LoPRA News page

Hello Heather,

I’ll try to reply to your questions.

What are the full sets of specific criteria used by the YDNPA to ascertain site suitability and the decision making process?

In order to shortlist sites for allocation the Authority will be looking at evidence of need for affordable housing and then undertaking a site appraisal and consultation with key partners. Site appraisal will look at how a site fits into the current pattern of development, its prominence, impact on any listed buildings or conservation area, impact on neighbouring amenity, topography and any implications for the conservation of the Parks special qualities as set out in the Local Plan 2006. Key consultations may include highways, archaeology, ecology and environment agency (floodrisk and waste water disposal). Very few sites are ever perfect. Development almost always causes some degree of disruption and change which some may regard as harmful. Some compromises are inevitable in the allocation and development of land.

What specific criteria will be used for the definite exclusion of a site for development? (ie SSSIs, etc)

Sites with fundamental constraints eg. floodrisk, open countryside (distant from a village edge), national ecological designation, very poor access, sites that would clearly be harmful to the character of the countryside or the special character of a village by reason of its prominence or scale. The reasons for recommending the allocation or rejection of each site will however be published.

Will the YDNPA be consulting with NYCC regarding suitability of access before they make a ‘shortlist’ of suitable sites?

Yes. We will wish to have the results of consultation before we publish a draft Housing Development Plan for public consultation.

It is vital that affordable housing developments are not built in return for the construction of a % of non-affordable houses. How does the current call for Housing Sites within the Park relate to the ‘Rural Exception Site Policy’ [PPS3] which decrees that exception sites should be used solely for affordable housing in perpetuity (the YDNPA has proposed that the mix will be a 50:50 mix of affordable and local needs housing rather than 100% affordable housing)?

The rural exception policy will continue.

The objective of the allocation strategy is to proactively identify sites that will help reduce the long term shortfall of affordable housing and to do this through a publically accountable process. They are not exceptions sites. Consultation and completions evidence demonstrate that only a very small proportion of the shortfall of affordable housing is being addressed each year in the Park. The Authority has decided to investigate whether it can do more. However in order to get landowners to release sites in the first place, they have to be economically viable. Research by the Authority’s consultants demonstrated that 50% affordability on sites should be achievable, even assuming 50% ‘local market’/occupancy restricted housing.

If there is a paucity of suitable sites will the YDNPA seek alternative sites through consultation with Parish Councils and the Public?

This option remains open should the Authority decide there are insufficient suitable sites to choose between. That decision will depend on analysis of what has been submitted already.

As a matter of due process we deem it vital that, at each stage of the selection process, the Park provides details of environmental impacts considered in relation to their choice of sites and that the precise reasons for choosing those sites are made available to the Public for consultation and, if necessary, reconsideration. We would expect appropriate professional assessments (e.g. landscape, visual, ecology, archaeology, etc.) to be made for each site separately; that these assessments are related to existing environmental strategies and policies, including the authority's current landscape assessment; and that this information and process be detailed, transparent and fully available to the public. This point also refers to the policy statement (H5) that 'the development must respect the character and appearance of the settlement and it’s setting in the countryside'. We would also expect a full Environmental Statement/EIA to be carried out for any selected sites, given the exceptional nature of the development. At what stage of the consultation and development processes are the Parish Councils, voluntary bodies and the Public invited to comment and to what degree will points raised be taken into consideration to form part of the final decision making process?

Each stage of the Housing Development Plan is subject to Environmental and Sustainability Appraisal as a matter of process. However that will not amount to Environmental Impact Assessment of every site shortlisted. EIA is usually at the discretion of the National Park Authority and is only required where a development proposal would be considered to have significant environmental consequences. In this process the Authority should not be allocating sites for development that would have a significant environmental impact. Sites will be expected to fit into their context with only relatively minor impact, although the extent of that impact might be an area of debate.

The next stage of public consultation will be when a draft Housing Development Plan containing all the context, objectives, visions, policies and proposed sites is published, perhaps later this year. There will then be an opportunity to submit formal representations when the plan is ultimately published and submitted to the Planning Inspectorate for scrutiny.

What Geographical area will Long Preston’s ‘sub-area’ be comprised of with respect to housing need?

Long Preston falls within ‘lower Ribblesdale’ in the Craven Housing Needs Survey 2005. We would anticipate it picking up housing need predominantly from its own parish, given its proximity to Settle and Hellifield. However supplying affordable housing is not a precise process so some flexibility would have to be built into any occupancy agreement to avoid periods of under occupancy

It is vital that the YDNPA make it a matter of principal that they correlate the existing needs of villages, which lie in a parish/ward of which part lies adjacent to the Park and have already been covered by a relevant Sustainable Community Strategy, without duplication in their own housing needs figures. How will the needs of Long Preston be assessed bearing in mind that Long Preston and Hellifield Ward already have their housing needs set out in Craven District Council’s Affordable Housing Guide [July 2008]?

