Vale of White Horse District Council responses
Background
Vale of White Horse District Council officers attended a Stanford in the Vale Neighbourhood Planning Steering Group meeting on 17 March 2014, to explain the proposals for Stanford in the Vale in the emerging Vale Local Plan 2031 Part 1, and to answer questions about the Local Plan and the Neighbourhood Planning process.
The questions and written responses to the questions arising at the meeting are listed below. The response to each question will appear when the respective question is clicked on.
A .pdf version is available by clicking here (opens in new window/tab). A .doc version is available here.
It should be noted that these officer responses are based on the understanding at the time of writing, and this position may change, particularly in light of new evidence and responses to the current Local Plan ‘Housing Delivery Update’ consultation. We will review all responses we receive to the consultation and will publish our responses to these in due course.
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[wc_accordion_section title=”1. What is the total working population increase which they anticipate from the housing increase in the District?“]
The recently published Cambridge Econometrics (CE) report projects three different working population projections as follows;
| 2011 | 2021 | 2031 | |
| Baseline* | 67,200 | 71,700 | 76,400 |
| Alternative Population** | 67,200 | 72,100 | 77,900 |
| Planned Economic Growth*** | 67,200 | 81,600 | 90,200 |
* The population projections used for the Baseline projections are based on the ONS’ 2011-based interim Sub-National Population Projections made consistent with the latest mid-year estimates to 2011. Adjustments were made to the Baseline projections for education. This is because the education sector in Oxfordshire is thought to have particular characteristics that mean that benchmarking all its growth against the South East or UK is not appropriate going forward.
** The alternative population projections are thought to give a more likely picture of population growth in the future and represent the direct impact on employment that we might expect due to new policy and planned investment
***The direct additional employment by sector from the alternative population projection are added to the employment from the adjusted population-based projections and the model run to create the planned economic growth forecast with direct and indirect impacts.
The ‘planned economic growth’ scenario projects employment growth in the Vale of 23,000 during the period 2011-2031 and it was this scenario that was taken forward to inform the Oxfordshire Strategic Housing Market Assessment (SHMA). The Local Plan will therefore need to plan for 23,000 jobs to accommodate the additional growth in population during the period 2011-2031.
The Cambridge Econometrics report can be accessed on the Vale website at: http://www.whitehorsedc.gov.uk/services-and-advice/planning-and-building/planning-policy/new-local-plan-2031/evidence-base/oxfordsh
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[wc_accordion_section title=”2. Where do they anticipate that the difference between (increase in population) – (increase in jobs in the District) will seek employment?“]
The CE report anticipates that most of the future employment in the Vale will take place in the South-East of the district. Of the 10,200 above trend jobs (over and above what is ‘normally’ expected to happen) projected for Vale, 5,400 are projected for the Enterprise Zone with 2,500 projected for the Satellite technology industry. For details of those sectors we would expect to see ‘above trend’ growth in, please see Appendix A (attached).
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[wc_accordion_section title=”3. What implications have they identified for changes in commuting patterns?“]
The Strategic Housing Market Assessment (SHMA) assumes that commuting patterns will remain consistent in relative terms with a 4% net flow out of the district to work. This is consistent with the 2001 Census and takes account of the district’s proximity to larger employment centres such as Oxford and Swindon.
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[wc_accordion_section title=”4.What are the railway capacity implications for total housing increase in VOWH, South Oxfordshire and elsewhere along the whole of the main line route?“]
The council is currently not investigating rail capacity directly, but is working closely with the Highway Authority and has regular dialogue with Network Rail. The Highway Authority and Network Rail are also both formal consultees of the council’s consultation.
We have started dialogue with Network Rail to investigate the long term potential of introducing a new stopper service on the railway line west of Didcot.
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[wc_accordion_section title=”5. How will additional capacity on the main line be provided?“]
Network Rail is responsible for planning for rail capacity and set this out in their strategy documents. The electrification of the main line between Bristol and Paddington is designed to increase both speeds and capacity.
