What does the Census 2011 tell us about our future housing needs?

The recently published Census 2011 data suggests to us that we did not need 175 new houses in Hawkwell for our children and grandchildren as the Council suggested to residents when they protested.

Nor perhaps the housing estate developments proposed in the rest of Rochford District.

With the age group 0 to 18 having increased across the whole District by only 186 over 10 years we leave it to you to decide about that.

Even if the birth rate in Rochford District shoots up from 2012 onwards as predicted these youngest children will not need new houses until earliest 2031 which is almost outside of the house building plan period.

With 0-18’s remaining around 17,000 over 10 years it is evident that the 1,828 new dwellings built in the District over 2001 – 2011 contributed adequately to their housing needs and other age groups. That is on average 183 new houses per year against the 250 per year which has been forced on our District by the last Labour Government and the new Coalition Government.

So if new estates numbering thousands in the District are to be built then many of these new homes must be for new residents to the District.

We are promised new jobs. When will the new jobs be created?

As the majority of the 6% population increase for Rochford District in the Census was in the over 60’s then instead surely we will need retirement villages to release “secondhand” family homes instead of new housing estates for a phantom birth rate or incomers to the area.

We adopted this policy as Independents several years ago.

On 9 April 2011 we wrote to Miss Laura Graham who was the Goverrnment Planning Inspector responsible for making a Decision on the Rochford Core Strategy.

“You should be recommending that the LPA should, therefore, take the existing CS away and press ahead without delay in preparing up dated development plans to respond to Planning for Growth and the LPA should use that opportunity to be proactive in identifying, driving and supporting the type of housing growth that this district really needs.

Instead of building new homes for families the housing strategy should focus on releasing smaller parcels of green belt in appropriately strategic locations to accommodate the needs of our aging population in terms of retirement villages which use a smaller footprint of green belt and release over housed family properties for re-use on sale.

Indeed Planning for Growth says “LPA’s should make every effort to identify and meet the housing, business and other development needs of their areas, and respond positively to wider opportunities for growth, taking full account of relevant economic signals such as land prices. Authorities should work together to ensure that needs and opportunities that extend beyond (or cannot be met within) their own boundaries are identified and accommodated in a sustainable way, such as housing market requirements that cover a number of areas, and the strategic infrastructure necessary to support growth.  I do not believe that the CS meets these requirements.”

We were interviewed by Rochford Life;

“Interestingly enough, when I mention retirement villages, I was quite heartened that in this Thames Gateway draft that the consultant have been putting together, that issue seems to be coming back, so maybe the noise we made, and the noise we made to the Inspector on the Core Strategy, has been read by someone and maybe this is the way our ideas come back and come into fruition.

I don’t honestly understand why the Inspector, when looking at the Core Strategy and looking at the potentials, didn’t turn round under the subject heading of housing and housing types, didn’t actually introduce that into the debate. If she had brought that idea forward with the developers, we may have found that many of them would have put their hands up and said, what a great idea, we can do that and it’s highly profitable and it’s socially sensible, it’s entirely engaging because it releases less Green Belt, so why don’t we do that. It’s a mystery to me.”

But today the Telegraph publishes that there is now support for this policy from a respected think tank report.

Pensioners stuck in family homes

A report from Demos has claimed that millions of pensioners face growing old in social isolation because they are trapped in family homes which they cannot leave. Pensioners who would like to downsize are sitting on a stockpile of properties with an estimated value of £400bn, the reports says. However, a shortage of smaller homes suitable for retirement means that more than three million over-60s are unable to move, it adds.

About Demos

Demos is Britain’s leading cross-party think-tank. We have spent 20 years at the centre of the policy debate, with an overarching mission to bring politics closer to people.

The Government’s response to the housing crisis is a focus on increasing home ownership among first-time buyers. Our latest report argues that building retirement properties for older people keen to move could free up over 3 million family homes.

The District of Rochford is part of the Thames Gateway Housing Market which comprises Rochford, Castlepoint, Southend, Basildon and Thurrock. This is a “Strategic Housing Market” and we are part of that “SHMA” (Strategic Housing Market Assessment) which will be published again by the end of 2013.

As with the Labour legacy of the Regional Spatial Strategies, it would appear that the number of new houses required to be delivered in Rochford District will not be decided solely by Rochford District but by consultants partly paid for by the Council and possibly by adjoining Councils under the “duty to co-operate” who would like us to take part of their quotas.

Will the new SHMA increase the yearly requirement from 250 per year in RDC?

According to the experience of the last 10 years according to the Census 2011 perhaps that figure should have been reduced already to the original 190 per year?

To justify 250 per year or more we need explanations and furthermore justification why we cannot have less.

[Notes: Rochford District Council provided the metrics referred to above and as such were verified and validated by the Council. The base information has since been requested and provided by the Council although Councillor John Mason has simplified the spreadsheet to allow the comparison between 2001 and 2011 to be seen at a glance here.]

Rochford Core Strategy Costs Already at £2.1 Million

£2.1 million of Public money has been poured into R&D costs of Developers which they do not pay for.

You did !!

Surely the Coalition Government should have found some sort of mechanism for this public money to be recouped from the profits made by each developer?

Rochford District Council has spent £2.1m plus over the past 7 years to April 2013 on the Core Strategy.

Within that £350,000 to Consultants.

£1 million came from Council Tax and £1.1 million from Government Grants making £2.1 million overall.

All money paid by you in Taxes.

How do I know? Because as Members of Rochford District Council (independents) Christine and I asked the question on behalf of residents.

If you want to see the full information supplied to us go here.

How do we see things?

• The Conservative Party promised to reduce the extent or even stop unwelcome development in their manifesto for the 2010 General Election.
• The National House Building Federation lobbied the new Government over many months and The Chancellor of the Exchequer reversed the manifesto promises by creating a policy for economic recovery based on house building; boom and bust repeated.
• Localism was promised in 2010 with local communities having a say in development was promised but all it meant was that Conservative controlled Councils would decide instead.
• The views of local communities calling for a stop were ignored.
• The reductions proposed by the Conservative Administration of Rochford District Council in mid 2012 were rejected and RDC now has yearly targets based on the Labour Regional Spatial Strategy coupled with a legally obligated Review for more years and more houses to meet the shortfall for adopting the Plan too late and finishing the build profile in the Plan years too early.
• The Conservative Secretary of State, Eric Pickles, failed to dismantle the Regional Housing Policies (RSS) of the previous Labour Government until January 2013. Too late to matter as the Rochford Core Strategy was Approved by a Government Inspector and Adopted in December 2011 at 250 new houses p.a. rather than the preferred RDC number of 190 p.a.
• So why has RDC not used the change in the law to revert to 190 p.a.?
• Surely residents would have expected the Council to have reduced the number of houses in the Allocation of Sites which is in Public Inquiry in September?
• The Hawkwell West development at The Christmas Tree Farm (Clements Gate) went ahead despite the fact that there has been no formal decision on the site at the Public Inquiry. So the Allocation of Sites could have been pulled until the numbers could have been reduced without opening the District up to the promised free for all from developers building even more houses.
• Too late for Hall Road (600), Brays Lane (100) and Hawkwell (175) where plans are already passed but a benefit of reduction in Hullbridge and Rayleigh.

An Outsiders View of the Rochford Core Strategy Suspension

Planning guru, Andrew Lainton, takes an interest in the Rochord Core strategy.

He writes in response to the Article that John Mason wrote in whiche he wondered if certain legal issues, namely a High Court case called CALA II could impact on the Council’s request for Suspension.

Interestingly John spoke of his concern in the Council Chamber even then about the further potential delays which might be caused by the Government having to conduct Regional Strategic Environmental Assessments (SEA) to finally abolish the Labour Housing targets (RSS).

Andrew talks about the third option that John also put forward which was withdraw and re-submit when the legal uncertainty was over.

Finally Andrew has advice for Local MP, Mark Francois, who is a senior government whip who wrote a letter of support to the Planning Inspector on behalf of the Council.

Over to you Andrew Lainton.
 
“It is not that simple, in CALA II one of the key issues was to do with the law on whether or not administrative degree could overcome the will of parliament.  After Royal Assent the will of parliament will be clearer.

But none the less as the junior minister Bob Neill has consented to there will be no revokation until the SEA process has been completed, consulted on and responded to.

Until then the RSS remains the development plan and the legal requirement for general conformity remains.

A material consideration can never trump a legal requirement, this is not a matter for weighing and balancing.

Suspension now of the examination could be challengable as it would be prejudging the outcome of the SEA consultation, indeed imprudent remarks from Ministers have made a challenge on grounds of the Seaport case (a NI SEA case in the European Courts) inevitable, which will take at least two years to conclude.

What is more statements by government payroll members (such as the local MP who is a whip) that after the royal assent the RSS should be disregarded (see letter) could be regarded as prejudicial to the SEA process, the MP needs to keep a judicial silence as his action is likely to be quoted in court as evidence of government prejudice – he could have led to the RSS being given life until conclusion of judicial process.

If the Inspector suspended the EIP (Examination in Public) it would be prejudging, the outcome of an SEA process and consultation that hasn’t even begun.  She should carry on and determine the plan of the basis of what is and not what might be in six months or two years – indeed they have a legal duty to. 

The situation of EiP examinations lasting over a year – when they used to last only a few days or weeks prior to May 2010 – has become a joke which discredits the whole process.

If Rochford was not happy with this they could always withdraw and resubmit later.