Yes. Craven District Council are the Strategic Housing Authority and will provide advice regarding the shortfall of affordable housing in this part of the district. The National Park Authority would be unlikely to allocate a site contrary to District Council advice on the shortfall of affordable housing during the plan period.

With respect to point [8] and the aggregation of affordable housing needs for Long Preston and Hellifield villages as a ward we deem it vital that the affordable houses being built on Station Road in Hellifield are taken into account when considering Long Preston, as are any other future developments within the ward. How will the Park Authority co-ordinate with Craven District Council on this?

Noted. The District Council will be involved in the allocation process by advising the Authority on evidence of need for affordable housing.

How will the YDNPA regulate Local Needs Housing bearing in mind the paper and recommendations, ‘Housing Rights: The Duty to ensure Housing for All’ (Commissioner for Human Rights, Council of Europe, April 2008,) which surely precludes any form of discrimination?

This paper is about addressing the wider needs of society for housing which across Europe is becoming increasingly treated as a commodity. This is a particular problem in this National Park because external demand for second homes, retirement housing and long range commuting is inflating prices beyond the reach of local incomes to the social and economic detriment of some communities. A strategy of increasing the provision of affordable housing and the addition of more intermediate housing, through occupancy restriction, should help address some of these problems. The policies will only apply to new housing stock leaving the existing stock of 10,000 dwellings predominantly unfettered for market consumption.

Will the YDNPA be pursuing their policy, which prevents people from buying up second homes with respect to New Builds and Conversions, etc, bearing in mind the point above and the recent response of Margaret Beckett on this issue with respect to the ‘Matthew Taylor Review on Rural Economy and Affordable Housing’ and how will they protect new housing built for ‘Local’ or ‘Affordable’ needs from the second home market?

Since 2005 Local Plan Policy has restricted most new housing in the park (new build and conversions) to occupancy by households that need to live in the Park for economic or social reasons. This is gradually building up a stock of housing that should not be capable of being lost to the open market and which should also be slightly cheaper and therefore more accessible to the priority list of households identified in para 4.39 of the Local Plan.

Item 31 of the ‘PPS3: Housing’ points out the importance of making effective use of existing housing stock. We resubmitted our housing paper to you with our last letter in February, which is in line with this policy. This would enable residential units to be made available to households in need very quickly. Some housing authorities are already doing this, taking advantage of the lower costs of existing housing as a result of the recession. Our earlier paper suggests how this approach could be financed. There are several suitable houses on the market in Long Preston, with prices from £160,000. Given the time and cost in bringing forward and developing new sites we believe this is a cost effective means of achieving affordable units. We would suggest a joint approach between Craven District Council and the YDNPA is essential to progress this proposal. We ask for a specific response from the YDNPA as to why this option is not being vigorously pursued; additionally as the YDNPA is not a housing authority or housing provider how will the YDNPA ensure this policy is incorporated?

I agree that the provision of land for house building is only a part of the solution and it will not be an objective of the new Housing Development Plan to meet the entire shortfall of affordable housing, through the allocation of land. There should also be other initiatives which could include mortgage discount or equity share schemes. However these are beyond the remit of the Planning system. If they were successful enough to reduce the need for affordable housing then this would filter through the needs evidence and through monitoring of policy and might ultimately reduce the need to release land for new housing.

The Long Preston Parish Plan states that the general consensus of the community is to defend and keep the village boundary/building line sacrosanct, prevent creeping development and keep the village’s Green Fields. Bearing this in mind LoPRA believe it is vital that the YDNPA do their utmost to conserve the Greenfield sites and current boundary and ensure that preference for any new development is given to Brownfield sites, even if this means renegotiation of suitable sites. Furthermore we do not believe that the boundary should be modified to incorporate allocated sites but that those sites should remain as ‘Exception Sites’ beyond the boundary – how will the YDNPA manage this to prevent creeping development in future?

Subsequent Local plan policies since the mid 1990s have prevented the development of Greenfield sites for housing across the National Park, the exceptions have been a handful of affordable housing schemes. The majority of the new housing that has been built, including in Long Preston, has been on brownfield sites or through residential conversion.

Whilst it is perhaps regrettable to have lost so much employment land in Long Preston it was probably inevitable given the demand for commuter and retirement housing at that time and the lack of policy support to negotiate a proportion for affordable housing. If suitable brownfield sites are no longer forthcoming then the Authority will have to choose whether to release a greenfield alternative, if it wishes to allocate land to help address the shortfall of affordable housing.

Most larger settlements in the National Park will continue to expand to some extent, over the longer term, assuming that population continues to increase and that there is a need for new development and infrastructure to support their function. The purpose of the Town and Country Planning system is to facilitate that process of change for the benefit of the public interest, having regard to all material considerations, including National Park purposes.