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[wc_accordion_section title=”6. What is the anticipated additional volume of traffic on the A417 from the additional housing planned in Faringdon, Shrivenham and Stanford in the Vale?“]
Detailed traffic modelling work is ongoing in partnership with Oxfordshire County Council. Information is available from:
Broadly speaking, our current transport assessment work shows that the proposed development is likely to lead to increased congestion at junctions in Wantage on the A417, and increased traffic along the A417 east of Wantage. Our currently modelling indicates the road network is within capacity west of Wantage. The next stage of the transport assessment work will include testing mitigation measures to help address traffic impacts.
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[wc_accordion_section title=”7. What measures are planned to improve safety and capacity on the A417 west of Wantage given the increased volume of traffic?“]
OCC are currently developing an A417 strategy, although this is focused on Wantage to Blewbury. Our current modelling indicates the road network is within capacity west of Wantage.
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[wc_accordion_section title=”8. Will it be possible to adopt our Neighbourhood Plan at the same time as the Local Plan is adopted, i.e Q1 2015? “]
In principle, yes it is possible to adopt a Neighbourhood Plan (NP) at the same time as the Local Plan Part 1 (LPP1), but it might be easier if it followed closely behind the LPP1, otherwise it may be difficult for an inspector to make decisions / judgements. This is particularly true if the Neighbourhood Plan is seeking to allocate sites.
Our current LPP1 timetable is for adoption in Summer 2015 (i.e. Q3 2015). We will need to work closely together to ensure conformity, as this approach would be likely to lead to LPP1 examination and NP examination at similar times. We will need to consider some of the practical implications of this.
This approach would also be subject to detailed project planning: it is important to note that the district council will not be running any referenda between January and June 2015. We would be happy to meet to discuss a draft Project Plan once this is available.
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[wc_accordion_section title=”9. How many dwellings must be identified in our Neighbourhood Plan for it to be acceptable to VWHDC?“]
Our Local Plan Part 1 will not identify specific numbers for each village to provide, so we don’t currently have an answer to this question.
It is important to remember that a Neighbourhood Plan is not about stopping development. In our Local Plan we are proposing that there should be a presumption in favour of sustainable development within the existing built area of the village, so we wouldn’t be setting a ‘maximum’ level of houses for the village.
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[wc_accordion_section title=”10. It would give the SC Committee and the wider community significant confidence in the NP process if it could be demonstrated that decisions made at Officer and Committee level supported the emerging NP Plan by refusing any applications that do not fit with the Primary and Contingency Sites proposed. Can we have an assurance that Officers and Planning Committee members will support the NP Process by NOT supporting or approving development which is clearly contrary to their own Local Policies (new and Saved) and the emerging NP?“]
We do not currently have a five year housing land supply in the Vale, and this means that we cannot give full weight to our Local Plan 2011 policies in relation to housing.
Once our new Local Plan is in place, we will be able to demonstrate a five year housing land supply, and will therefore be in a position to refuse applications where these don’t meet Local Plan housing policies.
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[wc_accordion_section title=”11. One example of the above is Blue Cedar Proposal at Horsecroft, which should NOT be granted at LA level for the following reasons, as supported by the recent SHLAA Report.
a) Policy Constraints – Greenfield, 2.1ha Flood Zone 2 and 2.1ha Flood
Zone 3, 4.2ha CTA, 4.2ha Archaeological constraints, Grade ll listed building
b) Accessibility – Horsecroft is fairly narrow and rural in character (in fact it’s a shared surface with no width to accommodate a pavement for traffic and pedestrians in wheelchairs or buggies to pass safely)
c) Site is unsuitable due to areas of flood risk and Conservation Target Area. (Also contrary to Saved Policy NE9)
d) Overall assessment of site deliverability – Undeliverable
Can they confirm they will NOT support Horsecroft or any other unsuitable site which conflicts with local Policy and is contrary to the emerging NP?”]
We cannot confirm this.
