Response to the Central Lincolnshire Local Plan Further Draft from
Cllr Mrs Marianne Overton MBE
Objections or “suggested improvements” to the Local Plan follow
and some support, where stated.
Paragraph references are in the Strategic Housing Market Assessment which also refers to the
Economic Needs Assessment, and the infrastructure delivery plans.
The vision and LP1
The vision is attractive and I support the recognition of the need to maintain a balance
between local businesses driving prosperity and the costs needed to provide essential
infrastructure and services. All this needs to be without damaging the attractive rural
environment and heritage that characterises Lincolnshire.
However, the last paragraph suggesting that “through growth” our health inequalities and
lack of infrastructure will be resolved, seriously lacks credibility and undermines the
integrity of the whole vision. The earlier paragraph that states that “growth will be closely
linked to jobs and infrastructure” is the more sensible of the two, as an aspiration at least.
Number of Dwellings Needed
Most seriously, I object to the high number of new proposed dwellings, at “36,960 between
2012 and 2036”, an average of 1,540 per year for 23 years. This is equivalent to 68,400 more
people. (Turley verbal affirmation)
The Infrastructure delivery plan identifies a considerable amount needed, with a shortfall of
about £300m, let alone the resources to run the services. So who is going without a school
place, an ambulance when needed or making do with poor roads and heavy traffic?
The government calculated that around 929 new dwellings per year would be needed for
Central Lincolnshire including the current higher birth rate, longer lives and a net migration
into the area. (SMHA fig 6.11) However, the plan proposes nearly double that, at 1540 new
dwellings a year. This is a rate “reflecting that which was seen briefly prior to the recession”.
The proposal is to continue at that rate on average until 2036!
The consultants reckon that the government figures are too low because people haven’t
been leaving the area as much as in the past. However, that ignores the trend seen in figure
6.4, which clearly shows more people are leaving the area, and the gap between those
coming in and those going out is narrowing. It is true that the government estimated level of
outward migration in future is higher, but it correctly mirrors the inward migration, in the
same way as it has done in the past, when people generally get itchy feet!
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Testing the 2012 government population estimate against reality in 2013, the “reality
showed a 0.2% population greater than the estimate which the consultants have leapt upon
to demonstrate an underestimation. However, the mid-year population estimates used as
“reality” are known to have a 2.8% error. I am not clear why the estimates are not checked
against a 2015 estimated population. However, the consultants now suggest a figure of
1,460 new dwellings per annum, based on an “assumed higher level of migration”, with little
evidence. (Para 6.33, fig 6.2)
For comparison, a projection based on ten years prior to 2012, includes 3 years of recession
and seven years of boom and suggests an extra 56,404 more people and 1,367 more houses
per year over a 23 year plan. (6.8) This gives an unrealistic figure, biased by a high
proportion of boom years. A 20-year period would include some “normal” years and be
more realistic, this was used to illustrate the house build trend. (fig 5.11)
A further 20 households per year are suggested for the Unattributable Population Change,
the 0.2% but this is undermined by the large margin of error as described above. (Para 6.36)
The household formation rates
The consultants also assume that people who currently are living with parents longer or
extended families living in one household, will find money and move out to set up separate
households. (6.58-6.59)
This ignores a number of factors which would reduce the number of dwellings needed: the
trend of reducing public support for housing benefits and for elderly care. Linked with an
increase in international immigration, household formation is not likely to return to earlier
levels in the foreseeable future. Added to this, interest rates are currently very low, and
most likely to rise in future. Even a slight increase would make more housing unaffordable
and reduce household formation rates further, reducing the need for so many houses. The
economic needs assessment has demonstrated that 47% of the new houses would need to
be affordable, based on wage rates and house prices. That is clearly not achievable, leading
to less household formation, more multi-occupation units, extended families under one roof
and dividing of current houses into smaller units. Student fees are rising, encouraging more
students to live at home and go to a more local University. All of that means fewer dwellings
needed and none of this has been taken into account.
