Response to First Consultation
(Lincolnshire Independents and Independents)
19th July 2019
Our members together represent many thousands of people. During the Local Plan Consultation Period, we have directly consulted our Parish Councils, written to members of the public though newsletters and held a public meeting in Leadenham. We have received significant responses, although there were complaints that members of the public found the documents hard to access and not easy to understand the ramifications.
Probably the biggest issue is the vision says nothing about sustainable communities, only “growth,” at any cost. That is carried through the rest of the document. Development must come with matching services and facilities, jobs. It must come with carbon reduction, which means local services, public transport, walking and cycle links and protection of soils and trees. Since the original vision, we have a poorer economy with reduced growth, which should lower our expectations of “growth”. The overall rate of growth is less than before, but still way too high, expecting houses to be built faster than ever before, and kept at that rate year on year for the next twenty plus years, setting us up to fail.
If the plan fails, we will be back to developers choosing where to build for their benefit, not for the benefit of our residents. Planning is supposed to get control of the process, so that development fits with what local people need and want.
In particular, the public are bewildered in that they understood the development so far planned was for the period of 2012 to 2036. Neighbourhood Plans were drawn up to match, with a huge amount of time and money. Yet all three options given for the villages break this and involve more growth for small and medium villages. In addition, we see the plan to make more allocations for over 2,300 more dwellings. Neighbourhood Plans will all need revision, which is in itself, a time-consuming process.
These recommended revisions from the CLISP are contrary to local democracy. Two years after the plan was adopted the “preferred option” is to ignore what is built and start again with a new 10 or 15%. This is together with the new additional allocations on smaller sites. Both these mechanisms take the power for decision-making away from the villages and gives it to twelve people on the Central Lincolnshire Local Plan Board, not even to our recently elected and politically representative District Councils!
Please have a look at our suggestions for improvement to the proposals. Please let me know what amendments you would like to see, so we can work with our councillors and members of the board to get the best outcomes for our communities.
I sent in my response as a personal one. Now we have a chance to work together to strengthen our voices.
Marianne Overton MBE, NK Independent Group (Lincolnshire Independents and Independents)
Response to Local Plan Revisions
Q1 Vision: Too focussed on “Growth”
1. The Vision is set around simply increasing growth is now a too narrow approach, and needs to recognise the latest movement towards a better quality of life through more sustainable development that is more in keeping with our resources.
The first and last paragraphs need to be deleted. The first because it is so narrow and the last because it is clearly untrue. You cannot solve those problems with more houses, you merely create more needs. We have more people bring more demands when public services are in a straight-jacket. Services and facilities need to match growth. Delete First and last paragraphs
“Central Lincolnshire will be a location of positive growth. Its city, market towns and many of its villages will see new homes built, new jobs created and improved infrastructure developed… “
“Through growth, current issues such as health inequalities, community deprivation, infrastructure deficit and low skills, all of which are currently found in pockets of Lincoln, Gainsborough and some rural areas, will be tackled and addressed. Growth will attract investment, businesses and new residents to the district.”
“Central Lincolnshire will be sustainable place to live, where growth of housing, employment and infrastructure are at a pace that maintains or enhances the quality of life of residents: A place where services, facilities, open spaces, mobility and jobs match our local needs. A place where we live in a pleasant, safe environment, with rich built and natural heritage, protected agricultural land, open spaces, clean air, designated local nature reserves and SSI’s. Local services, design and transport links will be created to minimise carbon emissions.”
The latter are anyway the things we are required to measure, so they need to be in the vision and in the objectives.
Question 2 Objectives
2c) Local Economy: enable small business units in rural areas to match local need?
Local business units may be allowed close to local centres of population, eg Navenby Parish Council wanted to build some local units.
Add: To improve and enhance infrastructure to match local needs.
Delete: To make efficient use of existing infrastructure.
