supply. Taken together the estimated yield from these sites is 3830 dwellings

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Bringing the evidence together

4.28 Table 9 below summarises all of the above information to show how the Plan period housing

requirement is being met at the District Level. This shows that, in addition to planning for a 5% buffer, there is still flexibility within the plan period equating to an additional 16 month’s supply beyond the plan period requirement. Table 10 disaggregates that data across the district’s settlements to show how it meets the distributional requirements set out in adopted Core Strategy policy SG1 Table 9: Meeting the housing requirement

Table 10: Meeting the housing requirement across the District Harrogate Knares-

borough Ripon Borough-

bridge Masham Pateley

Bridge Villages Total

1. Plan period requirement 3744 1092 624 273 156 234 1677 7800

2. Homes delivered 2062 484 577 300 47 28 1294 4792

3. Homes delivered net 1959 460 548 285 45 27 1229 4553

4. Remaining requirement 1785 632 76 -12 111 207 448 3247

5. Requirement, plus 5% buffer

1874 664 80 -12 117 217 470 3410

6. Windfall allowance 176 52 30 12 8 10 78 366

7. Remaining Requirement 1698 612 50 -24 109 207 392 3044

8. Draft allocations 2032 638 139 83 99 103 610 3704

9.Oversupply/Undersupply 334 26 89 107 -10 -104 218 660

Delivery of housing

4.29 Draft Policy SG6 in the SPDPD sets out that the release of housing sites will be managed to

avoid significant over or under provision of housing land by the end of the plan period with sites or parts of sites being released to ensure a five year supply is maintained throughout the plan period. An indicative trajectory has been produced to illustrate how sites can be released and developed by the end of the plan period. The trajectory takes account of completions since the start of the plan period, existing commitments (sites in the planning process with planning permission), draft allocations in the SPDPD and an allowance for windfalls. In producing the indicative housing trajectory, consideration has been given to:

prioritising the use of previously developed land;

the performance against the environmental objectives of the sustainability appraisal;

impact on settlement character;

development constraints;

infrastructure requirements;

lead-in times from planning permission to start on site; and

the maintenance of a five year housing land supply throughout the plan period.

Dwellings

1. Plan period requirement 7800 2. Homes delivered (completed and homes with planning permission) 4792 3. Homes delivered net (95% from RSS) 4553 4. Remaining plan period requirement 3247 5. Remaining plan period requirement, plus a 5% buffer 3410 6. Windfall allowance in years 4 and 5 366 7. Requirement to be met through site allocations 3044 8. Draft Allocations 3704 9. Oversupply/Undersupply 660

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4.30 The trajectory (figure 1) shows a significant increase in the housing completions in the first three years following adoption of the plan, taking into account lead-in times and build-out rates. Lead in times and build out rates have been based on information provided by the development industry as part of preparing the second review of the SHLAA. Figure 1: Illustrative Trajectory

Annual average requirement (390 dwellings)

4.31 Lead in time is the time necessary to get a site ready for development, including where appropriate contact with land owner, agreeing heads of terms, conditional contract or option, preparation of planning application, consideration of planning application, S106 agreement, technical approvals and mobilisation and start on site. The following timescales were agreed:

for sites with consent: 6 months

for sites without consent and a yield of under 50 dwellings: 12 months

for sites without consent and a yield of 50 to 200 dwellings: 18 months

for urban extension sites without consent 200+ dwellings: 24 months

4.32 The build out rate for a site determines the number of houses that can be delivered on a site each year. The following rates were agreed:

an open market sales rate of 30 dwellings per year with any number above 30 being made up from affordable units, meaning that 40 dwellings is possible in locations where a high affordable housing provision has been agreed; and

a higher build out rate of 80 dwellings per year has been assumed on urban extension sites that are capable of being developed at the same time by two housebuilders

4.33 The consultation on the Publication Draft SPDPD coincided with an increase in developer activity within the District. A number of sites identified as draft allocations have now been granted permission and these are shown in table 11.

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Table 11: Draft allocations with extant permission Site Ref Site Name Location Yield Progress on site

H400 Bogs Lane Harrogate 74 Permission granted, not started H18 Ripon Road Harrogate 14 Site under construction RL1093(1) Between Park Side and Oak

Cottage Follifoot 10 Awaiting S106 to be signed

RL1145 Adjacent Primary School Sicklinghall 7 Permission granted, not started

4.34 Many of the major sites included as draft allocations in the SPDPD have been the subject of

pre-application discussions with the Council and Table 12 summarises the stage these are at in the planning system.

