NPPF consultation May 2018 – my response

Government asked us what we thought of the proposed changes to the National Planning Policy Framework (NPPF) and I responded. Here’s what I told them:

NPPF Consultation May 2018
10 May 2018 D Hallett

I am Cllr Debby Hallett, Deputy Leader of the Liberal Democrat Group, and Chairman of
Scrutiny for Vale of White Horse District Council.

I have four points to make regarding the proposed NPPF:
1. Affordability is the most important thing
2. Housing Delivery Test must ensure it promotes the right behaviours and targets the
right people
3. ‘Sustainability’ needs a robust policy definition
4. ‘Viability Loophole’ needs to be closed

The main thing, as I see it, is that planning policy’s basic assumption is that private
developers can solve our county’s housing crisis. That’s not reasonable. Developers are in
business to make a profit for themselves and their shareholders, not to provide enough
affordable housing for people who need it. It seems clear that the problem won’t be solved
in the way we’ve been going about trying to solve it.

But as long as we have the current systems in place we must put in place policies that are
well-designed and well-considered in terms of the behaviours they promote and how we
can mitigate against unintended consequences. For one example, the Government’s Right
to Buy scheme costs councils money (a loss with every house sold), while at the same time
Government is reducing funding to local government (so there is no money or incentive to
build more council houses). These no-win situations should be fixed, but since they are
unlikely to be, we need well designed policies to encourage development of more houses
that are truly affordable.

Affordability

So long as land values are rising faster than earnings, the problem of not having enough
housing that people can afford will continue. The NPPF says its goal is to increase house
building. I think that’s the wrong goal. The goal should be to increase the stock of decent
houses to rent or to buy, and ensure that the people who need them can afford them.
I recently asked for a report to come to my council’s Scrutiny Committee on the state of
housing affordability locally. It came in Feb 2018; it’s called ‘Houses that People Can Afford’.

The report is here:
http://democratic.whitehorsedc.gov.uk/documents/s43516/Housing%20that%20is%20truly%20affordable%20FINAL.pdf

Vale’s report confirms what’s previously been anecdotal evidence. Here are some main
points:

  1. The affordability level as defined by Oxfordshire’s SHMA is higher than as defined by
    Institute for Public Policy; SHMA uses gross income, IPP uses net income, so income is
    considered after tax. Further, the planning framework instead considers affordability as a
    percentage of market price. We need a consistent definition of ‘affordability’. Basically, a
    useful heuristic might be this: housing is affordable if a household spends 35% or less of its
    net income on housing. Affordability should not be based on a percentage of market price,
    especially now that those prices are rising faster than household income.
  2. There was no data available for Vale or Oxfordshire housing specifically (why not?), so we
    used data from all of Western England, as the closest comparable area. Housing in Vale is
    more expensive though, so the affordability is likely even lower than what’s quoted in the
    report.
  3. We looked at house prices, rents, and income in quartiles. In order to buy a lower quartile
    property costing £255,000 in Vale, an income of £57,000 is needed, which is an upper
    quartile income. So only the highest income levels can afford to buy the lowest priced
    properties. House prices are rising higher than household income.
  4. Only 18% of ownership options are comfortably affordable at all, and then only to the
    highest incomes. (Ownership options are shared ownerships, first time buyers, help to buy,
    starter homes etc.) So four out of five ownership options are basically unaffordable to
    everyone. This needs to be turned around.
  5. Help to Buy schemes make houses affordable only to top earners (over £56,000). That
    wasn’t the intention of the scheme, as I understand it. Help to Buy is not working here in my
    district.
  6. Private rentals and any sort of ownership tenure are unaffordable to lower quartile
    income households. Only social rent is affordable to them, and we don’t have enough social
    housing. (Social rents are approximately 50% of market rents.)

And finally, our current policy requires 35% of major sites be affordable homes. But NPPF is
set to change that to 10%. What is the expected impact of that?

Housing Delivery Test

Implementation of this is likely to drop many councils right into the red, with terrible
consequences, even after years of local plan production and monitoring. I think Ministry
should consider what behaviour it is that this HDT is intended to promote. House building
rates are not under sole control of local planning authorities; developers can decide to sit on
land with planning permission to wait for land values to increase, for example. I think this
test is ill-conceived and does not promote the behaviour that’s intended. Instead, it
punishes local planning authorities for results out of their control. I don’t have a solution.
I’m sure there are clever systemic thinkers in the civil service who can define a metric that
does promote more house building, but the HDT as defined in the NPPF isn’t it.