The SHLAA report is an evidence base document which informs the Local Plan. The inclusion of sites within the deliverable or developable supply of this study should not be taken to imply that the council will allocate them for housing development, nor that they would be approved if submitted as a planning application. Conversely, the exclusion of a site from this supply does not mean that it could not come forward, providing that the constraints identified could be satisfactorily overcome.
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[wc_accordion_section title=”12. As the land owner also owns land which is identified for development West of Faringdon Rd, would LA be prepared to suggest the Horsecroft development is moved here, particularly as it is highly likely to get support from the PC & NPSC at this alternative location?“]
The district council has to determine all planning applications submitted to it, and hence will need to determine the application submitted for the Horsecroft site. However, the NPSG could contact landowner and initiate discussions of this nature.
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[wc_accordion_section title=”13. Would they agree to refer all initial Planning enquiries to the NPSC for informal discussions before recommending Pre-App advice or Application?“]
Pre-application discussions are confidential, and we are not therefore in a position to share details with the NPSC unless we have agreement from the parties concerned. We can however refer to the emerging NP, where relevant, when responding to pre-application enquiries.
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[wc_accordion_section title=”14. In light of the SHLAA assessment of land North of Cottage Road, for up to 300 homes:-
a) are the LA considering this as a potential development site in the next 15 years or beyond and would they consider granting PP here if such a PP was to be made by current or subsequent owners and b) if granted, would this be in addition to the 290 West of Faringdon Rd or instead of?“]
a) We considered this site as part of our site selection process for the current Local Plan consultation. Details of all the sites we assessed across the district are set out in our Housing Delivery Update Supporting Paper (February 2014), which is available on our website. We considered two sites in Stanford in the Vale: land west of Faringdon Road (site 38) and land north of Cottage Road (site 32).
We have not proposed land north of Cottage Road for allocation in our current consultation , because our Landscape Capacity Study indicated that the majority of the site would be unsuitable for development due to landscape impacts: the rural approach to and setting of the village and the Conservation Area would be impacted by development of the site.
We therefore consider that land west of Faringdon Road is a preferable site for development in Stanford in the Vale, and are currently proposing to allocate this in the Local Plan.
If a planning application was submitted at the current time, we would have to consider this against the National Planning Policy Framework, as we do not have a five year housing land supply. However, once the new Local Plan is adopted, we will have a five year housing land supply, and we would therefore be able to apply Local Plan policies. The emerging Local Plan can also gain weight as we progress through the plan preparation process.
Our current proposed Local Plan policies are to allocate land to the West of Faringdon Road for housing, and to support applications for sustainable development within the existing built area of the village. Any development outside the existing built area of the village would need to be allocated through either the Neighbourhood Plan or through LPP2 (once the plan is adopted).
As noted above, our proposed Local Plan policies may be subject to change.
b) We would need to review this situation if it arose, including careful consideration of any cumulative impact.
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[wc_accordion_section title=”15. Re Part 2 of the Local Plan and further Small Sites to be identified,
a) what is considered to be a Small Site – between 1 and 200 homes? b) would the LA agree the NPSC can identify these sites (in consultation
with LA)? c) what numbers should we expect to have to accommodate in addition to the 290 + 73 at Jockey + any other Windfall Sites which may come forward prior to adoption of NP and Local Plan? “]
a) Yes.
b) An NP can allocate sites if it wishes to, but we cannot necessarily confirm that these can replace sites that may be proposed through the LPP1 or 2.
c) We are currently not proposing to identify minimum growth figures for individual villages (see answer to Q9 above).
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[wc_accordion_section title=”16. a) Can the NPSC negotiate with land owners and developers to secure benefits for the community in exchange for ‘support’ for proposals and what is legal position? i.e. transfer of land for community use, footpaths, ponds, contributions towards facilities, etc. and b) If not NPSC, would LA be prepared to negotiate and secure these on our behalf?“]
a) Yes
b) We have published draft site templates alongside our current consultation: these set out the key infrastructure requirements for each proposed site. Examples of our proposed requirements for the site West of Faringdon Road include contributions to bus services, a network of footpaths/cycleways within the site to connect to wider network, and additional planting along the A417. We would welcome any feedback on our draft site templates as part of your responses to the current ‘Housing Delivery Update’ consultation.