Table 12: Draft allocations subject to planning applications Site Ref Site Name Location Yield Progress with application

H3(1) Penny Pot Lane Harrogate 600 13/00976/EIAMAJ - Outline application for 600 dwellings, primary school community / retail facilities and open space with access considered (Site Area 27.8ha).

H32(3) Cardale Park West Harrogate 450 13/02786/EIAMAJ - Outline application for 450 dwellings, mixed use local centre to include retail, primary school, village green, open space and associated infrastructure with access considered. (Site area 28.07 ha).

H3021(1) North of Skipton Road Harrogate 210 13/01038/OUTMAJ - Outline application for residential development with open space, landscaping and associated access with access considered (site 7.7 ha).

K2b Manse Farm Knaresborough 600 13/00535/EIAMAJ - Mixed use development comprising residential dwellings (Use Class C3), employment use (Use Classes B1 and B8), a neighbourhood centre (Use Classes A1, A2, A3, A4 and A5), open landscaping, a primary school (Use Class D1) and associated access. Permitted subject to S106

H74a Dunlopillo Pannal 120 13/02358/OUTMAJ - Outline application for demolition of existing buildings to be replaced with a mixed use development to include dwellings, serviced employment plots (use class B1), retail units (use class A1), park and ride, sports pitches and amenity space with access considered (site area 10ha). Permitted subject to S106.

H102(1) Kingsley Farm Harrogate 85 13/03412/SCREEN - Environmental Impact Assessment screening opinion on part of site (28 dwellings)

H1023 Spa Tennis Club Harrogate 13 12/02099/FULMAJ - Erection of 13 dwellings with associated access road, parking area, garages and bin/bike store (site area 0.49ha). Permitted subject to S106.

R10 Auction Mart Ripon 75 12/04671/OUTMAJ - Outline application for demolition of Auction Mart, sheep pens, shop and public house and erection of 75 dwellings with access considered (Site Area 2.68ha).

R23 Red House Ripon 70 13/03474/FULMAJ - Conversion and extension of Red House to form extra close care housing community to include administration centre, communal facilities, 5 dwelling units and 1 staff house. Conversion and extension of Stable Block & Lodge to form 5 dwelling units and erection of 59 one and two bed dwelling units. Alterations to existing

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site entrance and formation of pedestrian entrance. (Site Area 1.9ha )

RL1015a Adjacent Cricket Ground Killinghall 62 13/02897/OUTMAJ - Outline planning application for residential development with all matters reserved (Site Area 3.5 ha).

R3005(1) Cathedral Choir School Ripon 112 12/03580/SCREEN - Environmental Impact Assessment Screening Opinion for erection of 112 dwellings.

4.35 In addition planning applications have also been received on sites which have not been

selected as draft allocations. Details are shown below. Table 13: Other sites subject to planning applications Site Ref Site Name Location Yield Progress with application n/a Boroughbridge Road Knaresborough 13/02074/OUTMAJ - Outline application for

residential development with access considered (site area 6.8ha). Up to 170 dwellings – permission refused

n/a Crag Lane Harrogate 13/02897/OUTMAJ - Outline planning application for residential development with all matters reserved (Site Area 3.5 ha). Up to 62 dwellings

4.36 This level of activity from landowners, agents and housebuilders suggests that the indicative

timescales within the trajectory, subject to approvals, is realistic and that the market may be capable of delivering a significant amount of the District’s housing requirement on sites allocated in the Submission SPDPD soon after adoption of the Plan. With further applications under consideration and expected to be submitted on draft allocations in the short term, this supports the justification for including a significant increase in dwelling completions in the early years after the adoption of the DPD.

5-year housing land supply

4.37 The early delivery of housing (2013-2018) will be through the existing 5-year housing land

supply as at 30th September 2013. This comprises various elements that that will make a contribution to supply in the next 5-years. The five year supply position is continuously monitored and reported on twice yearly. Details are set out in the table below.

