Letter of concern sent by Parish Council Chairman: All Cornwall City, Town & Parish Councils 23rd June 2018 Dear Councillor/Clerk, Neighbourhood Plans, Affordable Housing, and Cornwall Local Plan Housing Apportionment Reference: Cornwall Local Plan Adopted November 2016. The Cluster Group has become aware of a serious problem concerning Rural Exception Sites (Policy 9) within the Local Plan. At the June meeting of the Central Sub-Area Planning Committee, a planning application for a 22 house affordable led scheme was granted outline planning permission, on a Rural Exception Site in Crantock Parish. There are 30 families with a local connection to Crantock on the Cornwall Housing Register. This latest permission was granted despite planning permission already being granted for 45 affordable houses, on two other sites within the parish, where planning permission is still in date, but where building has not yet started. This latest planning permission brings up to 67 affordable houses on three different Rural Exception Sites, into a parish that has only 30 local connection families on the housing register. The report documentation for this decision at planning committee includes details of ‘cascading’ of any excess affordable houses to other parishes, including a parish in a different Community Network Area. Rural Exception Site policies are therefore being used to build excess housing on green field sites, outside of a settlement boundary, deliberately to satisfy the affordable needs of outside parishes, including parishes in other Community Network Areas. Paragraph 1.74 (Policy 9) of the Cornwall Plan states: “Where a five year supply can be demonstrated, the adequacy of supply in meeting the needs of a particular CNA or town over the whole Plan period will be a material consideration when making planning decisions. Any deficiency in supply should be accommodated within the CNA with a shortfall and not be compensated for by increasing supply in other CNA’s where existing supply is sufficient to meet its local Plan target.” The situation is greatly exacerbated further. Crantock has received planning permissions over the last two years that increases the total parish housing stock (including affordable housing) by over 30%. The local primary school (Cubert School) is full, with no plan or room for further enlargement. The neighbouring parish of Cubert (joint school catchment area) has received planning permissions over the last 30 months that increases their total parish housing stock (including affordable housing) by over 30% also. There are no places therefore, for the primary school children of the 310+ houses that are to be built in the two parishes. The excess children will be bussed to schools afar. It is not helped that the report to the planning committee stated that the school was only 89% full, despite notice being given to both the education and planning department as well as the Planning Committee by parish representatives. The two small parishes, making up 12% of the total population of the Community Network (St Agnes & Perranporth), have provided three times the minimum apportionment requirement for the whole of the Community Network to 2030 (as shown in Table 1, page 27 of the Local Plan). There has been no stop to planning applications being received for the two parishes, despite the massively excessive attainment of Local Plan housing apportionment and affordable housing targets. Further Rural Exception Site land is being purchased by developers as we write. Neighbourhood Plans. Many town and parish councils will be looking towards completing their own neighbourhood plans. There are completed plans, now adopted. The Crantock Neighbourhood Development Plan was passed by referendum last month. There was a 51% electoral turnout, with 85% in favour of the plan. The planning officers described the Neighbourhood Plan as therefore receiving “great weight” during the June Planning Committee. Councils will know that a great amount of work is put into the creation of local neighbourhood plans, and that they are put under scrutiny by both Cornwall Council planning department officers and outside examiners. This was the case for the Crantock Neighbourhood Plan. Given the recent 30%+ increase of housing stock and the over-attainment of the required housing apportionment within the parish, the Neighbourhood Plan highlighted the need for restrictions on open market housing, and that only Rural Exception Sites should be granted when there was a proven need for affordable housing, as and when that future need or shortage appeared. This was supported by the Affordable Housing Team at Cornwall Council. One of the really worrying concerns that spring from this issue is that the case officer(s) reporting to the Planning Committee state that, because the housing already granted planning permission within the parish is still to be built (time limits on build start have yet to be reached), then no weight or acknowledgement is to be given to those permissions, and that the housing register requirement for the parish therefore MUST remain at 30 families. Apart from the obvious unreasonableness of the situation where the whole ethos of Rural Exception Sites within the Local Plan is thrown into chaos – building of affordable housing on green field sites, in excess of the local parish requirement – deliberate cascading of excess affordable housing to other parishes, including parishes outside of the local Community Network. There is an issue of “land banking” here. Land Banking, or affordable housing banking. Rural Exception Sites are supposed to be the only way for developers to gain planning permission for housing outside of settlement boundaries, outside of infill and rounding off sites, and on green fields. They bring profit, and can be lucrative, compared to some awkward brownfield sites, etc. Local Planning Authorities, including Cornwall Council, will find it hard to refuse any Rural Exception Site where there is shown to be an existing local connection need on the housing register. If the planning officers advice to Committee and elsewhere is that there is to be no acknowledgement of planning permissions already granted and “currently live” that would reduce the housing register totals, then developers can continue applying for Rural Exception Site after Rural Exception Site, in the same parish, no matter what the circumstances might be (school places, sewerage capacity, medical, transport and highways), all over-ridden by the supposed (but illogical) affordable housing need. There is more. If a developer owns a site with planning permission that is running out of build time, then that developer merely needs to “begin” the building work, whilst still able to apply for even more Rural Exception Sites, because the initial houses are still not filled with the housing register families. And even more. If a developer fails to “begin” a development within the time limits conditions of a planning permission, it is likely that the Local Planning Authority will be hard-pressed to win an Appeal decision against the same planning application, re-submitted, for the previously granted Rural Exception Site. And even more. If the housing register local connection for a parish does eventually achieve zero, will the developers who have planning permission for housing (on Rural Exception Sites) be able to quote lack of need, coupled with viability concerns, to turn a Rural Exception Site into an open market site on green field land? Surely not! In a nutshell: 1. A very recent Neighbourhood Plan that, because of massive increases in local housing stock, allows only affordable needs housing to be built, is overridden because greater than required affordable housing has not yet been built and occupied. 2. Affordable housing permission is being specifically granted in one parish, to accommodate the needs of other parishes, including those outside of the local Community Network, against the ethos and policies of the Cornwall Local Plan. 3. Little account or weight is being given to the lack of local services (school places, sewerage, medical, transport and highways). 4. The creation of a loophole for developers to build on green field sites with little protection, against the ethos and policies of the Cornwall Local Plan. As you can imagine, the parishes have made complaint to the planning committee, with no reasoned, acceptable, reply provided to date. May the Cluster Group count on your support in this matter? Does your council face a similar position, and are you concerned that expectations for your own Neighbourhood Plan may be thrown into doubt by these recent events? Yours sincerely Alan Percy BEM. Chairman Copy to: All Cluster Group Councils All Cornwall Councillors Once again, a classic example of OUR planning department fighting for the developers AGAINST our communities, despite well laid out and rational local plans. I wonder what Messrs John Betty (john.betty@cornwall.gov.uk) and Phil Mason (phil.mason@cornwall.gov.uk) will have to say about this moral outrage (if they're not too busy at a developer's champagne reception)?! Do they even care?? The photo taken from Porth Kea shows the demolition of Tolgarrick Farm at Arch Hill, where Truro's southern 'Green belt' has been breached by Persimmon Homes, after Phil Mason failed to fight the appeal and NONE of the council's own conditions for building were met by the developer.