As this project progresses, the answers to previously asked questions may change – particularly as Government make changes to National Planning Policy and as we receive more feedback as a result of other Neighbourhood Plans going to independent examination.
As soon as time allows, all Questions and Answers will be revisited and updated but in the meantime, please be aware that when you read the questions and answers below, the answer given on the most recent date (in brackets beside the questions) may supersede an earlier answer to the same question.
Frequently Asked Questions (Sep 2015)
Why is there is so much new information compared to the January 2015 consultation? (09/15)
In January it was necessary to present approximately 25 sites to the community. It was never likely to be the case that this process would result in sufficient clarity to allocate the small number of sites needed by the plan. There was always likely to be a second stage and these workshops are part of it. In order to inform this second stage of the process, more detailed advice has been taken on certain matters such as highways and from MSDC planning officers. So there has been change and updates, which is why sites such as Constance Wood Field and the Land behind St Stephens Church are been put forward as possible options.
Why have we published 3 sites as ‘No longer being considered? (09/15)
Since January we have learnt that there is a covenant in place for the Jeffreys Farm Front Field site (HKNP017) which states that the landowner would not erect any building of any type on it other than for a sports pavilion with storage and a toilet facilities. In short, any development on this field would be in breach of covenant. This led to a re-appraisal of the sustainability assessment for all Sugar Lane sites, as HKNP017 has no potential to deliver housing, which impacted the overall assessment of HKNP014 and HKNP016.
An officer from WSCC gave informal advice that the existing access has limited visibility and limited scope to improve it without purchasing additional land, and suggested moving access northwards to between existing mature trees to reduce impact on vegetation and allow full standard visibility splays to be incorporated into the design.
An officer from MSDC planning gave informal advice against the risk of using all the fields around Jefferies Farm, as it would potentially create a knock on or domino effect of development, and there would be little control over a mass estate being developed.
Could the covenant on Front Field, Jeffrey Farm, be lifted? (09/15)
That would be for negotiation between the landowner and the covenant holder.
Why have we allowed dispensations to Councillors with apparent conflicts of interest? (09/15)
Councillors are required to make declarations of interest relating to any matter being discussed at the Neighbourhood Plan Steering Group (NPSB) meetings and these declarations are recorded in the minutes for the meeting.
In accordance with the Horsted Keynes Parish Council Code of Conduct, 3 members of NPSG applied to the Clerk for dispensation to allow them to discuss and/or vote on matters relating to potential development sites within the Parish regardless of site location.
Councillors consider that without dispensation the work of the NPSG is unable to progress as there are only 4 members of the group.
Any dispensation granted will only apply at NPSG meetings – not at Parish Council meetings where final decisions will be made.
The Parish Council’s agreement that NPSG Councillors can apply for dispensation is recorded in the Parish Council minutes 14/07/15 to ensure transparency and to put the matter into the public domain.
What is the purpose of the Neighbourhood Plan? (09/15)
Neighbourhood plans are a fundamentally new tool to give communities more control over the type, location, size and design of development in their area. These plans, developed by a parish council or neighbourhood forum, become part of the development plan for the area once passed by an examiner and ratified by the community through a referendum. Planning application decisions in those neighbourhoods will then be made taking into account the policies set out in these very important plans.
What number of houses will MSDC settle for? (09/15)
We have been very clear throughout that the District Council is not setting a target, and meeting the objectively assessed need in full of 126 dwellings, which would not be supported by the Horsted Keynes community and the constraints that are in place at that location.
At no point has the District Council stated that Horsted Keynes must provide a specific number of homes. What was stated is that we must start with our objectively assessed need (126) and justify a lower plan number supported by evidence in order to be able to navigate successfully through the plan preparation process.
If the Neighbourhood Plan provides zero homes it will be challenged by developers and potentially fail at examination.
If the Neighbourhood Plan provides 126 homes it will be challenged by the community and potentially fail at examination and referendum.
I had heard that the planning rules that mean sites of 10 dwellings or less don’t have to provide any affordable housing have been scrapped. Is this true? (09/15)
Yes. Previously, small sites would not have had to provide affordable housing. However, in July 2015 there was a successful legal challenge by two Berkshire local authorities and the Government was ordered to scrap this.
Affordable housing policy is set by Mid Sussex District Council and their draft policy in the Emerging Local Plan did reflect the old guidance. As such, it is likely that they will review this and seek to ensure that small sites do provide some affordable housing.
Until the Emerging Local Plan is adopted – which could take another 12-18 months, their old Local Plan policy will apply. This states that sites of 15 dwellings or more, or 0.5 hectares or more, will provide 30% of the total number of units as affordable dwellings.
I saw recently that George Osbourne had announced an initiative to provide Starter Homes on rural exception sites. Is this true? (09/15)
Yes, in August 2015 George Osbourne announced a number of plans aimed at boosting the countryside economy. The Rural Productivity Plan covered issues ranging from high-speed broadband to school funding and childcare.
It also proposed that the government’s Starter Homes scheme will be rolled out to rural exception sites, in a bid to provide more housing for first-time buyers with existing links to rural areas.
Rural exception sites are sites that are delivered for affordable housing. This can either be 100% affordable housing or it can include a very small amount of market housing where it is needed to fund the scheme.
Starter Homes — discounted private-market homes for young first-time buyers — were intended for brownfield sites, so the intention is to allow this on rural exception sites.
These are only proposals at present, so are not in national policy or guidance. Our understanding is that the provision of Starter Homes as part of a rural exception site would be optional, i.e. you could just provide 100% affordable housing as normal.
The only site put forward in Horsted Keynes as a rural exception site is land at Constance Wood Field. This is owned by Mid Sussex District Council and it is our understanding that they would only wish for this to be developed for affordable housing. Whether they would want to include some Starter Homes is, at this stage, not known.
Once you have decided which sites to allocate, will I have another chance to comment? (09/15)
Whilst the Steering Group is the body that ultimately decides which sites go into the draft Plan, in reality the decision is largely made by the community. Any site allocation has to represent sustainable development but clearly it is important that we reflect, as far as is possible, what the community wants to see.
Before sites are allocated, we would re-engage with the respective landowners to address particular concerns that you raise. We would also then engage with the relevant statutory bodies. For example, if there were issues relating to access or pedestrian safety then we would run any draft policy past West Sussex County Council, the highway authority.
Once we have prepared the first draft of the plan, there will be a formal 6-week consultation process where you will have a chance to make your views known. We will look at all of those and decide whether to make changes to the plan. Once that has been done, we then submit the plan to Mid Sussex District Council and they run another formal 6-week consultation where you will again be able to make your views known. So there will be plenty of opportunities for you to comment on the plan as it evolves.
What is the purpose of this consultation? (09/15)
In order to have control over where growth should be located, the Neighbourhood Plan needs to allocate sites for development. These sites need be able to deliver the objectives of the Neighbourhood Plan which have previously been endorsed by the community. We therefore need to you to tell us which sites will be the best ones for delivering the objectives of the Neighbourhood Plan and why.