Table 14: Five year Supply of Housing Sites Calculation of five-year supply – 30

th September 2013

Component How is this calculated? Total (a) Requirement 1 April 2004 – 30

September 2018 Core Strategy housing requirement from start of plan period to 30 September 2018 (390 x 14½ years)

5655

(b) Completions 1 April 2004 to 30 September 2013

Housing completions from start of plan period to 30 September 2013

2979

A 5% reduction of the gross figure is applied, based on the comparison between the net and gross requirement previously set out in the RSS for the District (390 net / 410 gross = 95%)

(c) Residual requirement (a) – (b) 2676 (d) Residual requirement + 5% buffer

(c) + 5%

2810

(e) Residual annual requirement + 5% (d) / 5 562

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(f) Site specific supply – sites available and deliverable within 5 years

Made up of:

adopted Harrogate District Local Plan sites

brownfield sites selected as draft allocations at April 2013

sites in the planning process comprising:

o outstanding permissions on large sites

o small sites under construction

o outstanding permissions on small sites not started

Total

25

534

544

277

702

2082

(g) Windfall allowance Based on compelling evidence of sites in the planning process that have come forward and continue to come forward, excluding garden sites (years 4 and 5 only)

366

(h) Applications pending5 176

(i) Total supply (for 5-year period between April 2013 to September 2018)

(f) + (g) + (h) 2624

(j) Supply in years (i) / (e) 4.7

Managing risks to delivery

4.38 As part of the preparation of the SPDPD, extensive consultations have taken place with

landowners and agents as well as key infrastructure and utility providers to ensure there are no barriers to the delivery of the identified allocations. As a result the following risks, constraints and other considerations to delivery have been assessed and are all considered low:

land availability or land ownership;

viability; and

infrastructure. 4.39 Throughout the preparation of the SHLAA and the SPDPD the Council has kept in regular

contact with landowners to ascertain their intentions. Following the close of the consultation on the Publication Draft SPDPD the Council again contacted landowners to enquire as to when they anticipated their sites coming forward. All confirmed land availability.

4.40 The Economic Viability Assessment (EVA) prepared as part of the evidence base to the

Community Infrastructure Levy has modelled the economic viability of the development of a range of land uses in the District. It has taken account of the costs related to local policy requirements in connection with affordable housing, sustainable construction targets and developer contributions towards education, open space and village hall provision and other abnormal costs to development in particular areas of the District. The EVA concludes that there is every prospect that the scale, type and location of development set out in the Core Strategy and SPDPD will come forward as expected over the plan period.

5 The figure included for applications pending is the number of dwellings expected to be delivered within 5 years from

these applications and may differ from the total yield

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4.41 The Council has worked closely with infrastructure and service providers during the preparation of the Core Strategy and SPDPD to identify and deliver the infrastructure required to support growth in the District over the plan period. The Infrastructure Delivery Plan identifies specific infrastructure requirements, potential funding sources and suggested phasing of works. Dialogue will be maintained with infrastructure providers to ensure that there are no barriers to the provision of infrastructure to ensure that development can be delivered as programmed.

4.42 Harrogate District is a place where housebuilders want to build as evidenced by historical

development pressure and the implementation rate of planning permissions; with sites that are granted permission normally being developed. The District has not suffered from sites stalling through the recession. A delayed recovery of national economic conditions and how this continues to impact upon financial institutions, the construction industry and the local housing market may impact on housing delivery. However as evidenced by information above on planning applications there appears to be a renewed confidence in the development sector as it applies to Harrogate.

4.43 Housing completion rates are monitored annually in the Annual Monitoring Report and this

will highlight whether there is a significant deviation from expected delivery rates. In the event that housing delivery falls short of, or exceeds, expected levels it will be necessary for the Council to identify measures to ensure that housing targets meet the requirement by the end of the plan period. This could include working with developers to bring forward sites with planning permission or allocated sites.

Contingency within the SPDPD

4.44 The Core Strategy sets a target of 7800 dwellings to be delivered in the period up to

2023/24. Draft allocations are being made to meet this requirement, in full, with an associated buffer. If the housing allocations are delivered in line with the rate predicted in the housing trajectory, the housing target will be met across the plan period. If this occurs, it is expected that the Council will exceed the housing target by about 660 dwellings. This will provide some flexibility in housing delivery.

4.45 The Council has taken a conservative approach to calculating its windfall allowance. Past

history demonstrates that significantly more than 183 new homes per year have come forward as windfalls. Similarly, the Council has not sought to apply the allowance over the plan period. Whilst NPPF permits the inclusion of windfalls in the first five years it does not explicitly exclude windfalls from a particular period and therefore there is a case to be made that in fact the allowance could be applied across the Plan period6. If this was the case then this would result in an additional 1007 dwellings over the period. The Council fully expects that windfalls will continue to come forward over the plan period. The number of dwellings expected to contribute to future delivery could increase from a variety of sources including unidentified greenfield sites within development limits. This provides for additional flexibility in land supply in the District.

