OVA's Response to the Draft NPPF Consultation

Date posted: 
13th June 2018

                                                                                                                                                                                                                                                            

 

SUMMARY

1 The Otter Valley Association’s (OVA) opinion is that the draft NPPF has an emphasis on increasing housing growth in an urban conurbation and will not address the housing problems in our rural area of benefit.

2 In the OVA’s opinion there is no need for weakening of NPPF policies to encourage housing growth. There is no shortage of housing development in the OVA’s area. The current adopted East Devon Local Plan has an 18-year target to build a minimum of 17,100 houses, 63% more than those required to meet the demographic need and there is at present a 5 year supply. 

3 The draft NPPF does not address the problem of producing enough low cost housing in rural areas where the locals are unable to buy and find renting very expensive. There is a need for old style social housing. Yes, our District has many houses being built but they are not the affordable housing for those on very low incomes needed in the area.

4 The OVA is of the opinion that there has been a weakening in the draft NPPF of protection of assets and retaining the character of an area. This is essential in an area in which one of the mainstays of employment is its natural and historic environment which attracts tourists. 

BACKGROUND INFORMATION

5 THE OTTER VALLEY ASSOCIATION. (OVA), a civic amenity Charity with approximately 800 members, was founded to promote and conserve the environment, landscape and history of the lower Otter valley. It was established for the public benefit in the lower Otter valley area and includes the four villages nestling alongside the banks of the River Otter, Otterton, East Budleigh, Colaton Raleigh and Newton Poppleford, and the town of Budleigh Salterton at its mouth. 

6 PROTECTED LANDSCAPE. The whole area is in a protected landscape: is in the East Devon AONB; the coast line is on the World Heritage Jurassic Coast; the two Anglo Saxon villages of Otterton and East Budleigh and the town of Budleigh Salterton have conservation areas; there are numerous nationally listed buildings in the villages.

7 ECONOMY. It is a rural and tourist economy with the services industry accounting for over 80% of the employment which predominantly comprises low paid sectors.  There are a large number of retirees moving to the area- nearly 40% compared to 16.4% the rest of England.

8 HOUSING STOCK. Retirees and second home owners push up the price of housing. The small thatched cottages in the villages which would have, years ago, been the dwellings of local people are now much sought after by incomers. This has resulted in average national house prices being 8 times average incomes. The cost of rents are also high and those on low incomes now pay an unsustainable proportion of their incomes on rent.

9 LOCAL HOUSING MARKET. The demand for homes for the retired, second homes and holiday homes means that all new homes are very quickly sold.  

10 AFFORDABLE HOUSING. The need for affordable housing was recognised in the East Devon Local Plan Strategy 21 “the principle consideration for Budleigh Salterton will be the conservation of its outstanding natural environment and affordable housing and employment uses will be given priority over other forms of development” We have plenty of houses being built but not ones that our indigenous young working families can afford. 

11 THE GREATER EXETER STRATEGIC PLAN. This plan provides the overall spatial strategy and level of housing and employment land to be provided in the period to 2040 in the area and trumps the local and neighbourhood plans.  This plan will provide the high level strategic planning policy framework for the area. It is impossible to provide the level of housing needs for Exeter and at the same time conserve and enhance the natural and built environment in the rural areas. The OVA ‘s opinion is that the needs of Exeter and the university are put at the expense of the rural countryside- brownfield sites in Exeter which could have been used for affordable city housing are now used to build student housing instead of using the extensive university campus grounds.

COMMENTS ON DRAFT NPPF

12 DESIGNATION PROTECTION. The OVA is deeply concerned that the “highest status of protection” for the AONB protected landscapes has been downgraded “to great weight should be given to conserving landscape and scenic beauty and the extent of development in these designated areas should be limited and planning permission for major developments be refused for major developments other than in exceptional circumstances”. 2/3rds of East Devon LPA land is designated AONB. Under the current NPPF and East Devon Local Plan the remaining third has been assigned the majority of new development in the area. The dilution of para. 170 would put the AONB in considerable vulnerability if further housing were assigned to the district.

13 DESIGNATED HERITAGE ASSET. The OVA is also deeply concerned that para. 190 concerning designated heritage assets has downgraded the protection.

14 AFFORDABLE HOUSING. The increased emphasis on low cost homes to buy will not solve the need for affordable housing in the OVA’s area of benefit. The local young people are not earning a high enough wage to even afford starter homes.

15 The present system of affordable housing relies on developers producing a small percentage of developments for the market. However, all too often the developer, having gained planning permission successfully pleads poverty and few affordable homes get built producing large estates with 3 and 4 bedroomed dwellings covering Grade 1 agricultural land in East Devon. The draft proposal to reduce the target to only 10% of affordable homes on major sites will make matters worse.

16 STRATEGIC PLANS AND NEIGHBOURHOOD PLANS. Strategic plans produced by combined authorities such as cross-district and Devolution Panels (for instance, those based on Local Enterprise Panels with a vested interest in development) override and undermine local democracy and risk making Local Plans irrelevant.

17 Nine town and parish councils in East Devon have “made” neighbourhood plans and a further 31 are in preparation. This is localism in action, providing the housing sites that are needed and wanted. We would like to see the place of neighbourhood plans strengthened in paras 13 and 14. 

18 EXPANSION OUTSIDE SETTLEMENTS. The OVA finds the idea of small scale developments outside BUABs very disturbing. It is contrary to the logic of Local and Neighbourhood Plans which accept development within the settlement. The result of this would be settlements ringed by developments which would expand with ever larger and larger circles. The OVA does not understand how this would enhance or conserve the AONB. 

 

 

Dr. N. Daniel  

Otter Valley Association 

2 May 2018