East Hanney Parish Council

Serving the people of East Hanney

Clerk: Guy Langton
12 Brookside, East Hanney
Wantage, Oxfordshire OX12 OJL

Tel: 01235 867403

Please click on the picture to view the white paper

East Hanney Parish Council has engaged with this consultation exercise and will be submitting responses to the Ministry as outlined below.

Ministry of Communities, Housing and Local Government Consultation White Paper: Planning for the Future.

Response from East Hanney Parish Council. 13th October 2020.

  1. 1. What three words do you associate most with the planning system in England?

Response: Imprecise, bias, destructive

  1. 2. Do you get involved with planning decisions in your local area? [Yes / No]

Yes

(a). If no, why not? [Don't know how to / It takes too long / It's too complicated / I don't care / Other – please specify]

Response: Not applicable.

3. Our proposals will make it much easier to access plans and contribute your views to planning decisions. How would you like to find out about plans and planning proposals in the future? [Social media / Online news / Newspaper / By post / Other – please specify]

Response: By post and online.

4. What are your top three priorities for planning in your local area? [Building homes for young people / building homes for the homeless / Protection of green spaces / The environment, biodiversity and action on climate change / Increasing the affordability of housing / The design of new homes and places / Supporting the high street / Supporting the local economy / More or better local infrastructure / Protection of existing heritage buildings or areas / Other – please specify]

Response: The environment, biodiversity and action on climate change. Protection of existing heritage buildings or areas. Protection of green spaces.

  1. 5. Do you agree that Local Plans should be simplified in line with our proposals? [Yes / No / Not sure. Please provide supporting statement.]

Response: No. The suggested number of zones are too few (3). In a post-Brexit, more environmentally conscious situation there needs to be an awareness that there should be zoning for the reservation of land for reserving land for agriculture, farming, forestry or minerals. The model referenced is the German model, a country with currently a lower population density (more people but more land).

6. Do you agree with our proposals for streamlining the development management content of Local Plans, and setting out general development management policies nationally? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes, we support the reduction of the timeframe, as outlined later in this paper but policies need to be kept local as the country is diverse, what is relevant to a coastal area of the south west is less relevant to a former mill town in industrial north west. Even within one principle planning area, there is diversity that needs to be recognized, and that can only be done locally.

7. (a) Do you agree with our proposals to replace existing legal and policy tests for Local Plans with a consolidated test of "sustainable development", which would include consideration of environmental impact? [Yes / No / Not sure. Please provide supporting statement.]

Response: No. They could benefit from review but a safety net must be retained and a consolidated sustainable development test could be superimposed to ensure consideration of environmental impacts.

(b). How could strategic, cross-boundary issues be best planned for in the absence of a formal Duty to Cooperate?

Response: The formal duty to cooperate should be maintained.

8. (a) Do you agree that a standard method for establishing housing requirements (that takes into account constraints) should be introduced? [Yes / No / Not sure. Please provide supporting statement.]

Response: No. All areas of the country cannot be treated the same way. There could be a standard method but this consultation does not provide the detail of how this would or could be applied. A model, for example, which would result in a more equal distribution of development could be beneficial.

(b). Do you agree that affordability and the extent of existing urban areas are appropriate indicators of the quantity of development to be accommodated? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes. However it is not necessarily the way forward. What should be happening is housing growth should be strategically considered, making use of new areas and not imposing development on existing communities. Plan to look forward, not back. For example, locally Oxford city's unmet need is what increases affordability issues in the city and surrounding area. Those houses have already been sold at a price that would put the owners in negative equity if affordability improved significantly. Employment opportunities must go hand-in-hand with any development.

9. (a). Do you agree that there should be automatic outline permission for areas for substantial development (Growth areas) with faster routes for detailed consent? [Yes / No / Not sure. Please provide supporting statement.]

Response: No. There are insufficient types of development zone. There should be areas identified for agriculture, forestry and minerals.

(b). Do you agree with our proposals above for the consent arrangements for Renewal and Protected areas? [Yes / No / Not sure. Please provide supporting statement.]

