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Gwrthwynebu

Revised Development Strategy

ID sylw: 55323

Derbyniwyd: 29/07/2013

Ymatebydd: Ray & Marion Bullen

Crynodeb o'r Gynrychiolaeth:

The existing 2007 local plan is not to be considered out‑of‑date simply because it was adopted prior to the publication of this Framework; Policies contained in NPPF are material considerations which local planning authorities should take into account and must also be taken into account in the preparation of plans: due weight should be given to relevant policies in existing plans according to their degree of consistency with this framework

The existing local plan adopted in 2007 following a Public Inquiry during 2006 into objections to the proposed plan. The Inspector produced a 562 page report. Some of the issues are relevant to the new local plan proposals. It settled many questions of concern for the community, in effect setting a contract with the community, upon which many people made decisions about their lifestyle arrangements. The RDS with a dramatic change to the size of the district and the concentration of very large amounts of new housing on land that is currently subject to Rural Area policies, is seen by many as a breach of that contract. As a result there is much concern and indeed, anger, at the proposals being consulted on and in the way that the door has been left open by the Council for planning applications to be made that negate the purpose of any local plan and the consultation process to establish it.

The purpose of Local Government is to serve the community in the district that it covers. It is not to impose in a dictatorial manner changes that will erode the quality of life of those that live in that District unless there should be a very good set of reasons that carry greater weight than maintaining and improving the Strategic vision of the authority. At the many meetings in the last 6 weeks, not found anyone that supports the proposals.

Key findings of the inspector (about the plan after 2011): Council is able to show that there is no need to identify further housing sites; The balance of 2,210 dwellings to be provided between 2005 and 2021 equates to 138 dwellings per year; Satisfied that the Council is justified in not identifying sites to meet the requirement to 2021; Residual housing requirement for the period 2005-2021 can be met - RSS housing requirement 2001 - 2021: 8,091, Dwellings completed 2001 to 2005: 3,324, Remaining dwellings to be provided: 4,767.

By the end of 2011/12 the dwellings completed had increased to 6,084. Deducted from the original requirements this leaves 2,007 remaining to be provided by 2021. If 2,007 is the plan for 10 years, then for 18 years until 2029 it might be 200x18= 3,600. The latest Hearn figure for the 18 years is 8,500 persons or 3,705 dwellings, so it looks as though we should be getting back the anticipated plan. This ties in with census findings: 21.74% increase in households compares with 15.32% over the whole of England for the same 20 year period. The District has done more than most.

How did 2,007 become 12,300? In 2008 the RSS came up with a figure of 8,300 for the next 20 years up to 2029. The banking and economic crisis followed, a change of government, abolition of the RSS. Views were sought from the public and 58% agreed low growth. The first consultation was for 10,800 homes, higher than the RSS. This was rejected by 87% of respondents. A reasoned assessment based on ONS data was done that indicated a figure of 5,400 homes by 2029 was the housing need for the locality. Localism Act 2011, giving local people a chance to influence the way that development grew.

The plan so far fails to meet NPPF requirements (para 150-155). The vision and aspirations of the local communities, the definition and implementation of sustainable development to achieve net gains on all three dimensions thereof avoiding adverse impacts on any are not only not demonstrated, they seem to be ignored. Local plans should be aspirational but realistic and address the spatial implications of change.

If 2,007 homes by 2021 was considered to be realistic by the Inspector in 2006/7, and shown to be so by the District council at the time, what are the reasons for the unrealistic numbers now? A wide section of the community is engaged and would wish that it was proactively so. But this requires a listening district council.

In December 2012, the Economic and Demographic Forecasts Study prepared by GL Hearn updated the forecast for population growth. Until the joint SHMA is received, the 12,300 household cannot be considered as a valid consultation. Across the neighbouring authorities, jobs ought to follow unemployment so far as it is sensible to do. Since our unemployment count is very low, and job availability is still very fragile, then building a larger volume of homes than we have ever done does not seem to be a good strategy. It could give us a dramatic employment problem.

Maybe part of the plan is to grow homes to get new homes bonus, but this is not a material consideration in NPPF terms. It is not a good business plan either, because the infrastructure needed to support a 29,000 or so population increase has yet to be provided. The CIL paper acknowledges that there will be a funding gap unspecified. There could be a £100m capital cost shortfall between total public infrastructure costs (County, District, NHS, & central government) compared with CIL, section 106 and other charges to the developers after accounting for 40% number reduction for CIL-less affordable housing and approvals already given.

With a reduced housing target of 5,400 the infrastructure need would to be less because it is a smaller volume and can be spread more evenly around the district spreading not concentrating infrastructure overload.

Strongly request that you reconsider the quantity of housing needed by the plan, limiting it to no more than 5,400 homes by 2029. This will produce all the homes needed by the locality, gives achievable 5yr land supplies through the plan period, reduces the infrastructure cost and spreads traffic volumes, avoids the need to take valuable greenfield sites and restores the confidence of the electorate in the local authority. It has been produced as an objective assessment, that takes all the requirements of the NPPF as well ONS projections into account, establishes a realistic employment strategy that recognises greater problems in neighbouring areas but allows a controlled and realistic amount of economic growth. That should then mean that we have a sustainable local plan that will fit well into the limited space we have available.

Testun llawn:

A new Local Plan will be examined by an Inspector to ensure compliance with the NPPF.
6. says "The...
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