How will the information from this consultation be used? (09/15)
We will look at what you tell us and, alongside the sustainability assessments, consider which of the sites should go into the draft plan as specific allocations for development. We cannot allocate sites that are clearly unsustainable.
What is the sustainability assessment? (09/15)
The Neighbourhood Plan cannot simply allocate the most popular sites for development. Sites have to be ‘sustainable’ if their allocation is to be justified and the sustainability assessment has looked at the key criteria that are used to determine sustainability. Ultimately, the sites that go into the draft Neighbourhood Plan will need to be demonstrably sustainable but will also have to reflect the views of the community. It will clearly not be acceptable to propose a site for development in the plan that is unpopular with a significant proportion of the community.
Why haven’t you ranked the sites in the sustainability assessment? (09/15)
This process is not about creating a league table of sustainability. The Neighbourhood Plan does not have to allocate the ‘most’ sustainable site or sites. It has to demonstrate that the site(s) it does allocate are sustainable and are sustainable when compared to the alternatives. Also, the purpose of the sustainability assessment is to provide the community with a clear understanding of the issues and opportunities relating to each site. Ultimately this technical information needs to be combined with the views of the community in coming to a view about which sites to allocate.
That site spoils my view. Why is it scored ‘green’? (09/15)
The fact is that matters such as the view of an individual from their property are not planning matters. We have assessed the sites in terms of the contribution that they make to delivering the vision and objectives of the Neighbourhood Plan. These were developed in consultation with the community – the vision was published for comment in September 2014 and the objectives in November 2014. We have reflected the inputs from the comments we received.
This site has 5 ‘red’ scores and 10 ‘green’ scores but is rated overall as ‘red’. Why? (09/15)
The sustainability assessment is based on recognised sustainability criteria. These criteria have originated from those used by Mid Sussex District Council in developing its Local Plan and have been adapted to ensure they are directly relevant to Horsted Keynes. We have then asked our independent planning consultant to assess the sites against these criteria. In the process there is an element of professional judgement that has been applied. It is not appropriate to ‘score’ the sites based on the number of green or reds because each criteria would need to be weighted according to its importance and that exercise would be highly subjective – what is an important criterion to one person may not be important to someone else. This follows a recognised approach to assessing sustainability.
Why don’t we just have a vote to determine the most popular sites? (09/15)
Because experience elsewhere tells us that this will simply end up being a reflection of where voters live! It will not ensure that the most sustainable sites with the greatest potential to deliver the community benefits that the residents of Horsted Keynes want to see are delivered. We want your view on the sites and, importantly, why that is your view.
Can we suggest other uses that should be included on sites along with any housing development? (09/15)
Yes absolutely. We want to explore the opportunities that the sites can offer to deliver wider community benefits.
Some of these sites are very large. Do we have to allocate all of the land on any site? (09/15)
No, definitely not. If part of a site is suitable for development then it can be allocated. For example HKNP012 (The Old Rectory, Church Lane) is a very large site but the sustainability assessment has considered that it is a sustainable site only if a relatively small part of the site is developed. With the rest of the site given over to community open space, it will also help to protect against a larger development on the remainder of the land in future.
Will there be a further opportunity to comment on the sites that go into the draft plan? (09/15)
Absolutely. There is a referendum at the end of the Neighbourhood Plan preparation and we need the majority of those that vote to say ‘yes’ to the plan. If we get the wrong sites in the plan then it is likely that we will get a majority ‘no’ vote and the plan could therefore end up being scrapped. But before that there will be at least two formal consultation stages where you will be able to give your views once the plan has been drafted. It is also expected that we will want to confirm that the community is happy with the emerging plan through an informal consultation prior to this.
What’s in it for me from all of this development? (09/15)
The simple answer is that the delivery of the vision is what’s in it for the community of Horsted Keynes. If we deliver housing on sites then it can pay for the delivery of the other items of community infrastructure that you want – this could include, for example, the provision of a community shop. Also, if you don’t accept this opportunity to be involved in where development should go and what it will deliver, then these decisions will be made by Mid Sussex District Council and you will not have as much of a say.
What are we doing about phone mast and broadband? (09/15)
Possible sites have been identified for Phone Masts but it is up the telephone companies to request building permission to erect the mast. High Speed Broadband is now available in Horsted Keynes.
What is the difference between Affordable Housing and Social Housing? (09/15)
Affordable Housing is social housing for rent, owned by housing associations. It provides rented housing to eligible households whose needs are not met by the market. Eligibility is determined with regard to local incomes and local house prices.
Affordable Housing is where the rent is set at up to 80% of the local market rent
The following questions and answers were written in March 2015 and were intended to assist the consultation process by providing more information about the practical, economic, demographic and legal context in which neighbourhood planning is being undertaken in Mid Sussex and how this has affected neighbourhood planning in our own Parish.
If you are looking at the Q&A on the Parish website, you can go straight to the particular question that interests you by clicking on the question in the Table of Contents below.
Table of Contents
Q1 NEIGHBOURHOOD PLANNING IN GENERAL. (03/15)
Q1.1 Are Neighbourhood Plans (NPs) necessary? (03/15)
Q1.2 What are the benefits of having a NP? (03/15)
Q1.3 Is there a mandatory process needed to produce a NP? (03/15)
Q1.4 How does a local authority’s Objectively Assessed Need’s figure affect housing totals in a NP? (03/15)
Q1.5 Are there other benefits of having a NP? (03/15)
Q1.6 What are the definitions of affordable housing and local connection? (03/15)
Q2 MID SUSSEX DISTRICT COUNCIL AND NEIGHBOURHOOD PLANS. (03/15)
Q2.1 Do Mid Sussex District Council (MSDC) support neighbourhood planning? (03/15)
Q2.2 How many Parish Councils within Mid Sussex District are producing NPs? (03/15)
Q2.4 Have MSDC set an OAN figure for our parish and how did they calculate it? (03/15)
Q2.6 Will we not be protected from large developments even without a NP because we are in an AONB? (03/15)
Q2.8 Do not MSDC define Horsted Keynes as a small village? (03/15)
Q3 HORSTED KEYNES NEIGHBOURHOOD PLAN. (03/15)
Q3.1 What brief was given to the Steering Group and to the consultant? (03/15)
Q3.2 Why do we need any development? (03/15)
Q3.3 Can we not just have an option to say “No” to substantial development? (03/15)
Q3.4 In practice, how many houses will need to be built to fulfil the objective? (03/15)
Q3.5 People talk about a draft plan, but does one yet exist? (03/15)
Q3.6 When the NP is drafted, will there be a formal consultation period? (03/15)
Q3.7 Can I vote on the plan? (03/15)
Q4 DEVELOPMENT OF SUSTAINABLE SITES IN HORSTED KEYNES. (03/15)
Q4.1 Is the site sustainability assessment detail still available? (03/15)
Q4.4 What about the impact on the landscape, especially views from the west? (03/15)
Q4.10 How was the housing potential of each sustainable site assessed? (03/15)
Q5 INTEGRITY OF THE NEIGHBOURHOOD PLANNING PROCESS. (03/15)
Questions and Answers
Q1 NEIGHBOURHOOD PLANNING IN GENERAL
Q1.1 Are Neighbourhood Plans (NPs) necessary? (03/15)
Legally no. The Localism Act 2011 was designed to empower communities to have a greater say in their future, not to compel them to do so. So they are voluntary and available to those communities which consider the benefits of having a NP worth the time and effort and cost of producing one.