Response: No. Protected areas should be exactly that, protected. Renewal areas should be subject to protections as outlined in the paper for Protected areas, on a case by case basis and as currently exists.

(c). Do you think there is a case for allowing new settlements to be brought forward under the Nationally Significant Infrastructure Projects regime? [Yes / No / Not sure. Please provide supporting statement.]

Response: Not sure. There is insufficient detail in the consultation for formulate a response.

10. Do you agree with our proposals to make decision-making faster and more certain? [Yes / No / Not sure. Please provide supporting statement.]

Response: No. The Parish Council has experience of developers submitting multiple schemes for one piece of land at the same time. This proposal would actually encourage such activity, which is to the detriment of local planning outcomes, communities and the environment. The concept of more efficient decision making is welcome but these proposals are not the way of going about it. We agree that infrastructure assets could be fast-tracked but not dwellings as they are developer lead.

11. Do you agree with our proposals for accessible, web-based Local Plans? [Yes / No / Not sure. Please provide supporting statement.]

Response: No. It is not inclusive. To be fully accessible web-based local plans must run alongside the more traditional methods. Approx. 20% of the adult population does not have sufficient access to suitable IT.

12. Do you agree with our proposals for a 30 month statutory timescale for the production of Local Plans? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes. Indeed this should go further and the 30 months should sit within an election cycle so one administration can see the Plan through.

13. (a) Do you agree that Neighbourhood Plans should be retained in the reformed planning system? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes. And the weighting attributed to them should be increased due to the intricate and intimate knowledge of the neighbourhood, which a Local Authority cannot be expected to have.

(b). How can the neighbourhood planning process be developed to meet our objectives, such as in the use of digital tools and reflecting community preferences about design?

Response: More weight can be placed upon them, due to the intricate and intimate knowledge of the neighbourhood, which a Local Authority cannot be expected to have and the Authority should be required to adopt them in a statutory timescale (and not deliberately put them off to enable a Local Plan to be developed).

14. Do you agree there should be a stronger emphasis on the build out of developments? And if so, what further measures would you support? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes. However infrastructure funds should be paid on the commencement of the development to the local and Parish Councils. Also, if a developer does not substantially commence the works within a stated time scale (9 months), then planning permission is automatically withdrawn. If the developer does not adhere to an agreed, time-based phase plan (agreed with the Parish and Local councils), the financial penalty should be levied, to the benefit of the local area. This would ensure developments are not commenced but left incomplete across the country.

15. What do you think about the design of new development that has happened recently in your area? [Not sure or indifferent / Beautiful and/or well-designed / Ugly and/or poorly-designed / There hasn't been any / Other – please specify]

Response: Ugly and poorly designed. Beauty is constrained by developer's adherence to fairly rigid design templates.

16. Sustainability is at the heart of our proposals. What is your priority for sustainability in your area? [Less reliance on cars / More green and open spaces / Energy efficiency of new buildings / More trees / Other – please specify]

Response: More green and open spaces, as the Covid-19 pandemic has highlighted the need for. There should be less reliance on cars, development should be sustainable and as whole and complete communities not dormitory towns.

17. Do you agree with our proposals for improving the production and use of design guides and codes? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes, in principle. However, experience within the Vale of White Horse more widely and each village more locally demonstrates that beautiful design falls away in the face of financial pressure. Surely this is an area where strengthened Neighbourhood Plans would positively support a revised and renewed planning process.

18. Do you agree that we should establish a new body to support design coding and building better places, and that each authority should have a chief officer for design and place-making? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes, but avoid standardization of design, even on a local level this would not reflect the built vernacular of an area. Design should arise from a robust Neighourhood Plan process and be community driven.

19. Do you agree with our proposal to consider how design might be given greater emphasis in the strategic objectives for Homes England? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes, but designs like the one on p50, accompanying this question, is to avoided at all costs!

20. Do you agree with our proposals for implementing a fast-track for beauty? [Yes / No / Not sure. Please provide supporting statement.]

Response: No, there is no detailed control that would ensure the beautiful buildings are being provided.