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[wc_accordion_section title=”17. How detailed and strict can our own Policies be in respect of what is and is not permitted in certain areas in relation to design and materials (Conservation Areas, In Settlement, Outside Settlement)“]
There are no set criteria for how a NP policy should be written, but it is important to remember that the plan should be positively prepared, and shouldn’t be used to stop development. It will need to be in general conformity with the strategic policies of the local plan and national policy and guidance.
The Vale is in the process of commissioning consultants who will be preparing a new and updated Design Guide for the Vale with a particular emphasis on local distinctiveness. It is intended that the new Design Guide is developed as a Supplementary Design Guide. Any design related policies in the neighbourhood plan must therefore be in conformity with the emerging Design Guide for the Vale.
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[wc_accordion_section title=”18. Can we identify a firm, defined Settlement Boundary to assist in making clear Policies relating to development inside and outside such Boundary line, as other LAs do?“]
In principle, the Neighbourhood Plan could identify a Settlement Boundary. However, this is not the approach we have taken in the Vale historically, partly because drawing a line on a map might encourage development to ‘fill in’ up to the line, whereas a more flexible policy approach gives flexibility to oppose unsuitable applications.
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[wc_accordion_section title=”19. Can we have a Meeting with Planning Officers and Planning Committee to brief them in our emerging NP so they can support us when considering applications.“]
Planning officers can attend meetings of the NP Steering Group at key stages. Anna is the first point of contact for the Group with the Council, and can pass draft policies and content to other colleagues for feedback and comment.
In terms of using the emerging NP when considering applications, the emerging NP can only carry limited weight in the early stages of preparation. Emerging NPs can start to gather more weight as they move through the consultation process, e.g. after the 6 week consultation period run by the LA (just before the examination). At this stage the amount of weight to be given to the plan will depend on the level of outstanding objections.
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[wc_accordion_section title=”20. How easy would it be to vary a Section 106 Agreement between the LA and land owners or developers if such amendments would clearly benefit the wider community, i.e. a Nature Reserve or Recreation Facility?“]
It is possible to vary S106 agreements but this would need to be undertaken through a legal process, and is not likely to be easy.
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[wc_accordion_section title=”21. Can we set up a Community Land Trust and transfer some of the 40% Affordable Housing land to the CLT to ensure it is genuinely for the benefit of local people from SITV and not elsewhere.“]
The requirement for 40% affordable housing is based on addressing the district-wide need, and therefore we would not be likely to want a situation where some of the affordable housing is restricted in perpetuity for those with a strong local connection only. Rural Exception Sites will always provide local priority in perpetuity.
Our new allocations policy enables 20% of all new build affordable housing units to be allocated to people with a strong local connection. This should be very helpful to housing register applicants in the rural areas. For example, a site with a total of 75 units would deliver 30 affordable homes, of which 6 would be allocated to people with defined local connection. Order of priority of housing need would still apply amongst local people, but for that 20% someone with the local connection could effectively be allocated the home above someone with a greater housing need but who does not have the local connection.
Whilst a local connection criterion is beneficial for local people who may not have the highest housing need, if this is more widely introduced than the use of the 20% allocations policy plus any rural exception sites, then those without any local connection to specific sites/villages will be adversely affected.
If Stanford in the Vale wishes to have affordable housing that is retained for local people in perpetuity then a Rural Exception site will be very appropriate and could also be delivered through a Community Land Trust.
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[wc_accordion_section title=”22. Do we HAVE to have 40 % Affordable Housing, as this will equate to close 100 new homes and likely families with little or no job prospects and the nearest possible job opportunities being in Faringdon, Grove or Harwell, all requiring the need for transport, which is contrary to National Policy?“]
Affordable housing need is calculated across the district as a whole. Our proposed policy approach is to require 40% affordable housing on all sites of three of more dwellings, subject to viability.
