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What is the Neighbourhood Plan doing about new housing?

The Neighbourhood Plan allocates a single site for 20-25 homes at Tuners Lane in policy DD1. The policy includes a list of requirements that the development should meet to ensure that it is safe, well designed and meets the needs that it generates. The policy requires the developer to work with the local community through the planning process.

If there is no strategic need for Wiltshire’s Housing Site Allocations Plan to identify any housing sites in the Malmesbury Community Area, why is the Crudwell NP allocating any at all?

The consultation on the draft neighbourhood plan showed that the local community consider there to be a lack of affordable housing in Crudwell. Wiltshire Council’s Parish Survey came to the same conclusion. Therefore, the neighbourhood plan aims to deliver a site that includes affordable housing to help ensure that future generations can afford to live in Crudwell.

It is also worth remembering that if the Crudwell neighbourhood plan does not allocate a housing site, then Crudwell is vulnerable to speculative proposals from opportunistic developers. With a “made” (i.e. completed or adopted) neighbourhood plan, the local community has much more control over developments in the Parish.

Why is a single housing site proposed for allocation for 20 to 25 dwellings, rather than a number of smaller sites?

One of the main reasons for providing new homes in Crudwell is to meet the identified need for eight affordable homes from the Parish Survey. The community told us that providing new affordable homes in Crudwell was important.

The Government’s planning rules do not allow affordable homes to be sought on sites of 10 homes or less. In other words, they can only be sought on sites with 11 or more homes. So, to enable the provision of affordable homes, we needed to find sites big enough to accommodate 11 or more homes. If one site has 11 homes, then the other would need to have 11 to 14, so that affordable housing could be required on both, in principle, while meeting the overall requirement for 20 to 25 dwellings.

Following the regulation 14 consultation, the Steering Group met with the Tuners Lane and Ridgeway Farm site promoters. One of the issues raised for discussion with both developers was the potential for the Neighbourhood Plan to allocate two smaller sites, delivering a total of 20 to 25 dwellings.

Both developers noted that this would impact on their ability to deliver a number of other community benefits, including the delivery of affordable homes and other on site facilities, high quality design and green technologies and to make contributions towards other existing services and facilities in Crudwell. On this basis, the Steering Group concluded that a single site should be allocated for 20 to 25 dwellings.

Why is the Crudwell NP allocating the Tuners Lane site?

Ten potential housing sites were suggested to the Steering Group when we asked for sites earlier in 2018. Of these, some were not available to be redeveloped before 2026, some had a capacity for fewer than 11 dwellings (so no affordable housing would be delivered on them), one was not adjacent to Crudwell village (so developing it would conflict with Wiltshire’s locational strategy for new development), and one would have resulted in many more homes than are needed. This is summarised in paragraphs 6.23 to 6.32 of the Sustainability Appraisal and Evidence Base. The individual site assessment sheets are in the Design and Development Focus Group report included in the Consultation Statement.

This left only two sites that:

  • Were large enough to deliver affordable homes; and
  • Would deliver housing before 2026; and
  • Would meet the Wiltshire Core Strategy preference for expansion of Crudwell village rather than the smaller villages and hamlets in Crudwell parish.

These sites are Tuners Lane (site J) and Ridgeway Farm phase 2 (site F).

When we weighed up all of the evidence, Tuners Lane was the considered to be the best site, mainly because we have independent advice that tells us that it is easier to get to most of the village’s facilities safely on foot from the Tuners Land site than it would be from the Ridgeway Farm site, and because developing the Tuners Lane site would have less of an impact on the village’s heritage assets that developing Ridgeway Farm would.

What about considering Ridgeway Farm phase 2 with 20-25 houses?

When we weighed up all of the evidence, Tuners Lane was the considered to be the best site, mainly because we have independent advice that tells us that it is easier to get to most of the village’s facilities safely on foot from the Tuners Land site than it would be from the Ridgeway Farm site, and because developing the Tuners Lame site would have less of an impact on the village’s heritage assets that developing Ridgeway Farm would.

If we reduce the size of the site allocation or split across more than one, what is the impact on affordable housing, S106 obligations and on the infrastructure levy?

As long as the housing site has a capacity of 11 or more dwellings or the total housing floorspace is greater than 1,000 square metres, then affordable housing at a rate of 40% of the total dwellings and S106 obligations (for example towards funding the teenagers’ play facilities) can still be sought. The Community Infrastructure Levy is usually payable on any development that creates one or more new dwellings.

However, following the regulation 14 consultation, the Steering Group met with the Tuners Lane and Ridgeway Farm site promoters. One of the issues raised for discussion with both developers was the potential for the Neighbourhood Plan to allocate two smaller sites, delivering a total of 20 to 25 dwellings.