Of course on re-submission if they propose building much less than SHMA assessed need and without ‘duty to cooperate arrangements to cope with the housing they would displace beyond the green belt they would not just have a potentially unsound plan they would (after royal assent) have a potentially unlawful one.”

http://andrewlainton.wordpress.com/2011/08/01/rochford-asks-for-core-strategy-examination-to-be-suspended-in-light-of-nppf-and-cala/

Rochford District Council – Suspension of Core Strategy

Councillor John Mason’ s Speech in Full Council on 21 July 2011 opposing Suspension

Open Letter 1 following Full Council Decision to request Suspension

Open Letter 2 following Full Council Decision to request Suspension

The Portfolio Holder for Planning and Transportation, Councillor Keith Hudson, very kindly sent all Members of the Council two letters on Friday, 29 July.

1. The Council’s Letter requesting Suspension
2. A Letter from Mark Francois MP supporting the request

http://dl.dropbox.com/u/1063718/Letter_to_Inspector_re_suspension.doc

http://dl.dropbox.com/u/1063718/Letter_to_Laura_Graham_-_from_Mark_Francois_MP_29.07.11.pdf

http://dl.dropbox.com/u/1063718/minutes%20rdc%2021072011.pdf

The full story is in the Council’s Letter and the Minutes above.

The Council has quoted three precedents in its letter to Government Planning Inspector Ms. Laura Graham.

From the above Minutes “The situation the Council was in was not unique, the approach being suggested reflecting that taken by Inspectors in some other parts of the country.”

Had these been quoted in the Report making Recommendation which was debated in Council on 21 July I should have liked to have spoken about these before the Council made its written request.

Yes, they were all suspensions but you need to look at the detail.

South Wiltshire Core Strategy suspended August 2010 !!

Cllr John Brady, Cabinet member for economic development, planning and housing, said: “I am delighted the inspector has recognised that we find ourselves in highly unusual circumstances with the abolition of the RSS taking place towards the end of the Examination of the South Wilts Core Strategy. His agreement to suspend his report to allow us time to reassess our situation is most welcome.”

Note in 2010 !! Different circumstances to RDC and before any of the Cala Court Cases.

Surrey Heath Core Strategy suspended (est. March 2011)

“The planning inspector considers that there is insufficient justification to support the Council’s departure from the South East Plan’s housing requirement for the Borough. Bearing in mind the substantial level of housing need identified in the SHMA, the inspector considers this to be a potentially serious failing. In response, Surrey Heath has requested a suspension of the examination to enable more work to be undertaken.”

Again different circumstances to RDC. And before Cala II.

Luton/South Beds Core Strategy Examination suspended ( est. July 2011)

http://andrewlainton.wordpress.com/2011/07/05/the-legal-problem-that-got-the-lutonsouth-beds-core-strategy-examination-suspended/

Reading the above link and according to Andrew Lainton “The final point is a killer. The Joint committee had proceeded on the basis that the abolition of the RSS was material. At the time Mr Village wrote his letter we didn’t know the outcome of the Court of Appeal in Cala II. Now we do know.”

“The lesson is clear any LPA which has submitted a DPD taking into account the proposed revocation will be contrary to CALA II.”

Note before Cala II.  This looks critical according to Andrew Lainton who is a planning consultant.

This is the critical Para 24 from Cala II;

“It would be unlawful for a local authority preparing, or a Planning Inspector examining, development plan documents to have regard to the proposal to abolish regional strategies”.

My thoughts below;

Essentially, if the Inspector agrees to the suspension, she could be viewed as being in direct contravention of the principle established in the Cala II Appeal [para 24] as she would, in effect, be encouraging the authority to have regard to the proposal to abolish the Regional Strategy.

Should prove very interesting !!

Pickles – Court Says That Revocation of Housing Targets was Illegal

Guardian, 10/11/10

The Government’s ambitious plans to let English councils decide where new housing is to be built were thrown into confusion last night after Eric Pickles, the communities secretary, lost a court battle over his decision to scrap the the previous administration’s regional targets.

Upon taking office in May Pickles wrote to local authorities to announce his intention to “rapidly abolish regional spatial strategies” and instructed councils to start devising their own housing targets. The result was that local authorities cancelled plans for 189,000 new homes.

Today courts ruled this was illegal with a judge accepting that primary legislation should have been introduced, giving MPs the opportunity to debate an issue crucial to future planning in England.

Shadow Communities Secretary, Caroline Flint said the court ruling “raises embarrassing questions about the way Eric Pickles ripped up plans for desperately needed new homes. The coalition’s housing policies are doing little to meet the aspirations of the hundreds of thousands of families who want to live in a decent home”.

Editor’s Comment

I hear that PINS has yet to issue guidance and that Planning Inspectors in the middle considering Public Examinations are not necessarily going to follow the letter issued by Steve Quartermain at the DCLG on behalf of the Government.

http://www.communities.gov.uk/documents/planningandbuilding/pdf/1765467.pdf

This is my analysis of the position in Rochford District vis a vis the decision of the Courts for Cala Homes and, presumably, Colonnade, who named RDC into their action. 

I would be really surprised if these two companies have spent many tens of thousands of pounds on such actions if they could be meekly turned aside by a letter from DCLG saying that a Bill will be published shortly. Think about it !!
 
Here is my view on the RDC position.
 
The amendment to the Core Strategy represents, we were previously told by RDC, was a real REDUCTION in the number of houses that were to be imposed under the RSS Housing Targets.
 
The authority for the change or rather REDUCTION by RDC was cited as the revocation of the RSS in the Statement sent to the Planning Inspector in July. 
 
So if the authority for the change is not lawful yet then so is the proposition for the changes which are now being consulted upon.
 
The publication of a Bill changes nothing, such changes can only lawful on Royal Assent and this will not be before the end of the Consultation (30 November 2010) or the beginning of the re-opening of the Public Examination which the Planning Inspector says will be in January 2011.
 
Technically it must be UNSOUND if considered by the Inspector before Royal Assent because conceivably in a democracy and the fragility of an untried Coalition the Bill may not be approved in the passage required through both the Commons and the Lords.

It will be interesting to read considered legal opinions as they are published.

First from the http://www.plan-it-law.com/ web blog run by planning lawyers Mills & Reeves

“The judgment is out in this case. Mr Justice Sales decided today that Cala won on all grounds of their challenge.  The result is that the revocation of RSSs by the Secretary of State on 6th July was unlawful.  It must follow that the decision is quashed, thus reviving RSSs.”

“In practical terms therefore, until the abolition expected in the Localism Bill takes effect, RSSs are back again and form part of the development plan, relevant to planning decisions, unless there is a successful appeal by the Government.”

“If you’re interested in the reasoning, it follows a well-trodden path that statutory powers cannot be used to frustrate the purpose of the legislation – in this case, to have nationwide RSSs.  Also as RSSs are “plans or programmes” under the Strategic Environmental Assessment Directive, any alterations must follow the procedures for SEA.”

“Quite simple really.”

David Brock

and from the same site later………

“So in effect the position is intended to be as it was before Mr Pickes letter of 6 July – although presumably the weight to be attached to that particular consideration should not be quite as great now that it is clear RS cannot be dispensed with across the board by the Secretary of State but must await the deliberations of Parliament.”

 

Council in Battle with Government Inspector over Core Strategy

Everything that Michael Hoy and I (John Mason) asked Rochford District Council to do in our recent Motion on the housing needs of our district has been borne out by a Governmment Planning Inspector.

On 27 July the Motion was defeated by the block vote of the Conservative Administration and consigned to the bin.

But on 2 August the Government Inspector charged with deciding whether the Council’s housing policy and strategy for 20 years is SOUND or UNSOUND raised exactly the same type of questions formally with the Council.

Here are some extracts.

“On the basis of what is said in your letter, I am of the view that such changes could not be regarded as minor, albeit that the main thrust of changes would relate to the timescale of delivery rather than the overall quantums. These changes will therefore need to be subject to consultation and SA [SUSTAINABILITY APPRAISAL]. The consultation period would need to be a minimum of six weeks and fulfil any requirements in the SCI [STATEMENT OF COMMUNITY INVOLVEMENT].”

“I consider it would be of considerable benefit to the examination and its participants if these matters could be set out comprehensively in a Topic Paper.The paper should explain what account has been taken of the matters set out in PPS3 paragraph 33 and summarise the chain of reasoning for the revised figures by reference to any relevant documents such as the principal sources of evidence for the EEP, Strategic Housing Market Assessment documents (SHMA), Strategic Housing Land Availability Assessment documents (SHLAA) and any other relevant main sources (links to relevant sections of the evidence documents would be welcome).”

“In the absence of a requirement to meet targets in a higher level policy, are there any exceptional circumstances (PPG2 paragraph 2.6 [GOVERNMENT GREEN BELT POLICY] to justify altering Green Belt boundaries in relation to housing and employment provision.”

From http://www.rochford.gov.uk/pdf/corestrat_letterinspector2aug.pdf

But the Council in its response seems set to try and defy the Government Inspector and NOT have any further full public consultation on the changes. Here are some extracts.

“From the Council’s perspective it is disappointing to see your conclusions about the proposed changes to the Core Strategy being considered as significant changes and that a further consultation should be carried out to gather views prior to consideration at the examination.”

“It seems entirely reasonable for the examination when reconvened in September to consider affordable housing and the proposed changes that result from the consideration of the implications of the revocation of the East of England Plan. Without there being a need for a further round of consultation.”

“Whilst in the final analysis I will advise the Council of the need to comply with your conclusions about reconsultation, I would be grateful for some further thoughts and advice on this matter, not least in relation to the delay in receiving your final report.”

