May 2017 Update to Parish Council Plus Feedback from PC & HDC

Following on from my 2 updates yesterday (2nd May), the letter from Chris Lyons (HDC) and feedback from the PC & NP Team, the next steps were discussed at the UBPC  on the 2nd. May and agreed the following from the points raised below:

As well as my notes David Caldwell had had a meeting with Norman Kwan at HDC and felt that if we were to get the support of HDC we would have to do a new HNS.
Lots of discussion about using the existing HNS and the fact that whatever the new number of houses required might be, UB simply did not have the space to develop any more than our current NP was proposing unless we were able to use sites within SDNP.

Everybody agreed the last statement but it was clear that unless we properly identified what the Housing Needs figure was for all types of housing (current one mainly focused on Affordable) we would be liable to lose any future close scrutiny of our figures by any Developers, Planning Authorities, Courts etc.
If we do nothing and stop the NP we leave ourselves open to HDC dictating sites and possible Developers suggesting sites already classified as not suitable but not registered in an NP trying to develop again.

It was therefore agreed that we would:
1. Pursue with HDC if they would support us using the existing HNS with additional housing numbers added.
2. AiRS would identify the additional requirements of the AECOM HNS to their original one.
3. If 1 was not supported even with the additional requirements of 2 we would carry out the AECOM HNS.
4. We would seek additional support from AiRS and seek a further grant and support from Locality.
5. Based on the outcome of the decisions above we would produce a new project plan
6. I would remain as Chair of the NP with a contract from the PC to be agreed.

I hope this clarifies where we are and when we get points 1 & 2 clarified we will be in a position to move on.

Since writing the above we have had further clarification from HDC and sight of the independent report Henfield had carried out on their failed NP. It is clear from both that we will have to carry out a new HNS as shown in bold above. I have asked AiRS to produce a new plan and costings and started the ball rolling with applying for a new grant and support from Locality. (12/5/17)

Sean Teatum

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A quick add in to my initial report issued this morning.

These are from our NP Consultant and I have shown them in red italics.The recommendation from them is to go for Option 2.

2. Start a new HNS as per HDC’s recommendation and possible new Call for Sites. Faustina (AiRS) & Allison’s (NP Consultant) recommendation.
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This month’s focus has been around our meeting with the HDC Team and their recommendation that we need to carry out a new HNS or possibly carry on with our current NP but without allocating Development Sites just Green Spaces. Following on from the meeting I wrote to HDC for some clarification only to find that they had changed direction and it would now be unlikely that HDC would support an NP that was for Green Spaces only and did not include any development site allocations.
Having got feedback from Allison (our NP Consultant) & Faustina (AiRS) I wrote back to HDC for their comment on the following points. Their summarised response is in italics below:

Produce an NP with no new HNS and just include Green Spaces. Would HDC support or not and would it get through the Inspector.There is a risk that an NP that does not provide sites for housing would not pass an examination, where it can be demonstrated that suitable sites are available. If this is the case the plan would not conform with the HDPF or meet the Basic Conditions.
Produce an NP with new HNS and development site allocation. You said this would identify a higher number of houses and as we already have great problems finding sites outside of SDNP to meet our initial HNS requirements would this also require a new Call for Sites. As we are unlikely to meet this demand, how is this dealt with by HDC / the Inspector. HDC’s recommendation is that the PC continues to develop its NP with site allocations . HDC’s own policies require 1500 homes to be delivered through NPs. In order for Parishes to be considered to be in conformity with this approach we would expect that parishes make specific allocations unless there are very specific circumstances as to why this would not be appropriate. Settlements with Built Up Area Boundaries (BUABs) such as Upper Beeding are identified as the key locations for further expansion.
Do nothing at all, put the NP on hold for a few years until HDC carry out their new Housing review, allocate a quota to each Parish and then we will clearly know what is required of us. (don’t think this would have any impact on CIL as no new large developments planned in UB over next few years. COULD THERE BE ANY OTHER IMPACTS THAT YOU CAN MAKE US AWARE OF IF WE WENT DOWN THIS LINE).There is a significant risk that this would not lead to a successful Neighbourhood Plan and its policies would not form part of the Development Plan. In these circumstances HDC would need to allocate sites as part of a review of the Local Plan (HDPF) with the local community no longer taking the lead in shaping the future of development and planning matters in their parish.
Ask Henfield if we could be part of their NP and let them help with doing item 2 as they are about to start theirs again. (unlikely not to be a goer as extra demand on Henfield but worth asking the question). Joint working with Henfield would require both parties to revoke their current area designation status and reapply as a joint cluster. This will lengthen the plan preparation process and be dependent on Henfield’s willingness to develop a plan in conjunction with Upper Beeding.

