- Public Inquiry Timetable
- Matters, Issues and Questions
- Focus on Housing
- Focus on Transport
- Next Steps
Summary of comments by John Walker: Housing Aspects of the Canterbury District Draft Local Plan – Executive Summary
1. Fundamental Principles.
In our response document we set out the fundamental principles that need to be embodied in the Plan having regard to the size, character and constraints in and around the city. We conclude that the Publication Draft fails to comply with these fundamental principles and should therefore be regarded as unsound in its present form. All Local Plans should comply with the principles of sustainability as defined in the National Planning Policy Framework (NPPF) Introduction Paras. 7-10. We conclude that the present proposals fail to do so and therefore the Plan as submitted is unsound. (See 12 below)
2. Economic and Employment Growth.
Value judgements in the Plan about economic and employment growth are contradicted by some of the evidence in the Nathanial Lichfield and Partners (NLP) Report Jan 2012. For this reason the plan should be considered unsound.
3. The New Homes Bonus
We conclude that reductions in government grant to local authorities have driven the housing numbers to an unnecessary high level which is not justified by wider economic and employment indicators or by the constraints in 1 above.
4. Recent Local Housing Surveys
We find that the council have appeared to “cherry pick” those parts of the NLP Report and the Ipsos Mori Report which give credence to their unrealistic aspirations about economic growth, whilst simultaneously playing down some of the negative impacts of their own subjective preferences. Conclusions about the level of public support for the Draft Plan are not borne out by the evidence in the report.
5. Level of Housing Provision in Relation to Economic Growth
There appears to be an unexamined belief underlying the Plan that more house building will help to “kick start” an economic recovery in the area. Economists tend to the view that increased house building activity is the result of economic growth not the cause of it.
The Council’s housing proposals are designed to cater for employment growth of 9.44% over the plan period compared to the 6.25% predicted in the NLP Report. This represents an increase of 51% over the NLP projections without any explanation being offered.
6. Level of Housing provision in Relation to Past Rates of Completions
The average annual rate of housing completions over the previous 21 years was 545pa (but reduces to 484pa when adjusted for the spike in the figures in the three year “boom” period” 2007 to 2009). The proposed provision of 780 units per annum is therefore not supported by the evidence over the previous 21 year period, which included the largest property boom since World War 2 and lead to the recent severe financial crisis. This level of growth is not sustainable as defined in the NPPF.
7. Level of Housing Provision in Relation to Population Growth
There appears to be no correlation between the Council’s proposed provision of 780 units per annum and the requirement for 433 units based on the population growth forecast in KCC Strategic Forecast (Nov. 2012)
8. Brownfield Sites
By not allocating the former colliery site at Hersden, the largest brownfield site in the district, the Council would be ignoring its own evidence to the NPPF consultation in October 2011 that:” Notably the Draft NPPF omits the existing policy that 60% of homes should be built on previously developed land……the principle of Brownfield land in preference to Greenfield land wherever possible is important to ensure efficient use of land.”
We make a strong case for the allocation of the former colliery site at Hersden as part of a Regeneration Masterplan for the village, which would benefit from inward investment that development at Hersden would produce.
10. South Canterbury
Considering that this is the largest and most controversial proposal in the Publication Draft it is remarkable that there has been hardly any information placed into the public domain by either the developers or the City Council about this proposal. The developers have failed to engage in any meaningful way with the local community and the City Council claim that there are no minutes of the meetings they have had with the developers over the period of the preparation of the Plan. NPPF Section 8 Para 69 states that: “Local Planning authorities should create a shared vision with communities of the residential environment and facilities they wish to see”.
11. Duty to Co-operate
We see no convincing evidence that the Council have complied with the Duty to Co-operate as set out in the NPPF (Par 178-181) in any meaningful way. For this reason we consider the proposed housing allocation in the Plan to be unsound
12. Sustainability and the National Planning Policy Framework
We are concerned that the Council appears to be “retrofitting” the NPPF test of sustainability to the Plan after it has already decided on the level and location of the proposed housing rather contemporaneously with the process. In our view this methodology is suspect and likely to lead to poor quality outcomes. In addition whilst claiming it is simply responding to broad brush national policies dictated by “central government”, the Council has ignored Para 10 of the NPPF which stated that: “plans and decisions need to take local circumstances into account, so that they respond to the different opportunities for sustainable development in different areas.”
It is essential that the Plan complies with the principle of sustainable development as set out in Paragraphs 7-10 of the NPPF. We conclude in our response that the Plan as currently drafted fails to do so and should be considered to be unsound.
13. Strategic Housing Numbers and Locations
Based on our assessment of the evidence for employment and population growth we conclude that an annual rate of 545 units per annum would be sufficient to achieve sustainable growth over the plan period. This annual rate is capable of being provided on land already identified in the Council’s SHLAA List and the 4000 houses proposed in South Canterbury are therefore unnecessary to meet the Council’s Corporate Plan objectives.
14. Affordable Housing
There is a major systemic problem with providing the right level of affordable housing that is needed both locally and nationally. This problem can only be resolved when national government take the decision to make this provision a funding priority. Until then the proposals in the Local Plan to provide 3 affordable houses for every 7 private houses, at the developers’ expense, can only be an interim measure which will not be sustainable in the long term. In the past planning conditions and agreements designed to secure previously agreed levels of affordable housing have been waived or renegotiated. We would like to see more robust proposals in the plan for securing the delivery of affordable housing on sites that are to be allocated.
15. Student Housing and Homes in Multiple Occupation (HMOs)
This is a major concern amongst residents in the City and one which the Local Plan does little to ameliorate. We recommend that following a period of consultation with the universities, the Council adopt a Local Plan Policy based on the Oxford City Council Core Strategy (2006) Policy CS 25.
1. Whilst we support sustainable development in Canterbury we have concluded that the Publication Draft 2014 is based on an overly optimistic view of the prospects for economic and employment growth for which there appears to be no convincing supporting evidence. This Plan is an overreaction to the problems of boom and bust from which we are still recovering and will only lead to a repeat of the same cycle rather than a pattern of growth that is sustainable in the longer term. The Plan fails to achieve a sustainable balance between the economic, social and environmental impacts on the city, as set out in the NPPF. For these reasons we consider the Plan to be unsound,
2. The provision of 780 units per annum is excessive given the constraints imposed by the historic character and setting of the City and will lead to very damaging traffic impacts on the city. For this reason we believe that the plan fails to comply with the requirements of the NPPF.
3. We would support the provision of around 580 units per annum over the plan period which can be accommodated within the Council’s SHLAA List without the need for an additional 4000 houses in South Canterbury.
4. The proposed 4000 house allocation in South Canterbury is unnecessary and unsustainable and should be deleted. Instead this area, along with Thanington, could be identified as an area of further investigation and public participation if additional housing became necessary towards the end of the Plan period in 2031.
5. The failure to allocate the brownfield former colliery site at Hersden is contrary to the advice in the NPPF and further recent ministerial announcements and unless this site is included the Publication Draft Plan should be regarded as unsound.
Click to download a copy: Local Plan – housing comments by John Walker