From http://www.rochford.gov.uk/pdf/corestrat_response_rdc.pdf

But if the Council continues in its wish to rush things through without another full public consultation then The Government Inspector left the position open with the Council to negotiate with formal objectors to the affordable housing policy.
 
“If any of the proposed changes will have a bearing on affordable housing policies, it may be expedient to prioritise consultation on those changes and negotiate agreement of those making representations on this topic.”

So what I have done is become a formal objector on Affordable Housing within the timescale of 17 August to support the Government Planning Inspector so that the new housing policies can be properly assessed and explained with reference to a local housing needs study that was asked for in our Motion.

Is the Pickles Abolition of Labour’s Housing Targets a Political Sham?

Promises made in the General Election and Local Elections could have been a cynical political sham.

Once the promise to revoke the RSS Housing Targets was enacted by Eric Pickles on 6 July, District Councils had the chance to make sure that the views of the majority of residents put forward in public consultations on their respective LDF/Core Strategies were acted upon.

But Rochford District Council has decided not to reduce the Labour house building targets but to just spread the same number over another 5/6 years. No green belt is saved. 

What could be a reason for building more houses than are required to meet local needs?

How many other Councils will also fail to act up and down the country? 

Please email me at john@onlinemail.me.uk about what your district council is doing so a country wide picture is formed.

Here is the evidence.  Judge for yourself. 

The Conservative Party Green Paper on Planning in February announced policy which actually has the clear objective of increasing the delivery of housing and other development.

Here are the direct quotations which support that view.

House building

In our previous green papers we have explained at length how and why we will be rejecting the current Government’s counterproductive housing targets, and instead offering local authorities a powerful council tax matching incentive to encourage new house building. We believe this incentive will prove strong enough to produce the scale of house building the country needs. However, we will keep the level of this council tax incentive under review in order to ensure that it does deliver.

A framework of incentives for development

We have already set out in a previous green paper our commitment that when your community builds more homes, central government will match pound-for-pound the extra money that your area gets through council tax for six years – and when your community attracts more businesses, we’ll let your area keep the increased business rates for six years.

Specifically, to encourage the building of affordable housing, we have decided that every new affordable housing unit that is built will earn the local authority in question 125% of the council tax raised by that unit, annually for a period of six years, to be paid through our Matching Fund.10This will induce councils to promote the development of affordable housing (by means of their local plan).

Shortly after the General Election articles in the Press confirmed;

 “It is Tory policy to encourage housebuilding by matching authorities’ council tax income from new developments.”

Then came the Con/Lib Coalition Government’s first Budget on 22 June 2010.

Budget 2010 – implications for planning

It was announced, inter alia, “Consider the most appropriate framework of incentives for local authorities to support growth, including exploring options for business rate and council tax incentives, which would allow local authorities to reinvest the benefits of growth into local communities.”

We now await formal announcements on the delivery of the Matching Fund Scheme from DCLG Ministers, either Grant Shapps or Greg Clarke.

But this is what we can expect in financial terms from the Times (12 June 2010).

Mr Shapps said: “An authority that ensured 10,000 new homes are put up could be in line for £100 million over six years.”

(http://property.timesonline.co.uk/tol/life_and_style/property/article7148429.ece)

Doing the math (£100,000,000 divided by 10,000 homes = £10,000 which in turn = £1666.

This is the Council Tax per year which compares quite nicely to Rochford District Council Band D and validates the math.

“From RDC’s Web Site The Council Tax for 2010/11 was agreed by Council on 16 February 2010. The total average Band D Council Tax for Rochford residents will be £1,518.63.”

So there is no misunderstanding in my mind on the financial incentive to build more houses than you need especially at the time of further cuts because the article was quoting a Minister on just 12 June.

This is big money.

At the 190 dwellings per annum that the Council has passed this could mean for the first 5 years of the Core Strategy this is on Band D a bounty sum of £1,442,100.

To finish my post from the same article in the Times.

“Grant Shapps, the Housing Minister, has told The Times that he will reward local authorities that give planning approval to housing developments by matching the council tax revenue collected from these homes. The money will continue for six years, with extra provided for affordable homes for first-time buyers.

Mr Shapps is determined to overcome those who object to new developments, despite allowing local people more say under the “revolutionary” planning overhaul”

Comment

The new Con/Lib Coalition Government will hardly be congratulated by residents when they realise that promises have been reneged on and they still cannot have their say on and be listened to  on anything that really matters locally despite all the spin on The Big Society and Localism and Decentralisation.

It is still about top down Government forcing its will on residents.

How is it that I can claim that?

• Well the Zero Council Tax decreed by Government for 2011/12 creates a Council Deficit of £1.5m over 5 years.
• And the bounty paid for building new houses over 5 years is £1.4m.
• So the deficit forces the Council to build the houses on green belt that you do not want.
• So if there was no decreed Zero Council Tax then the houses could have been cut back to local needs and aspirations.

That is the huge cost of the Zero Council Tax in 2011/12.

Is that what you wanted?

Core Strategy – A Done Deal Despite Further Consultation?

Although the Dismissal of the David Wilson Homes Appeal for 330 dwellings was known over a week ago I have not felt able until now to comment over and above publicly stating in the Echo that I am delighted with the result.

The residents groups of Hawkwell, the parish council and the many residents who have individually campaigned against  the proposals of David Wilson Homes are to be congratulated heartily for the work that they have done for our community.

What has become clear in the last week or so is that there will be 175 new dwellings built in Hawkwell West most probably between 2011 and 2015 because the Council has signalled that it will continue to include the preferred (general) location in Hawkwell West in its housing development plans and no reduction in housing numbers.

Some residents and residents organisations have expressed a preference for a number of smaller sites to be developed by a number of developers. 

Residents think that the first consultation on the actual site options, concluded in April, is already too limited despite further consultation being promised.

Another single planning application on the Appeal site or a Council preference for just the Appeal site would render the further consultation in February a sham in my view.

Whatever happens I will, of course, safeguard our interests by ensuring in Development Control Committee that every new planning application meets all of the the recommendations of the Planning Inspector and provides Hawkwell with the best result possible. I will also defend the position strongly if any future amendments are sought because my experience is that changes are sometimes sought which materially change a development from the ideal that we have already agreed to.

But a note of technical caution.

 Whilst the recommendations and observations of the Government Inspector will be helpful in ensuring that certain Design issues are unlikely to be repeated in any subsequent planning applications  you should bear in mind that these recommendations are only applicable against current policy. The new Government has pledged to put in place the basis of a new national planning framework in the summer of 2011.

Hawkwell had the first Action Group in Rochford District and since then the example has inspired the formation of new groups in Rochford/Stambridge, West Rochford, Hockley and Hullbridge. Well done  to the residents and community especially in Hawkwell West.

Notwithstanding the many claims from the Council in public meetings over the last few years that it had no choice but to plan for the housing numbers required by the Labour Government and its promises that following a change of Government that the position would be materially different I am so disappointed to be able to tell you that, despite the new Con Lib Government having delivered on its promises to you, that Rochford District Council has NOT. And Will Not.

The new District Councillor in Hullbridge, Michael Hoy (Green Party) and I put forward a Motion to ask the Council to undertake a study which would identify our local needs and only build houses to meet this.

One of the reasons that I did this is because I do not believe that that following the change in Government that the Public Examination of the Core Strategy, despite the representations of residents, and ironically developers, that the Core Strategy can now be judged to be UNSOUND and sent back to the Council.

I believe that the Core Strategy will be found to be in accordance with the policy of the new Con/Lib Government which is in favour of local councils building as many houses as they choose in return for financial incentives (an additional bounty of 100% of Council Tax per new property each year over 6 years).

Building in excess of local needs has its attractions to the administrations of local councils because it will cushion the effects and demands of spending cuts.

But do you wish to effectively sell your green belt for such a ridiculously small financial return? I doubt very much that residents want this.

So were you consulted before the Council’s decision on new housing numbers that will generate this bounty? No.

Should Rochford District be in the business of building houses to support London and the Thames Gateway Regeneration?

So I am even more disappointed to tell you that the request in our Motion for a local housing study was turned down.

And you will still NOT be consulted.

A copy of my Speech is here.

Instead the Council will adopt amended figures put forward to the previous Government, by a Quango that has been abolished, which, although the quota represents a reduction in the annual building quota for Rochford District, it results in the same number of houses being built over a slightly longer period.

The Administration scaremongered at Council that other housing studies inferred that 13,000 houses would need to be built and, were the housing numbers to be re-examined as we proposed, then Rochford District would be faced with 4 times their proposal.

13,000 was clearly nonsense hence we wanted to studies to be re-examined by the consultant at no extra cost to explain why such a ridiculous figure was necessary. And during the examination that the consultants should come up with a figure for actual housing needs rather than market demand which is led by regeneration and developers.

So the Administration has either panicked and grabbed at any figure it can which is convenient or it had an eye to the bounty of building extra houses for London and the Thames Gateway.  What a great way to go along with the almost hidden policy of the new Con Lib Government to build houses as an economic policy.  So much for handing decisions back to local views.

So no green belt identified for development by the previous Government will be saved by the New Government in Rochford District; full stop.

If you feel that you have not been listened to, and although the new Government says that you will be, then you have every reason to be disappointed with the administration of your local council.

What you do about that is up to you individually as residents and in the residents groups across the district.

Each Action Group could, for example, run a local campaign against the decisions of your local council administration right now running through to the next local government elections in May 2011. Bearing in mind that this coincides quite nicely with the next public consultation, which is provisionally timetabled to start in February and end in March/April, this will represent the very last opportunity to change the minds of those who represent the administration of the Council. Residents elected them and residents can elect other people.

