Hookhams Path Development
Tuesday, June 23, 2020
HOOKHAMS PATH DEVELOPMENT
The planning application has now been submitted to the Borough Council of Wellingborough by the developer. The date to submit presentations has passed.
The Parish Council objected to the development and a copy of the report is attached.
Hookhams Path – Wollaston Parish Council response Planning Application WP/20/00314/FUL Residential development consisting of 98 dwellings, a community woodland, SuDS attenuation, open space including children's play area, access arrangements off Hookhams Path, and associated landscaping, infrastructure and ancillary development.
1. The Wollaston Neighbourhood Plan identifies land east of Hookhams Path as the key location for residential development in the village. The Parish Council has worked closely with the Duchy of Lancaster over a number of years and, more recently, Bloor Homes in developing a scheme that can deliver significant benefits for the village including housing to meet the needs of the local population, open space, a community woodland, traffic-calming measures, biodiversity enhancements and contributions towards community facilities.
2. However, it is only in more recent months that the Parish Council has been informed of the developer’s intention to put forward a scheme for considerably more dwellings than previously envisaged. It is extremely disappointing to note that the developer has been unwilling to accommodate the concerns expressed on several occasions by the Parish Council regarding the number of homes and it is, therefore, with great regret that the Parish Council has taken the decision to object to this planning application.
3. The Proposal submitted on behalf of Bloor Homes Ltd is for the development of 6.3 ha of land to the east of Hookhams Path for 98 dwellings, a community woodland, SuDS attenuation, open space including children’s play area, access arrangements off Hookhams Path, and associated landscaping, infrastructure and ancillary development. The community woodland is 2 ha in size with a further 1.3 ha of land used as multifunctional green infrastructure. The residential development is to be accommodated on the remaining 3ha of the site and equates to a net density of about 33 dwellings per hectare.
4. The Planning Statement submitted with the planning application provides an explanation as to how the figure of 98 dwellings has been determined. In summary, it asserts that: The proposal seeks to balance the efficient use of land and need for smaller 1, 2 and 3 bed properties with the capacity of the site, the village edge location and the housing requirement for Wollaston in the Development Plan; Granting planning permission would not materially exceed the requirement of Wollaston set out at Table 5 of the JCS. Granting permission for the submitted scheme would secure delivery of the required number of homes in a comprehensive fashion, and in accordance with both the JCS and Neighbourhood Plan. The scale of development would provide some additional comfort if other sites do not come forward or permissions lapse, protecting the integrity of the Neighbourhood Plan policy framework to resist less suitable applications; and The application is supported by a suite of technical assessments which have not identified any reason for restricting the number of homes. Furthermore, pre-application discussions have not identified any limit on the scale of growth due to a lack of capacity in local schools or other facilities, subject to appropriate planning obligations. The conclusion set out in the Planning Statement contends that the scheme accords with the development plan and no material harm has been identified that suggests the amount of development should be restricted to less than 98 dwellings.
The Parish Council’s Objection The Development Plan 5. Government policy set out at paragraph 12 of the National Planning Policy Framework (NPPF) indicates that ‘Where a planning application conflicts with an up-to-date development plan (including any neighbourhood plans that form part of the development plan), permission should not usually be granted. Local planning authorities may take decisions that depart from an up-to-date development plan, but only if material considerations in a particular case indicate that the plan should not be followed’. The key policies of the Development Plan related to the Parish Council’s objection are outlined in paragraphs 6 to 10, below.
6. Policy 11 (The network of urban and rural areas) of the North Northamptonshire Joint Core Strategy (JCS) requires Local and Neighbourhood Plans to identify sites within or adjoining the villages to meet the rural housing requirements of 160 new homes in Wollaston during the period 2011-2031. The policy further indicates that other than small scale infilling or ‘rural exceptions’ schemes, development above this requirement will be resisted unless agreed through the Part 2 Local Plan or Neighbourhood Plans to meet a particular local need or opportunity. This element of policy is repeated in Policy 29 (Distribution of new homes) of the JCS.
7. The Plan for the Borough of Wellingborough forms the Part 2 Local Plan; it was adopted in 2019. It does not include any housing allocations for Wollaston but explains at paragraph 7.2.1 that the Wollaston Neighbourhood Plan, made at an earlier date (2016), makes provision for the housing requirements in the JCS.
8. Policy H1 (Number of new homes) of the Wollaston Neighbourhood Plan explains that the housing requirement of 160 new homes is to be achieved through the allocation of sites, windfall development and sites already granted planning permission. Development in excess of 160 new homes will be permitted where the proposal relates to either a small site within the Village Boundary or ‘rural exceptions’ housing.