The development boundary around Long Preston and elsewhere should not necessarily be regarded as sacrosanct, even if it has been fixed for more than 13 years. It is likely that there will remain a need for some additional carefully controlled housing a long way yet into the future. Also the boundary does not prevent non housing development where other policies support eg. new community uses, employment development, utilities, tourism and agricultural uses.

Kind regards,

Peter Stockton
Strategic Planning Officer
Yorkshire Dales National Park Authority
Yoredale
Bainbridge
North Yorkshire.
DL8 3EL
Tel direct (01969) 652334
office (0300) 456 0030
FAX (01969) 652399
peter.stockton@yorkshiredales.org.uk
www.yorkshiredales.org.uk

     1. As there is usually confusion as to the exact meaning of 'affordable housing', 'local housing' and 'social housing'
         I wondered if you could clarify the type of housing the park is looking to provide [on the sites put forward or
         through purchase] and definitions for each type of housing proposed.

The following are national definitions set out in planning Policy Statement no. 3 housing:

     Affordable Housing is:
     Affordable housing includes social rented and intermediate housing, provided to specified eligible households
           whose need are not met by the market.
     Affordable housing should:
         —   Meet the needs of eligible households Including availability at a cost low enough for them
               to afford, determined with regard to local incomes and local house prices.
          — Include provision for the home to remain at an affordable price for future eligible households or,
               if these restrictions are lifted, for the subsidy to be recycled for alternative affordable housing provision.

      Social Rented Housing is:
       Rented housing owned and managed by local authorities and registered social landlords, for which guideline
       target rents are determined through the national rent regime. The proposals set out in the Three Year.
       Review of Rent Restructuring ( July 2004) were implemented as policy in April 200n.
       It may also include rented housing owned or managed by other persons and provided under equivalent
       rental arrangements to the above, as agreed with the local authority or with the Housing Corporation
       as a condition of grant.

Current affordable rents for 2-3 bed properties are between 60 and 80 pounds per week.
The intention is to allocate sites for 50% affordable housing and 50% local market housing. This would be housing restricted to the categories of local need (or very similar) as set out in Policy H2 of the Local plan 2006:

4.38 Applications for housing in H2 and H3 settlements will need to be supported by evidence of the local need that they would accommodate. This may be provided through the completion of a questionnaire accompanying a planning application or by reference to relevant evidence in the District Council Housing Needs Survey.

4.39 The following are the priority needs for new housing:

i) Existing residents of the National Park establishing a separate household

ii) A head of household who is or whose partner is in or is taking up full-time permanent employment in an already established business within the National Park (or in another part of a parish split by the National Park boundary)

iii) Householders currently living permanently in a dwelling which is either shared but not self contained, overcrowded, or is otherwise unsatisfactory by environmental health standards and which is within the National Park (or in another part of a parish split by the National Park boundary).

iv) Elderly or disabled persons requiring sheltered or otherwise more suitable accommodation who already live permanently within the National Park (or in another part of a parish split by the National Park boundary

v) Persons having to leave tied accommodation within the National Park (or in another part of a parish split by the National Park boundary).

vi) Former residents of the National Park (or of another part of a parish split by the National Park boundary) with close relatives in the National Park (or in another part of a parish split by the National Park boundary) whose case is accepted in writing by the National Park Authority as having an exceptional need to return to the National Park.

There may be other priorities for local housing which are occasionally justified by material considerations.

Categories set out in paragraphs i), iii), iv) and v) above will apply only to persons who have resided permanently in the National Park for the preceding 3 years.

2. An indication as to the number of houses that may be put forward for Long Preston and in what way these
relate to past Housing Needs Surveys.

No target has been set for Long Preston or the National Park as a whole yet. The annual shortfall has been estimated at 88 affordable dwellings per annum but we are not planning to meet that or indeed anywhere near it. A target for the Park may be included in the draft Housing Development Plan, depending on the number of sites proposed for allocation. So in other words our target will be based on capacity.

All allocated housing sites will be driven by evidence of need within the sub area, which will probably be by dale or surrounding parishes inside the Park.

Density would be around 35 dwellings per hectare.

3. Whether commercial housing will be allowed (i.e. free market value housing with no ties, etc) as part of
any proposed developments.

No. Unlike Craven outside the Park, The Yorkshire and Humber Regional Spatial Strategy requires all new housing in the two National Parks to be for ‘local need’ which we interpret as either affordable or ‘local market’ housing.

   4. Until now the Village Boundary (building Line) has been deemed sacrosanct and Long Preston's Greenfield sites
       and open aspects are vital to the character, environment and well-being of the village as a whole - does the call
       for housing sites now mean that the boundary is no longer protected?

The boundary will continue to be protected. If any sites are allocated they will be identified as such on the new plan. In effect the boundary will be modified but only to include any allocated sites. Land outside the boundary would continue to be designated as open countryside with regard to further housing development.