Both developers noted that this would impact on their ability to deliver a number of other community benefits, including the delivery of affordable homes and other on site facilities, high quality design and green technologies and to make contributions towards other existing services and facilities in Crudwell. On this basis, the Steering Group concluded that a single site should be allocated for 20 to 25 dwellings.

How are flooding and sewerage issues being addressed?

Firstly, we only considered allocating housing sites that are not at risk of flooding.

Secondly, policy IT1 ensures that after any site is developed, surface water flows off the site are lower than they are currently.  This is usually done by storing water in heavy rain on site, in a pond or in underground tanks, and then allowing this water to release when the local waterways can cope with it.

We have been told that sewerage flooding occurs when surface water gets into the sewerage system, so controlling the rate of surface water run off from any development site will help to control this, and Wessex Water has fixed a number of leaks that allow surface water in already.

Finally, policy DD1, which allocates the Tuners Lane site, explicitly requires the Tuners Lane developer to ensure that the site does not floor and that it will drain safely and at a lower rate than currently, and that it should not make existing flooding worse, and should ideally improve it.

What will the impact of the Tuners Lane development be on traffic volumes?

The independent technical report that was produced by Cole Easdon Consultants for the neighbourhood plan concluded that the Tuners Lane development would result in an additional 14 vehicle trips in the morning and evening peaks, i.e. between 08:00 and 09:00 and between 17:00 and 18:00.  This equates to roughly one extra vehicle trip every 4¼ minutes.

This is the busiest time so traffic numbers will be lower at other times.

How will the NP ensure new homes are more affordable for local people?

The proposed site is sized specifically so that we can deliver 8 affordable homes for Crudwell. This has been a key factor in all our work to date.

How does the plan enable us to secure houses which are really affordable in terms of the housing market rather than just social housing?

The Government’s definition of affordable housing includes a range of different categories of affordable housing, including:

  • social rent;
  • rent at least 20% below local market rents;
  • starter homes (for first time buyers below 40 years of age with a discount of at least 20% below market sale price);
  • discounted market sales housing (similar to starter homes but not necessarily to young first time buyers);
  • shared ownership housing (where the occupant owns a proportion and rents a proportion from a housing association).

In principle, the 40% affordable homes provided on site can be any of these, or a mixture.  Wiltshire Council maintains a housing register with input from housing associations, so they know what particular affordable homes are needed locally, and they are likely to have an input into the affordable homes that are provided based on this local need.

In addition, policy DD1 requires the remaining 60% market housing on the Tuners Lane site to be predominantly smaller, low cost dwellings.

Additionally, policy DD1 provides the Community Liaison Group, which will be set up to work with the developer on the planning application, with an opportunity to influence the type of affordable and market housing provided on the Tuners Lane site.

What will be the effect of the Tuners Lane development on Crudwell Primary School?

At an average of 0.3 primary school children per dwelling, 20 to 25 dwellings would result in an additional 6 to 7.5 children at Crudwell Primary School, although this could be higher or lower. For reference, with the 10 houses at Chapel Way, there were no net new pupils at the school.

Policy DD1, which allocates the Tuners Lane site for housing, requires the developer to provide funding towards the primary school to cater for the additional children that would result.

The neighbourhood plan also includes a policy – CL1 – aimed at protecting the school.

What measures is the NP taking to address concerns about pedestrian safety?

One of the reasons that the Tuners Lane site was chosen over the Ridgeway Farm site is that the Tuners Lane is less busy than Tetbury Lane, and it is easier to extend the existing footpath all the way to the A429 on Tuners Lane.

We have also included a policy – IT2 – which requires developers to demonstrate how pedestrians will safely access the parish’s facilities from the site.

There has been some fantastic road safety work carried out recently by Wiltshire Council, and the Parish Council will continue to work for improvements.

How will the NP ensure that the design of any new development is in
keeping with its surroundings?

The neighbourhood plan includes a brand new Crudwell Design Guide which new developments should comply with. This is referred to in policy DD2.

For the first time, we capture the identity of the Parish and include design cues from existing properties, particularly those of historical standing within the Parish.

The Tuners Lane allocation policy, DD1, specifically requires the design of that development to be in keeping with Crudwell’s character and to accord with the Design Guide.

Policy DD1 also provides the Community Liaison Group with the opportunity to influence the development’s design.

What measures are being taken in the NP to ensure low carbon footprint for developments eg will there be requirements for grey water recycling, solar panels, wind power etc?

Preserving the natural environment and wildlife in Crudwell is very important to Parishioners. 85% of responders rated the impact of development on biodiversity as being either extremely or very important.

The regulation 14 draft policy included policies to protect biodiversity and to encourage renewable energy, as long as it is in the right place.