Q1.2 What are the benefits of having a NP? (03/15)
The UK planning environment is defined by the National Planning Policy Framework (NPPF). This has simplified the planning regime and created a presumption in favour of ‘sustainable development’, defined by the UN as development which meets “the needs of the present without compromising the ability of future generations to meet their own needs.” One of the five principles of sustainability adopted by the UK is achieving a sustainable economy, although this is tempered by the principle of environmental conservation.
The NPPF presumption in favour of sustainable development has given the green light to developers to go ahead with schemes which they can argue fulfil NPPF objectives and has made it harder for local authorities and communities to resist schemes they consider inappropriate for their area. Many cases have been reported in the media in the last year or so of large scale developments being imposed on small communities because well funded developers have been able to overwhelm local authority opposition to their plans by launching expensive appeals (see Q2.6 for local examples).
The Localism Act 2011 has offered mechanisms by which local policies can shape and constrain developments so that they are appropriate for an area and bring benefits to its local communities, namely local and neighbourhood plans. The Campaign to Protect Rural England (CPRE) say this in its guide to neighbourhood planning:
Neighbourhood Plans provide a great opportunity for you to have more influence on how the places in which you live and work will change over time. Your local knowledge, and your sense of what needs to be protected and what needs to change, can really make a difference.
It is important to note that once passed by referendum a NP gains statutory force. It becomes part of the local authority’s Local Plan, and must be taken into account in all future planning decisions.
Q1.3 Is there a mandatory process needed to produce a NP? (03/15)
No, but there is much advice about the stages need to produce a viable NP. The following programme has proved successful elsewhere:
- Data collection through household surveys to gather evidence about housing and infrastructure needs.
- Draft a Vision Statement describing what residents want their community to look like at the end of the planning period, 2031.
- Draft a Statement of Objectives to flesh out the vision.
- Draft Policies to support the objectives, including housing policies.
- Identify an Objective Assessment of (Housing) Need (OAN) for the community – for its own purposes the local authority must establish an OAN for its district and allocate individual OANs to the communities in its area.
- Develop site sustainability criteria consistent with local and national policy as a means of evaluating any sites that will be put forward.
- Make a call for land by placing notices in local media outlets publicising the requirement for land and the call period’s expiry date.
- Apply the sustainability criteria to any sites put forward in response to the land call to identify those which on balance may be judged sustainable.
- Assess the upper and lower limits of new build capacity resulting from the sustainability assessment and identify infrastructure issues.
- Develop policies for each sustainable site to fulfil the plan objectives and overall housing policies (e.g. on housing mix).
- Draft key statement and reports required by planning policies and guidelines such as the Sustainability Appraisal Scoping Report.
- Assemble documentary evidence supporting the policies drafted for the plan.
- Draft the Neighbourhood Plan document itself – a process that may overlap most of the above stages.
A neighbourhood plan belongs to the community for which it is being prepared, so community engagement and consultation will be an ongoing process through these stages to ensure that the residents are in broad agreement with the final document.
Once the NP has been drafted, there must be a minimum 6-week period of consultation that anyone can respond to, and the plan must be amended as necessary to take account of comments received. After that, the NP is submitted to the local authority and they hold a second minimum 6-week period of consultation to which anyone can respond. There then follows an independent examination of the plan. This examination will ensure that the NP fulfils legal and policy requirements and meets three key conditions, namely that (a) it has regard to national planning policy, (b) it is in general conformity with strategic policies in the development plan for the local area, and (c) it is compatible with EU obligations and human rights requirements. Amendments may then be required by the inspector before the NP can be finalised.
Finally, those on the electoral roll have an opportunity to vote for the plan at referendum. A majority of 50% of those voting plus 1 will ensure that the NP acquires legal status as part of the Local Plan and must be taken into account in all future planning decisions.
Q1.4 How does a local authority’s Objectively Assessed Need’s figure affect housing totals in a NP? (03/15)
The local authority’s OAN is based on existing demographics extrapolated into the future based on natural population growth and historical trends in migration patterns. It is a starting point, not a plan housing figure. The OAN allocated to a community must be taken into account, but the final figure included in any NP submitted for examination will be decided by the community bearing a number of constraints in mind (see Q3.5).
Q1.5 Are there other benefits of having a NP? (03/15)
Yes there are.
Provisions for affordable housing set out in section 39 of MSDC’s Housing Allocation Scheme are particularly favourable for parishes in an AONB who have a NP:
- In the case of first lettings of affordable housing in developments in such parishes, priority will be given to Applicants with a Local Connection to the parish where the homes are located.
- In the case of subsequent lettings of a designated 50% of the homes in the development, priority will be given to Applicants with a Local Connection to the parish where the homes are located.
- These special rules will apply once a NP has been submitted to MSDC even if planning permission for a development has been granted in advance of the adoption of the NP.
These provisions mean that 50% of rented affordable housing developed under a NP will be held in perpetuity for the benefit of those with a local connection. Without a NP, such housing can become available after the first occupancy to those with no such connection.
Other very significant benefits of having a NP are:
- The Community Infrastructure Levy (CIL) allows local authorities to set charges which developers must pay when bringing forward new development in order to contribute to new or enhanced services and infrastructure. 15% of CIL will go to local communities where development takes place to spend as they see fit (capped at a maximum of £100 per Council Tax paying dwelling), but this rises to 25% (uncapped) if a NP is in place. Affordable housing is exempt from the charge. Given MSDC’s proposed CIL for market dwellings in villages of £210/m2, one dwelling of 100m2 would yield £100 without a NP but £5,025 (25% of £21,000) with one, a bonus of £4,925 per dwelling. 60 say built under a NP would yield a gain to village funds of £295,500 to provide local facilities.
- The New Homes Bonus scheme provides cash for areas that allow new homes to be built in their area. Government funding has been set aside for local councils that welcome new housing development which they can spend to benefit their local community. Under the scheme the Government matches the council tax raised from new homes for the first six years through the New Homes Bonus. Councils and communities work together to decide how to spend the extra funding, e.g. giving local residents a council tax discount or boosting frontline services like rubbish collection.
Q1.6 What are the definitions of affordable housing and local connection? (03/15)
Affordable housing is housing provided at below market prices for those who are unable to afford to purchase or rent houses generally available on the open market without financial assistance. MSDC’s Policy DP29 in its draft Local Plan requires that 75% of such housing be for below market rental, with 25% for sale at below market rates. Rentals would be set at up to 80% of market rates, which is generally above social housing rents. MSDC will pursue a similar policy for shared ownership homes until such time as no one with a local connection applies.
