REP-190-001 Mr Colin Mitchell Further Statement Issue 9

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Lewes District Joint Core Strategy Part 1
20th January 2015
Further Statement by Colin Mitchell
Issue 9: Housing Policies
Colin Mitchell
5 Mildmay Close
Ringmer
East Sussex BN8 5JQ
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1. I live in Ringmer Parish and have done so for the last 20 years
2. Ringmer is a rural parish in the northern section of Lewes District. About 20% of the
land area of the parish lies within the South Downs National Park (SDNP), with the
remainder within the rural Low Weald part of the District.
3. The parish includes two main settlements. In the Rural Settlement Study [CD/091]
Ringmer village is classified as a ‘Rural Service Centre’ and the Broyleside as a
‘Local Village’. Ringmer Parish Council agrees with these classifications. Ringmer
village is immediately surrounded on its south-east, south and west by the SDNP
boundary. The Broyleside lies within the Low Weald. In addition the rural area of the
parish includes a number of hamlets, not distinguished in the Rural Settlement Study,
some of which are of great antiquity.
4. Ringmer Parish Council has, with the assistance of Lewes District Council and the
South Downs National Park Authority, prepared a Neighbourhood Plan covering the
entire parish. This Neighbourhood Plan has been submitted for examination. At the
time of writing the outcome of this examination is unknown, but the examiner’s report
is expected to be published prior to 20 January 2015.
5. I have worked in the field of affordable housing for the last 35 years, in various
practical roles as a regional director of funding for the then Government quango, as a
developer of affordable housing with major national house builders in both strategic
and project based roles, with specialist developers and latterly with local Registered
Providers (RPs) or housing associations in advisory and executive roles
6. This statement addresses the Inspector’s Issues 9(i) & (ii).
7. I recognise that policy CP1 is no longer compliant with national policy, as a result of
changes in national policy made by the Secretary of State since the date of
submission of the Core Strategy. However, there is an ongoing need for new
affordable housing in most if not all rural communities, including Ringmer. As many
new residential developments in rural areas are small in scale (10 units or fewer), the
changes in national policy may have a negative effect on the ability to meet this
need. This will require a stronger emphasis on alternative means of meeting this
need, such as a greater emphasis on the use of exception sites than is currently
envisaged.
8. Policy CP1 also does not recognise strongly enough the provision of alternative
forms of delivery of affordable housing. In the past twenty years only four homes
have been delivered on one exception site in Ringmer Parish, and only one site has
delivered ‘conventional’ affordable housing, all of which was allocated to residents
with no connection with the Parish.
9. There exist numerous workable models for affordable housing provision, focused on
the needs of local residents, rather than the conventional RP model. This imports
new residents who are then unable to sustain their place in the economy because of
lack of employment opportunity or good public transport connections.
10. It is often argued that affordable housing is uneconomic for the developer to provide
because of the low value payable by often grant funded RPs for the land. Whilst CP1
contains a test for viability for affordable rented housing and equity sharing, there is
no such requirement for other forms, nor any support for such forms in CP1. An
example is the Community Land Trust model
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11. CP1 should be modified to support alternative models of provision and include clear
open book accounting, all through the delivery process, not just at land acquisition
12. Demographic projections indicate a marked increase in the proportion of older
residents during the plan period. Inevitably a proportion of older residents will require
homes adapted to the use if they are to be able to remain living independently within
their community. To meet this need a high proportion of new housing should be
constructed to Lifetime Homes standards. This should be required, rather than simply
encouraged. The present wording in policy CP2(2) is too weak: it risks being ignored,
and thus ineffective.
13. I also strongly supports policy CP2(3) on rural development densities. A major issue
in rural communities in East Sussex, and in Ringmer in particular, is high car
ownership levels [Appendix A]. Previous policies seeking to reduce car ownership by
restricting parking provision have been tested, have failed the test and have rightly
been abandoned because of their negative impact on road usage and road safety.
The lower development densities proposed for rural areas in policy CP2(3) will permit
the inclusion of adequate off-road parking provision in all new residential
developments. This should be a specific requirement, included in the policy. Similar
policies are required for other rural developments, including developments for
employment and social and community facilities. Proposals for domestic extensions
in rural areas that increase the capacity of the housing should also be required to
make appropriate provision for off-road parking commensurate with the extended
size.
Appendix A: Median household income and car ownership in Lewes town and
Ringmer
Median household income
Households with no car
Households with 2+ cars
England East Sussex Lewes District Lewes town
£28,661
£28,091
£29,741
£30,702
26%
22%
20%
28%
32%
35%
34%
21%
Ringmer
£33,216
12%
44%
Car ownership data taken from the East Sussex in Figures website,
www.eastsussexinfigures.org.uk, maintained by East Sussex County Council and accessed on
20 December 2014.
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