Wiltshire Council told us that their Core Strategy policies deal with these issues sufficiently already. We plan to look into environmental issues in more detail in the next Neighbourhood Plan, to 2036, but for now we felt that it was best to get the Neighbourhood Plan made quickly, so that we are protected from inappropriate development.

Is there a risk that we could end up with housing at Tuners Lane and Ridgeway Farm?

Yes it’s always possible, but we’re minimising the risk by having a neighbourhood plan which allocates a site for housing.

Normally, applications for housing on sites outside the settlement boundary or allocated sites would be refused, unless there is a good reason to approve it. This is partly why the Ridgeway Farm application was refused by Wiltshire Council in 2018 and then by a Government Inspector in 2019.

This balance changes if Wiltshire Council has less than 5 years worth of housing land. Then, an application like this would normally be approved unless there is a good reason to refuse it.

However, where the application relates to an area which has a made neighbourhood plan that allocates a housing site, like the Crudwell plan with Tuners Lane, then the housing requirement, in effect, reduces from 5 years to 3 years. This means that, even if Wiltshire only has something between 3 and 5 years worth of housing land, the application would still normally be refused.

What are the risks to the community if we fail to get this plan made, will we again be at the mercy of large allocations by Wiltshire Council?

Wiltshire Council planned to allocate a site for another 40 homes at Ridgeway Farm through its Housing Site Allocations Plan but they later agreed to remove that allocation on the basis that the Crudwell Neighbourhood Plan would determine the number of homes needed locally and decide where they should go.  A Government Inspector agreed that the neighbourhood plan should be left to make this decision too.

If the Neighbourhood Plan does not allocate a site, there is a chance that Wiltshire Council might allocate a site for us.

However, the greatest risk would come from developers submitting planning applications because it is easier for a developer to get planning permission for housing outside Crudwell’s settlement boundary if there is no Neighbourhood Plan in place.  Please see “Is there a risk that we could end up with housing at Tuners Land and Ridgeway Farm” for further details.

What happens after this plan is made? Will the next NP (to 2036) protect us from large housing allocation, or can it ensure that we develop according to the communities needs and requirements?

This Neighbourhood Plan reflects the same timetable as Wiltshire’s Core Strategy, i.e. it runs to 2026.

Wiltshire Council and Swindon Borough Council are now working together on plans that will run up to 2036.  These will need to provide for more homes to meet demand between 2026 and 2036, and Wiltshire Council will need to specify the number of homes needed in Crudwell Parish up to 2036 (in theory they are supposed to do that now but this requirement has only just been introduced so they are not in a position to do so).

It is likely that Crudwell will be required to provide some more housing up to 2036, so the best way for the community to have a say in where these houses go, and also to avoid developers getting permission on other sites outside the settlement boundary, will be to produce another Neighbourhood Plan.

An application was approved in Malmesbury recently despite Malmesbury having a made Neighbourhood Plan. Could the same happen in Crudwell?

The Malmesbury application was approved because of a combination of a relatively old neighbourhood plan and the proposal causing relatively little harm.

Normally, there is a presumption against permitting new homes outside settlement boundaries. Where Wiltshire has less than 5 years housing land supply, this balance tilts in favour of approval, unless the harm “significantly and demonstrably” outweighs the benefits.

Where a neighbourhood plan was made less than two years ago, this 5 year target falls to 3 years. Wiltshire’s housing land supply hasn’t fallen that low in years (other than in the south of Wiltshire which is not relevant to Crudwell) so it is pretty unlikely to happen in the next few years either.

If the neighbourhood plan is more than two years old, in theory the three year target goes up to five years again. In practice, the weight that would be given to a made neighbourhood plan diminishes gradually over time.

The Malmesbury neighbourhood plan is more than 5 years old so its weight has diminished quite a lot, and the application proposal was not considered to cause any major problems, so the application was approved.

Would developing the Tuners Lane site mean that land between Tuners Lane and Tetbury Lane becomes an infill site?

Not really, no.

Infill is only really relevant in places defined as “small villages” in the Wiltshire Core Strategy.

Where a town or village has a settlement boundary, like Crudwell village does, the settlement boundary defines where development is acceptable (within the boundary) and where it is not acceptable (outside the boundary).

“Small villages” don’t have settlement boundaries, so the Wiltshire Core Strategy explains that development in these places will be limited to infill.  Infill is not defined, but conventionally it means an undeveloped street frontage between two developed bits of frontage, so normally it would need to be on the same side of the road as the developed parts.

Crudwell parish has no small villages, so the infill policy is not really relevant.  As Crudwell village is a large village with a settlement boundary, the settlement boundary is the most important factor in deciding where development is acceptable in principle, and where it is not.

This FAQ document will be continually updated in response to parishioner questions.

Please email any questions to plan@my-crudwell.org