13/03/2014 - Haywards Heath Town Council Draft Neighbourhood Plan Consultation - Response from the Haywards Heath Branch Labour Party
The NP and its costs
In terms of its general aims and aspirations for our town, Haywards Heath Branch Labour Party welcomes the draft Haywards Heath Neighbourhood Plan (NP). It acknowledges the considerable resources committed to this process, which, including officer time, will partly account for the increased Council Tax that Haywards Heath people will pay from April, when the Town Precept is raised.
Context: a District Plan on which it heavily depends but which is not yet in place
However, this investment will yield little return until a new Mid Sussex District Plan is in place to give it force. For, despite Labour councillors' repeated warnings over the past ten years, the District Council has failed to comply with basic Government requirements to prepare and adopt such Plans. MSDC, ignoring the Localism Act 2011, has not consulted every neighbouring planning authority. Nor has it identified a five year land supply - without which our District is at the mercy of any development applications, whether or not they comply with the policies set out in town or parish council neighbourhood plans. (The avoidable absence of a new District Plan also has other undesirable knock-on effects, such as a temporary inability to charge to developers any Community Infrastructure Levy - CIL - and therefore to have to continue to rely only on S106 contributions. The draft NP is silent on these important facts.)
The NP's excellent general aims but vaguely drafted policies: much more work needed
Nobody could argue with the draft town plan's objectives on sustainability, maintaining a green corridor and the town's character, encouragement of cycling and walking; nor with better access to the countryside and the Bluebell Railway. However, in this hefty document, in which the first sections for the most part simply repeat and echo the aspirations and strategic policies within the unadopted Mid Sussex District Plan (set out in the NP's later sections) and conform to NPPF requirements, it is disappointing to find that it contains very little planning and very few fresh ideas that could put flesh on the bones of, or go beyond what is set out in, the draft District Plan. That is a missed opportunity.
Yet, crucially, it is a key requirement of NPs that they can be shown to rely on a sound evidence base. Already in this District at least one (parish council) NP has recently fallen at this very reasonable statutory hurdle.
And yet such a sound, comprehensive evidence base, setting out an informed vision for the Haywards Heath area up to 2026, was, only seven years ago, drawn up and discussed by councillors and various experts on the following policy areas: the environment, settlement pattern, affordable housing, gypsies and travellers, town centres, shopping, employment, rural issues, community facilities, infrastructure and energy, housing strategy and broad locations for development. Discussions on its invaluable findings culminated in July 2007 at the Haywards Heath Area Core Strategy Workshop, following extensive research and consultation with a plethora of well informed local and national organisations. Its remit was comprehensive, its findings highly detailed and with a high standard of critical analysis. Yet in the draft NP no mention or acknowledgement of that document and the high quality research involved, or of any attempt to update its findings, is to be found. This is a serious weakness.
The avoidable overall lack of a distinctive Haywards Heath viewpoint and Haywards Heath policies, such as its own town council might be expected to provide and advance, is evident also in there being in the draft NP hardly any practical details or costings. Just three examples, regarding Highways and Transportation, of this pervasive vagueness and lack of attention to detail throughout the draft NP relate to:
- cycle paths (Objectives 8B and 8H)
- support for public transport (Objective 8C) and
- the aspiration to reconfigure the Muster Green gyratory system (Objective 8F)
These are sensible, desirable general ideas that are surely worthy of being worked up into a properly detailed blueprint.
Housing: understatement of the expansion; underestimation of the need for affordable homes
Equally disappointing is an almost total absence of discussion of or plans for affordable homes for local people. Here the NP sadly echoes the recent seemingly lower priority for such housing found in the unadopted District Plan, in which provision for that key requirement is less robust than in the 2004 District Plan. Surely the day to day basic requirements of its townspeople, current and future, across the whole income range should be as much a focus of a town's NP as the highly desirable provision of a pleasing, energy efficient and healthy environment as the setting for aesthetically pleasing roofs over residents' heads?
On the subject of housing, the NP heavily relies on a technicality - its aim to allow for 488 houses including 334 'already approved', plus unquantified 'windfall' brownfield housing sites of up to 5 houses - to present the increase in housing numbers over the next 17 years as one that is relatively modest and under control. This is a gross understatement of the significant and virtually uncontrolled expansion that is already under way, for reasons set out at (2) above, as a result of the poor planning performance of the District Council. Moreover that avoidable MSDC policy planning vacuum will be exacerbated over the next few years as a result of another green flag being waved to developers by the Coalition Government - its 2013 Growth and Infrastructure Act, which nullifies the 2011 Localism Act's provision for an effective local say over planning matters.