Having said that I believe that the next public consultation is actually a sham which could stimulate many to campaign or in the minds of many residents resolve right now that they could and should elect others to represent them.

In a letter of objection dated 16 June 2010 submitted to the Council in respect of the Hall Road Planning Application (10/00234/OUT), Colonnade Land LLP allege that in evidence to the Coombes Farm Appeal that the [RDC] Planning Policy Team Leader confirmed that the Council could not resist applications for residential development at the broad locations in the CS.

What does that mean? Will the public consultation on the Allocation of Sites be a sham?

Well there are two major planning applications already to be decided upon in the preferred Location areas of West Rochford and Ashingdon. And these will be decided upon before the next consultation on what is called the Allocation of Sites Development Plan Document. These will be the actual green belt sites that will be built on.

So what will be the point of a consultation on actual sites when the Council allegedly has already said that the Council could not resist applications for residential development at the broad locations in the Core Strategy? We already know that these will Locations will remain at the number of houses already out forward but just spread out a little more in timescale.

But I cannot see any developer having the viability of its big site developments being spread over ten years rather than five.

So will the 190 dwellings per annum be the number built or will it be more? Because those planning applications already in total 750, and there are already 435 others in the 5 Year Supply monitoring report then the rate of building could still be 250 per annum. Or even more if developers for the 50 in Hockley and 175 in Hawkwell actually put in applications that are decided on before the one in West Rochford which the Council has agreed will not be until February 2011.

Or if the EON site comes forward for housing development as the Council seems to hope for then will this be in addition to all of these.  Somehow I can’t see the Council turning down a development on a brown field site being refused even if it has already exceeded the so called new 190 pa for 5 years.  

So which developer will get their permission first? Will the 190 X 5 = 950 be adhered to?

Or will the Council have to approve all of these planning applications because it cannot not resist applications for residential development at the broad locations in the Core Strategy or perhaps it cannot re-schedule development into a longer period?  

So the public consultation on the allocation of sites for the first ten years will be a sham in my view. The Lib Dem Councillors who put forward a Motion for identifying housing numbers up to 2025 had the right idea.  I supported that but again that was not what the eager house building administration wanted.

As a District Councillor, acting for Hawkwell West, and where appropriate with other opposition members, I feel that I have done all I can to represent the views of my residents  and those which also have active and independent Action Groups, which are both new and others long established.

 If there is to be any further change to the policy that has been adopted by the administration of our local council then it will have to be actively demanded by local residents. If there is such a campaign then, in principle, I shall support it.

Will Tough talk on the election trail actually be turned into action right now?

Today the Secretary of State announced the revocation of Regional Strategies with immediate effect.

In its Press Release on 17 June, Rochford District Council declared that it needed legal revocation and Government guidance in order that it could take action on pre-election promises on the Core Strategy – now it has both !!

What were the promises?

“Following its adoption [The Rochford Core Strategy] and when our electorate returns a Conservative Government to Power next spring, we shall be able to carry out our own housing needs study, it is then that we shall be able to adjust the housing allocations, as I promised so many months ago, to satisfy the needs of our community – not a penny more nor a penny less.”

Surely there can be no more excuses now?

Did “adjust” infer “reduction”  in the minds of residents?  Probably, YES .

Is that what residents are expecting? YES.

Or could “adjust”  mean something else? Mmm.

The prediction of The Rochford Independent is that the “political reduction” will be as follows;

-10.9%
East of England Regional Assembly
23,900 local authority option one figure
26,830 current RSS figure

[Source http://www.insidehousing.co.uk/ihstory.aspx?storycode=6508627]

The difference represents an attempt by the now defunct EERA to impose housing targets of 250 dwellings per year in the development time line from 2025 to 2031 which the Council had already rejected !

In other words NO CHANGE !! If this is what the promises actually mean then is that what you thought would happen? Or did you expect a reduction immediately?

Here are some extracts from the Government advice that was given yesterday to local planning authorities.

These are thought to be particularly relevant to the Rochford District but they are not thought to mean much in view of the above analysis and the further analysis in this article.

Local planning authorities should continue to develop LDF core strategies and other DPDs, reflecting local people’s aspirations and decisions on important issues such as climate change, housing and economic development.

These local plans will guide development in their areas and provide certainty for investors and communities.

Local authorities may wish to review their plans following the revocation of Regional Strategies.

We recommend reviews should be undertaken as quickly as possible.

Authorities may decide to review and/or revise their emerging policies in the light of the revocation of Regional Strategies. Where authorities decide to do this they will need to ensure they meet the requirements for soundness under the current legislation.

The examination process will continue to assess the soundness of plans, and Inspectors will test evidence put forward by local authorities and others who make representations.

Local planning authorities will be responsible for establishing the right level of local housing provision in their area, and identifying a long term supply of housing land without the burden of regional housing targets.

Some authorities may decide to retain their existing housing targets that were set out in the revoked Regional Strategies.

Others may decide to review their housing targets.

We would expect that those authorities should quickly signal their intention to undertake an early review so that communities and land owners know where they stand.

It is important for the planning process to be transparent, and for people to be able to understand why decisions have been taken. Local authorities should continue to collect and use reliable information to justify their housing supply policies and defend them during the LDF examination process.

Local planning authorities should continue to use their plans to identify sufficient sites and broad areas for development to deliver their housing ambitions for at least 15 years from the date the plan is adopted. Authorities should also have a five year land supply of deliverable sites. This too will need to reflect any changes to the overall local housing ambition.

The Government is committed to the protection of the Green Belt and the revocation of Regional Strategies will prevent top-down pressure to reduce the Green Belt protection. Local planning authorities should continue to apply policies in PPS2.

Surely there can be no more excuses now?

Let us just take a look at another of the promises………………………………from the leaflet in Hawkwell.

“Conservatives do not believe in Labour’s “top down” housing targets, which produce additional pressure to build houses in local areas, often regardless of whether those areas can really accommodate them.”

“The Conservatives believe that these targets, which were not decided by local people, should be abolished and that locally elected councillors, chosen by the people of their own District or Borough, should decide instead how many houses an area can cope with, and where they should go.”

Did residents think that this meant a reduction in housing numbers? Probably, Yes.

But where does this promise say “reduction” ?  Is that what residents are expecting? YES

So why might there be no reduction in housing development and loss of green belt? What are the issues?

The Government has instructed Council’s to place a zero council tax rise in their 2011/2012 Budgets. As the Rochford Independent has already reported this will in all likelihood mean a loss of income of £300,000 in the first year and cumulatively £1.5m over 5 years.

The only viable alternative is to cut services or to recoup this over each year off lost cash flow with income from another source.

Hey presto, here is what Eric Pickles will do to plug that gap.

“Imposed central targets will be replaced with powerful incentives so that people see the benefits of
building. The coalition agreement makes a clear commitment to providing local authorities with real
incentives to build new homes.””those local authorities which take action now to consent and support the construction of new homes will receive direct and substantial benefit from their actions. Because we are committed to housing growth, introducing these incentives will be a priority and we aim to do so early in the spending review period.”

Other issues could revolve around what are referred to as Option one numbers.

Eric Pickles says “Authorities may base revised housing targets on the level of provision submitted to the original Regional Spatial Strategy examination (Option 1 targets), supplemented by more recent information as appropriate.”

All local planning authorities were required to project the number of homes they believe are needed to meet their requirements by 2026. Known as option one numbers, these figures were submitted by local councils themselves to regional development agencies, with both parties negotiating over the number of homes to be included in the regional spatial strategy.

As I understand the position the figures put forward under Option one by RDC are those which were in the RSS and are in the Core Strategy.

So no help there perhaps.

And the Strategic Housing Market Assessments (SHMA) and Strategic Housing Land Availability Assessments (SHLAA) for Rochford District could be just put forward as local housing needs assessments which have already been produced and only relatively recently.

Representations to The Planning Inspector examining the Core Strategy by both residents groups and developers are united in saying that  much, much more work needs to be done to justify the Locations chosen.

At least that could mean that there will be the chance for residents to be to be consulted on the price THEY are prepared to pay in terms of reduced budget at RDC in return for less loss of green belt?

The Rochford Core Strategy needs to be reviewed in significant areas and hopefully the Government Planning Inspector will concur and see this as an opportunity to also declare it officially UNSOUND so a fundamental review can be undertaken.

These are the outstanding decisons where you can judge whether your interpretation of election promises have been delivered.

1. Residents of Rochford (326) and Hawkwell (330) wait for Mr. Pickles decision on the two Appeals at the end of July/beginning of August.
2. Ashingdon waits for the Council’s Decision on the Brays Lane Planning Application (150) on 19 August.
3. The whole of Rochford District wishes the Planning Inspector to declare the Rochford Core Strategy to be UNSOUND and to be sent back to the Council for a major revision.
4. The Council to decide to do what it promised  “to carry out a housing needs study for Rochford District and adjust the housing allocations proposed in the Core Strategy to satisfy the minimum needs of our community”. [reduction in housing numbers?]
5. Residents of Rochford also wait for the Council’s Decision on the Hall Road Planing Application (600) due in February 2011 under an agreement between the Council and the Applicant (PPA).

The Rochford Independent will let you know what happens over the Summer and Autumn in respect of the first four decisions and if the promises that were made to you are delivered.

You might like to read some recent articles that explain much more of the background and other issues that affect these decisions.

A Review of the Implications of the Abolition of the RSS on Rochford District

What Councils can do to revise an emerging Core Strategy

Will the Rochford Core Strategy remain unchanged?