9. Policy H2 (Housing mix) of the Neighbourhood Plan requires a mix of dwelling types and sizes to help meet the needs of different sectors of the community. The mix on an individual site should have regard to the character and density of surrounding development; and evidence of housing needs.
10. Policy HA1 (Land East of Hookhams Path) of the Neighbourhood Plan allocates land east of Hookhams Path for ‘approximately, and no less than, 80 dwellings’. The policy further states that ‘Detailed proposals, including the precise quantity of development and the southern and eastern boundaries, will be determined by a comprehensive scheme’. The meaning of ‘approximately, and no less than, 80 dwellings’.
11. The developer has concluded that granting planning permission would not materially exceed the requirement of Wollaston set out at Table 5 of the JCS (see paragraph 6, above). However, while Policy HA1 (Land east of Hookhams Path) of the Neighbourhood Plan introduces a measure of flexibility in the number of dwellings to be built at Hookhams Path, criterion 1 of that policy indicates that the site should provide ‘approximately, and no less than, 80 dwellings’.
12. The Oxford Dictionary defines ‘approximately’ as ‘to bring near, very close to, closely resembling, getting near to a quantity sought where no process exists for ascertaining it exactly’. The Parish Council has always been willing to accept some variation in the number of dwellings on the site. However, it contends that 98 dwellings is 22.5% higher than the minimum number of 80 homes referred to in Policy HA1 and does not therefore accord with the definition of ‘approximately’. Furthermore, in commenting on the proposed development, the planning policy section of the Borough Council has stated that the proposed scale of development is ‘not considered to be ‘approximately’ 80 dwellings – it significantly exceeds the figure. It therefore needs to be established whether significantly exceeding the figure set in the neighbourhood plan is justified’.
13. The proposal for 98 dwellings does not therefore accord with the definition of ‘approximately’ and consequently conflicts with Policy HA1 of the Neighbourhood Plan. Meeting Wollaston’s housing requirement.
14. The phrase ‘approximately, and no less than, 80 dwellings’ was introduced by the examiner who held the examination into the Neighbourhood Plan. At the time that the Neighbourhood Plan was submitted for examination in 2015 it was envisaged that commitments and allocations, including the provision of 80 homes at Hookhams Path, would provide 122 of the 160 dwellings required in Wollaston between 2011 and 2031, thereby leaving 38 dwellings to be provided through windfall sites.
15. However, the Report by the Independent Examiner explains (at paragraph 69) that while the examiner recognised that this figure implied a significantly lower rate of windfalls than had occurred over recent years, he had some doubt as to whether 38 dwellings would come forward on windfall sites by 2031. At paragraph 87 of the report he explained that a shortfall in the number of windfalls would necessitate additional allocations or a higher number of dwellings on the Hookhams Path site and he therefore concluded that it was necessary to allow some flexibility to accommodate a higher number of houses on the site.
16. The examiner further noted that while the reason for the specific number of dwellings was to keep the number of houses to the minimum required to reflect the wishes of many respondents to the draft plan, there was a tension between this wish and the presumption in favour of sustainable development in the NPPF. He concluded that a precise cap on the scale of development was not consistent with paragraph 16 of the NPPF with regard to the requirement to ‘plan positively to support local development’.
17. Policy HA1 of the Neighbourhood Plan indicates that developer contributions will be sought towards community facilities and infrastructure as part of the Hookhams Path development. In the absence of evidence to indicate that these contributions could be justified and funded from a development of 80 dwellings, the examiner explained (at paragraph 88) that ‘It is possible for instance that the most sustainable solution for the village may be a somewhat larger number of dwellings which could support a greater contribution towards the facilities that are sought’.
18. As a consequence of his deliberations, the examiner recommended the introduction of the phrase ‘approximately, and no less than, 80 dwellings’ in Policy HA1 of the Neighbourhood Plan.
19. The Planning Statement submitted on behalf of the developer as part of the planning application indicates on page 10 that the Borough Council had advised that there was a residual requirement for 97 homes in Wollaston to 2031. However, more recent data provided by the Borough Council is set out in the table below. The table provides a breakdown of housing completions, commitments, housing allocations and the residual housing requirement at April 2020. This information is based on the assumption that the Hookhams Path site is developed for 80 dwellings and indicates that the residual requirement (excluding the housing allocations in the Neighbourhood Plan at Hookhams Path and Hinwick Rd) is for 13 dwellings Dwellings Housing requirement 2011-2031 160 Housing completions 2011-2020 52 Existing commitments (as at 31st March 2020) 13 Outstanding allocations (Hookhams Path and 190 Hinwick Rd) 82 Residual requirement 13
20. The table indicates a residual requirement for 13 dwellings with more than 50% of the Plan period remaining. In addition, the Parish Council has now been notified by the Borough Council of a planning application (WP/20/00388/OUT) for a further 6 dwellings at Raymond Close. Approval of that application would reduce the residual requirement to 7 dwellings. In addition, the owners of Doc Martens have undertaken some public consultation in advance of a planning application for housing on land off the High Street. The development of these two sites (Raymond Close and High St) would more than meet the residual requirement of 13 dwellings and would therefore negate the need to provide more than 80 homes on the Hookhams Path site to meet the Plan requirement.