In the real world, as the Town Council is well aware, especially those of its members who are also members of MSDC:
- It is, sadly and yet rightly, standard practice now that MSDC planning officers insert into the agenda papers for all planning applications a reminder that the Council has not set a five year land supply; and
- There are going to be far more new houses built in and on the borders of Haywards Heath by 2031 than 488 plus an unknown number of 'windfall' homes.
For the NP itself acknowledges that the 2014 starting point is that, being built now, or in the pipeline, with MSDC or Lewes DC approval granted or pending, are 797 houses on or close to the borders of town (including 295 off Gravelye Lane and Lyoth Lane and up to 140 off Greenhill Way) and 838 in the town itself (including 220 on Butlers Green Road, 222 off the top of Fox Hill and 235 at Penland Farm). That adds up to 1,635 new homes in or on the edge of town - a huge growth happening already. And that massively higher figure must surely, in the current planning vacuum created by the inaction of MSDC and made worse by Government policy, be regarded as an absolute minimum of what we can expect.
Only the adverse impact of the recession on the construction industry has so far acted as an effective brake on such free-for-all development. Owing to this failure of MSDC to enable itself to refuse unsuitable planning applications and be confident that at appeal their refusal will be upheld, both MSDC and the District's parish and town councils are relying on a mixture of good luck and public appeals to developers to go easy on us.
Compliance with new house building and non-residential building standards
Repeating what the draft District Plan says, the draft NP talks about new houses conforming to Level 4, Code for Sustainable Homes before 2016 and Level 5 thereafter (and for non-residential developments BREEM rating Very Good to 2016 and Excellent thereafter). Nowhere is it explained why the Town Council supports a policy that will allow house and non-residential building to meet lower standards before 2016 than after 2016.
Whatever those reasons might be, the stark reality is that, in the current development free-for-all, very many houses and non-residential buildings will be erected to lower standards (no doubt less expensive for the developers to meet). Surely residents' well being should, if only as an aspiration, be rated more highly than any convenience for developers who are already cashing in on a wonderful (for them, not us) window of planning opportunity? Pleas to them to refrain from excessive building here, when to do so before 2016 is particularly attractive for them, are not likely to be heeded.
Infrastructure: failure to address some key issues
Some key infrastructure issues of pressing concern to our townspeople are scarcely mentioned in the NP, and a few not at all, such as:
- Pressure on existing schools to take more pupils while over 1,600 new houses will soon have been built, but while a new primary school has, as the NP notes, been ruled out by WSCC (6.24, p. 28). Although developer contributions are mentioned (6.23, p. 28) no substantive costings or details are provided to illustrate how viable that reliance on developers will be.
- The baby boom that is now increasing that same pressure. This is not mentioned in the NP.
- What the NP, in passing, rightly notes will be the 'significant impact' of 4,000 new Northern Arc houses on Haywards Heath. Astonishingly, the NP makes no mention of how it is proposed to deal with that very significant expansion to within 1.5 miles of our town, which is bound, in several ways, to impact on our own infrastructure, not least on traffic flow and parking, especially when Haywards Heath railway station is likely to be very convenient for those new homes that will be built closest to our town.
These are just some of the crucial issues that townspeople would rightly expect to have been comprehensively discussed and planned for, but which in this draft NP have not been. To highlight just one important area glossed over in the draft NP: education:
School and College Provision
In such a lengthy (and often repetitive) document there are some inexplicable things about education that are included and omitted. These are a cause for concern regarding the degree of rigour and expertise involved in drafting the document.
An unexpected item included is found in Appendix 5 (Policies): 'Policy L8: The Plan will support proposals for the improvement of schools in the town'. Surely school improvement is a specialist matter that falls within the remit of school boards of governors, education authorities and the Ofsted inspection regime? What practical support, statutory or otherwise, a town council can lend to them, and at what cost to the Council Tax payer, in order to support such a laudable process, is not clear.
An unexpected omission is, within the Appendixes, any list, let alone analysis, of existing school and college provision and what capacity those institutions may have to absorb additional pupil numbers. What is well known, but again not mentioned in the draft NP, is that last year all the town's primary schools were over-subscribed.
CONCLUSION
While welcoming the draft Haywards Heath Town Council NP, the Haywards Heath Branch Labour Party is extremely disappointed by its failure to match its generally laudable policy objectives (though they need to give proper weight to the importance of affordable housing) with the requisite degree of rigour and detail, including costings.
Moreover, the Branch is concerned that the draft NP is:
- over-reliant on developer contributions and on a less than robust evidence base and,
- in failing to face the reality of the District's development planning policy void, it is not presenting with sufficient clarity, and in policy terms is not addressing the key implications, of the full extent of the currently unstoppable housing expansion both in and around the town and, just to the south, the Northern Arc development of 4,000 new houses.
Melvyn Walmsley
Secretary, Haywards Heath Branch Labour Party