Question 3 Policies not changing
Policy LP7: A Sustainable Visitor Economy should change. Please include:
Development of estates of static caravans or “holiday homes” will be limited to a small number of high-quality attractive accommodation units, where the need can be demonstrated. Yet by contrast, LP2 is prevents any development in the open countryside almost entirely.
Question 4 Plan Period
Plan period should not change. The Neighbourhood plans are all geared to that agreed time period. Changing the period would be equivalent to a new plan and require greater work. A reset to 2018 would be therefore be damaging and politically uncomfortable, forcing hard-won neighbourhood plans to also change, which is a slow and laborious.
Secondly growth levels are very difficult to predict with uncertainty over Brexit and whether people from abroad will need accommodation in the UK. North Kesteven gets a knock -on effect from the main conurbations like London, where prices have reversed and have just fallen for their fifteenth consecutive month.
Question 5 Heirarchy
The current hierarchy is good, reflecting natural character of areas.
The thresholds need to move with the growth of villages, so that villages tend to stay in the same threshold. The definition of a hamlet needs to reflect the spread nature of its few houses.
Question 6 Number of dwellings
The number of dwellings should be set at the minimum, so we have a better chance of the policy not being out of date in just a few years. The government target is already way out of reach, as it would require a faster rate of house-building than we have ever seen before- every year. Meanwhile the economy is slowing with Brexit
These Government method of calculating housing need is now outdated by Brexit, which was not foreseen at the time the calculation method was being developed.
This figure of growth is totally unrealistic, and increasingly unrealistic. It needs to be lower and decreasing over the next ten years. There is no advantage in a range. The first lower figure is totally unrealistic, so certainly no point in adding an even higher one.
Question 7: Strategic Growth Areas
- The Lincoln area should be reassessed. Now the congestion is worsening, more people are working other than Lincoln, for example at the MOD. Also many house-byers are not working and not commuting to Lincoln. A larger proportion should be “elsewhere”.
- B) and C) Growth around Gainsborough and Sleaford should be maintained. /Continued
- D) No, marketability should not be the first consideration or there is no point in planning, just leave it to market forces. Planning can help control market forces by limiting the supply in some areas to keep prices up and allow opportunity for both developer profit and contribution to public facilities.
Question 8 Urban Extensions
These should be kept. The dwellings should be near places of work. Expectations should not be reduced. As other places are less available, the pressure to build on these will increase.
Question 9 Allocations on small sites
The public have a lot of difficulty in engaging with placing of allocations and are shocked when they find out about them. It is not a good process. Windfall sites occur successfully, with public engagement, which gives the community a sound defence against poor quality speculative developments. Allocations are unhelpful and not needed.
Ten dwellings is too many for most villages. Small and medium villages can only realistically take smaller sites with 4-5 houses. The smallest number should be 1.
Allocations should only be made following a local village housing needs survey and built to match that local housing needs survey.
Question 10a and b Deallocations
No, these should not be deallocated. It could be expensive and not productive as a subsequent developer would be hard to resist. The Plan must deliver benefits across the region to maintain viable rural communities. Developers cannot be allowed to cherry-pick continuously and need to be encouraged to also develop proportionately in more rural areas.
Question 11 Growth in medium and small villages
Large, medium and small villages should have a percentage growth of 10%. No change needed.
There should not be higher amounts in some areas. 10% should be the maximum as there is already a mechanism for increased development through public consultation.
That puts residents at the heart of the decision-making on their own area.
Growth needs to match the capacity in the villages, not just the number of houses or presence of a school.
Question 12 Reset
Option 1 and 2 both fail in that a reset is the wrong approach. The plan was set out and agreed, now villages are asked to take more just a few short years into the plan. Villages that already have had the most development, get the same requirement again. This takes no account of development already received, pressurising local services and the character of the village. Worse it takes no account of permissions given but not yet built in the relatively short period the plan has been operating.
Option 2 also fails as it creates more development in places that have already taken the most development. Thus bigger villages get bigger faster, and certainly faster than their services and facilities can cope with.
