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.