And finally, here is what Eric Pickles had to say about Abolition of the RSS;

Parliamentary Statement by Secretary of State, DCLG, Eric Pickles

Revoking Regional Strategies

Today I am making the first step to deliver our commitment in the coalition agreement to “rapidly abolish Regional Spatial Strategies and return decision-making powers on housing and planning to local councils”, by revoking Regional Strategies.

Regional Strategies added unnecessary bureaucracy to the planning system. They were a failure. They were expensive and time-consuming. They alienated people, pitting them against development instead of encouraging people to build in their local area.

The revocation of Regional Strategies will make local spatial plans, drawn up in conformity with national policy, the basis for local planning decisions. The new planning system will be clear, efficient and will put greater power in the hands of local people, rather than regional bodies.

Imposed central targets will be replaced with powerful incentives so that people see the benefits of building. The coalition agreement makes a clear commitment to providing local authorities with real incentives to build new homes. I can confirm that this will ensure that those local authorities which take action now to consent and support the construction of new homes will receive direct and substantial benefit from their actions. Because we are committed to housing growth, introducing these incentives will be a priority and we aim to do so early in the spending review period.

We will consult on the detail of this later this year. These incentives will encourage local authorities and communities to increase their aspirations for housing and economic growth, and to deliver sustainable development in a way that allows them to control the way in which their villages, towns and cities change. Our revisions to the planning system will also support renewable energy and a low carbon economy.

The abolition of Regional Strategies will provide a clear signal of the importance attached to the development and application of local spatial plans, in the form of Local Development Framework Core Strategies and other Development Plan Documents. Future reform in this area will make it easier for local councils, working with their communities, to agree and amend local plans in a way that maximises the involvement of neighbourhoods.

The abolition of Regional Strategies will require legislation in the “Localism Bill” which we are introducing this session. However, given the clear coalition commitment, it is important to avoid a period of uncertainty over planning policy, until the legislation is enacted. So I am revoking Regional Strategies today in order to give clarity to builders, developers and planners.

Regional Strategies are being revoked under s79(6) of the Local Democracy Economic Development and Construction Act 2009 and will thus no longer form part of the development plan for the purposes of s38(6) of the Planning and Compulsory Purchase Act 2004.

Revoking, and then abolishing, Regional Strategies will mean that the planning system is simpler, more efficient and easier for people to understand. It will be firmly rooted in the local community. And it will encourage the investment, economic growth and housing that Britain needs. We will be providing advice for local planning authorities today and a copy has been placed in the house library.

Will The Pickles Letter and Abolition of the RSS Actually Matter?

DEVELOPERS have won a legal battle to build more than 300 homes on Green belt land at East Tilbury, prompting a leading local councillor in Thurrock to say he fears the “floodgates” are about to open.

Whilst back in Rochford in an email to a resident representing the West Rochford Action Group (WRAG) (and openly copied with no restriction to all Members of Rochford District Council) Portfolio Holder and Cabinet Member, Councillor Keith Hudson writes “I must profess disappointment and not just a little concern with respect to the planning appeal in East Thurrock towards the end of last week, the detail within the report is worth careful consideration.”

The scheme for up to 315 homes was opposed by both Thurrock Council and Thurrock Thames Gateway Development Corporation but Communities secretary Eric Pickles has given the green light for the development on appeal.

In his Decision Letter the Secretary of State concluded that the appeal proposal would cause harm to the Green Belt “by reason of inappropriateness and that there would also be harm to the purposes of the Green Belt by reason of inappropriateness and loss of openness”.

However, the Pickles Decision Letter went on to say that because there was “a need for more land to be brought forward for housing in the Thurrock area”, Pickles gave “significant weight to the quality of design of the proposed scheme and its sensitivity to its setting”.

He concluded that “these together amount to very special circumstances sufficient to justify allowing the appeal”.

My concern as a Ward Member for Hawkwell West, where there is an Appeal against a proposal for 330 houses in green belt is that, remarkably, this has already been given a green light for 175 by the Council allegedly in evidence to the Coombes Farm Appeal.  All that  notwithstanding the fact that the Council has in the words of The Portfolio Holder reported by the Echo  [the abolition of the RSS] “It’s something we’ve been banking on ever since we embarked on the core strategy”.

It is hard to escape the conclusion that the Council wish to see a housing estate in Hawkwell come what may.

In the meantime I continue to encourage residents to write to Mr. Pickles and the Council to express their views.

Indeed the Hawkwell Action Group has picked up on my suggestion in a leaflet to Hawkwell West residents providing a suggested letter to Mr. Pickles even at the eleventh hour.

But HAG could not have known about what Mr. Pickles was about to do in East Tilbury.

There are some remarkably similar issues which were considered by the Inspector.  Indeed in the Coombes Farm Appeal and the David Wilson Homes Appeal both developers submitted evidence in respect of their view of the 5 Year SUpply of Land provided by Rochford District Council.

The matter of the 5 Year Supply of Land is something that Conservative Rochford District Council has had complete administrative control over since, I think, May 2002.  My maths makes that a full 8 years of power. If these two Appeals in Rochford and Hawkwell are Allowed then residents should think very carefully about who to put their trust in next year at the Local Elections.  Especially as Conservative Candidates at the 2010 Local Elections inferred that abolition of the RSS was the key to the new Conservative Government in delivering both National and Local promises on overdevelopment of the Green Belt.

So what is there to concern residents of our district in the East Thurrock (Tilbury) decision in the detail of the Pickles Decision Letter?

In his Decision Letter Eric Pickles says that he took into account his own letter of 27 May 2010, The Pickles Letter, in which he promised to abolish the RSS (top down housing targets) and instructed decision makers to regard this a material planning consideration.

Did it work for East Tilbury ?  Whether it needed legisation or not, No, it did not !!

What Eric Pickles wrote was actually this;

“However, he [Mr. Pickles] does not consider it necessary to refer back to parties on the implications of this change of weight before reaching his decision as he would anyway have granted planning permission for this proposal for the reasons given in this letter.”

He goes on;

“The Secretary of State agrees with the Inspector’s reasoning and conclusions that this shortfall represents a failure to deliver a flexible and responsive supply of housing in relation to the housing targets required by the EEP. He considers that this is a material consideration in favour of the appeal proposals and that, notwithstanding the fact that the weight he affords to this matter is tempered by affording less weight to the housing figures set out in the EEP than formerly, it needs to be considered in the overall balance.”

“While he agrees with the Inspector that there are more sustainable locations for housing development in Thurrock than East Tilbury, he also agrees that the location offers a reasonable range of community facilities and reasonable access to jobs, key services and infrastructure and that the proposal would therefore perform well in broad terms against the requirements of PPS1, PPS3 and PPG13.”

And he also says;

“More significantly, he agrees with the Inspector (IR362) that the quality of design of the proposed scheme and its sensitivity to its setting weigh in favour of the scheme. He gives significant weight to those considerations and considers that these tip the balance so that the very special circumstances necessary to warrant allowing the appeal can be demonstrated.”

The decision on the Coombes Farm Appeal is expected on or before 26 July and Hawkwell on or before 5 August.

Let us hope that Rochford District Council has not already let residents down in the way that it has managed the housing development strategy over nearly the last decade  by following political objectives rather than the interests of residents. And that in Hawkwell and Rochford residents can still have a say in the future of housing development given that the new Government has promised to give this back local control.

Rochford Core Strategy – It’s Half Time

Basically it’s half time in the Rochford Core Strategy and the Council is taking a breather !! 

Come on England !!

This is a light hearted article by style and approach but it does focus on some real issues that concern residents of Hawkwell and the Rochford District.  

Rochford District Council, in its amorphous legal identity rather than a Cabinet Member charged with the personal responsibility for planning development or its paid Head of Planning, has issued a Press Release in response to my letter to Cabinet Member, Councillor Keith Hudson, on the matter of the Core Strategy following a series of announcements by the Conservative led Coalition Government.

The complete RDC News Release is here.

But  for ease of our readers I will extract particular parts of this News Release for greater focus and analysis in the time honoured tradition of “Match of The Day” with myself as a political rather than football pundit ( Councillor John Mason who is the only independent on Rochford District Council).

However Councillor Keith Hudson also had quite a lot to say at The Central Area Committee which was held at Hawkwell Village Hall on the same night as the Press Release, 17 June.  One wonders why there was not more in the Press Release?

Here are some the Action Replays from Thursday night in Hawkwell but first the game plan that was set out in the Press Release by the Manager of Rochford District Council United.

(Did I just write “United” ? Yes, well it could be if you were to count the Liberal Democrats are part of the National Coalition between the leading Conservative Party and the supporting Liberal Democrats but not quite because there is still an Independent and a Green who are not united with either of them in any way and the Rochford Lib Dems ferociously state on their web site OnlineFOCUS that they are not in a Coalition locally.)      

…..we are obliged to keep on course with our Core Strategy in order to comply with the legal requirement to provide a five year supply of developable land.

……prevent hostile applications from developers who may very well use any opportunity to push forward with proposals that are wholly unacceptable to our communities…

Well having the 5 Year supply of developable land did absolutely nothing to prevent the hostile planning applications at Coombes Farm, Rochford and the Christmas Tree Farm/Thorpe Road/Rectory Road Hawkwell.  And that was one of the major challenges that were made in the both Appeals by Colonnade and David Wilson Homes (Barretts). Just like 4:4:2 for England sorry guys but this formation doesn’t look like a winning formula !!

Action Replay: Councillor Keith Hudson said of the Hawkwell Appeal that he was 90% confident that it would be turned down because Secretary of State, Eric Pickles, would not stay in his job for long if he did not. (In an after the match interview he changed this to 99%.)  