21. When new development happens in your area, what is your priority for what comes with it? [More affordable housing / More or better infrastructure (such as transport, schools, health provision) / Design of new buildings / More shops and/or employment space / Green space/ Don't know / Other – please specify]

Response: All those things listed (More affordable housing; More or better infrastructure (such as transport, schools, health provision); Design of new buildings; More shops and/or employment space; Green space) are essential but there should also be an achieved zero-carbon build process and the local ecology and natural environment receive a net gain in biodiversity. It is essential that there is provision for equipped play areas which should be handed to the parish council (with its agreement) along with the required funds and not simply to a management company, to be ignored. There should be a guaranteed protection from flooding for new and existing local properties. Should flooding occur at new or existing local properties the financial risk is to be borne by the developer

22. (a) Should the Government replace the Community Infrastructure Levy and Section 106 planning obligations with a new consolidated Infrastructure Levy, which is charged as a fixed proportion of development value above a set threshold? [Yes / No / Not sure. Please provide supporting statement.]

Response: No change should take place unless it represents an increase in the funds available to the Parish councils as a result of any development.

(b) Should the Infrastructure Levy rates be set nationally at a single rate, set nationally at an area-specific rate, or set locally? [Nationally at a single rate / Nationally at an area-specific rate / Locally]

Response: No. There should be area-specific rates as outlined.

(c) Should the Infrastructure Levy aim to capture the same amount of value overall, or more value, to support greater investment in infrastructure, affordable housing and local communities? [Same amount overall / More value / Less value / Not sure. Please provide supporting statement.]

Response: More value for local communities.

(d) Should we allow local authorities to borrow against the Infrastructure Levy, to support infrastructure delivery in their area? [Yes / No / Not sure. Please provide supporting statement.]

Response: Within specific limitations. Local communities should be able to borrow down to the smaller authority level to ensure that vital facilities may be provided.

23. Do you agree that the scope of the reformed Infrastructure Levy should capture changes of use through permitted development rights? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes. Not all development would lead to an increase in the market value of the land.

24. (a). Do you agree that we should aim to secure at least the same amount of affordable housing under the Infrastructure Levy, and as much on-site affordable provision, as at present? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes, and it should be aligned to immediate local; need in type and quantity (e.g. provision of bungalows for those with limited mobility).

(b). Should affordable housing be secured as in-kind payment towards the Infrastructure Levy, or as a 'right to purchase' at discounted rates for local authorities? [Yes / No / Not sure. Please provide supporting statement.]

Response: It should be a right to purchase rather than an in-kind payment as a local authority may not consider the correct type of affordable home has been built to meet local need.

(c). If an in-kind delivery approach is taken, should we mitigate against local authority overpayment risk? [Yes / No / Not sure. Please provide supporting statement.]

Response: We believe it should not be an in-kind approach.

(d). If an in-kind delivery approach is taken, are there additional steps that would need to be taken to support affordable housing quality? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes, as under the current and proposed systems it may be built to the lowest acceptable quality, which is not what should be aimed for.

25. Should local authorities have fewer restrictions over how they spend the Infrastructure Levy? [Yes / No / Not sure. Please provide supporting statement.]

Response: Yes, but it should be allocated in the similar proportions as now, though the parish or town should be able to access a larger portion of the funds by direct contribution in order to provide facilities for the local community. It should also remain allocated to specific projects as the CIL is now, so but the spending authority, that way a smaller authority can ensure it meets the needs of its community at the time the funding is delivered, rather than when agreed, which may be may year's earlier.

(a) If yes, should an affordable housing 'ring-fence' be developed? [Yes / No / Not sure. Please provide supporting statement.]

Response: Not sure. The ringfence should be adaptable to meet local need.

26. Do you have any views on the potential impact of the proposals raised in this consultation on people with protected characteristics as defined in section 149 of the Equality Act 2010?

Response: Yes. Affordable homes need to meet local need not comply with a developer-lead designing template. Developers must be required to provide a range of home types on any major development to ensure all needs may be met. For example, homes with facilities for people with limited mobility, homes with facilities for live-in carers.