The government figures suggest a continuation of the current household formation rates
(6.57), and I believe they are right. The consultants say it has been “suppressed” and will be
reversed, but no evidence is given. On the contrary, Fig 6.18 shows a continuing trend of
houses becoming increasingly unaffordable. I would therefore refute the need to apply a
further housing for the mysteriously-named “headship rate sensitivity” that is used to take
the housing figures up to 1,432 pa. (fig 6.2)
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Factoring in Likely Job Growth: Taking the Economic Needs Assessment into Account
Assumptions (para 6.67) The assumption that commuting rates will remain constant does
not take into account the increasing traffic which discourages migration into the area,
discourages tourism and shoppers, inhibits businesses and reduces the accessibility to jobs.
Thus traffic creates a self-limiting effect on the economy.
This is made worse by the plan being very Lincoln-centric. Economic growth is too focused
on Lincoln, fed from a large strategic area, or “hinterland”. The transport strategy, the
employment areas and the infrastructure priorities seriously risk our rural sustainability,
creating dormitories around a traffic congested centre. All these policies need changing to
better support sustainable rural communities and our market towns. Public funding to
support public transport is reducing and likely to reduce further in rural areas and disappear
altogether in some areas.
Economic activity rates
The consultant suggests that more people will be needed for a bigger economy so we will
need more inward migration. (6.70) But this does not take into account the capacity in the
current population to work more hours. As the recession hit, there has been a shift from full
time to part-time work and from employed to self-employed and to the economically
inactive. Were there more reasonably well paid jobs available, this trend is likely to reverse.
People would work to an older age as well. Further, the reduction in benefits has meant that
fewer people claim and more are in the “economically inactive” category. So there is
capacity for more work hours without increasing the working age population. Hence, the
number of migrants and corresponding households needed is overestimated. The
calculations need to be redone to allow for a reverse of this trend if the economy increases.
A number of economic growth “scenarios” are invented and discounted. However, all the
models use the “headship rate sensitivity” which take the numbers up to 1540pa. The
figures should be calculated without this false assumption as discussed above.
Housing Need by Size
Central Lincolnshire has a high level of under-occupation. (6.95) So there is capacity in the
current housing stock to provide for an increasing population in a number of ways. The
number of new dwellings needed is thus overestimated. The capacity needs to be calculated
and included.
The flawed assumption in household formation discussed earlier are repeated in these
figures and need to be removed. (para 6.107-109).
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Affordable Housing
The definition of affordable is given. (para 7.45).
The trend created by the government’s ambitions to reduce benefits is described
convincingly (7.1). However, the drive for councils to reduce rent, sell off the best council
houses and send money to the Treasury and to private buyers is not yet included and adds
substantial pressure. The affordability of housing to rent or buy is neatly compared. (fig 7.9)
showing that more than a third of people cannot afford to rent privately, yet we have only
16%
The assumption that people who are paying too much will move out into the affordable
homes, seems unlikely to be so in all cases. For example, of those suffering the spare room
subsidy or bedroom tax, only 6% have moved and 28% have gone into arrears. (par 7.21)
They calculate that 17,400 dwellings need to be "affordable", that is about half, 47%. Yet the
plan suggests asking developers for only around 20%, and that is subject to a "viability
assessment", which means the houses may be built without making the contributions we
need. (LP11)
LP1a New Policy Needed on Housing Mix
The need to create policies that help ensure an appropriate mix of housing is built to match
the needs outlined in the evidence, summarized on page170 para 8.8 onwards draft.
A great deal of evidence is in the SHMA on types of housing, and this needs to be reflected
in a new policy. What is missing is a clear policy that allows the planning committees to
insist on an appropriate mix of housing that reflects the needs identified in the supporting
documents. We obviously do not want 37,000 four bedroom houses, still leaving our young
people unable to afford a home and a disabled granny with nowhere to go.
Economic Needs Assessment (ENA)
Some sectors of businesses are not performing as well here as they do in other parts of the
country. (para 4.39, 4.48) The needs assessment suggests they will therefore increase.
However, that does not take into account that we will be competing fiercely with every
other county, but with the same restraints as we have now, such as relatively poor transport
links to a very dispersed rural community with low incomes. There is little evidence that
these restraints can be overcome to increase business. The plan suggests we are currently
increasing at 9%, partly due to the population increase. They propose an increase to 11%,
suggesting it will pick up higher than before and continue at that level for over twenty years.