Sustainability

In our council, I’ve seen the concept of sustainability be reduced to a consideration of
whether the proposed development site is within 400 metres of a bus stop. Officers and
committee members consider this is adequate. Even if that were an adequate definition, it’s
unrealistic to rely on it when councils are taking actions that directly reduce local bus service
(such as removing subsidies). Include in the new NPPF a rigorous definition of sustainable
development, so that it’s useful to decision-makers and encourages developers and officers
to consider all the aspects of what is intended by a ‘sustainable housing development’.

Viability Loophole

Developers are in business to make a profit. They know that if they submit a viability report
that shows their profitability will fall to an unacceptable level if they are required to be
policy compliant, the local planning authority will give them a break. In our district we see
developers regularly avoid our policy of a percentage of affordable houses. As it is right
now, the damage is theoretical, since by ‘affordable’ they mean 80% of market vale. As our
study has shown, prices at that reduced level are still unaffordable to all but the very
highest earners. But two things about that: 1) nationally, we must change the way
affordability is defined to consider household income against local housing prices, and 2)
national policies must be put in place to require developers to be policy compliant with
Local Plan policies (once they pass Inspection and are adopted). If that’s a problem, then the
systemic relationship between genuine affordability, project viability and development
policies should be explored.

Ox-Cambs Expressway – Vale’s position

Vale of White Horse have told councillors that the council’s response to the Ox-Cambs Expressway consultation has been submitted. The actual responses are in a Dropbox file here: https://www.dropbox.com/s/wc138yhqbzjjsmt/2018_04_12_VOWH+Expressway+Corridor+Consultation-+final+response.pdf?dl=0

This Vale Tory response is quite different from the Vale Liberal Democrats’ response (see the Lib Dem position here: http://cllrdebbyhallett.com/2018/04/18/oxford-to-cambridge-expressway-vale-liberal-democrats-response/)

If you only want the bottom line, then here’s a summary:

Thames Water Reservoir – Vale’s position

Vale of White Horse District Council had sent an update to all councillors to tell us of the general position Vale will take in responding to the consultation.

I was happy and surprised to hear that this Tory administration agrees with the Vale Lib Dem position; not sufficient evidence of need or appropriateness of the solution. They go further than I have; I said we need public consultation, Vale says we need public enquiry.

I’m fed up with litter on the A34. FED UP!

Since I was elected to the district council in 2011, I’ve tried everything I know to get the Tories to take responsibility for and clear up the litter along the A34. It’s not so bad elsewhere, like up in Oxford City area, or Cherwell. But in Vale, especially from the Marcham exchange (by Abingdon Tesco) up to Wytham, it’s just awful – an embarrassment to us all. It’s worse in the winter when the grass verges die back and you can actually see it all.

Over the years, I’ve asked publicly for Tory cabinet members to get the litter along the A34 cleared up. Repeatedly, and by different Tory cabinet members, I’ve been told that it’s not Vale’s responsibility. ‘Not my job, gov.’

This week I discussed the (intractable?) problem with Vale’s new Head of Service for Environmental Health, and she told me it absolutely IS Vale’s responsibility. !!!

So she’s going to meet with Highways England to agree an approach to solving this problem, and I say, ‘About time!’

I wanted to let you know the latest. An improvement may be coming soon.

I think it’s time for me to ask the Tory Cabinet member for another answer, and ask for the truth this time. I’m fed up.

Oxford to Cambridge Expressway – Vale Liberal Democrats’ response

Response to Oxford to Cambridge Expressway Consultation

This response is from the Liberal Democrat councillors representing the Vale of White Horse District Council.

  • The corridor decision is scheduled for Summer 2018. Although stakeholders have been involved in consultations to progress this project, the people and places that it affects may still be totally unaware of the full consequences. There should be full public consultation not only on the Expressway corridors but on the wider ramifications of the scheme before the corridor decision is taken.
  • The three corridors were all prepared as ‘desk-top’ choices based purely on data collected on East/ West travel. The current corridor choices are only now being subjected to an interactive regional traffic computer model. The current timetable should be put on hold whilst these results are analysed and further public consultation has taken place.
  • A railway freight train is capable of transporting the equivalent of 140 freight trucks. This results in a huge reduction in diesel fumes, NO2 emissions, road repairs, congestion etc. The Liberal Democrat view is that the East-West Rail project, including electrification, should be progressed as a priority. There should be transparent discussions between Highways England and National Rail about the costings and viability of the rail connection from Oxford past Bedford to Cambridge.
  • The relationship of each proposed corridor to Green Belt areas, SSIs, AONBs, heritage assets, hamlets, villages and towns should be clearly delineated on large scale maps available online to the public and widely advertised in the counties and districts concerned before the corridor decision is taken.
  • The current traffic congestion on the A34 as it runs through the Vale district causes severe problems to residents and the local economy. None of the expressway corridor options will significantly reduce this congestion. The building of the road will cause widespread disruption for no overall benefit to the Vale District.

