What is the Neighbourhood Plan doing about new housing?
The Neighbourhood Plan proposes to allocate a single site for 20-25 homes at Tuners Lane, and to include a policy to ensure that housing built within Crudwell’s settlement boundary meets local needs.
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?
Our survey showed that people do feel that in particular, there is a lack of affordable housing in Crudwell. Therefore our plan aims to deliver a site that includes affordable housing to help ensure that future generations can afford to live in Crudwell.
It’s worth remembering, if Crudwell does not have a Neighbourhood Plan allocation it is vulnerable to speculative proposals from opportunistic developers.
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.
At the same time, the Neighbourhood Plan can only allocate sites which will deliver housing before 2026, which is the end date of the Neighbourhood Plan.
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 on pages 52 and 53 of the Sustainability Appraisal [link SA]. 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).
The reasons for choosing to allocate Tuners Lane over Ridgeway Farm are explained in detail on pages 53 to 61 of the Sustainability Appraisal [link SA], Development and Design Focus Group Report [link D&D] and summarised in the answer below.
Some people have asked us why we could not allocate two sites for about 11 dwellings each. The reason we could not do this is because there were not two sites suggested to us that are capable of delivering 11 homes and that are deliverable by 2026.
Others have asked why we could not identify a site or sites solely to meet the need for eight affordable homes. This mainly relates to deliverability. We need to be pretty sure that the homes on the allocated site will be built, and it is much more difficult to fund a development solely consisting of affordable homes than it is to fund the delivery of affordable homes with some cross-subsidy from open market housing.
It is also worth bearing in mind that the delivery of eight affordable homes is not the only reason for determining a need for 20-25 homes overall. There are a number of different ways that the total housing requirement can be calculated. These are all explained in the Housing Needs Assessment, which can be found under the Regulation 14 documents heading on this website.
Why is the Crudwell NP allocating Tuners Lane?
When we weighed up all of the evidence, Tuners Lane was the best site. All of the other sites apart from Ridgeway Farm would either not deliver homes before 2026, which is what we need to do, or were too small to deliver affordable housing. Some are also at risk of flooding.
Tuners Lane was chosen over Ridgeway Farm because it is easier to provide a good footpath link from the site to the village’s facilities that can be used year round, the road is less busy now, and it has a lesser impact on the Conservation Area. The Tuners Lane site is also lower value agricultural land.
The community engagement suggested a clear preference for Tuners Lane over Ridgeway Farm too.
What about considering Ridgeway Farm phase 2 with 20-26 houses?
The Ridgeway Farm landowner proposed the site for 39 houses, which is more than Crudwell needs to 2026.
However, we considered the option that only 20 to 25 homes were provided at Ridgeway Farm anyway, to make sure that we were fair. This is set out in the Sustainability Appraisal [link to SA]. However, Tuners Lane was still preferred for the reasons explained above.
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, the current draft Neighbourhood Plan has concluded that Tuners Lane is the most sustainable site for housing of all the sites proposed, so splitting the housing into smaller sites means putting some homes on a less sustainable site. Also see “Why is a single housing site proposed for allocation for 20 to 25 dwellings, rather than a number of smaller sites?” and “Why is the Crudwell NP allocating Tuners Lane?” along with the Sustainability Appraisal [link to SA] for more detail.
How are flooding and sewerage issues being addressed?
We only considered allocating housing sites that are not at risk of flooding, and we have included two policies – IT1 and IT2 – which will avoid new development making flooding worse and, ideally, will make it better.
This will happen by ensuring that surface water from any new housing development runs off the site at a slower rate and lower volume than it does now. This will be done by including measures on site which store water in heavy rainfall, and only release this water to the Swill Brook and other streams and ditches slowly.
Sewage overflow problems are also caused by surface water getting into the sewer network in heavy rain, so slowing run off down will also help this problem. Wessex Water is also doing various things to reduce the likelihood of this happening in future.
What will the impact of the Tuners Lane development be on traffic volumes?
The technical report that was produced for Tuners Lane by the landowner forecasts an additional 16 car journeys during the morning peak hour, which is an average of one car every 4 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 specify what affordable homes are provided based on this local need.
The plan’s Policies DD1 (Tuners Lane) and DD2 (windfall housing) also require developers to take local needs into account for the remaining 60% of the homes. i.e. the “market housing”. This will make it easier for the Parish Council and Wiltshire Council to insist on smaller homes being provided if this is what is needed. These market homes will then be more affordable in the general sense, although they will not strictly be “affordable” based on the Government’s definition above. This way we can encourage all the housing on site to be more affordable.
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. The school feels that it would be able to accommodate this number of children
without expanding. In the medium term, this would be offset by reducing the number of out-of-catchment children who join on a yearly basis (anywhere between 20-45% of intake is from out-of-catchment).
The draft 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 – IT3 – 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 this year 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 Plan includes a brand new Crudwell Design Guide which new developments should comply with. 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.
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?
The majority of these requirements are covered by the Wiltshire Core Strategy, policies 41 and 42, so we haven’t repeated this.
Policy ENV2 supports the introduction of renewable energy technology and infrastructure on buildings and on a larger scale, but caveats are included to make sure that these proposals wouldn’t harm the local area, neighbour’s amenity or the wider landscape.
What provisions is the NP making for self build and how can the NP prevent those houses being re-sold for a quick easy profit producing more unaffordable housing?
DD2 covers windfall housing, which is generally allowed by Wiltshire’s Core Strategy within the settlement boundary subject to a number of provisos.
Self Build is defined in the Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) is where an individual, an association of individuals, or persons working with or for individuals or associations of individuals, build or complete houses to be occupied as homes by those individuals.
Policy DD2 encourages the provision of homes which meet a number of criteria, including that they meet Crudwell’s identified housing need. There is already an identified need for a handful of self-build homes in Crudwell so this is one of the potential types of housing that the policy encourages.
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 recently.
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.
Where the application relates to an area which has a made neighbourhood plan that allocates a housing site 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 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. If the Neighbourhood Plan does not do that an allocation may well be imposed upon the community by Wiltshire.
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.