Since the WDC Submission Draft Local Plan was issued on 3rd March our colleagues in SWOT (Save Wealden from Overdevelopment Team) have been working hard to understand and unpick the plan housing figures which are not clear or easily understandable.
Key points are that the Draft Local Plan is for a shorter period of 15 years v/s 20 years in the Core Strategy and 24 years in the Issues Options & Recommendations which required 19,500 houses approx for Wealden District.
The above should be borne in mind when considering the latest plan housing figures of 14,101 for the District.
The Objectively Assessed Need (for housing aka OAN) has increased to 950 dpa (dwellings per annum).
However, it is expected that Wealden will set a housing target in the plan of 800 dpa based on the new constraints.
This will involve new plan modelling of ESCC services (road infrastructure, schools etc) and CCG doctor services.
On 6th March when the plan went before the Local Plan sub-committee important new information was also provided.....
New Ashdown Forest (SAC) modelling was issued in the meeting, the housing numbers being proposed for Wealden District to 2028 are now 11,456 (instead of 14,102 in the draft of 03/03/17).
It is also understood that the constraints of the traffic impacts (increased Nitrogen levels) on the Ashdown Forest SAC (Special Area of Conservation) will outweigh the lack of 5 Year Housing Land Supply.....NB: Heathfield is well within the 15km zone around the forest....
And that this will determine any application approval going forward .
This is hugely important when considered against Wealden District Council declaring their failure to assemble a 5YHLS in 2016 and was given as the major reason for their approving the 'feeding frenzy' of planning applications in Heathfield High Weald Area of Outstanding Natural Beauty.
Thanks to work by SWOT the housing figure for Heathfield has been clarified with WDC as being 218 (not 248) and taking into account houses already built this gives an overall figure of 459 for Heathfield.
Somewhat confusingly WDC have further explained that the 'additional' housing number of 250 is included in the 218....we will find out more detail on this !
The picture changes again with the new information provided to the committee on 6th March in which the new homes figure for Heathfield is now shown as 191 due to 2 allocations being removed.... it is expected that this will reduce the total for Heathfield from 459 to 432 TBC.
It is important to note that although the allocations have been removed the Heathfield Boundary has not been changed accordingly.
See Downloads below to read: Local Plan Extract and Map for Heathfield, the new Table of Housing Figures, and the changes made to the plan between 3rd and 6th March....
Extracts from the plan: The (new) development boundary generally follows the line of existing development on the northern edge of the town.... Further outward encroachment of development into the wooded slope of the AONB would be inappropriate and visually intrusive.
Closer to Vines Corner, the boundary excludes land below the ridge and either side of Marklye Lane which is exposed and highly sensitive in the AONB landscape.
To the east, the development boundary follows the built up edge to the town where it adjoins Heathfield Park. The Council considers that any development beyond Park Road would be detrimental to the character and setting of the Park and should be firmly resisted.
Heathfield Park is a registered Historic park and garden and a designated SSSI and Ancient Woodland. Any new development will need to consider its proximity to Heathfield Park, taking into account its designations, and its High Weald AONB location.
Extract from the plan: of particular importance for further growth is the recognition within the NPPF that the siting of major development in AONBs would be inconsistent with the aims of the designation, and that only proven national interest and a lack of alternative sites can justify an exception. Any major scheme, including that relating to infrastructure provision, will need to meet the exceptional circumstances test including whether it can be demonstrated that the development would be in the public interest. It is therefore unlikely that further major development over and above that identified in this Plan will rarely be justified in the public interest.
Policy EA 5 High Weald Area of Outstanding Natural Beauty Development within or affecting the setting of the High Weald Area of Outstanding Natural Beauty (AONB), as defined on the proposals map, will only be permitted if it conserves and seeks to enhance natural beauty, having regard to the character of the landscape including potential impacts on its character components and its functions as set out in the High Weald AONB Management Plan. Development should also not detract from the visual qualities and essential characteristics including views into and out of the AONB in relation to its location, siting or design.
There are several sites to the West and North East of Heathfield which will enable +248 new houses to be built between now and 2028 (previousl plan period was 2037)
The worry is that the applications for those sites will come in quickly after the Local Plan is finally approved.... and after those sites are exhausted will there be yet more land 'released' from the AONB?
At the moment the Vines Corner sites have been withdrawn and appear to be excluded from the plan. Heathfield Park which in 2016 was subject of early proposals for development is also excluded. There is strong wording in the plan emphasising the importance and value of the AONB - and we can only wait to see if WDC maintain their commitment to the AONB.
Read on for more information about the Local Plan and the Timetable for Approval.... you can read the full Submission Draft of the Local Plan and see the Map of Heathfield with the new boundary and sites for development.... see Downloads at the end of these pages.
The new Wealden District Submission Draft Local Plan is the version which will be submitted for approval firstly by the Wealden District Council Planning Committees for North and South - followed by Full Council.
The SHELAA (Strategic Housing and Economic Land Availability Assessment) which is the map of 'offered land' for development' has now been been WITHDRAWN by Wealden - so our only visibility of what sites in Heathfield may be being targeted for development are those shown in the plan.
We are told that the SHELAA will be available in time for the public consultation period - and that there will be further iterations of the map with sites being added or withdrawn. This leaves the worry that sites which have withdrawn 'now' may re-appear later..... for those affected by the sites in the Local Plan have almost no time to lobby our Councillors !
The Submission Draft Plan was made available on 3rd March.
On 13th March the Submission Draft Local Plan will be ratified by the North and South Wealden District Planning Committees. On 22nd March the Submission Draft Local Plan will be ratified by the Full Wealden District Council Committee.
The WDC approved version is then provided to the Government Inspector who will formally approve the plan after a 6 weeks public consultation process.
This timetable means that the sites in the Local Plan will be effectively 'pre-approved' for development without Heathfield residents having the chance to make their views known BEFORE it goes to Committees!
Whilst what is in the plan now appears to be 'better' for Heathfield - we must remember that housing numbers are 'minimum' and that sites whether in the plan or the SHELAA can be added or withdrawn as is evidenced by the changes to the plan between 3rd March and 6th March.
The timetable is still a steam rollering exercise ....and a DEVELOPERS CHARTER enabling applications to be put in for the sites in the Local Plan safe in the knowledge that the applications will be approved !
The key factor is that the plan lacks the 'Evidence Base' as we have seen recently - because Wealden District Council have chosen to issue the plan without the supporting evidence and they admit that it is 'fluid'. How does the plan hold any real weight when the evidence is lacking ?
The approval of the Submission Draft Local Plan by the Full Council should be delayed until all the supporting evidence is available and reflected in the plan.
The public Consultation period of 6 weeks has been delayed to start in May.