For all the above reasons, we do not support the current proposals for the Oxford to Cambridge Expressway.

 

 

HMOs – changes in the wind

Changes are coming to how HMOs are regulated. HMOs are Houses of Multiple Occupancy, where 5 or more people making up 2 or more households are sharing quarters.

Right now, licensing regulations only apply for 3+ storey homes, which omits most of the examples in Vale of White Horse.

The new regulations, expected later this year, delete the 3 storey criteria. That means there will be several hundred (a best guess) HMOs in Vale that will become subject to regulation. There will be a minimum room size per person, accommodation requirements, and requirements for rubbish storage capacity. I don’t know if there are local flexibilities; we really REALLY need parking regulations for HMOs.

This is good news for British renters at the lower end of the rental scale. They are often vulnerable and victimised by unscrupulous landlords, and these changes in regulations will help.

See more here: http://blog.shelter.org.uk/2016/10/license-to-thrill-new-changes-to-hmo-licensing-are-worth-getting-excited-about/

West Way update 2 Feb 2018

(If you have a West Way photo I can use, please contact me?)

This is the latest message from Mace:

2 February 2018
BOTLEY DEVELOPMENT COMPANY (A MACE JV COMPANY) COMPLETES PURCHASE OF WEST WAY

The redevelopment of the West Way area was first awarded a planning consent in June 2016,
and Botley Development Company (BDC) has since worked tirelessly to secure agreements
with all businesses and landowners, helping those who want to stay and supporting those who
have opted to leave.

On 26 January 2018 BDC completed the purchase of the land from Vale of White Horse District
Council.

Works will commence in February 2018, starting with the creation of a temporary retail area,
allowing some existing businesses to continue trading at West Way throughout the
construction period, including temporary premises for Tesco, Co-op, Lloyds Pharmacy, North
Hinksey Parish Council and Baptist Church.

BDC is currently finalising the construction timetable for the main redevelopment. Subject to
the recently submitted amendments to the existing planning consent being approved, and
finalising highways agreements with Oxfordshire County Council, commencement of the main
works is anticipated in June 2018. By this time, the temporary retail area will be fully
operational.

Work on Phase 1 should then be complete in late 2020, with Phase 2 starting around halfway
through Phase 1.

Hoarding has been placed on and around the vacant premises at West Way for security
reasons. BDC is looking at ways of incorporating artwork to make the hoarding more attractive,
and is in dialogue with a local art group and nearby school.

BDC will be sending regular updates on upcoming works to local residents throughout the
construction period, supported by construction partner SDC and community engagement
consultant SP Broadway.

Commenting today, Huw Griffiths, Development Director at BDC said: “The planning consent and purchase has been a long and complicated process, involving a number of businesses and landowners with differing aspirations and ambitions at West Way. We are delighted to have finally completed the purchase of the site, and to have formed agreements that all parties are happy with. Mace would like to thank all stakeholders who have been involved in the process.”

Notes for Editors:
1. Botley Development Company (BDC) is a joint venture between Mace and Doric Properties.
2. For further information, visit the community consultation website  www.westwayconsultation.co.uk or contact:
David McFarlane, SP Broadway (assisting with consultation) – 0203 405 1400 or
david@spbroadway.com

Puffin crossing West Way at Poplar Rd

Oxfordshire County Council’s consultation for the new pedestrian crossing of West Way at Poplar Rd is open until 16 Feb 2018.

You can take part here:  https://consultations.oxfordshire.gov.uk/consult.ti/B4044WestWayPuffin/consultationHome

Here’s the comment I submitted:

I have two main worries, and I feel it’s important for me to highlight these for the county officers who will make this final decision. 
 
First, this is the main crossing for pupils to get to school and back home again. At the rush hour, the pavement on the north side of West Way isn’t wide enough to hold everyone safely. Crowds of people waiting to cross West Way mean others who are trying to pass by can sometimes be forced off the pavement into the street. There is no slack here; parents waiting on the pavement have been hit by bus mirrors. It’s that close to traffic. Can the pavement be made wider, safer and more capacious here?
 
Second, with the number of different vehicles using West Way right here, I think a 20mph limit would be helpful and advised. HGVs, service vehicles, cars, cycles, pedestrians, parents pushing push chairs, wheelchair users and blind people are all sharing the road and pavement here. Plus this crosswalk is just as west bound buses reach the bus stop and pull in. We’ve had some serious accidents here. Let’s slow everyone right down, to make it safer. 
 
4 Feb 2018