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[wc_accordion_section title=”23. How much Recreation or Leisure Land is required for every home or resident (%)?“]
There is no simple answer to this, as requirements are calculated on a site by site basis. The way it works is that we require a financial contribution per home. This contribution may be for on site or off site provision, depending on what the needs are. It could be towards a new Green Space, or could be a contribution to improve an existing facility.
Development would be expected to make appropriate provision for open space and recreational facilities, as outlined in the council’s Leisure and Sports Facilities Strategy and the Open Space, Sport and Recreation Future Provision SPD.
The Leisure and Sports Facilities Strategy can be accessed at: http://www.whitehorsedc.gov.uk/services-and-advice/planning-and-building/planning-policy/local-development-framework/core-strateg-6 The Open Space, Sport and Recreation Future Provision SPD can be accessed at: http://www.whitehorsedc.gov.uk/services-and-advice/planning-and-building/planning-policy/local-development-framework/supplementary-
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[wc_accordion_section title=”24. The 363 New homes proposed would suggest the need for a new 315 capacity (1.5 form) School.
a) What support would there be for a new Primary School and how would this be funded?
b) Where do LA feel would be most suitable locations for new School?
c) What uses would LA support on old School site? (Retail, Residential, Small Business, etc)”]
a) We are working closely with Oxfordshire County Council in order to ensure that an appropriate school solution is found to accommodate the growth proposed at Stanford in the Vale. The County Council is aware of the parish council’s desire to expand the existing, or build a new, primary school, and discussion of this will be part of the county council’s response to our current consultation. The appropriate school solution is still being considered, and hence we do not yet know whether the county council would support a new Primary School, or how this would be funded.
b) An appropriate location for a new School would need to be discussed with Oxfordshire County Council. We do not currently have a view on the most suitable location, if a new school is the most appropriate solution.
c) Our new proposed Local Plan includes a presumption in favour of sustainable development within the existing built area of the village. This policy therefore supports the principle of redevelopment of the school site. The school site is located within the Conservation Area, and any proposal would therefore need to avoid adverse impact on the Conservation Area.
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[wc_accordion_section title=”25. Why is the assumption that ‘we need more houses’ never counter-balanced by any strategy to reduce demand for new housing? We cannot go on forever just adding more housing. We need less demand and policies designed to provide accommodation via other means. E.g. substantially increasing the tax free allowance for the ‘rent a room’ scheme may significantly reduce demand for houses and quite quickly, better controls on immigration, policies that promote the family and thereby reduce demand for ‘single’ home owners, etc. What is the council doing to reduce demand?“]
Much of what is mentioned in this particular question is outside the scope of the Vale local authority and is controlled at a national level. One of the main roles of the planning authority is to provide for a sufficient number of housing units to meet the objectively assessed need of the district over the period of the plan, as determined by the most up to date evidence base which, in this instance is the Oxfordshire SHMA.
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[wc_accordion_section title=”26. The Local Plan and SHLAA proposals seem to be adopting the position of strongly protecting the Conservation Areas and Conservation Target Areas in and around SITV (which is to be applauded) otherwise the village will be totally destroyed by the house volumes being proposed. Can we assume that if our Neighbourhood Plan seeks to reinforce this protection and to limit housing within the existing settlement boundary and in the CTAs to only Regeneration of Existing, Regeneration of Brownfield or to ‘micro’ infill (normally 1 dwelling), or essential houses for agricultural workers/farmers, that our District Council will strongly support this position?“]
Any proposals in the neighbourhood plan must be sufficiently backed up by evidence. There is a presumption in favour of sustainable development in the National Planning Policy Framework which, for plan-making purposes means that local planning authorities should positively seek opportunities to meet the development needs of their area.
