Response from Holbeck Homes / Holker Group , C/o Garner Planning Associates
1. Holbeck Homes / Holker Group , C/o Garner Planning Associates : 5 Jan 2016 14:52:00
Policy Area and Topic
Housing - Rural Housing - Exceptions Sites and Infilling & Rounding Off
Please make your comments below on the Policy Area / Topic you have selected. Where appropriate, make reference to the Option you prefer and the question number referred to in the Discussion Paper.
Representation on behalf of Holker Group
Consultation Questions – Rural Exceptions Sites and Infilling & Rounding Off
10. For each sub-topic, which option do you think is appropriate?
No comment on Rural Exception Policy.
Infilling and Rounding off in Small Villages and Hamlets
Option 2 Adopt a new policy but simply amend the definition of infilling and rounding off.
11. For each sub-topic, if these matters are progressed in accordance with Option 2, comments are invited on the possible changes suggested, the nature and level of evidence required and whether these matters may be better reviewed in the forthcoming single Local Plan review from 2017
Infilling and Rounding off in Small Villages and Hamlets
The Core Strategy intention is that 11% of 8,800 dwellings (i.e. 968 dwellings) are to be completed in the District’s small villages and hamlets in the period 2003/04 to 2024/25. In the period 2003/04 to 2014/15 just 347 dwellings were completed. To be on target 528 dwellings should have been completed, so completions are just 65% of the target.
In addition to the 347 dwellings completed in the rural areas there are a further 228 dwellings with planning permission. So assuming all the outstanding planning permissions become completions before the end of the plan period there is a need to grant planning permission for at least 393 dwellings (968 – (347+228)), allowing, unrealistically, for no slippage i.e. consents granted but not fully implemented.
The implications of the Community Infrastructure Levy, for small site delivery, is not yet known. As is indicated below the 35% affordable housing policy has been a brake on housing delivery. The combination of the two costs to development is unlikely to improve delivery.
In order to address the under-performance in housing completions and encourage more sites to come forward, the following amendments to policy are suggested:-
1. The definition of “infilling” relates to a “vacant plot”. This is open to differing interpretations by planning officers – either a plot for one dwelling or a plot to accommodate several dwellings. It is suggested the definition is changed to ”the filling, or partial filling, of a gap in an otherwise built-up frontage”.
2. The definition of “rounding off” is currently very restrictive. It includes “the completion of an incomplete group of buildings on land which is already partially developed”. Clearly there is a deliberate distinction drawn here between partially developed and previously developed, with the latter having a clear NPPF definition. The reference to partially developed therefore allows the development of residential gardens, agricultural buildings, recreation grounds etc. Nevertheless for the most part, partially developed land will in fact be previously developed land. As there is little or no industrial legacy around small villages and hamlets, the reference to partially developed land is extremely restrictive and has meant very few rounding off sites have been granted planning permission or completed since the introduction of the infilling and rounding off policy in October 2010. A review of the 2015 Housing Land Position Report indicates that no site has been granted permission and is under construction based on the “rounding off” policy definition. The only rounding off consent is at Greenside Farm (SL/2013/0594) and this consent was granted contrary to the planning officer’s recommendation because it was not considered to be neither infilling and rounding off. The definition needs to change to allow rounding off opportunities to come forward. The new definition should be:- “the expansion of small villages and hamlets to an existing logical physical feature, such as walls, hedgerows, trees, or existing built development.”
There is no need to refer to “small-scale” in the rounding off definition as this is already within the CS1.2 policy.
3. Affordable housing requirements of 35% relate to any development of 3 dwellings or more. Again by reference to the 2015 Housing Land Monitoring Report that not one affordable dwelling has been delivered within small villages and hamlets on a planning permission granted since the introduction of this requirement in October 2010. For the most part housing schemes have been limited to 1 or 2 dwellings. The only small village or hamlet scheme with planning permission and includes an affordable housing element is the aforementioned Greenside Farm site. For this site the on-site provision has been reduced because of a lack of need in the local area. The affordable housing threshold needs to change from 3 or more to more than 10 dwellings to encourage more housing delivery in the small villages and hamlets and reach the targets envisaged by the Core Strategy for this category of settlement.
12. If you think a ‘small village or hamlet’ should be more closely defined, what do you think the definition should be?
There is no need to specifically define a small village or hamlet. Appeal decisions at Goadsbarrow (SL/2011/0490) and (SL/2012/0295) that settlements of 8 and 9 dwellings respectively constitute a hamlet. Inspectors may take the same view of a lower number of dwellings. Any more restricted definition than 8 dwellings would impact on the delivery of housing from this category of settlement.