A local connection means that either the housing applicant or a close relative has been resident in the area for a certain number of years. The full definition can be found in clause 38.6 of MSDC’s Housing Allocation Scheme.
Q2 MID SUSSEX DISTRICT COUNCIL AND NEIGHBOURHOOD PLANS
Q2.1 Do Mid Sussex District Council (MSDC) support neighbourhood planning? (03/15)
Yes, very much so. In their press release dated 23rd February 2015 they say:
MSDC support neighbourhood planning … Neighbourhood Planning ensures that local people decide the level of development in their local area.
Q2.2 How many Parish Councils within Mid Sussex District are producing NPs? (03/15)
All 19 Parish Councils within MSDC are actively progressing NPs. 3 are now live (including Ardingly) and in place and several more are at an advanced stage in their preparation.
Q2.3 The MSDC draft local plan does not list a requirement for building any specific number of houses, so is there any need to build any? (03/15)
It is not true that MSDC has no specific number. Its draft local plan is for an average of 650 new dwellings per year over the 17 year period from April 2014 to April 2031, a total target of 11,050. This was recently added to the draft plan.
MSDC submitted its first draft plan for inspection in 2013 but this was rejected on inspection because its housing figure was substantially too low. Its revised plan follows the approach set out in the National Planning Practice Guidance and specifies the above figures. Having excluded Burgess Hill (which will be building 3,500 dwellings of the total) and housing commitments already subject to planning permission elsewhere or previously allocated, MSDC have to allocate 1800 dwellings through neighbourhood plans (see Q2.5 below).
The approach recommended by the National Planning Practice Guidance can be viewed at https://planningguidance.planningportal.gov.uk/blog/guidance/housing-and-economic-development-needs-assessments/methodology-assessing-housing-need/.
Q2.4 Have MSDC set an OAN figure for our parish and how did they calculate it? (03/15)
MSDC have advised us that our OAN figure is 120 (see Q3.4 below). The relevant MSDC planning officer has recently advised:
The OAN figure for Horsted Keynes is set out in this Report which is available on our website https://www.midsussex.gov.uk/media/DraftHEDNA_Feb2015.pdf … This explains the methodology for arriving at the 120 OAN figure for the Parish. In simple terms, the Report takes the overall OAN for Mid Sussex and distributes it between the parishes according to the proportion of the total population and households each parish contained as at the Census date in 2011. Whilst this is not a perfect methodology, it is a reasonable one since the OAN is partly based on demographic needs, and the more households/population in a parish in 2011, the more new households will form from young people growing up.
The report referred to is a very detailed technical report of 112 pages in length.
Q2.5 Are we not just developing a NP on the assumption that if we don’t do so, MSDC will impose something far worse? (03/15)
No, this has not been our assumption. We see the main threat coming from developers, not MSDC. We know from the land call that a number of landowners are keen to sell land in the Parish for development, and our concern is that sooner or later developers will seek to take advantage of this. For example, if a house backing onto a potential development site came on the market, a developer could do a deal with the site owner to buy and demolish the house to give access to the site. Or sites outside the village boundary could be sold to a developer for a development that changed the whole character of the community.
Q2.6 Will we not be protected from large developments even without a NP because we are in an AONB? (03/15)
Although we do have some protection by being in an AONB, this does not automatically preclude development and legal loopholes abound. The Parish Council has therefore judged that we need the added protection of a NP. MSDC has recently stated:
It is important to progress the District Plan and neighbourhood plans to ensure that the Council can demonstrate that it has a five year supply of housing against the provision figure in the District Plan (proposed to be 650 dwellings per annum). The lack of an identifiable five year housing land supply means that permissions for housing are more likely to be granted planning permission either by the District Council or at Appeal. This can include identified parcels of land within the High Weald Area of Outstanding Natural Beauty and examples of this include sites in Ardingly, Handcross and Pease Pottage.
Ardingly has had to accept an unwanted development of 37 houses, but it has since voted in favour of its NP (88% on a turnout of 35%). Regarding Handcross and Pease Pottage, our liaison MSDC planning officer advises:
Both villages are in the Slaugham Parish which does not yet have a Neighbourhood Plan in place. The Parish is almost entirely within the AONB. The OAN for Slaugham Parish is 211 compared to 120 for Horsted Keynes. The permissions are likely to be implemented within 5 years.
The OAN of 211 for Slaugham covers the period to 2031. Between them, the two villages will be obliged to take 260 new dwellings plus 120 new care home places, a total likely to be built in the next five years that is 80% higher than their OAN. The grant of planning permissions was possible because there was no NP in place and illustrates the kind of risk we face until we have at least submitted one to MSDC.
Q2.7 When MSDC’s District Plan comes into effect, will we not be protected from major developments because MSDC Policy DP14 will prevent developments of over 10 houses in an AONB? (03/15)
No.
MSDC Policy DP29 on affordable housing is the policy referring to developments of over 10 houses because this is the threshold triggering a 30% provision of affordable housing. Policy DP14 addresses development in the High Weald AONB. MSDC officers have advised that it is very carefully worded and does not actually prevent such developments. Indeed, if you look at many local emerging plans within the AONB, larger sites are being allocated and passing inspection. A very local example of this is West Hoathly where there are three sites included in the plan with 15, 16 and 24 houses on those sites. All three sites are in Sharpthorne and outside the village’s present settlement boundary.
When MSDC refer to major developments, they have developments of many dozens, even hundreds, of houses in mind such as those agreed for neighbouring Lindfield. Remarks from MSDC officers designed to reassure enquirers with fears about major developments do not imply that we will be able to propose a very low level of development, let alone zero. In responding to one such enquirer who had proposed a figure of 60 as reasonable for our parish, the MSDC planning officer liaising with our Steering Group advised that we will be expected to have a housing target nearer to our OAN of 120 than zero.
Q2.8 Do not MSDC define Horsted Keynes as a small village? (03/15)
No. MSDC have said:
Horsted Keynes is defined as a ‘medium sized village’ providing essential services for the needs of their own residents and immediate surrounding communities. Other factors that neighbourhood plans will need to take into account are the needs of the area for development, the availability of suitable sites and localised infrastructure constraints and opportunities.
Q3 HORSTED KEYNES NEIGHBOURHOOD PLAN
Q3.1 What brief was given to the Steering Group and to the consultant? (03/15)
In 2011, the Parish Council heard advice from a MSDC councillor that a NP would be desirable because it would enable them to defend the parish against inappropriate development and judge for itself which sites were best suited for development and which were not. They decided that the parish would benefit from a NP, and to this end a working party was set up, leading to the surveys carried out in 2012.
It had become apparent by early 2014 that the workload of producing the plan required the employment of a consultant and the formation of a new working group, and volunteers were sought for the latter. A group comprised of parish councillors and volunteers was formed in the spring and became known as the Steering Group (SG). It is a sub-committee of the Parish Council appointed to develop a NP, operating within agreed standing orders and budgetary constraints, and its primary function has been to bring the NP process started in the parish in 2012 to completion.