But don’t get your hopes up with predictions from Keith because I understand that Mark Francois expressed the view to a resident last week that if the Planning Inspector finds in favour of DWH then Mr. Pickles would probably still not dismiss the Appeal as it has gone through a Public Inquiry and the Inspector’s report and recommendations most certainly will be accepted. Otherwise what’s the point of having public inquiries. 

Mark Francois might well be right because Eric Pickles said in declining to call in the Brent Cross Cricklewood regeneration plans “the application does not raise issues of more than local importance”.  That gives some idea of his thinking in excercising the powers of The Secretary of State and if a Planning Inspector is in favour of allowing an Appeal it is difficult to see that he would see anything other than issues of more than local importance.

I can’t see him being sacked or losing his job as Keith Hudson suggests (unlike football managers) just because of a local issue in Rochford District which was arguably the fault of the political administration of a District Council in failing to take appropriate action to protect the interests of residents from hostile, premature, planning applications.        

We now await further direction from government……………. we need to understand the arrangements for assessing housing need and how such assessments will inform future housing provision……

Well that worries me because the rules are going to be changed a little bit in who decides on the number of houses to be built and Rochford District Council United (RDC United) is not going to think about right now how it can change how it plays until the new rule book is carved into a tablet of stone instead of the paper version that we have already.

I don’t think that the Manager of RDC United likes the idea of managing the next game himself and that he wants Essex County Council “Wanderers” to go back to managing things as they did some year ago.

If Essex County Council gets the responsibility for deciding the number of houses think back to the way ECC has managed to keep the North of Essex, leafy, well funded with a vastly higher spend on transport infrastructure as compared with South Essex.  Expect the same number of houses for Rochford District if ECC decides. 

Why on earth is RDC looking to abdicate the opportunity to decide how many houses will meet our local needs when the Government is offering them the chance to be the sole manager of the game. (Lose the Game?)   

………..so that our plans for future housing development can be adjusted to reflect the needs of our communities and no more..

It worries me that RDC United is only talking about an “Adjustment” when the consultations with residents indicate that they are looking for a radical change in the next game.

But Keith Hudson clearly said, Action Replay; that [the Core Strategy] will not be the book you have already seen.

So which is it “adjustment” or “new book”?

Personally I think that the Council might be guilty of talking up the performance we can expect in the next game , it’s the play off of whether we go up or down next season, and I think that we are bound to go down if we keep playing the game to the old rules.

Talking of the old rules, Essex County Council is likely to go back to the old rule book and turn to existing documents and do nothing else when actually a radical re-assessment of local housing needs is required bu our local planning authority (LPA).

If you are interested then these documents they are the Strategic Housing Market Assessment (SHMA) produced in 2008 by the Thames Gateway South East and the RDC Housing Strategy of 2009.

I have great concern that these studies come up with specific targets for Affordable Homes and those who have applied to RDC for Housing.

I understand that the 5 year figure for Affordable Homes is in the region of 655 and the number of families, but in some cases single persons, requesting housing is in the region of 840.

Based on the Government Housing Policy, PPS3, real housing developments are required to deliver 35% of Affordable Housing.  Using 35% you can see the gross total of housing developments over 5 years is around 2000.

So what needs to be done in my opinion is an urgent piece of work that questions our local residents what are there likely family and personal needs for housing are over the forseeable 15 years in bands of 5 years.

Those asking for accomodation in Rochford need to be equally closely questioned about their precise needs and how they arise including where they are living right now, how this may change over the same period and how they are avoiding being homeless.

Back to the main game, the Press Release which also says;
The government appointed Inspector with the responsibility for determining the soundness of the Core Strategy is due to return to Rochford on 7 September 2010 for a session on affordable housing. In the meantime, she has written to all parties involved in the examination asking for comments on the implications of the proposed abolition of regional spatial strategies as well as the change to the definition of previously developed land and the removal of minimum densities for new housing development.

This is a critical and may be pivotal response by the Council given that it will be made alongside all other Respondents, some of whom have notably challenged the Council in two recent Appeals that it has a 5 Year of developable land in consideration by Planning Inspectors of both the Appeals and the Core Strategy.
 
At the heart of Miss Graham’s request are the implications of the Pickles Letter of 27 May which once legislated upon in the terms he states, the abolition of the RSS, would, prima facie, allow the Council to reduce the annual denominator of the 5 Year Supply calculation.
 
Will the Council actually accept the responsonsibility to establish itself the local needs of our district in terms of housing?

The question arises because the Council’s Portfolio Holder shed some doubt upon that when he spoke at the Central Area Committee on 17 June because he gave an impression that the Council might be more content with this being passed back to Essex County Council because in his example he came up with a locally assessed housing need of say 1000 which would have to be built in Rochford whereas a County view by ECC might place some of these elsewhere like Chelmsford or Colchester.

 I wonder just how widely the Council will consult before it replies to the Planning Inspector or whether any other Members of the Council will be permitted to provide any input.

If as a Member of the Council I am permitted to speak then I will be using the content of this article on behalf of residents of Hawkwell and residents of Rochford District generally.

Councils Can Surely Halt Housing Development Decisions – if they really try !!

Sarah Calkin’s article on “Housing targets are to be scrapped” published on the Echo Online on 5 June carried some fairly luke warm comments from Councillor Keith Hudson who is the Cabinet Member for Planning on Rochford District Council.

I have heard Councillor Hudson say in public many times that he did not wish to see so many houses built in Rochford District but that he had no choice but to put forward such proposals because the Government required this by Law.

Here is what he has published.

He has also said that everything will change if there is a Conservative Government.

BUT NOW HE IS STILL SAYING THAT HE CAN DO NOTHING AGAIN BECAUSE OF THE GOVERNMENT !!     

Echo Online, 5 June 2010 

“”Meanwhile, Rochford’s planning councillor has urged the new coalition Government to change the law as soon as possible.

Keith Hudson said he welcomed the Government’s intention, but wanted it to act straight away, otherwise the district was still vulnerable to large-scale developments.

Rochford District Council has to built 5,500 new homes before 2025 as part of its core strategy plan, which has just been the subject of a public planning inquiry.

Mr Hudson said: “It’s something we’ve been banking on ever since we embarked on the core strategy.

“We need it to happen now, otherwise we are obliged to continue on the route we have.

“We have a lot of residents who are unhappy and need some certainty.”

Mr Hudson said he was aware of major planning applications being drawn up by developers to take advantage of the current housing targets.

Other councils have reportedly already taken steps to abolish their regional targets, such as South Oxfordshire District Council, which has withdrawn plans showing where 5,000 new homes would be built across the district.”” (End of quote from Echo)

A Government Inspector called a halt to the Hearings on the Core Strategy relating to Housing at neighbour Castle Point on Friday following the publication of Advice from The Planning Inspectorate.

I think that we can all see that all new legislation takes time to pass.  It is unlikely that the full Decentralisation and Localism Bill will be passed in 2010 and most likely it will be 2011.  It is possible for a Minister to make an Interim Statement in the House.  But even that might not be possible before the Summer Recess.

But The Planning Inspectorate has thrown a life line. 

Rochford District Council can now surely lobby the Planning Inspectors who are considering two Appeals and The Rochford Core Strategy to also call a halt under the same provisions.

The Council as a principal party can do even better and make legal representations to the Planning Inspectors. 

Here is a Letter that I sent to Councillor Hudson today.

Dear Keith
 
I am sure that as Portfolio Holder for Planning and Transportation  you are already well aware of the subject of my email.
 
The full advice letter from PINS is here (http://www.planning-inspectorate.gov.uk/pins/advice_for_insp/rs_forthcoming_abolition.pdf).
 
Having read this very carefully I am of the opinion that in respect of the Coombes Farm Appeal, The Christmas Tree Farm Appeal and The Rochford Core Strategy which are all still in the consideration of Planning Inspectors that Rochford District Council can use the options available to it as a Party to each to make representations for either deferment or postponement of Recommendations to The Secretary of State until, at the very least, clarification has been made by Ministerial Statement.
 
Can I have your written assurance that Rochford District Council will  now diligently consider the options available and make such representations in each instance as to follow and reflect the views of the majority of residents which have been expressed to you and the Council on a consistent basis in each of the instances referred to above.
 
Could I also ask you to arrange for a Briefing Note to be sent to all Members as soon as possible stating the actions that the Council will now be taking to reflect  the interests of the residents of Rochford District in each of the proceedings referred to above.
 
I look forward to hearing from you at your earliest.
 
With my regards,
 
Sincerely
 
 
Councillor John Mason
Hawkwell West Ward

The Pickles Effect – And Castle Point throws out a Planning Application

Originally reported here at the Echo (520 homes and business park rejected on Thundersley Plotlands)

and Commented upon by Simon (assumed to be Simon Hart Vice Chairman of Hands off our Greenbelt Action Group)

I would like to say a THANK YOU to every one involved Publicly as I have done via email already.

To Barry Braizier who has fought for this land for many many years with the support of the local and wider area residents.
To the Councillors of Castle Point for Listening to the residents of the Borough it was fantastic to see unity in the Council Chamber over a topic that is so important to everyone with constructive objections to the Barratt’s application. This action of unity sets out the Councils Stance on development to all Developers setting out to submit plans to Castle Point.

Thanks also to Rebecca Harris (MP ) for actively perusing the Conservative Party before the election and the Coalition after the election and for Eric Pickles for issuing a formal letter of intent for the abolishment of Spatial strategies, which will remove the threat of enforced development on protected greenbelt land like Canvey and Daws Heath.

 The Kiln Road site needs to be allocated a new status that is outlined in the new Local Government Bill a site of local and wildlife interest. Thanks to Bob Spink for his support, and the Echo for keeping the story alive in the local press.

