BASE HEADER

Flooding and impact of climate change
Given the projected increased severity and frequency of storms and flash flooding due to climate change in the area the following are potentially inappropriate development site.
a. the area marked up S. of Sydenham to the East of the railway which is a further breach of the boundary between Whitnash and Radford Semele. The impact of such a development on drainage from the site itself and from the proposed development at Fieldgate Lane will probably lead to increased frequency and depth of flooding in both areas.
b. Similarly, the recent and extended winter flooding of the areas bordering the A452 south of Harbury Lane and the restricted drainage in that area would raise the question of whether it is wise to propose building in such areas.
Lack of planning for modal shift in travel behaviour

In 2012 the Council has adopted a Low Carbon Action Plan, but this is not reflected in the local plan document.

Throughout the plan there is a clear bias towards supporting and increasing travel by private motor transport. Park and Ride is a great idea for out of town visitors but will do nothing to reduce car traffic and use within the urban area from an increased residential population. Moreover, the lack of integrated provision for enhanced cycling, walking and bus travel is a major deficit in the whole plan.

There is now good evidence from other areas that have adopted a sustainable travel strategy that a modal shift in travel behaviour can be achieved.
The local plan should ensure that housing, employment and community facilities are planned in such a way to be in line with the Low Carbon Action Plan Appendix V point 4.1 - Walkable communities, which the District has adopted:

"The council through its responsibility for planning, including the local development plan for the area...has a very major influence on development in the district. The way in which new neighbours are set our and existing ones are developed has a critical impact on transport sustainability. The extent of the relationship between planning and sustainable transport has in the past been overlooked, with the motor car being viewed in the twentieth century and the universal solution. More recently the negative impacts of the motor car have come to the fore, including noise, pollution, accidents, congestion, deterioration of the natural and build environments and not lease carbon emissions..there is now the realisation that there needs to be a new paradigm not just for transport but addressing the causes for the need for transport. This type of neighbourhood [walkable community] enjoys...improved health, reduced crime, improved social contract and being an inclusive community."

The local plan does not recognise need for walkable communities outlined in its own adopted document and demonstrates a total lack of ambition in looking to influence travel patterns.

In particular the location of primary schools, the siting of which appears unrelated to proposed housing density and distribution.Similarly, there is no mention of where the required GP practices would be sited. The positions and nature of the proposed 'community centres' where such practices might be sited again do not appear to relate to the density and distribution of the housing. Employment locations are being planned as far away as the gateway and relying on people travelling to work by the motorway network.

Housing Efficiency
Housing on green field sites should be at level 5 of the code for sustainable homes to reduce carbon emissions.


Affordable Housing

The Council has an overall target for affordable housing of 40%, but green field developments, should have a higher percentage of affordable homes - 50% than brownfield sites, to encourage brownfield development. This would strengthen the hand of the Council in negotiation with construction companies.

The council's own Strategic Housing Market Assessment (SHMA) suggests that
if all affordable housing needs are to be met, about 77% of new homes
should be affordable. Therefore, the council's lack of ambition regarding
affordable housing is disappointing and suggests greater concern for
developers than local residents who are in desperate need of suitable
housing. The Council risks building housing simply to increase inward migration without solving the housing problems in the district. The Council accepts the Affordable Housing Viability Assessment
(AHVA) assessment that it is possible to have up to 50% affordable housing,
yet it is not willing to take a flexible approach and categorise sites by
level of viability i.e. insist many sites have more than 40% affordable
housing. This is despite good work of the AHVA in setting out 3 categories
of site. The Council should work harder to maximise affordable build and
therefore should:
* Categorise each site by viability to maximise the number of affordable
houses which it recognises are so badly needed
* Increase density of housing which will reduce the cost per home and
therefore enable more affordable properties to be built
* Follow the advice in the AHVA, 7.49 and reduce the threshold for
affordable properties to 7 properties in urban areas
* Seek independent opinion regarding the 20% of Gross Development Value
(GDV) return figure in the AHVA upon which viability figures are based.
This figure is not justified in the document and expected GDV returns are
falling in the property industry e.g. see
http://www.thepropertyspeculator.co.uk/tag/gross-development-value/ which
suggests 15% is more realistic. LDZ who wrote the AHVA also work for
developers and so potentially they have an interest in inflating this
figure to the benefit of developers at the expense of local residents


SUMMARY

The SHMA suggests 77% of new homes should be affordable. The AHVA says up
to 50% affordable housing is possible, so the council must insist many
sites have more than 40% affordable housing. The Council should:
* Categorise each site by viability to maximise affordable housing
* Increase density of housing so more affordable properties are built
* Reduce the urban threshold for affordable properties to 7
* Seek independent opinion regarding the 20% of GDV return figure as 15% is
more realistic

Housing density and release of land

The District is justly proud of the excellent rural areas surrounding for
our small towns. Therefore it is scandalous that this local plan seeks to
build recklessly, and largely, on green field sites. This is
entirely unnecessary for the following reasons:
* There is not a clear link between economic growth and housing
* Housing should be focussed on brownfield sites within urban areas
* More effort should be made to use currently vacant homes and retail/
office spaces, especially homes above shops
* Excellent residential schemes of up to 200 homes per hectare are quite
common, so there is absolutely no reason to advocate 30 homes per hectare
(note section 4.23 of the Strategic Housing Land Availability Assessment,
SLHAA). As household size is tending to reduce, the need for small homes
continues to grow, enabling much higher housing densities than proposed in
this plan


Even if the council does not accept the full force of the above arguments,
it should still be acknowledged that there is uncertainty in their
prediction that so much housing is required. Therefore, it is imperative
that there is gradual release of land for housing over the timescale of
this plan, with the most suitable land released first e.g. only brownfield
sites usable for the first few years, then selective low-grade agricultural
land. Only when all other sites have been built upon, should the rest of
the allocated land be released for development.

SUMMARY

Building mainly on green fields is largely unnecessary because:
* Economic growth and housing aren't linked
* New housing should be on brownfield sites
* Vacant homes/ offices should be used
* 200 homes per hectare are common, so advocating only 30 homes per hectare
is wrong. Small homes are needed due to smaller households, enabling much
higher housing densities.

Uncertainty in predictions means land should be released gradually; most
suitable first e.g. only brownfield sites, then low-grade agricultural.