In July 2014, having asked for quotations from three consultancies, the Parish Council appointed Chris Bowden of Navigus Planning Ltd. as the consultant, and he reports to the SG. His fees are part-funded by a reserve fund set up by the Parish Council, but the main part of the funding has come from a non-governmental organisation, the Community Development Foundation, which is a national organisation managing governmental funding programmes, in this case on behalf of the Department for Communities and Local Government. His brief has been to:
- carry out a gap analysis on NP work preceding his appointment;
- advise on community engagement, especially hard-reach-groups;
- gather and assess technical evidence;
- engage with statutory bodies and relevant landowners;
- formulate the sustainability criteria for assessing sites;
- apply those criteria to asses all 23 sites brought forward for allocation;
- advise on NP events and help in preparing display materials;
- draft plan policies, including reviewing polices in MSDC’s Local Plan;
- prepare Basic Conditions and Consultation Statements;
- prepare Strategic Environmental Assessment;
- meet with MSDC officers as required;
- support SG in responses to queries at all stages of community engagement;
- support at NP examination
Q3.2 Why do we need any development? (03/15)
Of all the questions we are asked, this is probably the most critical.
Firstly, we need to conform with MSDC’s planning policies which are based on a detailed report (the draft Housing and Economic Development Needs Assessment – HEDNA) suggesting that the district’s population will grow by 12%. It is the need for housing to accommodate such projected growth that has resulted in MSDC’s Objectively Assessed Need (OAN) figures and HK’s OAN allocation of 120.
Secondly, our plan needs to address the lack of new affordable homes. There are currently 19 applicants on the MSDC Housing Register with a local connection to HK, clear evidence of a need for affordable housing in the parish. The preamble to MSDC’s District Plan policy on affordable housing (DP29) notes that “44.2% of newly forming households in Mid Sussex cannot afford to rent or buy on the open market.” As the stock of social housing in HK has remained static for several decades, the number on the waiting list will continue to grow. As 30% of new developments exceeding 10 housing units must be affordable homes, a minimum of 64 new homes on such developments (19 affordable) would need to be built to meet current demand and more would be needed to allow for future demand.
Another factor is that, with an ageing population, growth in Horsted Keynes’ population is necessary to check the ageing profile of the village. Highly valued community assets such as school, shop, pubs and village club, and services such as the bus service, are more at risk (indeed some are on a knife edge, e.g. the currently closed post office) unless we can arrest a population profile that is ageing faster than average in Mid Sussex and the South East. This is because of a steady exodus from the village of young adults who wish to leave home (perhaps to start a family of their own) but cannot afford accommodation here. Census figures (ONS tables UV04 2001 and QS103EW 2011) show that in the decade to 2011, the percentage of young people under 17 in HK held up well against district or regional figures, but in the 17-35 age group it fell from 17% to 13% (a real decrease of 52 young adults), compared with 21% to 20% in Mid Sussex and 25% to 24% in the South East. We acknowledge that there are other reasons why young adults leave, but affordable rented accommodation would help, indeed encourage, those who wish to stay in the village to do so.
We do not believe that a plan for the future that fails to offer the prospect of new affordable housing is either acceptable in the present planning climate or consistent with the wishes of villagers. This requires modest growth and more housing from developments big enough to provide affordable dwellings, i.e. over 10 dwellings. As mentioned above, a housing total of 64 would over time only suffice to accommodate those already on MSDC’s waiting list, but something like 90 new dwellings on such developments over the plan period would provide 27 affordable homes and help to meet future demand. Such levels of provision would make a big difference to families with a connection to the village who are struggling to get onto the housing ladder as well as young people who want to leave home but would like to stay in the village if they could afford to do so, and this would achieve a valuable check on the ageing process.
The ageing problem was clearly identified as a major concern in the 2009 Village Plan and it was confirmed in the NP surveys carried out in 2012. This is why the draft Vision Statement which attracted a wide measure of support last year stated (from the projected perspective of 2031):
Housing within Horsted Keynes has increased by approximately 15% comprising mainly more affordable small and medium sized family properties, generally on developments beyond the current village boundaries. The addition of new families has offset the tendency towards an ageing population and maintained the demographic balance in line with that of the region as a whole.
15% over 16 years averages less than 1% per year, a figure consistent with the aim of modest growth. This aim translated into Objective 3 which (in its new form) states:
Increase the population and meet their housing needs over the planned period with emphasis on housing that addresses the needs of younger people and families to help maintain the village age profile.
Q3.3 Can we not just have an option to say “No” to substantial development? (03/15)
A neighbourhood plan cannot be used to say ‘no’ to development because the policy presumption in favour of sustainable development is nation-wide (see Q1.2 above). Equally it does not have to plan for ‘substantial’ development (although everyone’s definition of this will be different) but the evidence gathered through the NP surveys suggests that there are significant numbers of people who would like to continue to live in Horsted Keynes in the future but may be unable to, either because there is no small, first-time buyer housing at relatively affordable prices, insufficient social rented housing, or no smaller properties for older people to ‘downsize’ to. Planning for growth seeks to address these real needs.
Q3.4 In practice, how many houses will need to be built to fulfil the objective? (03/15)
The final number will depend on a number of factors. The MSDC planning officer liaising with the Steering Group has put it this way:
The amount of development planned needs to take account of the OAN number, but also needs to take into account other factors such as constraints (like the AONB), the capacity of suitable, available and achievable sites and the sustainability of the amount of growth planned. Infrastructure will also be a key consideration, and this may be a constraint (if there is insufficient capacity and it cannot be improved) or an opportunity (if additional development could fund new infrastructure provision). This may result in a lower plan figure than an OAN figure, or it may result in a higher figure. The Neighbourhood Plan should be following all of the evidence. Therefore it may be legitimate to only allocate housing sites for approximately 60 dwellings over the plan as opposed to 120.
120 is the OAN figure MSDC has allocated to our parish. As noted in Q3.2, 60 new dwellings on developments of over 10 dwellings would produce 18 affordable homes, but 90 would produce 27. This is one of the factors that will influence the parish’s decision.
Q3.5 People talk about a draft plan, but does one yet exist? (03/15)
No.
Major sections of the plan have yet to be drafted, including the site selection section which has been the main focus of our consultations since the Community Consultation event on 24th Jauary.
Q3.6 When the NP is drafted, will there be a formal consultation period? (03/15)
Yes.
We will continue to engage with the community through to the production of a draft NP. Once the Steering Group has satisfied the Parish Council that the informal consultation process has been completed, there will be a formal, statutory 6-week consultation period when you will be able to comment on the draft NP.
Q3.7 Can I vote on the plan? (03/15)
If you live in the parish and are on the electoral roll, yes. Once the plan has been reviewed following our consultations, it will go to MSDC who will refer it to an independent inspector for examination. If (subject to revisions required by the inspector) it passes scrutiny, there will be a referendum in the Parish where all of those on the electoral roll will be able to vote to accept or reject the plan. Those who disagree with key parts of the plan as well as those who do not wish to have a plan at all can vote No.