In regard to housing in Castle Point do not forget that the Council located nearly 4000 sites for homes that were not on Green Belt , that still a huge amount of homes for the infrastructure to support .

A big thank you goes to everyone who wrote in and objected or turned up to the meeting .

Once again every one WELL DONE, Castle Point has made a massive leap forward.

What other Councils have done;

– Taunton Deane Borough Council: reduced its housing target from 18,000 to 14,000 a year
– Cotswold District Council: cut its housing target from 345 to 300 homes a year
– West Oxfordshire District Council: stopped work on preparing its core strategy
– South Oxfordshire District Council: stopped preparing core strategy
– Telford & Wrekin Council: ripping up its housing targets
– Castle Point Borough Council AGAIN !!: planning inspector scrapped hearing on housing numbers
– Bristol City Council: planning inspector holding a slimmed down session on housing targets
– Dacorum Borough Council: taking advice from the Planning Inspectorate
– South Northamptonshire Council: delaying decisions on large scale housing developments pending further guidance

Will the Rochford Core Strategy Remain Unchanged?

Currently, under existing Legislation, no local authority can avoid the targets set out for it in the RSS (regional spatial strategy), as the Planning and Compulsory Purchase Act 2004 strengthened the powers of the previous Secretary of State over local planning authorities.

The LDF (local development framework) and the Core Strategy, which the Rochford District Council has produced, must be in general conformity with the regional spatial strategy and is currently before an examination in public by a planning inspector before approval. That planning inspector can recommend changes and, hopefully, Miss Laura Graham, the planning inspector, will make the changes that were sought by residents at the Hearing on 12 May 2010.

Surely this does not matter now given that the Conservative Party has formed a Coaltion Government with the Lib Dems and the Coalition Agreement includes a pledge to abolish the RSS?

The problem is that I do not think that there is any intention to abolish the Core Strategy.

The only promise for rapid change is to abolish the bureaucratic and undemocratic tier of local planning. That will include the abolition of the regional spatial strategies, the regional planning boards and national and regional targets.

At the present time we can only anticipate seeing primary legislation sometime in the first year of the new Coaltion Government.

We do not know in which Session of Parliament that will see the Decentralisation and Localism Bill take passage through the Commons and the Lords. I have asked Mark Francois MP to find out what he can for residents.
 
But it could be that prior to such legislation, The new Secretary of State could use executive powers to revoke the regional spatial strategies in whole or in part.

The recent Letter from Eric Pickles to chief planners at all local councils in the UK is not viewed as a Order or Directive with legal force but it is a signal to local councils that the regional spatial strategies and the targets will be abolished soon.  (When?)

It is unlikely that his expectation that his Letter will be taken as a material planning consideration by a local planning authority as a defensible reason for Refusal of a Planning Application.

That brings us neatly on to Appeals against Refusal.

There are two in Rochford District where decisions are expected at the end of July and early August.  These are Coombes Farm, Rochford (326 dwellings) and The Christmas Tree Farm [330](Rectory Road/Thorpe Road), Hawkwell.   

Residents of Rochford and Hawkwell, to their great credit, have shown that activism is not dead in the 21st century. The people who live in these areas have organised themselves and expended huge amounts of time and energy defending their interests and those of their communities in order for sense to prevail.

Eric Pickles has also addressed his Letter to Chief Planners to The Planning Inspectorate (PINS) whose planning inspectors heard both Appeals in April. It is difficult to see The Planning Inspectorate taking the Pickles Letter as being a material planning consideration.  The Pickles Letter is just “material” not a “material planning consideration” which is significant.

It is surprising that Eric Pickles is seeking planning decision recommendations from PINS on the premise that the Pickles Letter is a material planning consideration  because, actually, he has the final decision on each Appeal anyway.  It seems to suggest that unless PINS recommend Dismissal (Refusal) that there might be a problem here?

I personally fear that there will is a big risk here unless Mr. Pickles can issue an Order very soon under the executive powers of the Secretary of State to abolish the RSS because both Appeals revolve around housing targets in many ways, including the 5 Year Supply Rule from PPS3.  In any event, Coombes Farm is not even proposed in the Core Strategy and Hawkwell is proposed for 175 and not 330 as in the planning application.

I would recommend to all the action groups involved to write to Mr. Pickles to lobby him to dismiss the appeals and to make the abolition of the RSS of legal force before decisions are forced to be taken by him and the Coalition Government.
   
We can now get conveniently back to the issue of what really needs to be done.

The core of the issue is that if the current framework for planning applications remains in place developments will be imposed on other communities with little or no regard to the feelings of the local people who have to live there or to their livelihoods.

Housing must reflect the real needs of real people, which is why developments such as those proposed for Hawkwell and Coombes Farm must be stopped before they are begun. There is insufficient flexibility in existing legislation to deal with these problems which I dare say is replicated in other parts of the country.

Rochford District Council has found itself at the receiving end of a huge tide of local anger, and the situation has been compounded by communication and consultation issues.

I was hoping to have read in the Coalition Agreement that the Core Strategies themselves will be abolished rapidly too.  I don’t think that they will although a new national planning framework is promised except that this will be in the long term. Professional planners think it unlikely that the Coalition Government can actually dismantle the whole LDF structure and maintain any momentum in house building which is forecast at a significant level to meet the births and death dynamics of the existing population, ignoring immigration.

I do not know if immigration is a significant factor in population increase forecasts for Rochford District but it could be, and probably is, for nearby Southend.

So the Rochford Core Strategy stays.

Just tinkered with. 

Is that what you thought when you voted in the General and Local Elections?

What does this mean for Rochford District? 

You could feel very disappointed if my concerns are fulfilled.

My concerns are the following;

• that district councils do not have the resource, skills and expertise to assess local housing needs and that the responsibilty for this will be passed  back to Essex County Council in the form of the previous Structure Plan methodology……….which means that these will still not be local needs assessed and set locally

  

•  the new housing targets that are set will not change the development locations or numbers of houses proposed to be built in the first 5 years (2011 – 2015) of the existing Core Strategy and these will still go ahead……….why?

 

•  the original proposed development block quanta in 2011-2015 would stand because house builders will argue that smaller blocks are uenconomic and undeliverable

 

• and  the building of a significant number of houses (775) on green belt between 2011 and 2015 is unavoidable because the existing Rochford Core Strategy does not allow building on any brown field sites UNTIL between 2016 and 2025 AND THIS CANNOT BE BROUGHT FORWARD  

  

• so this would mean that although the RSS housing targets had been abolished, a lower target based on local needs would not be deliverable at the revised applicable annual rate…………..in other words houses would be built at a higher rate than necessary and in the first instance on green belt.

 

• that the reduced housing needs would be delivered at the expense of saving brown field sites instead of green belt in the second of the 5 Year Periods

 

• that this would be a significant departure from the long eschewed principle at RDC that additional housing would be delivered across the district on a “Fair Shares For All” basis because only developments in 2016 to 2025 would be cancelled.

If you think that this is fanciful thinking then I would ask you to look back at an article that was published in the Echo as long ago as July 2009 and I referred to in Exposing the Rochford Core Strategy  .

This is the plan that I think that Rochford District Council will deploy unless the residents and action groups, together with the individual Parish Councils get together and demand that the Rochford Core Strategy is re-written and not just tinkered with.

I would also like to mention the Hall Road Planning Application. A PPA or Planning Performance Agreement has been entered into by the Council and according to that plan the Planning Application will not be decided upon until February 2011. Which is a lot of time for new legislation and the Pickles Effect. But will it be enough time?

And just may be perhaps, Miss Laura Graham, the Government Planning Inspector, conducting the Public Examination of the Core Strategy, might order some big changes in the Core Strategy?

But in the meantime expect, for the reasons above, for Rochford District Council to plough on with its Core Strategy as already submitted to The Secretary of State. 

You expected change, you wanted change. But will there be real change in Rochford District?

Unlikely in my view because the Core Strategy was probably designed to be like this as was already realised in July 2009.

But change is happening elsewhere.  For example South Oxfordshire, Castle Point, Forest Heath, West Midlands, Peterborough and The Cotswolds to name just a prominent few.

Local Coalition MP’s elsewhere are enthusiatically encouraging their local authorities to make the changes necessary. 

But we have heard nothing encouraging from Rochford District Council or the local MP’s, Mark Francois and James Duddridge.  

Housing must reflect the real needs of real people which is what the Coalition Government wants to happen but a Conservative Rochford District Council might not, if I am right, deliver that preferring to meet the needs of developers by providing large housing developments rather than a appropriate lower rate of delivery on smaller sites spread right across the district.

Since writing this Article, Rochford District Council has spoken to the Press…….

The Echo says…….Meanwhile, Rochford’s planning councillor has urged the new coalition Government to change the law as soon as possible.

Keith Hudson said he welcomed the Government’s intention, but wanted it to act straight away, otherwise the district was still vulnerable to large-scale developments.

Rochford District Council has to built 5,500 new homes before 2025 as part of its core strategy plan, which has just been the subject of a public planning inquiry.

Mr Hudson said: “It’s something we’ve been banking on ever since we embarked on the core strategy.

“We need it to happen now, otherwise we are obliged to continue on the route we have.

“We have a lot of residents who are unhappy and need some certainty.”

Mr Hudson said he was aware of major planning applications being drawn up by developers to take advantage of the current housing targets.

Other councils have reportedly already taken steps to abolish their regional targets, such as South Oxfordshire District Council, which has withdrawn plans showing where 5,000 new homes would be built across the district.