Option 3. Is the best option increasing growth at the same rate, but villages were clear this growth was for the planned period and now you are extending the same rate year on year through the whole new period of the plan. This is wrong. It also fails in that the rate of growth is set at the old, out of date higher rate and not the newly calculated rate.
Option 4 Should be retaining the growth limits over the whole period of the plan, as originally agreed. Development can still occur, but with public support. This process has been working and development has occurred under this system.
All the options that increase development above what was previously agreed, mean that developers continue to cherry-pick and outlying areas are left to deteriorate. Some further development in popular areas is already occurring, with community support, and its limitation will promote more outlying areas, enabling a wider benefit, where it is needed.
Numbers should be based on permissions given not built housing. Definition of “built” needed.
Question 13 Affordable Housing
13a The level of affordable housing needed is already clear, doesn’t need reviewing and does need including, of course. A review of Council housing for rent should also be reviewed and included. /Continued
13b. I cannot see how the plan could do more to insist on affordable housing, and would need to look at that as it is about balancing priorities. We do need more affordable and council housing, it is true. We calculated a need of close on half new houses to be affordable. We dropped the required level from 35% to 25% and 15% in the urban extensions. It cannot conceivably go any lower. Only exception sites are 100% affordable- could that be increased?
Question 14. Cheaper Housing
14a No allocation of sites outside villages as it creates a ghetto effect that damages social cohesion and increases crime rates. It needs to be pepper pot approach and indiscernible from the commercial houses.
14b New entry level housing should be included with dwellings for older people in the “appropriate mix of housing”.
Question 15 Employment Land
Some small exception sites of employment land should be allowed near dwellings, to allow more local working and reduce transport needs.
They should be carried forward and not deallocated for the same reasons as with housing allocated sites.
They should not be allowed for other purposes. Exceptions can be made if required, but opening the flood gates to housing would be counter-productive.
The definition of employment sites could be improved. People working from home would still not count as an employment site.
Question 16 Local Centres?
Local sites could be identified, but no advantage is evident.
Question 17 Tourism in the Countryside?
Yes, greater clarity for tourism in the countryside should exclude large static caravan sites where there is little control about full time occupation and no little or no contribution made to the local council tax level. Holiday homes should be attractive and few in number, fitting with the agricultural character of our local countryside. By comparison LP2 has a much higher threshold to ensure quality
Question 19 Open Spaces
We need to be able to designate small open spaces of less that that specified in the example.
The amount of open space required per dwelling needs to be increased back to former levels. It can be commuted to offsite provision where appropriate. We are a rural area and expectations are higher. The health benefits are recognised and the savings on the public purse in terms of reduced long term conditions of diabetes, cardiovascular issues, respiratory diseases and mental health support.
Question 20 Energy performance
Houses should be required to have higher levels of energy-saving and charging points etc. The costs of this will decrease as it becomes universal and not specialist.
Question 21 Gypsy and traveller sites
Current need appears to be fulfilled in this area.
Question 25 Minimum Parking Standards
Minimum parking standards should apply, one per bedroom.
Question 28 Anything else?
The neighbourhood plans should be adopted and respected in the new Local Plan, as they were so thoroughly consulted on and received such strong support. Retrospective undoing of neighbourhood plans is unacceptable, bearing in mind the huge resources that went into their creation only two years ago. The curtilage of Welbourn in the neighbourhood plan should be retained.
Cllr Marianne Overton MBE, Councillor for North Kesteven District Cliff Villages and Lincolnshire County Council Bassingham and Welbourn Division, Hilltop Farm, Welbourn. Lincs LN5 0QH
07920 235 364 Marianne.email@example.com
Cllr Peter Lundgren Lead member for the Local Plan Elected member for Branston and Potterhanworth on North Kesteven District Council Member of the Central Lincolnshire Local Plan Committee White Home Farm, Branston Fen, Lincoln LN3 5UP
0775 111 2303 cllr_Peter_Lundgren@n-kesteven.gov.uk