Q4 DEVELOPMENT OF SUSTAINABLE SITES IN HORSTED KEYNES
Q4.1 Is the site sustainability assessment detail still available? (03/15)
Yes it is, on the parish website. Go to the Neighbourhood Plan pages and click on NP Site Assessment Results which will take you to a page providing results for each individual site – plus any subsequent amendments. Alternatively to see the single document covering all sites, go to the NP Call for Land page and click on Site specific results and the full site sustainability analysis document can be viewed. Repeatedly click on the Magnify + icon until you can easily read the text and then used the direction keys to navigate around the document. Don’t forget to also view the subsequent amendments on the NP Site Assessment Results page.
Q4.2 Did the sustainability assessment of sites put forward by landowners take account of conservation of habitat and other environmental concerns? (03/15)
Very much so.
Under ‘Heritage Assets’ and ‘Natural Environment’, it assessed if sites contained listed buildings, conservation areas, sites of special scientific interest or nature conservation importance, local wildlife sites or nature reserves, ancient woodland, tree preservation areas or important hedgerows. In making his assessments, our consultant took account of local, national and European policies. In addition, he has consulted on the Draft Sustainability Appraisal Scoping Report which is required to support the Neighbourhood Plan with Natural England, the Environment Agency and English Heritage and they have approved the extent of the assessment and the particular issues relating to the environment.
Q4.3 What about access to and from the sites for pedestrians and vehicles and proximity to the village centre? (03/15)
This was another major area of investigation. Access from the sites to the village centre, St Giles School, bus stops and significant highways, public rights of way, the existence or otherwise of footpaths, connections to neighbouring areas, and traffic impact on the village centre were all taken into account. In addition, the relevant authority at West Sussex County Council has been consulted, and their initial advice may be summarised as follows:
HKNP002 – Police House Field: “There are no in-principle issues with this proposal.” The best access to the site would to be at its western end.
HKNP012 – The Old Rectory, Church Lane: “The site is accessed along what are in places narrow lanes with no specific pedestrian facilities. The carriageway widths and alignments would act to restrict vehicle speeds.” Nevertheless, a variety of concerns for pedestrian safety exist, and the advice ends as follows: “If this site were to be taken forward, greater consideration would need to be given to providing for pedestrians on the existing narrow lanes.” [Consultation with the landowners of this site is seeking to address these concerns.]
HKNP013 – Jeffreys Farm Buildings: “Whilst vehicular access would need to be considered in greater detail …, the principle of development is otherwise acceptable.” A footpath linkage to Lewes Road would be needed.
HKNP014 – Land to North of Farm Buildings, Jeffreys Farm :”Whilst vehicular access would need to be considered in greater detail …, the principle of development is otherwise acceptable. It is recommended that a pedestrian route is provided alongside the proposed vehicular access.”
HKNP016 – Sugar Lane Field: “Two access options are indicated. An access (vehicular and pedestrian) would be better placed to the south or the centre of the site (there is no reason why a crossroads arrangement could not be provided with Jefferies). … The principle of development is otherwise acceptable.”
HKNP017 – Jeffreys Farm Field: “Whilst vehicular access would need to be considered in greater detail …, the principle of development is otherwise acceptable. A length of pedestrian footway would need … to tie in with existing footways on Lewes Road.”
Q4.4 What about the impact on the landscape, especially views from the west? (03/15)
This was one of the reasons why MSDC assessed HKNP016 and HKNP017 (the two sites alongside Sugar Lane) as “not currently developable”. It would apply even more so to HKNP013 and HKNP014. However, the Sugar Lane Field is in fact naturally screened from the west by a large bank of trees and by its lower level, although some additional screening may be needed. The Jeffreys Farm Field is higher and more exposed from a western viewpoint, and if developed more extensive screening would be needed. Development of the other two sites further from Sugar Lane could also be suitably screened to protect views from the west. Such requirements would be included in specific site policies.
It should be noted that that several buildings and houses on the ridgeline to the south and east of Jeffreys Field are already clearly visible from the west.
Q4.5 Why can’t we keep the current village boundary, meeting growth by infilling or conversion of large properties to flats? (03/15)
This strategy would provide very limited new accommodation, could not provide a reliable source of land or convertible properties, and would fail to keep pace with projected population growth. It would also produce zero affordable housing.
Many parishes preparing NPs have concluded that they can only accommodate new development by redrawing their village curtilage, as illustrated by the cases of West Hoathly cited earlier, where all three proposed sites are outside Sharpthorne’s settlement boundary, and Ardingly which has voted in favour of a plan containing a site to the south of its settlement boundary. This is because the provision of new affordable housing is a key national policy objective and suitable parcels of land will often not be available inside current boundaries for developments of over 10 homes. The Localism Act 2011 recognised this reality and permits village boundaries to be extended as part of the NP process.
It was apparent very early in our consultations that the widespread desire in the village to protect the green spaces at its heart (the village green, cricket pitch and recreation ground) coupled with past infilling would drive much new development to the edges of the village. The Vision Statement quoted in Q3.2 above therefore envisaged an extension of the curtilage to allow for the unavailability of space elsewhere, and it must be noted that the two sites alongside Sugar Lane identified as sustainable were already on MSDC’s SHLAA (Strategic Housing Land Availability Assessment) list because of their eventual potential for development despite their being beyond the present boundary.
Looking at historical maps, it is clear that the settlement boundary has sometimes expanded in the past. A map dated 1961 shows no Hamsland, Challoners, Boxes Lane, or Cheeleys. More examples can be found going further back in time. Villagers now take such past expansions for granted, and experience shows that they will do so again if the boundary gets enlarged to provide new homes on 2-3 hectares of land on the western perimeter.
It is for residents as a whole to judge, but we believe that many residents would take the view that the Jeffreys Farm sites, especially if the main housing is confined to those adjacent to Sugar Lane, would amount to a relatively minor boundary extension compared with developments in the past, such as approximately 140 dwellings in Hamsland and Challoners built in the latter half of the last century.
Q4.6 Why are we disregarding MSDC’s view that Sugar Lane is a “defensible boundary” which protects the village from a westerly development sprawl? (03/15)
We are not disregarding MSDC’s view but identifying ways to address their concerns.
On the specific question of losing a defensible boundary on the western perimeter of the village and thus risking development sprawl, the consultant has advised that a defensible boundary can be re-established by adopting site policies for the provision of a continuous line of designated green spaces to the west of new dwellings. This important requirement would be stated in any site policy in order that development could be acceptable.
It should be noted that several houses exist on the western side of Sugar Lane’s extension into Lewes Road and Treemans Lane, and an access side road running parallel to Sugar Lane behind the existing line of trees and bushes topping the high bank which borders it would enable such ribbon development to be extended as far as the junction with Keysford Lane and retain heavy screening which makes the field invisible to local residents and passing traffic. This and other options will emerge as the draft plan is finalised before we reach the statutory six week consultation period.
Q4.7 Does not the fact that the Jeffreys Farm Field is protected by a covenant rule out any development on that site and should it not be kept for the recreational benefit of residents which the covenantor envisaged? (03/15)
It may do, but it is not unusual for a site otherwise suitable for development to be protected by covenant.
