OFFICERS’ REPORTS TO
PLANNING POLICY & BUILT HERITAGE WORKING PARTY – 23 JULY 2012
PUBLIC BUSINESS – ITEM FOR DECISION
1.
RESPONSE TO NATIONAL PLANNING POLICY FRAMEWORK – CORE
STRATEGY POLICY HO3
This report discusses the potential impacts of the publication of the National
Planning Policy Framework in relation to the Councils adopted policy on affordable
housing in the countryside.
1. Introduction
The National Planning Policy Framework (NPPF) consolidates and replaces most of
the national planning policy advice published by government in the last decade
including Planning Policy Statements (PPSs), Circular 05/2005 in relation to Planning
Obligations, and a number of advisory letters providing interpretation of various bits
of government guidance. The new framework is applicable to both Plan making
(policy formulation) and the determination of individual planning applications. A new
single Framework document was published on 27th of March and the previous
advice was formally cancelled.
The government expects that as a result of the new framework those Councils with
adopted policies may wish, or need to, review their policies and the framework
includes a 12 month transitional period to allow for this.
At the meeting of the Working Party in April members identified a number of policy
areas which would be considered further including rural housing provision. This
report considers the Council’s approach to the provision of affordable housing in the
countryside, often referred to as the ‘Rural Exceptions’ policy.
2. Policy approach to the provision of affordable housing in rural areas.
Para 54 of the NPPF includes reference to rural exception sites and a statement that
‘Local planning authorities should in particular consider whether allowing some
market housing would facilitate the provision of significant additional affordable
housing to meet local needs.’
Policy HO3: Affordable Housing in the Countryside, sets out the criteria against which
rural affordable housing schemes are assessed in North Norfolk. This policy aims to
allow new build residential development in the designated Countryside Policy Area
where it would meet an identified need for affordable housing in that rural area. The
policy has successfully delivered affordable homes in the countryside, which along
with a local letting scheme, has provided the opportunity of seeking to address
housing need at a parish level. To date the Housing Section of this Council and RPs
(Registered Providers) have taken a lead on bringing forward such development,
funded by RP borrowing and grant available through the HCA. In the past two years
this grant funding stream has been substantially reduced and there remains
uncertainly beyond 2015 as to whether this grant will continue to be available and if
so, how much funding will be available in North Norfolk.
The NPPF introduces the potential of funding additional affordable housing in the
countryside through allowing an element of market housing as part of a scheme. This
flexibility allows the recycling of profit from the sale of market housing to support the
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provision of affordable dwellings, in effect replacing the public subsidy. This
potentially allows the delivery of local needs affordable homes which otherwise would
not be possible in the absence of supporting grant.
The NPPF makes a clear link between the amount of market housing and the
provision of significant additional affordable housing. As such the primary aim of
rural housing policy in relation to ‘exceptions’ developments remains that of
addressing local affordable housing need as demonstrated in the Housing Needs
Assessment and Housing Register information. In this context it is considered that
the amount of market housing allowed within such proposals ought to be the
minimum required to fund the housing scheme identified to meet the needs of a
particular rural area. Schemes promoted by non- profit making bodies e.g
Registered Providers, community groups, parish councils, Community Land Trusts
therefore have the greatest scope to deliver maximum benefit.
Allowing such flexibility would appear to have considerable merit, both in terms of
quantity and long term provision of affordable housing as well the composition of
delivered schemes, which would have a broader income mix. There are however a
number of considerations:
It is not clear what amount of market housing would be required to deliver the
required funding and how this may affect the total number of proposed
dwellings and the affordable: market ratio. For instance how many market
houses would be necessary to fund a scheme of 10 affordables, 2 market, 5,
10…12?
Should acceptable rural exceptions schemes always be predominantly
affordable? – Would schemes of less than 50% affordable dwellings be
sufficiently justified in terms of meeting core objectives?