21. Furthermore, it is realistic to expect that, having regard to the size of Wollaston, further windfall sites will come forward and will provide a measure of flexibility in the event that not all existing commitments result in housing completions. Commenting on the planning application, the Planning Policy section of the Borough Council has stated that the residual requirement ‘amounts to 1.2 dwellings per year for the remainder of the plan period. This seems an entirely reasonable expectation, especially as the council has had a number of pre application inquires on sites within Wollaston’.
22. The examiner recommended the inclusion of the phrase ‘approximately, and no less than, 80 dwellings’ to provide limited flexibility in the scale of development at Hookhams Path in response to doubts over the likelihood that 38 dwellings would come forward on windfall sites by 2031. However, more than 4 years have passed since the examiner submitted his report and the evidence outlined above clearly indicates that windfall sites continue to emerge and that the housing requirement for 160 homes in Wollaston can be met without the need to increase the number of dwellings at Hookhams Path to 98. Furthermore, while the examiner indicated a possible need to enable more than 80 dwellings at Hookhams Path to support a greater contribution towards the facilities sought by the Development Plan, the Planning Statement submitted as part of the planning application does not identify this as a 1reason for the proposed quantum of housing development. The effective use of land
23. Section 11 of the NPPF is concerned with ‘making effective use of land’. It indicates that planning policies and decisions should support development that makes efficient use of land having regard to a number of factors including the identified need for different types of housing and the importance of securing well-designed, attractive and healthy places. It is especially important that planning policies and decisions avoid homes being built at low densities where there is an existing or anticipated shortage of land for meeting identified housing needs.
24. Paragraph 4.73 of the Neighbourhood Plan describes the site area of the land at Hookhams Path as being ‘approximately 4ha.’ However the Neighbourhood Plan examiner noted in his report (paragraph 89) that the allocation forms part of a larger field and there are no obvious physical features which justify the eastern and southern boundaries. Consequently, he recommended rewording in Policy HA1 to require detailed proposals, including the precise quantity of development and the southern and eastern boundaries, to be determined by a comprehensive scheme. He also recommended an amendment to the policies map to show the southern and eastern boundaries with a dotted line and an annotation to say ‘boundary to be determined by comprehensive proposals’. 25. The proposed development, excluding the 2ha woodland, relates to a site area of approximately 4.3ha, including 3ha of residential development and 1.3ha of open space. This results in a net residential density of about 33dph.
26. However, Policy HA1 does not specify the net residential density of development to be achieved nor does it require the residential element to be accommodated on 3ha of the site. In addition, the developer has not suggested that 98 dwellings must be provided to ensure the viability of the proposed scheme. Consequently, if the site area was reduced to 3.7ha, for example, consisting of 1.3ha of open space and 80 dwellings on the remaining 2.4ha, this would result in a net residential density of approximately 33dph. It is contended that this would be more efficient than the current proposal in terms of land-take as it would achieve a similar net density while reducing the loss of agricultural land from 4.3ha to 3.7ha.
The housing mix
27. Policy H2 (Housing mix) of the Neighbourhood Plan requires a mix of dwelling types and sizes to help meet the needs of different sectors of the community. The mix on an individual site should have regard to the character and density of surrounding development; and evidence of housing needs.
28. Existing development at Hookhams Path includes a mixture of detached and semidetached dwellings, including a significant number of bungalows. Many of these existing dwellings have large gardens and/or wide frontages resulting in a low density of approximately 16dph. The most recent evidence of housing needs, outlined in the Wollaston Rural Housing Survey (2018), is for some 27 affordable units (including 4 bungalows) and 8 market dwellings (including 3 bungalows). However, while the submitted scheme includes 4 market bungalows, only 1 affordable bungalow is proposed.
29. However, the most recent (2018) ONS population estimates indicate that Wollaston has a population that is, on average, older than the population of England as a whole. While 18.2% of the population of England is aged 65+ and a further 18.8% is aged 50-64, the equivalent figures for Wollaston are higher – 20.6% and 20.8% respectively. It is anticipated that the number of older people living in Wollaston will increase during the current decade. Consequently, the ‘Housing Mix’ section of the Neighbourhood Plan (page 34) emphasises the need for more bungalows to enable older people to downsize to properties that better meet their needs.