4.46 Recent announcements by the Ministry of Defence in respect of the barracks closure at

Ripon means it is likely that, within the life of the plan, a significant brownfield re-development opportunity within the development limit of Ripon will become available. This site offers the potential to deliver a significant amount of new housing, together with

6 See reference to the recent Inspector’s report into Suffolk Coastal District council’s Core Strategy 6 June 2013

(para 37)

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employment and open space provision. The Council is working with the local community to secure the effective re-development of this site.

4.47 The City of York Council, a neighbouring authority, is making significant provision for new

housing as part of its long term growth strategy. In this way York is meeting its own housing need and in so doing the figure also provides some flexibility to accommodate neighbouring authorities housing need if this is required.

5.0 Conclusion 5.1 Section 4 of this paper demonstrates that there is a sufficient identified supply of sites to

meet planned housing requirements over the plan period (from the anticipated adoption date of 2014) with an appropriate buffer. Housing delivery performance will continue to be monitored and progress will be reported in the Council’s Annual Monitoring Report. This will include updating the housing trajectory to compare actual delivery against planned housing targets.

5.2 The target set for the District is reflective of environmental and infrastructure and

consequent delivery constraints that restrict the amount of growth that can be accommodated to create a sustainable pattern of growth in the District without causing demonstrable harm. Further evidence of this is provided by the lack of serious alternative developer options, applications and pending applications. In a district like Harrogate, which is attractive to the market, it would be expected that there would be many more alternative proposals being actively pursued.

5.3 The SPDPD is the most appropriate vehicle for ensuring that development takes place

sooner rather than later and is in a planned way to match infrastructure and employment provision. To halt preparation of the SPDPD and review the housing figure would potentially act as a break on growth. The Council has, however, committed to an early review of the Core Strategy which will look again at the housing figure. It is this strategic level that is the most appropriate place to consider the annual housing requirement alongside economic growth and employment land provision and the provision of new infrastructure to ensure that a sustainable pattern of growth is planned. The review of the Core Strategy will commence towards the end of 2013 and it will ensure that land supply issues are addressed well before the end of the current plan period.

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Appendix 1

LEEDS CITY REGION: INTERIM STRATEGY STATEMENT

21 April 2011

Background In July 2010 the government revoked the approved Regional Spatial Strategy for Yorkshire and the Humber. This decision has been contested through the courts with the result that currently, the RSS remains part of the Development Plan albeit with some uncertainty regarding the weight to be attached to it in decision making. In these circumstances there is considerable uncertainty surrounding the strategic policy framework for spatial planning in the Leeds City Region which addresses those matters that are ‘bigger than local’ and require collaboration between the Planning Authorities in the City Region. The Government published the Localism Bill in December 2010 this includes a number of changes to the operation of planning legislation. As expected the Bill includes a ‘duty to co-operate’ on these strategic issues however this part of the Bill is likely be subject to amendments and its operation will only become clear once the secondary legislation that gives effect to the duty is published. The Bill also deals with the revocation of regional strategies and associated with this in Clause 89 of the Bill is the revocation of orders that have saved policies from existing development plans (the revocation of saved policies may only apply to Structure Plan policy, a clarification is being sought on this). This will particularly affect those authorities who have yet to complete work on their Core Strategies. It is expected that this Bill will become an Act sometime later in 2011. In the period before the Localism Bill becomes an Act there is a need for an interim strategy position to help manage the uncertainty on strategic policy and to make clear the continuing support for the policy principles in the RSS that support shared objectives across the City Region . Furthermore depending on the eventual content of the Act there may well be a longer period of time before the Local Planning Authorities can give effect to whatever procedures are put in place in the Act and to address the duty to co-operate and the potential gap created by the loss of previously saved policies. The City Region Partnership had been working on a city region strand for the wider Yorkshire and Humber Strategy that was being prepared by the Yorkshire and Humber Joint Board. This Yorkshire and Humber Joint Board was dissolved and its strategy work ceased following the general election. However the City Region decided that it is important to continue work across the city region on a strategy and investment plan that would bring greater coherence to policy and investment activities of the City Region Partnership and would support the development of the City Region Local Enterprise Partnership. The development of the interim strategy statement for spatial planning is seen as part of this wider strategy development activity. Proposed Interim Strategy Statement The 10 Local Planning Authorities in the City Region Partnership that are required to prepare LDF Core Strategies (NYCC the eleventh local authority is a planning authority in respect of minerals and waste only) have all used the RSS as a starting point for their Core Strategies and support the urban transformation ambition that is at the core of the RSS. Where there are adopted Core Strategies (Harrogate and Wakefield) those documents have a strong policy relationship with the RSS. Authorities who have not yet reached that stage are reviewing the relevance of the RSS approach in their on-going work on Core Strategies. All authorities recognise that the policies in the former RSS which articulate the urban transformation ambition, should provide the start point for an interim