Scale of development – Apart from close to the boundaries of Core Strategy
designated settlements HO3 restricts scheme size to 10 or less dwellings
(some limited increase on this has been allowed in acknowledgement of high
levels of local need and site suitability). This size restriction responds to not
only sustainability considerations but also the sensitively of landscape and
village character to new housing development. If the local housing need is for
a scheme of 10 affordables, should scheme size be allowed to increase to
accommodate the required number of market housing or should the threshold
of 10 be maintained?
Should the market housing element be required to meet other components of
rural need i.e. starter homes, 2/3 bed rather than 4 bed detached, therefore
seeking to increase the range and size of market dwellings in rural
settlements?
The answers to these questions may well differ depending on the site and particular
local circumstances. It is considered that at this stage any revised approach should
seek to retain a wide degree of flexibility.
RECOMMENDATION
That the Working Party recommends to Cabinet that in response to the NPPF
the Council resolves to support the inclusion of elements of market housing
within rural exception schemes which otherwise comply with the provisions of
Policy H03 subject to:
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Clear demonstration that the inclusion of market housing is necessary
to deliver affordable dwellings which otherwise would not be provided.
That the quantity of affordable dwellings exceeds the quantity of market
housing.
(Source: Mark Ashwell, Planning Policy Manager, ext 6325)
PUBLIC BUSINESS – ITEM FOR DECISION
2.
Fakenham Development Brief
This report provides a summary of the representations made in relation to the
Fakenham Development Brief following the recent consultation and recommends that
the brief is not approved at this stage.
INTRODUCTION
The adopted Site Allocations Development Plan allocates approximately 85 hectares
of land for a large scale mixed use urban expansion to the North of Fakenham.
Adopted policies require that before development can commence it will be necessary
to agree a development brief for the site. A draft brief has been prepared and was
subject to a six week period of public consultation commencing 26 March 2012. This
report provides a summary of the representations that have been made and indicates
where changes to the brief are considered necessary prior to it being formally
approved by the Council.
THE PURPOSE OF THE BRIEF AND WHAT SHOULD BE CONSIDERED AT THIS
STAGE.
A Development Brief comprises an intermediate step between the formal allocation of
a site for development and the grant of planning permission. A brief can include
varying degrees of detail but its main purpose is to lay down a set of standards
against which future development proposals can be considered. They are particularly
beneficial on large mixed use sites in multiple ownerships where it is expected that
development will progress over a number of years and be undertaken by a number of
separate developers. The preparation of a brief provides an important opportunity for
key consultees and the wider public to influence the final form of development.
Policy F01 of the Site Allocations Development Plan requires that the brief for
Fakenham should include details of:
Access and transport
Layout
Phasing of development
Conceptual appearance
Consideration of the brief is not an opportunity to amend adopted policies which in
this instance approve the principal of the site being developed, the quantum of
development, and the mix of uses. Neither should the brief attempt to predetermine
issues of detail that can be considered at planning application stage when specific
proposals will be made.
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REPRESENTATIONS AND SUGGESTED RESPONSE
A total of 59 representations were made. These can be viewed in the
Representations Report attached as Appendix A.
The summary of the main issues are set out in the table below. The first part of the
table summarises the concerns raised locally by members of the public during the
consultation period. The second part of the table sets out the main issues raised in
responses received by statutory consultees and other stakeholders.
TABLE 1- Summary of Key Issues
Concerns raised by members of the public
Local Concern 1 – Traffic management and circulation.
That the proposed traffic arrangements which would prevent vehicle access
between the northern part of the town and the new development (except for a bus
route) will adversely change the present access arrangements which allows
traffic to exit / access the town (via Water Moor Lane) on to the A148. As a
consequence this would increase traffic levels on the existing residential road
network (notably along Rudham Style Lane, Thorpeland Road and Claypit Lane).
Poor junctions and dangerous bridge cannot safely accommodate additional
traffic.
Lack of traffic integration will create separate communities.
Increased traffic resulting from the development will cause congestion in the town
centre where there is insufficient car parking provision.
Location of roundabout on A148 questioned, potentially encouraging increased
traffic to use a narrow country lane in the direction of Wells.
Parking associated with the new development could overspill into existing
adjacent residential area.