30. Having regard to the findings of the housing needs survey, the anticipated increase in the size of the older population, the popularity of bungalows amongst this age group and the need to have regard to the character and density of surrounding development, it is considered that the number of bungalows should be increased within the proposed development with a consequent reduction in the type of dwellings for which there is no identified need in the rural housing survey. This would result in a housing mix that would better meet local needs and have greater regard to the character of existing development in the vicinity of the site.
Highways 31. The Transport Assessment submitted on behalf of the developer has concluded that the development will have no material impact on the local highway network. However, while it assessed several junctions it did not examine the anticipated impact on the Irchester Rd/Bell End/South St junction. In 2019 a traffic survey undertaken by the highway authority following pedestrian safety concerns indicated that this is a busy junction with an average of 6,183 traffic movements per day including HGVs serving Scott Bader and Hinwick Road Industrial Estate; and school related traffic, including buses. The Transport Assessment fails to recognise the significance of this important junction within the village.
32. The Statement of Community Involvement submitted with the planning application summarises responses made following a public exhibition held earlier in the year. It explains that ‘the most frequently occurring concerns, by far, were transport and traffic related’. Concerns were raised about existing traffic issues in Hookhams Path including HGVs travelling to and from the Hinwick Rd industrial estate, Santa Pod Raceway traffic and the number of vehicles in the vicinity of the secondary school at drop-off and pick-up times. The local community also expressed concerns about traffic and parking issues within the wider village area and how the proposed development could worsen the situation. The Parish Council considers that additional vehicles would add to problems which already exist at pinch-points within the village, notably on Newton Rd in the vicinity of the Coop store, where traffic is particularly heavy on a Saturday, and on High St where the newsagents/post office is located.
33. Notwithstanding the findings of the Transport Assessment, a reduction in the number of dwellings to accord with Policy HA1 of the Neighbourhood Plan (i.e. approximately, and no less than, 80 dwellings) would therefore result in a reduction in vehicular movements generated by the development site and would help to address some of the traffic concerns expressed by the local community. Other comments and concerns.
34. In addition to the above concerns, the Parish Council wishes to comment on a number of other aspects of the development as follows: The maintenance of open space. The Planning Statement submitted on behalf of the developer indicates (page 30) that options for the management of the open space ‘include appointment of a management company or transfer of some elements to a body nominated by the Council. The Parish Council have stated an interest in the community woodland and other parts of the site.’ The Parish Council wishes to confirm that it wants to take responsibility for the maintenance of open space, including the woodland, subject to an agreed commuted sum. Local character. A number of the proposed properties are faced in stone, which is a locally distinctive material. This is supported by the Parish Council which requests that consideration be given to further increasing the number of stone faced houses within the development. The recommendations submitted by the highway authority and dated 23rd June 2020. In respect of: Recommendation 2.3 (internal footpaths) – the Parish Council objects to the recommendation that the internal footpaths will not be adopted as highway maintainable at public expense. Adherence to this recommendation is likely to result in maintenance problems at a later date; Recommendation 2.7 (emergency access) – the Parish Council objects to the recommended removal of this access which will also provide a pedestrian link between the development and the remainder of the village; Recommendation 2.8 (pedestrian crossing) – the Parish Council wishes to support this recommendation as it would provide an important traffic calming and pedestrian safety measure.
35. Policy HA1 (Land east of Hookhams Path) of the Neighbourhood Plan requires the quantum of development on the site to be ‘approximately, and no less than, 80 dwellings’. The current proposal for 98 homes does not accord with the definition of ‘approximately’ and represents a 22.5% increase on the minimum number of 80 homes referred to in the policy. Up-to-date information indicates that windfall developments in Wollaston continue to emerge at a significant rate. Consequently, the proposed scale of development cannot be justified on the grounds that it is required to meet the housing requirement in policies 11 and 29 of the JCS.
36. Furthermore, the developer has not indicated that 98 dwellings are required to secure the viability of the scheme nor is there evidence to indicate that this amount of housing is necessary to make effective use of land. While the Parish Council recognises that more dwellings will yield a greater level of developer contributions, it does not consider that this consideration should outweigh its fundamental objection to the proposed scale of housing proposed by the developer which conflicts with the Neighbourhood Plan.
37. The Parish Council wishes to ensure that the policies of the Neighbourhood Plan are upheld. Its key objection could be overcome by the developer acknowledging that it is unnecessary to provide 98 dwellings on the site to meet the housing requirement for Wollaston in the JCS and revising the application accordingly. Increasing the number of bungalows within the development would better meet local needs while reducing the overall number of dwellings would help to address some of the traffic concerns expressed by the local community.
38. Given that the proposal conflicts with an up-to-date development plan and there are no material considerations which indicate that the Development Plan should not be followed, Government policy indicates that permission should not be granted for the scheme in its present form.