This was presented to the APM on 27th April. The residents were overwhelmingly upset by HDC’s position on NPs in progress and their insistence that PCs had to undertake new HNSs or risk their NPs not being supported. These ranged from just do it anyway and see what happens to getting Nick Herbert involved.
Following on from the APM I wrote to Allison and Faustina for some more advice on the following questions:
Should we get an independent planning firm to look at the issue we feel bringing in another planning consultant would add to costs and delays as in reality that time would be better spent instructing AECOM. We have also asked Claire Tester – former Head of Planning at Mid Sussex and now a sub consultant to AirS to check all the correspondence from HDC and she has inputted to my replies to you.
Is there any other NPs that have got through not using the new HNS (AECOM) or just Green Spaces only. There are two issues to consider. The first is that what has happened recently in terms of NPs and judicial reviews and other matters – local authorities are becoming more stringent in their reviews and advice on draft NPs. Whilst I’m not here to defend HDC, in all honesty I feel they are making recommendations to you on the basis that they want you to succeed. Secondly – with many other NPs – they have a housing figure that they are working towards – this baseline work has already been undertaken for them by the local planning authority. You would need to find an example of a very recent NP that didn’t have a housing figure provided for them that have gone through the examination system without having a detailed HNS.
What are the main add ons in the AECOM HNS apart from identifying Market Housing Needs. Faustina and Simon (the researcher within the AirS) are fine with having a look at the gaps between your HNS and the specification/methodology set out in the AECOM report. That will give you an idea of the extra work required to meet HDC’s recommendation.
Should we call HDC’s bluff. We would recommend that you do go for option 2 as set out in your email as this would give you the most robust base from which to continue the NP from. However – we would know more when we see what Simon has identified in terms of gaps between the two HNS.
Would it be worth expanding the current HNS (not that old) and adding in Market Housing to make up the gap. Our Housing and Development Doc. does show an overall Housing need (151 homes) based on HDC’s formula. (reference to this is at the base of this report). We would recommend that you do go for option 2

Perhaps if the current HNS was re-visited and shown that sites currently within the BUAB couldn’t meet the 151 figure, hence we would have to look at sites adjacent to the BUAB. Also the site that everybody believes is the best site but in SDNP (Beeding Court Farm) would allow us to meet the 151 figure. If we showed SDNP that we had exhausted all possible sites that we would get residents to agree on would they reconsider.
Rather than spend more time carrying out a new HNS and call for sites perhaps we could re-evaluate what we already have and see if it would satisfy HDC’s demands.

I spoke to Allison on Friday (28th. April) who discussed our situation with Tom Warder of AiRS, she suggested the following on the phone and has since responded with an email which I have updated my earlier report in red italics:
AiRS would get one of their people to review the AECOM HNS (new) to see what differences there are from the AiRS (old) one
AiRS would consider providing more support to the NP Team to progress the new HNS if this was decided as the way to go by the PC.
If we wanted to go ahead with the existing HNS they would support but there maybe a further delay if HDC reject and then we have to carry out the new HNS
Allison said she would go back to AiRS late Friday and reply to me, (not yet received but will update you ASAP)

Based on the current info we have 3 options:

1. Go ahead with the current HNS, adjust to show some additional Market Housing (total 151) and hope HDC support.
2. Start a new HNS as per HDC’s recommendation and possible new Call for Sites. Faustina (AiRS) & Allison’s (NP Consultant) recommendation.
3. Give up now until HDC carry out a new Housing Plan and then consider starting a new NP.

The PC will need to consider which option to take at the 2nd. May Council Meeting

Sean

UBNP Team Chair

REFERENCE TO MARKET & AFFORDABLE HOUSING

From Page 17 of the Housing & Development Paper
10. Considerations
Any increase in housing numbers should be linked to the availability of additional local jobs. If a new development takes place, self-build should be encouraged. This provides a summary of the housing situation in the Parish. .
· Parish theoretical housing need (2031)
· Units already completed (Apr 2011 – Mar 2013)
· Units in the planning system pipeline as at March 2013
· Net further housing requirements
· Estimated housing capacity of identified suitable sites housing deficit 3 units

The theoretical need in 2031 is calculated by applying the 0.6% annual growth rate forecast in the HDC Plan to the current population and then dividing by the 2011 (census) occupancy rate as follows:
· Population estimated in 2031: 4215 people
· Population increase 2011-2031: 451 people
· 2011 occupancy rate: 2.6 people per dwelling
· Additional households 2011-2031: 151

Extract from HNS page 9/10 of the Housing and development Doc
Survey indicates a clear ‘YES’ to Affordable homes but ‘NO’ to Open Market homes although there is a demand identified for smaller units on the open market for older people to downsize to; these could form part of a mixed development and could help subsidise the affordable units potentially (a model often used by CLTs)There is a good level of support for affordable housing to meet local needs and limited support for market housing. The respective need / demand for housing reflects this with a substantial need for affordable housing identified and a modest demand for market housing. We need to identify sites to meet both the reasonable need for genuinely affordable housing and the modest need for downsizing housing.Some form of mixed development might be the best way to achieve this. Looking at sites outside of the development boundary (rural exception sites) we need a scheme designed to meet up to half the need identified in order to ensure that there are sufficient people with a local connection available to occupy the homes when they become available. Particularly as about half the need identified is amongst those living with parents, some of whom are young people (18 – 25) whose plans are likely to change in the years to come. We need to meet the needs of the community over the next 20 years so development should be phased accordingly and local needs are more likely to grow than diminish given the acute affordability problems that exist.It’s very clear that the villages do not want or need any major developments (such as Rydon Homes). What we do need is approximately 30 Affordable Homes, 30 Open Market Homes and some Sheltered Housing for our ageing population over the next 20 years. To be provided in small developments of 8, 12 or 20 houses as well as allowing the current one or two builds replacing existing on suitable plots.The Survey indicates that based on incomes we need to consider ‘social housing’ as there are very few houses with middle incomes which could afford “affordable rent” or some intermediate market housing product like shared ownership. A Community Land Trust (CLT) model may be worth exploring as this could seek to provide more genuinely affordable housing. It is also clear that some of the housing identified, needs to be rented rather than owned.

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