This is not credible. Central Lincolnshire GVA was £4.6bn in 2011, which is 15% /head less
than the rest of the country. (para 4.44) There is little evidence that this pattern will
change.
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Where we are “performing” is in real estate and manufacturing. Oxford Consultants
estimate that manufacturing will decline with the loss of 2974 jobs, only balanced by, yes,
you guessed it, more house-building construction. So the new jobs are temporary. The
increasing area of work that is sustainable is in care, described as human health and social
work. (Appendix 6) The trend of increasing reductions in public-sector funding and
outsourcing, sometimes far and wide, also takes money out of our locality. I do not see
where that is taken into account in the economic growth. The 720 job losses are shown but
this doesn’t include the knock on job losses, especially in the connected voluntary sectors.
It is hard to reconcile this with the proposed levels of growth or indeed, with the vision
which started the exercise with such optimism. Economic forecasts are notoriously
unreliable, but this one takes the biscuit!
Policy LP2 and Appendix A page 129-138
I fully support the sensible policy for small villages that enables them to grow more than
before, but not too much with 10-15% cap that is lifted only with community support. The
policy however, needs to state this much more clearly and that that it is the relevant village
community support that is needed. The small villages of Potterhanworth Booths has been
omitted but it could probably accept the same 10% over 23 years as the smaller villages.
Medium and large villages need a similar protection of 10-15% maximum growth in the
period to protect them from urban sprawl. Despite the limitations in the policy LP2, The
medium sized village of Potterhanworth appears to have an allocation which is
disproportionately large and should be removed. That would enable incremental growth at
a more appropriate rate.
The policy for large villages including Navenby, Branston, Billinghay and Skellingthorpe,
currently has no maximum. Since this plan removes the boundary, a maximum limit is
needed, such as 10 or 15% to prevent an unsustainable urban sprawl.
LP3 Level and Distribution of Growth
The Lincoln Strategy Area
The Lincoln Strategy Area is too large and should be drawn tighter round the city as in the
previous draft. The plan is now very Lincoln-centric. The rural areas are treated as
"hinterlands" or "dormitories" serving a city with a medieval street plan, rather than
sustainable communities in their own right. “LP3 3a9iii) seeks growth at settlements which
serve and are served by Lincoln.” But the Economic needs assessment mentions only as far
as Washingborough, North Hykeham and Skellingthorpe when describing the “wider reach”
of Lincoln. It is wrong to extend the new strategy area to more than twelve miles from
Lincoln, where communities are as much facing towards Grantham, Newark and Sleaford as
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they are towards Lincoln. There is no convincing evidence given to support this extension of
the Lincoln Strategy area and it is not in line with reducing the need to travel. (LP18)
Our rural villages contain many small businesses that will need to thrive without reliance on
a future traffic-blocked Lincoln, particularly once a further 6,000 dwellings are built on the
way and the Eastern bypass empties onto the B1188. The Eastern Bypass may help Lincoln,
but is funded by significant house-building creating more congestion at the access points,
making it less attractive to rural residents. The rural areas need to be sustainable in their
own right. Our rural areas are not dormitories of Lincoln, with a high proportion of residents
not dependent on Lincoln at all. The Transport policy also needs to better support the rural
areas. The delivery plans likewise. The city-centric dormitory approach is damaging and does
not reflective of our thriving rural communities that characterize our area.
Sleaford and other disproportionate development areas
The proposed 12% of new dwellings for Sleaford represents an increase on 58% which is
unsustainable. The town already suffers excessive congestion, lack of capacity in school
places and in medical facilities. Property prices are relatively low with developer
contributions correspondingly small, especially without the 85% CIL which goes instead to
the Lincoln Eastern Bypass. The public purse is already at full stretch and shrinking.
LP28 Lastly the sustainable extensions, which each include facilities for gypsy and traveller
sites, are too large, giving multi-national developers the advantage and draining money out
of our area. (LP28) Like townships in their own right, tacked on the edge of our market
towns, it is hard to see how they can be sustainably incorporated into the community
without over-burdening the local facilities. There should be a phasing mechanism, to enable
development to be sustainable. Small incremental development that matches what we can
afford and benefits our local businesses would be better. The policy for small villages does
this effectively and should be extended to include medium and large villages. (LP2)
Similarly the scale of proposed developments is disproportionate in some other areas,
especially Bracebridge Heath and Canwick which is set to receive up to 6,000 new dwellings
in total. Billinghay and Potterhanworth have disproportionately large land areas proposed
for housing, in areas without jobs, resulting in unsustainable and significant commuting.
