2020 October: Local Plan Inspector Hearings Page 1
Cheadle Unite - Comments Re Planning Inspection Feb 2020 (Full pdf doc Here)
Background
Cheadle Unite submitted comments on the ‘Main Modifications to the Staffordshire Moorlands Local Plan Submission Version 2018’ (Detailed in EL10.001) to the Planning Inspector (29th October 2019). We made a written request that the inspector be given the full text (concerns have been raised by other action groups that the inspector is only presented with a summary). The 3 recommendations we made were:
To Make the Local Plan sound we stated in October 2019:
i) The planned level of housing should be significantly reduced (I.e. by over 50%).This reduction can be done on a proportional (pro-rata) basis without any further impact on the local plan.
ii) Any assessment of housing build against unrealistic targets should be removed. Unrealistic targets would be figures that don’t tally with consistent national metrics (Office for National Statistics (ONS) figures), the local community and a sustainable environmental strategy.
iii) Genuine collaboration with Stoke on-Trent and the Potteries to work on a long term sustainable strategy for the reasons stated.
Outline
There is a massive disparity between the plan of 6080 dwellings to 2034 that are being planned based on a flawed ‘Oxford economics model’ and a more balanced perspective using a wider set of metrics that includes genuine ONS Population predictions, Department for Communities and Local Government ( DCLG) housing predictions, environmental, health, sustainability and local aspirations (as detailed in our 29th October 2019 submission). The only way to address this disparity on such high figures is to extend the timeline or ‘trajectory ‘of house build. Assessment using the Liverpool Method over the full 15 year plan period rather than over 5 years goes some way to address the discrepancy though in reality still allows for an end target build that sits well above genuine objectively assessed need using a balanced perspective.
Detail
Local Perspective and a balanced assessment
The DCLG housing requirements clearly do not convey a need for housing level of anything like 6080 dwellings to 2034. As far back as 2015 the DCLG figure was only 2573 dwellings a figure that looks to have dropped to a genuine requirement of only 650 dwellings if we look at the 2016 ONS population figures. The disparity is striking.
The excessive plan sits against the aspirations of residents which has been further illustrated with the new consultation on major modifications including sites in Biddulph (BDNew etc) and Cheddleton to name a few which adds to the many thousands of consultation responses already submitted across the Moorlands including Cheadle (which still stand) and contradicts a sustainable environmental policy which sets to increase Pollution and promotes declining health and long commuter journeys. A wide range of factors are likely to impact on supply and demand. Not least the local, national and global economy and other factors such as Brexit. A plan based purely on a fiscal policy carries significant risks if, for whatever reasons, it’s aspirations may not be met and it is the principle king pin of the plan. Both apply with the local plan with an overriding ‘Oxford Economics’ Model. Amongst the 2839 pages of representations submitted to the planning inspector ‘EL11.003 Individual responses’, there are a handful of responses from developers. Their comments as individual corporate entities should carry no greater weight than any other of the many thousands of representations that have been conveyed to both the District Council and the Planning Inspectorate over the last decade regarding the local plan. More so it is not the Developers (largely outside the district) that will have to live with the consequences of their developments (only their profits). It is the local community residents, environment and health and sustainability of future generations that will live with the impact. Surely our communities should have priority say over the profit motivated corporate targets of developers?
Looking at the Numbers
Despite the excessive targets for the Staffordshire Moorlands. SMDC have identified 5668 dwellings to the Year 2034 in the HIS (EL10.004), close to the highly leveraged target of 6080 and project a surplus of 192 houses by 2031/32 (12 Years from now) on their table page 11.
6080 dwellings sit massively above the ONS and DCLG required predictions that even on the 2015 DCLG Housing Projections (and 2012 ONS Sub National Population based figures) detailed only 2,573 dwellings. If we factor in the latest 2016 Figures the requirement is even lower by our calculation, a net population increase of 1491 to 2031 (and 1532 to 2036), would only require around 650 Dwellings based on the UK average of 2.4 occupants per household. It is more than reasonable to argue that monitoring against such inflated figures is not appropriate
Taking our home town of Cheadle Looking at the revised HIS July 2019 (10.004) Table Page 11 HIS > EL10.004 as of July 2019
Allocations: 1136
Full Planning Permission: 60
Outline Planning Permission: 40
Total 1236
SMDC Sites Under Construction 294
EL10.004 Details 1236 dwellings alone for Cheadle (detailed above), the latest ONS figures across the Moorlands predict a genuine need of around 650 dwellings. With an allocation of 25% (excluding the inclusion of Blythe Vale which would lower the percentage) it is reasonable for Cheadle Residents to suggest the figure should be under 200 dwellings rather than 1,246. The same assessment can be applied to Leek, Biddulph and all the local villages hamlets and rural locations.
The allocation of sites by SMDC that can meet 5668 dwellings to the year 2034 in the HIS (EL10.004) is, in our opinion, excessive and certainly should not be used as a trajectory target, but clearly demonstrates adequate provision over the plan period. Any review should be based on a Liverpool method (over the plan period of 15 years) rather than 5 as it is clear from the HIS that provision has been made for even these high ‘Aspiration’ figures.
Why it Matters - Consequences
From the above table Cheadle has provision for over 200 dwellings on Brownfield sites that can meet a more balanced proportionate ONS required level. With a much more relaxed build rate there may be further Brownfield sites that come forward over the plan period for future requirement (2034+ period). We feel the constant threat of additional site allocations encourages the Council to have to pass applications that may not be appropriate for the local community and they may in effect have to accept applications that are less than ideal given a threat that they have to release more land. This includes inappropriate access to Greenfields and spaces over regeneration sites. The following details the situation regarding Greenfields as conveyed by the Campaign to Protect Rural England as far back as 2015:
2020 Planning Inspection Page 2