This principle should also be applied to neighbourhood plans. Therefore to limit development as set out in the question above would be restrictive and not in accordance with the principles of the NPPF. It would also be likely to conflict with the proposed core policy 3 of the emerging Vale Local Plan, which includes a presumption in favour of sustainable development within the existing built area of the village.
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[wc_accordion_section title=”27. Because the new housing supply figures are so much higher than anyone expected or wants why are we not giving serious consideration to creating an Oxfordshire New Town to supply many of the homes thereby reducing damaging high impacts on many existing villages? People want to live in a village not a village with massive identikit suburbs bolted on the side.“]
The Vale currently does not have a five year housing land supply. In order for the five year housing land supply to be restored, the Vale must identify sites capable of delivering 4,025 homes within the first five years of the plan (2014-2019). This includes a 20% buffer to meet the NPPF requirements which reflects the Vale’s past under delivery of housing. A new town would not solve the housing problems in the Vale in the shorter term as the associated infrastructure required would not be deliverable within the first five years.
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[wc_accordion_section title=”28. Why are the new developments all large, identikit homes from National House Builders, all made out of Ticky Tacky and all looking just the same? They could be plonked anywhere in the UK and you would not know the difference. The scale of these estates, the high density and the blandness of the designs is mostly what people object to. Most people are realistic that some new development is needed but it seems the headlong dash for volume trumps all else and is what ultimately ruins landscapes and rural settings that have taken centuries to evolve and mature.“]
The Vale is currently in the process of commissioning consultants to prepare new Design Guidelines for the Vale district, with a particular emphasis on local distinctiveness, in order to address this issue. It is the intention that public consultation on a draft of the new guidelines will take place in August 2014, alongside the consultation on the pre-submission LPP1.
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[wc_accordion_section title=”29. For every home that is ‘affordable’ someone else’s home becomes more expensive as a result and subsidising homes in this way perpetuates and exacerbates the problem in the medium-long term. What is the justification for 40% affordable housing in the West SITV proposals for 290 new homes? In the 2012 SITV Housing Survey only 8% of respondents felt they needed such homes. “]
Our proposed affordable housing policy seeks to deliver affordable housing to meet a district-wide need, not just the need for the locality as suggested by the 2012 Housing Survey for SITV.
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[wc_accordion_section title=”30. A major cause of high house prices and high density developments is the high price of land. Since the sums landowners can expect are very considerable (tens of millions of pounds for relatively modest fields) why can’t the council proactively engage between developers and landowners to play landowners off against each other to ensure only those willing to accept lower figures can get planning permission? At the moment it would seem that the developers and the landowners are making all the running.“]
It is not the role of the planning authority to ‘play landowners off against each other’. The planning authority seeks to provide for the objectively assessed need for housing in the district in line with the most up to date evidence available.
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[wc_accordion_section title=”31. It is said that all housing demand in the UK can currently be met by regeneration of brownfield sites. Why are we allowing any green-field development except as an exception?“]
As referred to above, the Vale needs to be in a position to identify sites capable of delivering 4,025 homes during the period 2014-2019 in order to ensure that a five year housing land supply is restored. Part of our criteria behind the identification of sites for the Local Plan Part 1 was that sites must be capable of accommodating at least 200 units. No brownfield site was found to meet this criterion and so we had to consider greenfield land.
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[wc_accordion_section title=”32. How can we have any confidence anything of significance in the Local Plan will be changed as part of the “Consultation Process”? The consultation seems only a rubber stamp exercise to tick the “consulted” box rather than a serious attempt to take in feedback and change the overall plans.“]
As part of the plan making process we must undertake consultation exercises. We go through all representations received and subsequently recommend the most appropriate amendments to plans having regard to these. The Local Plan will be examined by an independent inspector whose roles is to assess whether the plan has been prepared in accordance with the Duty to Cooperate, legal and procedural requirements, and whether it is sound. In this regard the plan must be positively prepared, justified, effective and consistent with national policy. Any changes to the Plan arising due to representations received will therefore be carefully examined at examination stage.
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