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strategy statement. Along with policies that safeguard the environmental assets of the city region and the key spatial investment priorities that are set out in the already agreed city region strategies. Policy approach in the strategy The authorities in the partnership continue to support the broad policy thrust of the former RSS and the principles of urban transformation contained in the Plan. To ensure these principles are retained the authorities propose to include the following policies from the approved RSS that address spatial principles in a City Region Interim Strategy Statement. Spatial Principles Policy YH1 Overall approach and key spatial priorities (as these apply to the Leeds City Region) Policy YH2 Climate Change and Resource use Policy YH3 Working Together (as this applies to the Leeds City Region) Policy YH4 Regional Cities and sub regional cities and towns Policy YH5 Principal Towns Policy YH6 Local service centres and rural (and coastal) areas (as these apply to the Leeds City Region) Policy YH7 Location of Development Policy YH8 Green Infrastructure Policy YH9 Green Belt (as this applies to Leeds City Region) Thematic Policies To ensure that the city region’s environmental assets are effectively safeguarded the following thematic policies from the RSS will be included in the City Region Interim Policy Statement. ENV1 Development and Flood Risk ENV2 Water Resources ENV3 Water Quality ENV6 Forestry, Trees and Woodland ENV7 Agricultural Land ENV8 Biodiversity ENV9 Historic Environment ENV10 Landscape H4 Affordable housing City Region thematic strategies The strategy statement also captures the spatial implications of key strategic investment priorities in the city region, set out below. These priorities should be reflected in Core Strategies and other Development Plan Documents. Housing and Regeneration Strategy and Investment Plan - This strategy and investment Plan has four Key Priorities for Investment:

Accelerated strategic growth where investment will support the growth areas in Barnsley

Wakefield and Calderdale

Promoting eco living where investment will support the delivery of:

o the four Urban Eco Settlements: Aire Valley Leeds, York Northwest, Bradford-

Shipley Canal Road Corridor, and North Kirklees / South Dewsbury; and

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o the LCR Domestic Energy Efficiency Programme to eco–retrofit the existing housing

stock across the city region.

Delivering strategic urban renewal which will support the growth and regeneration

ambitions in the Leeds-Bradford Corridor, Green Corridor and Kirklees A62 Corridor.

Supporting rural economic renaissance in the Colne and Calder Valleys

Leeds City Region Transport Strategy - This strategy describes three broad spatial priorities for transport investment:

Priority A transport links beyond the city region

Priority B developing the roles of the sub regional cities and towns and priority areas for

regeneration and housing growth

Priority C strengthening the service roles of principal towns

Leeds City Region Green Infrastructure Strategy -The strategy:

Identifies the value of green infrastructure assets and the case for investing in them

Ensures green infrastructure complements other city region investment priorities

Establishes the current priorities for green infrastructure investment

Impels planning and housing policy work to support widespread improvements in green

infrastructure

Further Work to develop the Strategy Clearly, what is set out is an interim position and there will need to be further work in the context of the commitment to produce a broadly based but economic-led City Region Strategy and Investment Plan. The RSS included policies on the quantum and distribution of development, which have not been addressed in the interim strategy statement. The local authorities within the city region partnership have all undertaken reviews of the evidence that underpins these policies as part of their plan-making activities. Those authorities that have undertaken reviews in the past 12-18 months have taken account of the local implications of the range of factors that have led to a dramatic slow down in rates of development. These local reviews have led to different conclusions regarding the capacity of an area to deliver development. The partnership will work with individual authorities to help develop our collective understanding of the social and economic factors that are driving the need and demand for development, and the financial, economic and delivery factors that are restricting the ability to meet the need and demand for development. We will use our improved understanding of these factors in the development of a second iteration of the strategy statement that will examine quantum and distribution of development and is expected to form part of the wider economic led city region strategy. All this work will contribute to a more rounded Strategy Statement

Leeds City Region Secretariat Regional Policy Team Leeds City Council Civic Hall Leeds LS1 1UR