5. Is the YDNP looking to buy up any properties already on the market/lying empty to relieve the housing needs?

The YDNPA is not a housing authority or a housing provider. Its’ housing function is to work alongside its partners and help release land for the social and economic wellbeing of communities living within the National Park. However if initiatives were successful in addressing the shortfall of affordable housing through other non development solutions, then that might reduce the need to release land for development, as long as it reduced evidence of need.

6. How will the detrunking of the A65 affect access from the main road?

Consultations on vehicular access along the A65 are now undertaken with NYCC. We rely on their advice. Safety is obviously an important issue, particularly having regard to the weight of traffic using this route.

Long Preston Village already has a Parish Plan - how will this be used in conjunction with proposed sites bearing in mind this gives a clear indication as to what the residents of this village actually want?

The Parish Plan seems rather silent on the subject of affordable housing although it indicates that housing is not currently affordable in the village and that many residents consider there is a need for affordable housing. There is an action plan point to work with the YDNPA and other partners to address the need for affordable housing in the village. This supports research carried out by the District Council and ties in with the Craven Sustainable Community Strategy objective to increase provision of affordable housing for the benefit of local communities.

Potential allotment land has already been withdrawn as a direct result of the call for housing sites by the YDNP despite the fact that there are a growing number of people in the community - including a proposal for allotment land by the school - who wish to grow local produce. Although the Parish Council are looking into this matter, could the YDNP encourage landowners who have put forward their land for housing use to put it forward for community allotment use instead - the benefits to the community are numerous and far reaching. Obviously a huge amount of land has been put forward by landowners who are not resident in the village and whom have little knowledge of its needs.

Hopefully once the Authority has considered all the sites put forward and reached some decisions about allocation, then that will remove any current uncertainty in the minds of landowners.

Supplementary questions and replies:

      a) Could you clarify how 'local housing' will work within the communities - ie will 'local housing' be provided just
          for those within a Parish or does 'local housing' mean that first choice would be given to people from the
          Parish in the first instance, then adjacent Parishes and then the rest of the Park, etc?

There is a key distinction here between the ‘local needs’ and ‘affordable’ elements of any particular scheme.

Local needs (aka local market) restricted units may be occupied by any person meeting the criteria (which Peter’s e-mail set out). In geographical terms, the criteria apply to the whole National Park (including parishes split by the NP boundary) – they do not offer any additional geographical restriction down to the level of individual parishes.

The situation is quite different with affordable housing, which is subject to a legal restriction that precisely defines where occupants may be drawn from in geographical terms. This is usually based on a ‘concentric rings’ approach, where typically, occupants are drawn from the immediate parish in the first instance, normally followed by adjoining parishes, before spreading out to a wider area (normally the whole National Park).

The precise geographical preference system can be varied according to the location of the scheme, available evidence of need, existing affordable housing provision etc – typically, schemes developed in the National Park to date adopt the immediate parish as the first ‘tier’ of the geographical preference system, although in some instances it may be more appropriate to establish a group of parishes as the first preference.

The system can be effectively regulated since, in the majority of instances, schemes will be managed by a registered social landlord who will vet and approve occupants in conjunction with the District Council and where necessary the NPA.

   b) Additionally if one Parish (A) is deemed to have a greater need than another (whether for affordable or
       local housing) will housing be provided for them in another Parish (B) if that Parish (A) does not have enough
       suitable housing sites?

This question is not relevant to local market housing for the reasons outlined above (i.e. its does not control occupancy on a sub-National Park geographical basis).

Where affordable housing is concerned, the reason a ‘concentric rings’ geographical restriction is applied is to give a degree of flexibility. Housing need is forever in a state of flux for obvious reasons, not least because people’s circumstances will be subject to change. It is for this reason that we could never reasonably expect to be able to match exactly provision with need, particularly when we are talking about such confined geographical areas as individual parishes.

The existence of a ‘concentric rings’ restriction carries an expectation that, as a priority, the scheme should exist to meet the needs of the immediate locality in the first instance (whether that be a single parish or group of parishes). It should not be the case that affordable housing is developed in locality ‘B’ with the sole or predominant intention of ‘exporting’ the affordable housing need of locality ‘A’.

Conversely, the ‘concentric rings’ restriction also carries an expectation that the units should not be ring-fenced to a single parish, and that there will need to be an element of flexibility in terms of the geographical area of entitlement. I think there has to be a balance struck, so that affordable housing is developed in locations where there is a need in the immediate locality, but so that it can also be responsive to wider needs, and future variations, as and when necessary.

Further information can be found in these documents:

Planning Guidance - Affordable Housing Guide

Housing Supply - Affordable Housing

Budget 2009

or through the Parish Council (Parish Plan, available on cd-rom))