The covenant prevents any building on the site except for the erection of a cricket pavilion. However, no such use to date has been made of the field, and given the existence of a cricket ground and pavilion behind The Crown Pub and the central recreation ground, facilities which the NP seeks to protect, there has been no move to date turn it into a cricket pitch or to use it for other recreational purposes. It would therefore be untrue to suggest that any future development of the field would deprive the village of a valued leisure facility. On the contrary, the provision of recreational green space on such a development would add to the village facilities, not decrease them.
The covenant does not prevent other uses of the field such as the construction of an access road to adjoining sites. The Steering Group will be giving the implications of the covenant for the NP further consideration.
Q4.8 Is there not a danger that even by considering the sites alongside Sugar Lane for the NP, we are inviting MSDC to reconsider them, even though they previously deemed them “undevelopable”? (03/15)
This question is based on the premise that development there is both undesirable and unnecessary, a matter the community as a whole will decide. However, given our consultant’s advice that deliverable ways of meeting the concerns of MSDC are available and approval in principle from the West Sussex highways authority (see Q4.3 above), we think many will agree that the benefits of developing the sites identified by the sustainability assessment and their potential contribution to our plan objectives make any readiness by MSDC to re-assess them welcome.
It must be remembered that we are not drawing MSDC’s attention to these sites because they are already on MSDC’s Strategic Housing Land Availability Assessment (SHLAA) list which is reviewed annually. Nor has MSDC rated them “undevelopable“, but only “not currently developable.” This does not rule out eventual development by MSDC, and if the landowner wishes to see them developed, then we now know that ways of meeting MSDC’s concerns may well be available. By including the sites in the NP, we gain local control over site policies that we would not otherwise have.
If it is argued that the sites’ exclusion from a NP for which the community eventually votes should prevent MSDC granting permission to develop them, we have to point out that the sites were independently assessed as sustainable and as contributing to plan objectives. As such, they fulfil the national presumption favouring sustainable development. The evidence is in the public domain, and the community as a whole has no reason or justification for disregarding it.
Q4.9 Is not the HKNP Vision that “new residential developments have been spread throughout the parish” at odds with the sustainability criteria requiring new development to give reasonable pedestrian access to the village centre? (03/15)
Yes, it would appear so, because the sustainability criteria were not available when this clause was drafted. Local authorities deem sites that are away from settlements in open countryside to be less sustainable than sites on the edge of settlements. The MSDC Local Plan supports this principle, and we have been advised that if we include sites well away from the village settlement in our draft plan it is very likely that the examiner will recommend their deletion.
We will propose new wording and consult on the change in due course.
Q4.10 How was the housing potential of each sustainable site assessed? (03/15)
The rule of thumb the consultant considered would satisfy high-level planning criteria for rural villages was 20-25 houses per hectare, but all sites selected would need an access road onto it with footpaths. This means that a smaller site would have proportionately less room for housing whereas a cluster of sites sharing the same access road or a very large site would have more. The consultant took account of the requirement that developments should not be overly dense. Housing density per site would also be affected by the mix of housing required for the site (1-bed, 2-bed, etc; houses versus flats). Only a detailed planning application could define precise numbers, although site policies will define the maximum permissible.
Q4.11 Is it not true that the land call produced a huge over-provision of land compared with the aim of modest growth? (03/15)
That is not the SG’s view. We had no control over the volume or size of sites that came forward in response to the land call, nor could we have known whether any of them would survive the sustainability assessment process. In the event, 20 sites were offered for housing development, very much more than we expected, but only six of them were assessed as meeting the sustainability criteria, and in one case in particular (the Old Rectory), its capacity to accommodate new housing greatly exceeded the NP housing objective and was at odds with other key objectives. All this confirmed that it was better to have too much land on offer than too little.
Q4.12 If development is inevitable, can the NP ensure that it is spread fairly evenly in future years? (03/15)
No, unfortunately this is not possible. But the consultant advises that market forces are likely to deter the simultaneous development of several sites to avoid over-supply.
Q4.13 As the boundary shown for the HKNP013 site at the January Community Consultation was incorrect, is the correct boundary map now available? (03/15)
Yes, it can now be accessed in the NP section of the Parish website.
Q5 INTEGRITY OF THE NEIGHBOURHOOD PLANNING PROCESS
Q5.1 Is it true that the draft NP policies are no longer fit for purpose and the objectives have been changed to suit the sites put forward and no longer reflect the result of consultations with residents? (03/15)
No. The objectives have not been altered and have remained as presented for consultation, long before the call for land was issued and sites put forward.
In last year’s community engagement process, all the objectives received over 90% support of those consulted except for objective 3 (see Q3.2 above) which received 71% support. A rephrasing of objective 3 was put forward at the Open Day and was marginally preferred to the original. But this rephrasing had nothing whatever to do with the sites put forward and makes no reference to them.
The policy consultation at the Open Day covered seven policy statements and the responses to them have been publicised on the parish website. The cumulative total in favour of the policies was 643 with 61 against, Yeses therefore outnumbering Noes by over 10 to 1. This suggests that for the great majority of those wishing to register an opinion, the NP policies being developed remain very much fit for purpose and the objectives also command huge majority support.
Q5.2 Is the Steering Group’s view justified that coloured stickers placed in Yes and No columns at the Open Day and on other occasions amount to valid statistical evidence, given possible abuse (e.g. by unsupervised children)? (03/15)
The use of stickers was adopted last year as a quick and engaging way of enabling people to record their preferences, and whilst statistically imperfect it has proved an effective method. For example, as noted in Q5.1, over 700 stickers were applied on the policy charts at the Open Day with over 10 to 1 in favour of the proposed policies. A member of the Steering Group stood alongside the tables with policy charts for nearly three hours, and apart from seeing (indeed encouraging) two or three children to place stickers under parental supervision, he saw no abuse. This was not a referendum but a test of opinion which had to be practicable in a crowded venue with limited time, and the Steering Group do not agree with the criticism that only a purist but very cumbersome method such as signed responses to questionnaires could enable them to come to valid conclusions about the state of opinion among those who attended.
Q5.3 Would we not be better off accepting MSDC’s independent view of the suitability of the Jeffreys Farm and other sites rather than the opinion of the consultants who are biased towards development in their professional capacity? (03/15)
The imputation of bias has no foundation. The consultant has only done what he has been asked to do, and this has included giving us advice about which NP proposals are likely to succeed in the present planning environment and which are likely to fail. MSDC has an obligation to implement the NPPF presumption in favour of sustainable development, and it is this systemic ‘bias’ with which we must contend and which is one of the factors pushing us towards more rather than less development. In these circumstances, it makes little sense to the Steering Group to hand over responsibility for site selection to MSDC, and we believe most residents would agree.