Response The proposed traffic management strategy is based on preventing cars associated
with the development being able to travel in a southerly direction towards the town
centre via Queens Road, Rudham Stile Lane or Thorpland Road. A consequence of
this is the proposed closure of Water Moor Lane to existing traffic. The potential
adverse impact of this on existing traffic circulation was the principal local objection
raised during the consultation. In order to properly assess whether the proposal
would result in the problems envisaged by objectors a Transport Assessment (TA)
would be required. A TA should also assist in verifying the location of the new
junction on the A148.
Local Concern 2 – Employment
Lack of local employment opportunities to serve such a large increase in
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population. Proposed employment area insufficient to cater for proposed increase
in population.
Location of employment area will have adverse impact upon residential
properties on Rudham Stile Road.
Response –
Most people buying a new property are already in employment or have an alternative
income i.e. a pension. Although arguably the development may result in more out
commuting, Fakenham has, relative to other towns in the district, better employment
opportunities and these will be further strengthened by the additional 7 hectares of
employment land proposed.
Local Concern 3 – Infrastructure & Services
Capacity of local schools, health services, town centre car parks, sewerage and
water supplies to accommodate this amount of new development.
Need for swimming pool in the town. Need for community centre & hotel on the
site (as proposed) questioned
Response It is recognised that school expansion will be required and depending on the
composition of the housing, a new primary school may be required. This will be
closely monitored by the education authority and additional provision will need to
be funded by the development.
Fakenham has a newly developed medical campus which has been planned in
anticipation of the town’s expansion.
The development has been planned in a way that discourages access to the town
by car and instead promotes access on foot, cycle or public transport. Expansion
of the town should assist in supporting town centre uses and businesses.
Anglian Water and the Environment Agency have both confirmed capacity in the
sewerage infrastructure and water supplies.
Local Concern 4 – Lack of integration with existing town / community
Location of playing pitches adjacent to the A148.
Lack of vehicle access between existing and proposed developments.
Response Direct vehicular access between the existing and proposed development has
intentionally not been proposed in order to avoid traffic from the development using
adjacent residential roads to access the town centre. The rationale and
consequences of this approach should be tested by a Transport Assessment. This in
itself however should not be a barrier to integration which will be achieved through
layout, built form and green infrastructure, along with good walking and cycle routes.
The location of the proposed playing pitches is raised by a number of representations
and is considered below
Comments made by Statutory Consultees and stakeholders
Main Issue 1 Primary vehicular access to the site and impact of traffic
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Comment
County Highways have commented that until an appropriate Transport Assessment
has been completed the development brief cannot provide accurate details of how
future development should be accessed
In addition they have advised that :
HGV traffic wishing to access proposed employment land should access via
the Morrisons roundabout and this may require the use of width restrictions
All existing junctions onto the A148 from roads within the boundaries of the
site must be permanently closed, possibly including Wells Road.
Response –
Unlike a planning application the Development Brief has not been supported by the
submission of a Transport Assessment (TA). A Transport Assessment is a
comprehensive and systematic process that sets out transport issues relating to a
proposed development and identifies what measures will be taken to deal with the
anticipated transport impacts of the scheme and to improve accessibility. A key
purpose of a Development Brief is to establish the broad principles of access and
movement. In the absence of this evidence base it is not possible to verify the
acceptability of the access and movement proposals.
Main Issue 2 - Streets, parking and the pedestrian environment
Comment
C&D Landscape Officers have commented that although the layout is acceptable in
principle, the indicative road types indicate a design approach focused on highway
requirements. They comment that the opportunity exists for a more imaginative,
integrated approach to the layout of the development, maximising shared surfaces
/spaces and using hard and green infrastructure to create a more attractive informal
multi-functional environment.
The design of the east – west pedestrian/cycle route receives particular comment. As
indicated the separation of this route from the primary access road is considered
weak and a stronger ‘greenway’ design approach is considered to be more
appropriate.
County Highways have made various comments regarding the internal road layout,
including recommendations regarding design, surfacing and restrictions.