Is this the end for green belt housing in south Essex?

No, I don’t think so………… but Rochford District Council suggests that it is only waiting for the Coalition Government to formally change the Law. 

Spin or Truth? 

Time will tell !!     

Conservative Party Green Paper on Planning

In an effort to be first with an informed review of the latest NEWS in planning , I am publishing my immediate reaction to the new Conservative, shadow policy, on Planning.  It was published just this afternoon, 22/2. It was an interesting read of just 20 or so pages.  (That’s quite good in itself actually.) 

I think that many residents in Rayleigh, Hawkwell, Hullbridge, Rochford and Stambridge were hoping that the Conservative Party nationally would be the “white knight” which would promise to save their green belt if only they returned a Conservative Government.  May be…. may be not…. do read on.

Whilst the Conservative Party Green Paper, will undoubtedly encourage many residents to hope that this will be outcome for their cherished area the policy actually has the clear objective of increasing the delivery of housing and other development.

There are financial incentives for Councils and this was expected. Why? Read on. 

Councils will be legally enabled to revise Core Strategies but with national Conservative Policy, then in the capacity of a  “New” Government, Councils might find it difficult to deliver cuts in housing targets which have significance for delivering tax revenues to meet tough national debt repayments !!

With the promised abolition of regional housing targets while simultaneously shifting control to the local level, this is formidable challenge in terms of delivery. To avoid the electorate drawing cynical conclusions too early will be another hard trick to pull off.   

But there is a presumption that a planning application will be approved if it conforms to a new, simpler and rationalised, national planning policy framework and the development is,……….. err, sustainable.

Nothing new here. Just like PPS3 and PPS12. 

How do you actually define “sustainable”? It is very difficult because there can be no numeric criteria.  It is a judgement, currently without even a tick list of criteria which need to be met being provided by anyone.

Residents are trying to get across their judgement on this in Hawkwell West at the moment in the DWH Appeal and to the Council itself who both want housing estates of 330 or 175 dwellings respectively.  Some residents have even decided to “club together” and hire a planning expert and a barrister. To the extent that it has come to this sorry state of affairs, planning is crying out for reform.

So sustainability will be a double edged sword giving loopholes on one side or rigidity on the other depending on how Councils wish to play in a specific site situation that is not as clear cut as others. Could that mechanism give local councils a particularly wide discretion on making what decision they like ? …..err…yes, sure…. and if rules on appeals were to be curtailed then these decisions will “stick”. 

The provision of affordable housing becomes a local decision unless the applicant is a local housing trust and then approval is almost presumed. And there is a financial incentive for a Council to approve affordable housing.

The notion of developers having the legal right to almost negotiate (?) local consent with neighbours ahead of a even a planning application is novel but fraught with danger as locals could be split in personal or collective negotiations and misunderstood promises.  Under this model residents will want to make sure that they vote for a council candidate who actually, really, does live in their Ward and that they have the skills to help make this difficult scheme deliverable and justifiable to all residents. And with Parish Councils getting involved as a party to be negotiated with who is on the Parish Council suddenly becomes something that might really matter.   

The prospect of residents being able to appeal decisions is ground breaking but I cannot see that surviving the protest of developer federations.  Can you? 

If the reforms go through it will not be a day when residents can take their eye off the ball for one second !!   But with the return to localism where the Local Plan returns supreme with locally assessed housing targets, residents must make sure that their voices are heard even louder !! And a harder deal  for political party councillors to sell or justify.  Up to then it will have been too easy to blame the other party !!  

To read the whole paper go here….http://www.conservatives.com/News/News_stories/2010/02/~/media/Files/Green%20Papers/planning-green-paper.ashx

Council Tax Freeze?

David Cameron says in a leaflet, specifically and personally addressed to you and popped through your door during these elections, that “We’ve got plans to help people through this recession – like a council tax freeze.”

See Leaflet here http://dl.getdropbox.com/u/1063718/davidcameron.pdf

In this case the Conservative Party can take this action right now and before a General Election because it is in majority control of many local councils,  all County Councils and so they can put in a local council tax freeze just as David Cameron has personally promised you.

But will they do it?

I think that the Conservatives in control of Essex County Council and Rochford District Council will have to run hard to explain convincingly enough that council tax could not be frozen if we continue to remind them of David Cameron’s promises because it is going to be really hard to argue on the doorstep that a council tax freeze could not be put in before the next set of promises at the general election or next local elections in May 2010.

It’s certainly a vote winner for whichever of the two major parties actually delivers on a zero council tax increase. All Labour needs to do is maintain the Grant to Local Authorities at the present level and then they can argue that any increase is down to local councillors, mostly Conservative ones across the country and certainly in our area.

It would be really daft if Labour cut the money provided to local authorities, wouldn’t it?

Unless the unthinkable happens…………..David Cameron goes back on his word to you because he admits to the country that he made a big mistake? Didn’t mean to do it now when it really matters?  Just a bit of spin perhaps?

Or perhaps he meant something else and all is not what it seems in the simple language that he used to get your vote !!

So what would it mean for residents of Rochford if it really meant that a council tax freeze can start right now?

The first year for decades that the Council Tax doesn’t just go up by many percentage points regardless of what you think and a freeze providing real respite for families, young and old, who are under such financial pressure.

But will they really want to do this? Well it shouldn’t be too difficult anyway because there is no inflation rise required because the RPI is negative.

But any planned improvements in services would have to be shelved because we, the residents, can’t afford it this year, next year or the year after.

Councils will have to work harder to make savings on services that still need to be streamlined,  make voluntary reductions in the inflated cabinet councillor allowances and expenses and no employee salaries rises, if they want to spend more on improvements.

Work would  need to be done between now and February on re-working the accounts and making any necessary savings. 

Will political parties say just about anything to get your vote? Yes, because they think that you will forget and there is always a explanation why they could not do it. Blaming the current Government perhaps? Not this time surely?  This is something that can be delivered.

This is a great opportunity for a political party to keep a simple promise and to prove that me and other cynics are wrong.

We must keep reminding them of what David Cameron has promised us.

But I fear that in the weasel words of politics that he will have an incomprehensible reason as to why his promise means nothing in practice.

Just empty promises.  But please keep voting for us !!

Rochford Housing Policy – What happens next?

So the public consultation on the Rochford Core Strategy – Preferred Options closed at 5.00 pm on 17 December 2008.

So what happens next?

Rochford District Council has shared with the public the outcome of the consultation.

But they have yet to say what they intend to do about the objections.

In the meantime the Councillors responsible for planning policy strategy have embarked on yet another tour of potential sites.  John asked the Portfolio Holder in public if these members would read all the objections before they visit a location.  He said that he would so let’s hope that all the others do and get up to speed with the problems that they did not forsee because of the lack of ward specific knowledge. 

Could 200 of the properties to be forced on Hawkwell be placed in the centre of Hockley?  Yes, if that option in the Hockley Town Centre Plan which was too late for the Core Strategy Consultation is chosen.  But only IF !! 
 
But the timetable for the production of the Local Development Framework has not yet been finalised.  The last John was advised in December was that RDC was still waiting for advice from GO East.  It is now 3 months on and it still has not been formalised which is a matter of concern.  Let’s hope that the latest dates for compliance have been chosen because Conservative Party policy promises to cancel the requirement for the houses and a General Election could be salvation for our green belt.

But there is concern that the RDC Core Strategy might have to be pushed along and into law on fears that there is no longer 5 years developable land in the District and that developers could force through unwelcome developments because the core policy is not already in place.  If that is the case then the Conservative leadership at the Council will be responsible for failing to spot the vulnerability and plan ahead because being able to delay progress and success of their own party at a General Election just could have saved the loss of so much green belt.

So what is the likely timetable?  It is likely, however, that the formal round of consultation on the Allocations DPD and Development Control Policies DPD will take place in June 2009, with pre-submission consultation on the Core Strategy in July 2009.

There will only be one formal consultation before the preparation of the submission document, and then formal consultation on “soundness” prior to submission.
 
“Soundness” is a particular procedure set down by the Government in a document called “Development Plans Examination – A guide to the process of assessing the soundness of Development Plan Documents.”  You can read it here. http://www.planning-inspectorate.gov.uk/pins/appeals/local_dev/develop_plan_docs.pdf
 
The Allocations DPD is when RDC will finally reveal the individual sites that it wishes to see developed for new housing.

Consultation on the Allocations DPD will be carried out in accordance with the Council’s adopted Statement of Community Involvement.  The precise community involvement activities to be used and arrangements have yet to be determined, but it is likely they will be broadly similar to those used for consultation on the Core Strategy Preferred Options.
 
The consultation on the Allocations DPD will not simply be a referendum and we will be looking at the contents of any representations.  If a member of public wished to object to one of the options being put forward in the Allocations consultation, I would advise them to outline their reasons for objection and exactly what they are objecting to, rather than to simply state that they objected in principle. 
 
The Council is not obliged to withdraw a proposal in response to public consultation, but we are required to show how representations have been taken into account.
 
Hawkwell should be looking for the long list of sustainability and infrastructure objections that I raised on behalf of residents to be fully satisfied if “South” Hawkwell  or rather Hawkwell West remains a proposal for 330 houses.
 
If not then the final and ultimate test of soundness will be an appeal before the final Public Inquiry.

And if the total number of houses in Hawkwell can be reduced to 130 then perhaps they could be built on the industrial site in Windsor Gardens, Hawkwell.  Magees is on the Call for Sites.  But has it been looked at seriously in the latest Tour by the Councillors reponsible for planning policy and strategy?

Residents of Hawkwell should write to each of them and ask.