Appendix A Planning Report – September 2024

REPORT FROM THE PLANNING GROUP – September 2024

APPENDIX A

• Granted Applications

• Refused/Withdrawn Applications

• Pending Applications

• New Applications

• NW/24/00430 – New dwelling adj 90 London Road

Comments sent:

Although we consider that a satisfactory scheme can be achieved, there are three considerations that we would wish any scheme to address namely: safety of access, the impact upon the street scene and the protected tree.

Safety of access

The width of London Road at this point is restricted and the footpath is very narrow.  Any access to the site must ensure that pedestrian and road safety are not compromised.  It may be safer to access the site through the existing entry to 90 London Road making this into a shared access.

Street scene

The existing stone wall is important to the character of the street scene and, because of the narrowness of the road and footpath, it could be necessary to create a significant break in the wall for a new entrance in order to provide the necessary visibility splay.  The proposal to reuse stone removed from the wall to construct a bell entrance would mitigate the impact.

Protected tree

This can be protected providing the siting of the new dwelling does not impact upon the tree.  It would appear that the indicative siting should achieve this.

• Greenhill solar farm

A response was sent to the Scoping Opinion and PINS have published their response along with the submissions from the statutory consultees.  They did not allow the developer to omit several aspects of the potential impact of the scheme as they proposed to do.

Comments sent on the Draft Statement of Community Consultation:

We have reviewed the above draft and have the following concerns:

The “Co-design Workshops” gave the distinct impression that they were more of an information gathering exercise for the developer than being a truly cooperative workshop or consultation.  The scheme itself was presented as though any concerns would be disregarded because the planning system would allow the proposal.  We are concerned that the consultation responses will also have little or no influence the proposal.

Para 7.1 states that the consultation will take place “for six weeks between November 2024 and January 2025”.  This is known to be best time of year to discourage participation.  It is a time during which most people are preoccupied with preparation for and enjoying Christmas and New Year celebrations and events.  Many people also travel to spend time with relatives and friends over the Christmas and New Year period.  It is also at a time of year when the weather can restrict travel.  This timing would severely reduce the opportunity for people to participate in the consultation process and it should not take place during this busy time.

Para 7.2 states that visual representations will be presented.  In the response to the Scoping Opinion the Parish Council raised concerns about the viewpoints suggested because we were able to identify a proposed viewpoint location that would have little or no view of the scheme due to localised obstructions.  Will revised viewpoints be used for any representations that conform to industry best practice and which have clear views of the scheme?

Para 7.3 states that the PCZ will be restricted to 1km from the project site.  Given the size, scale and extent of the scheme this seems unduly restrictive.  Residents within the wider area will experience a substantial change in the character of the landscape in which they live, work and enjoy for leisure and so should also be included in the consultation.

Para 7.3 does not include Parish Meetings in the list of non-statutory consultees.  This seems an unacceptable omission given that one of the worst affected parishes, our neighbour Easton Maudit, has a Parish Meeting and not a Parish Council.

• NPPF Consultation response

The government is consulting on changes to the National Planning Policy Framework (NPPF).  The following comments are suggested:

Para27: Before as authority can offload unmet needs to a neighbouring authority it should be required to demonstrate that it cannot accommodate those needs within its own area.

Para62: By definition a standard method does not account for particular local conditions.  It should be possible to make exceptions where local needs differ from standard needs.  This could result in higher targets or a different distribution across property types.

When new targets are greater than under the previous method, LPAs must be given adequate time to adjust their plans to identify additional allocations.  This did not happen when the 5 year land supply requirement was introduced and speculative developers exploited the situation to gain permission for harmful or poorly sited developments citing the exception in Para11d.

Deleted Para62: Urban centres have the highest demand and have spiralling rents due to the lack of available homes.  They are also the most sustainable locations in which to build homes because they reduce travel to employment and facilities, have comprehensive public transport and do not consume land that can be used to mitigate the effects of climate change.  An uplift should be required in urban areas although it should be possible to demonstrate where this is unachievable.

Para76b: The rate of housing delivery is not in the gift of LPAs but in the hands of the developers who can decide the rate at which to build out large schemes.  Penalising LPAs in this way is counterproductive and can encourage developers to slow down delivery because by doing so they are able to demonstrate under-delivery and gain even more permissions that will only increase the size of their land bank.

That said, developers are also at the whim of market conditions and the economy.  They build out sites according to the level of demand and do not build houses that they cannot sell.  When there is a downturn in the economy or increases in interest rates the rates of demand and hence delivery fall and creating additional allocations will not speed up delivery.

Doubling the under-delivery penalty will not improve the situation and could make it worse.

Para94: Although beautiful is not the best terminology it is important that new development should not create and unattractive environment where people do not wish to live or visit.  Unattractive developments are future deprived areas.

Para98: In the past there have been problems because infrastructure has not been delivered in time to match need.  This change is very welcome.

Para113: This change would apparently allow a development that would cause a severe impact but not at all times or days.  To do so would be unacceptable.  If this is not the intention of the change then the change should be reworded.

Deleted Para130: It is important that sites deliver as many homes as possible, if developments are too dense they create places that become future deprived areas or even have to be redeveloped.  It is important to address this in some way.

Para159: The UK Climate Change Risk Assessment 2022 identifies 7 main risks of climate change ad only some are addressed in this paragraph.  Notably food security is omitted which should be one of the governments top priorities.  This should also be mentioned in this paragraph.

Para 160b: Although the wording is not itself of particular concern, the current Government’s policy for national technical standards does not require developments to maximise solar PV and so contribute to reducing emissions.  This is particularly contentious locally where vast areas of warehousing are being developed without it also acting as an urban solar farm meaning that double the land is lost.

Footnote 64: As noted in the comment on Para159, poor food security is an identified as one of the main risks of climate change.  Global emissions are still rising and so it is essential that the government prioritises adaptation and mitigation.  One important step must be protecting food security by discouraging the loss of productive agricultural land.