The amount of developer contribution to infrastructure is unfortunately small, expected to
be only 10-15% of public money required, leaving residents short.
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LP11 Meeting Housing Need
The amount of affordable housing sought should be higher, according to the evidence,
discussed above. 47% of housing needs to be affordable, so seeking only 15%-25% is never
going to be sustainable. Worse, less is requested from the SUE’s with big multi-national
developers, and more is requested from our smaller, local developments, draining money
out of our area. The evidence from the CIL report is that the developers can afford more.
LP12 Providing Infrastructure
This is probably the best principle in the book requiring infrastructure to be identified for
each development. However, it needs to include a reference as to how close the
infrastructure capacity has to be and the word “locally” should be incorporated with an
explanation as to what is meant by “local”. So “Planning Permission will only be granted if it
can be demonstrated that there is, or will be, sufficient infrastructure capacity locally to
meet all the necessary requirements arising from the proposed development.” By law,
primary school children need a school place within six miles, for example.
LP13 Transport
Latest Government guidance removes the maximum parking allowances. Better parking
provision should now be included, for private dwellings, for facilities open to the public and
for our village and for our market towns. “LP13 i Assist in bringing forward one or more park
and ride facilities in Lincoln”, “Sleaford or Gainsborough” should be inserted.
Support for Other policies
I support LP6 Retail and town centres, LP7 a sustainable visitor economy, LP9 Health and
wellbeing, LP10 standards for disabled access. LP45-47 Sleaford regeneration LP55
Protecting the open countryside. LP18 Climate change and low carbon living; “minimizing
energy and water consumption” and “their need to travel”.
LP52 Large Villages
Navenby Top Farm should calculate at 110 dwellings, not 125. This should be excluded,
since incremental growth is already allowed under LP2 and there are already sufficient
development sites ready and waiting within the curtilage. There should be a maximum for
large villages such as 15% for Navenby which would allow some incremental development
over the whole period of the plan in a more sustainable manner. Billinghay seems to be
overburdened. LP53 CL22 Nocton Park is a locally significant green space and deserves
protection. According to its size, Nocton would not qualify for a large further area of
allocated development.
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Conclusion
There are a lot of good ideas and principles here. The difficulty will be in affording them at
the same time as increasing demand on infrastructure and services, which is already
overburdened and at the same time, without damaging the nature of our rural
communities.
Fundamentally, that means keeping the numbers of new dwellings low, wherever possible
bringing into fuller use the ones we already have. That means keeping the numbers
relatively low as our best opportunity to make this plan affordable and therefore viable.
With the housing being allocated and built in advance of and separate to the business
development, it is inevitable that there will be a reduction in economic well-being.
Allocating vast amounts of land for industry does not make it happen. We already have huge
areas allocated, but empty.
The whole policy relies heavily on migration into Lincolnshire. Neither do I accept the high
levels of personal debt that would be required to achieve this.
The numbers of people and houses are too high and need to be reduced substantially. There
needs to be a staging process so that the land is released to development gradually over the
years. The infrastructure needs to be fully identified before outline permission is given,
including the knock-on effect for Lincolnshire’s highways and byways which are already
suffering from under-funding and over-use. Housing should only be built when the jobs are
clearly there. Hence there needs to be a concentration on the economic development of a
range of small businesses. More housing could then be connected to and funded by
successful economic development. It is not more of everything that improves our quality of
life. It is the balance of economic success and jobs, housing and the environment and
services, nicely described in the vision. Hopefully we can get the policies to match!
Many thanks and kind regards,
Marianne
Councillor Marianne Overton MBE
Independent Councillor for Branston and Navenby on Lincolnshire County Council
and for the Cliff Villages on North Kesteven District Council
www.independentvoice.org.uk
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Marianne Overton MBE, Hilltop Farm. Welbourn, Lincolnshire, LN5 0QH Tel:07920 235 364
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