It is to MSDC’s credit that they are strongly encouraging parishes to develop their own plans and to identify sites which meet sustainable criteria. The criteria which the consultant has developed are based on what is required throughout the country for site assessments, and he has applied the criteria with meticulous professionalism and even-handedness. For their part, MSDC have not undertaken (and could not afford to undertake) the very thorough and detailed work on site sustainability that he has done.
MSDC would be the first to agree that rural communities should be free to develop their plans to reflect their individual needs, and provided that they comply with relevant planning requirements, would not expect their own opinion to be the decisive one. But if we should vote down our NP, then MSDC would have no option but to decide how much development we should absorb and on what sites. As noted above, in addition to the Constance Wood field, the two sites alongside Sugar Lane are also on their Strategic Housing Land Availability Assessment list and, although assessed as not currently developable, MSDC could find ways of addressing their past reservations as we have sought to do. The village could quite possibly finish up with all three sites being developed over time, with Sugar Lane being the main access road for all of them. MSDC could also grant permission for the HKNP008 site behind Station Road to be developed.
The Parish Council has from the beginning believed that we should decide our own future through a NP and at their February meeting endorsed the direction taken by the Steering Group. They do not accept that site allocation would be done better or more sympathetically by MSDC than through a NP approved by residents.
Q5.4 Is it true that landowners motivated by money and outside consultants with no stake in the village have dictated site selection? (03/15)
No, there is no truth whatever in this allegation.
Landowners in the Parish have not been able to dictate anything at all about the NP or about the sustainability criteria used to assess their offer of sites in response to the land call. Nor have they been able to influence the assessment process in any way; indeed, some landowners have expressed disappointment either because their site has failed to pass the assessment criteria and they have no right of appeal or because there has been no opportunity after the land call period expired to make a late submission.
The consultant’s role has been to assess the sites submitted against the agreed criteria and to identify whether or not they would bring benefits to the community such as affordable housing or the provision of green spaces. He discussed his findings with the SG to agree which sites substantially fulfilled the criteria and which did not. The evidence dictated the outcome, not the consultant.
Q5.5 By making a call for land, are we not jeopardising the village’s environment by encouraging landowners to seek speculative gains? (03/15)
As noted in Q1.3, making a call for land is part of the NP process and the motives of landowners, financial or benevolent, are not relevant. All that matters is that future development that brings benefits to the community is not possible without land.
Secondly, the land call is not an ongoing process but reached its expiry date last October.
Q5.6 The first version of Objective 3 referred to increasing the population at a similar rate to what had occurred in recent years (average 5 properties per year), but is this not contrary to the facts and therefore an unsound basis for planning? (03/15)
This question has exercised the Steering Group and Parish Councillors because the observed rate seems closer to 2 new properties per year than 5.
The figures we used came from the published statistics from the 2001 and 2011 censuses. One set of tables showed a ten year growth of 49 in households. We have now written to the Office of National Statistics seeking an explanation.
It may well be that our belief that Objective 3 in its earlier version reflected past experience in the growth of housing was mistaken. However, that would not invalidate our belief that an average increase as low as 2 properties per year (an increase of 34 or 5% over the 17 year plan period) will not meet the Plan Vision and Objectives on which we have been consulting nor be acceptable to MSDC or the inspector. We would need to produce hard evidence that lack of appropriate sites or infrastructure constraints limit our capacity to provide for the 15% level of growth envisaged in the Vision Statement. However, we believe that the site sustainability assessment indicates that we do have a sufficient supply of land and, provided we have a NP in place, the Community Infrastructure Levy (see Q1.5 above) would in time suffice to fund any infrastructure improvements needed.
Q5.7 How can the call for land amounting to over 20 hectares possibly be justified in the light of the very low actual rate of new build in the past? (03/15)
The question implies that we had a choice, but we did not, because as explained in Q1.3, a recommended process has to be followed to produce a viable NP, and as the main focus of NPs is future development, a call for land is not an optional extra.
The question also implies that we made a call for 20 hectares of land, but we did not. We made a call for land with no idea whether even 1 hectare would be forthcoming, let alone whether any sites on offer would survive the sustainability assessment. We could have finished with zero land available for development. In the event we were gratified that so many sites came forward as it gave the parish a good chance of fulfilling the vision and achieving the objectives.
Q5.8 As it is for villagers to decide what kind of development is best for the village, should not the Steering Group stick to impartially presenting the facts and options? (03/15)
We agree, but this means that we must abide by the strong community support so far registered in the community engagement process for the NP Vision Statement (which envisaged a 15% population growth by 2031) and the Objectives.
The Steering Group strongly believes and has repeatedly emphasised that the NP is the community’s plan, and we know it will fail unless we succeed in reflecting the views of most residents. This is why so much time and effort and ingenuity has been invested in the community engagement process, and this will continue to be the pattern until the plan is finally submitted to MSDC for inspection.
As explained above, site selection has been dictated by assessing the facts about each site against the independently compiled sustainability criteria. It is evidence that has determined site selection, not the opinions of members of the SG.
It should be remembered that the SG comprises unpaid volunteers who have each given a great deal of their time because they only want what is best for our parish. However, they have all been on a rapid learning curve about the national and local legal and policy environment which decides what NPs can and cannot deliver and what they must deliver to pass inspection, and see part of their task as raising the level of awareness of such realities in our community through the engagement process.
Q5.9 Is the process of consulting on sites not divisive, because residents living near one site may feel they have no option but to favour a site further away with no chance to say No to both? (03/15)
We hope not, but acknowledge that those living near sites eventually selected for inclusion in the plan will have stronger reactions than those largely unaffected.
But it would be untrue to say that villagers have been unable to express disapproval not only of any particular site but of all sites if they so choose, whether near their home or not, and to do so without giving their reasons. The SG is doing all it can to give everyone that chance.
In the end, the NP process culminates in a referendum in which some will vote Yes to the plan, some will vote No, and some will abstain. As in any democratic process, the majority of those voting will carry the day and the minority will be unhappy with the result. But in the case of other parishes in Mid Sussex which have had a referendum, turnout has been good and the majorities have been very decisive, which makes the decision more palatable to those who voted against. We hope that will be the case here.
The SG believes that once developments have taken place and suitable efforts have been made to screen the new dwellings wherever desirable, the new homes will take their place in the village alongside older ones and, like developments of the past, will soon become an integral part of village life. We also believe that the majority of residents would rather undergo this short term democratic process than be exposed to the kind of long term fate that is befalling parishes like Slaugham.
Q5.10 Given the number of criticisms expressed since the Open Day, has not the time arrived for another survey of opinion in the village? (03/15)
The Steering Group has taken all comments and objections on board and is doing its best to respond to people’s individual concerns. We believe that this Q&A document describes the realities which all parishes preparing NPs have to face up to and provides a basis for understanding how we have got to where we are.
Responses to surveys have been producing lower and lower levels of response – 71% in 2009 (the Village Plan), 56% in NP survey 1 in 2012, and 39% in NP survey 2 later in 2012. A response well below 30% would not tell us very much. So the timing and content of any further survey is very important to ensure that responses are high.
We think that the present phase of consultation should run its course and that a good time to consider the need for another household survey would be in mid-April.
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