Response to Draft Local Plan

West Oxfordshire Draft Local Plan consultation document

West Oxfordshire District Council's Draft Local Plan was published for consultation in October 2012. It contains a wide range of new strategies and provisions that have direct relevance to the aims and objectives of Beacon Project Charlbury, especially in its recognition of the aims of the UK National Planning Policy Framework and the Localism Act. 


The consultation period closed on 19 December 2012, and Beacon Project Charlbury submitted the following specific comments:


3.4. The need for additional housing provision at rural service centres is recognised [Charlbury is designated a rural service centre of the West Oxfordshire district]. 

4.4. The need to sustain rural areas is recognised. 

4.5. The requirement to address the needs of those who cannot afford to buy or rent suitable market housing, including those who wish to self-build is recognised. 

4.6. The overall strategy principles are lauded. 

4.11. The need to respect the local character is welcome although it must be noted that with changes in energy policy, rural as well as urban development may change in nature and appearance due to increasing environmental design requirements such as orientation, passive energy gain, materials and substantially increased Building Regulation requirements under Part L from 2013. The Local Plan should acknowledge that residential design may not in future be a traditional version of the Cotswolds' form but an interpretation of it. 

4.33. 4.34. The additional requirement for housing and the demographic changes for key members of the community in rural areas are recognised. 4.35. The need for an imaginative approach to development including self-build is recognised. What is missing is an acknowledgement that a flexible approach to interpreting the Local Plan may be required to accommodate this approach.




4.37. This is a valuable addition to the Local Plan but clarity is required as if affordable housing is required, formal recognition of the interpretation of this important policy is essential. 

4.93. A separate site allocation approach for suitable development would be welcome as it appears that the development of approved Neighbourhood Plans is likely to be a lengthy process. 

5.32 This is a crucial item in the Draft Local Plan for the Beacon Project Charlbury. It reads:


"The NPPF refers to the possibility of allowing some market housing in rural areas where this would facilitate the provision of significant additional affordable housing to meet local needs. Any such proposal will be considered against the relevant policies of the Local Plan including in particular Core Policy 2 – Locating Development in the Right Places. Where the site is in a location that would not normally be considered appropriate for new housing, it will be for the developer or landowner to demonstrate not only why the site is suitable for housing, but also why a traditional rural exception site approach, i.e. one with 100% affordable housing, is not appropriate or achievable. In other words, they will need to demonstrate why the market housing is needed to subsidise the delivery of the affordable housing. In such cases, any market housing would be expected to be a subsidiary element of a predominantly affordable housing scheme."


The Beacon Project welcomes the provision for more flexibility in terms of the delivery of affordable housing, especially with regard to cross-subsidy by market housing. Since many landowners will not sell land for affordable only given the low land prices available for this, a more flexible planning approach will be necessary in order to achieve more affordable housing of a high environmental standard, as well as releasing more appropriate land for community housing projects, self-build projects, and other developments that will keep rural communities alive and dynamic places to live. 

SUMMARY

Generally, the proposed changes in the Draft Local Plan are welcome, however, for a group such as ours, representing a section of the local community who have been trying to self-manage a much-needed community housing project for some years, there remain what at times seem insurmountable obstacles. There are several important clauses in the NPPF which do not appear to be specifically addressed within the Draft Local Plan although general references might apply. These are highlighted as they have considerable significance for a group such as The Beacon Project:

•               The NPPF states that policies in local plans should follow the approach of presumption in favour of sustainable development so that it is clear that development which is sustainable can be approved without delay. All plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally (NPPF para 15). This does not appear to be formally acknowledged in the Local Plan as all presumptions and national objectives are subservient to the Local Plan conditions.

•                The NPPF states that planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Land allocations should be regularly reviewed. Where there is no prospect of a site being used for allocated employment use, applications for alternative uses of land or buildings should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities (NPPF para 22).

•               The NPPF states that if sufficient edge of centre sites cannot be identified, set policies for meeting the identified needs in other accessible locations that are well connected to the town centre (NPPF para 23). Applicants and local planning authorities should demonstrate flexibility (NPPF para 24).

•               At the heart of the NPPF is a presumption in favour of sustainable development which should be seen as a golden thread running through both plan-making and decision-taking (NPPF para 14). This sections states that local planning authorities should positively seek opportunities to meet the development needs of their area, and local plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change. For decision-taking, the NPPF advises where the development plan is silent or relevant policies are out-of-date, granting permission unless any adverse impacts would significantly and demonstrably outweigh the benefits when assessed against policies in this framework taken as a whole or, specific policies in this framework indicate development should be restricted. (NPPF para 14).

•               The NPPF also states that housing should be located where it will enhance or maintain the vitality of rural communities (NPPF para 55) and that Local Plans should allocate sites to promote development and flexible use of land, bringing forward new land where necessary and provide details on form, scale access and quantum where appropriate (NPPF para 157) and addresses the needs for all types of housing, including affordable housing and the needs of different groups within the community... sic,  and caters for housing demand and the scale of housing necessary to meet this demand (NPPF para 159).

•               The planning authority is charged by the NPPF to use their evidence base to ensure that their Local Plan meets the full objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in the framework including identifying key sites which are critical to the delivery of the housing strategy over the plan period (NPPF para 47).

  


Changing economic and demographic circumstances, the Localism Bill, Community Right to Build and the National Planning Policy Framework all indicate that a community group such as the Beacon Project should be able to undertake a sustainable community-based project as most stakeholders agree these objectives are essential to keep balanced rural communities. The Draft Local Plan offers encouragement through some new clauses referred to above, yet these steps are all meaningless unless the Local Plan is interpreted flexibly and with the intent to achieve positive outcomes as set out in the NPPF. The principles required to encourage sustainable community-led self-help development especially in the provision of balanced housing now exist, but an innovative interpretation of the changing legislation and overall direction indicated by the NPPF will be necessary from a planning policy perspective.