Response
See comments below
Main Issue 3 Open space/recreation Strategy
Comment
C&D Landscape Officers consider the approach to open space provision broadly
acceptable, although have made a number of comments/recommendations for
improvement:
Open space should be better integrated in to the Village Centre - creating
attractive public realm and promoting access
Sports pitch provision takes up a significant proportion of the open space. The
need for it given the location of Fakenham Sport Centre is questioned.
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The inclusion of an east - west greenway as recommended above in 2 would
allow better integration of open space into the layout and assist in the creation
of an attractive circular walking route within the development. Such a
greenway could be included within a multi-functional linear park feature
Linkages should be made between footpaths and cycleways within the site to
the open countryside and the existing public rights of way network.
Norfolk Wildlife Trust have made similar comments regarding linkages, advocated a
stronger more integrated green infrastructure strategy and the raised the possibility of
biodiversity off-setting.
Sport England commented that the proposed sports pitches should include ancillary
facilities including changing rooms and parking and must meet Sport England
standards in terms of design.
In addition they suggested an alternative location for pitch provision could be the land
adjacent to the existing rugby club and sports centre – facilitating the creation of a
single sports hub in the town.
Response –
The possibility of focusing new sports pitch provision in a location better related to
the Sport Centre should be explored further given the functional and operational
benefits. This approach would also allow a more flexible approach to the shape and
form of the open space within the development. The location of most of the open
space along the northern boundary of the site restricts an integrated approach.
Removing the functional need to provide sports pitches allows linear or smaller
pockets of open space to be better woven/embedded into the residential environment
– improving access, amenity and the quality of place. This approach would also
address concerns raised by C&D Landscape regarding the street/pedestrian
environment.
Main Issue 4 Design Quality
Comment
C&D Design Officer considers the design approach set out in the brief to be broadly
acceptable and has made recommendation regarding the following:
Reference should be made specifically as to how design quality will be
achieved across the development. Given the scale of development, thought
and imagination will be required of individual building if qualitative results are
to be secured.
Scale – Within the character areas described in the Brief, 2, 2.5 and three
storey buildings are referred to. With the development sitting on the edge of
the town, the overall scale of the buildings will be vital in ensuring integration
with the existing built form. Hence, it is considered that buildings should be
predominantly two storeys in height. Buildings above this height should be
restricted to occasional buildings and or important corner plots. There is
currently no reference to the use of single storey development as part of the
mix. It is considered that single storey buildings should be included not only to
ensure a full range of new homes but importantly to provide variety of built
form and roofscape.
Response The Brief should be amended to provide further detail on design quality and to
reflect the comments regarding scale of development.
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Main Issue 5 Location of the Primary School
Comment
A number of representations raise concerns over the location of the proposed
primary school on the principal road, Lime Tree Avenue. Although it is recognised
that the school will be a key community building and should be located in the village
centre, concerns are raised including from the Highway Authority, over the possible
conflict between children/pedestrians and vehicular traffic.
It should be noted that the County Council at this stage are unable confirm whether a
new build school will be required but are continuing to seek a site to be reserved for
that purpose.
Response Amend the Brief to ensure that land reserved for a primary school allows for safe
access.
Main Issue 6 Archaeology
Comment
The County Council’s response indicates that in relation to archaeology the Brief
requires updating to reflect known historic sites, including brick kilns and a windmill.
Response Amend the relevant text in the Brief following further consultation with Historic
Environment Services.
Main Issue – Foul waste network and treatment
Both Anglian Water and the Environment Agency have agreed that content of the
Brief
The Environment Agency highlight that this proposed growth will ‘use up’ a significant
proportion of the available capacity at Fakenham STW and that further growth is
likely to be constrained.
Response No action
RECOMMENDATION
That the Working Party declines to recommend approval of the Brief at
this stage pending further consideration in relation to:
The traffic circulation impacts of the proposed development on the
existing highway network to include the submission of a Transport
Impact Assessment to inform the access strategy.
Further consideration of the green infrastructure strategy and the
potential to redistribute both formal and informal open space to ensure
its better integration within the development.
Incorporation of textual changes to the brief as outlined in the
‘response’ section of Table 1 of this report.
(Source: Mark Ashwell, Planning Policy Manager, ext. 6325)
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