r&c1.pdfParish mtg


Rose and Crown Devt v 1 13 7 17.docx



Documents of interest to the campaign

EHDC Main Modifications
Proposed On-line input from APC v 3

MM/3/14. The Development Strategy
2011 – 2033 DPS2

Aston Parish Council have worked closely with PACE, led by
Steve Sypula, who has analysed EHDC’s own data on housing need and supply in
detail, and very importantly the assumptions that underpin these numbers

We believe several key assumptions are unnecessarily cautious
and, as a result, underestimate substantially the housing supply to 2033

Specifically the Windfall Allowance has been set at 75
houses pa through to 2033. Using hard data from EHDC, suggests that a more
realistic assumption is between 100 and 140 houses. This would increase the
notional surplus of dwellings by 2033 from 450 to between 850 and 1,490. We
attach the analysis undertaken by PACE in its Annex 1:  EHDC Housing supply 2011 – 2033. Summary of

In addition the assumption for the 8 group 1 Villages is
that they ‘will accommodate at least 500 new homes from 2017 to 2033. The AMR
identifies prior approval of 391 dwellings leaving a residual 109 to be
delivered between now and 2033.

An examination of the Council’s Planning Application portal
to test the robustness of the residual ‘Village’ contribution over the Plan period
was undertaken by PACE. As above, this examined the volume of net new-build
applications received by the Council between 31st August 2017, the cut-off date
for the AMR and this version of its Plan, and 28th February 2018. A second
sieve identified pre-August 2017 dwelling applications which have subsequently
been approved. As shown in its Annex 1 attached (Tables 2 and 3), the
examinations identify that applications for some 144 dwellings have either been
approved or have yet to be determined at the end of February 2018. A further
437 dwellings have similarly been identified in town locations, not covered by
Local Plan allocations, category 2 Villages, and other village / locations
which we assume will be considered as ‘windfalls’ by the Council.  

Whilst several of the current applications will not be
approved, others, earlier refused will come forward following appeal. The
volume of likely new dwellings evidenced, in just five months since the Plan
figures were finalised, together with pre-August 2017 applications subsequently
approved, clearly throws into question the Council’s assumption that only a
further 109 dwellings will be completed by 2033.

Looking specifically at the Category 1 Villages, if we
assume refusal of the application to build 105 dwellings in Walkern, that still
leaves 38 new dwelling applications received in just five months. This strongly
suggests that the residual Category 1 Village target of 109 assumed over the
remaining 181 months of the Plan period should be substantially increased.

In addition the Council itself accepts that there is scope
to increase the supply side further if delivery of homes at the Gilston Area is
accelerated (MM/3/16, Policy 3.3.12).


The combination of these three assumptions in APC’s view
seriously understates the housing supply projections to 20133

On the housing need side of the equation, the FOAHN
calculation uses a methodology that does not take account of the latest ONS'
population data released last October. The ONS data suggests there will be one
million fewer people in England in 2031 than previously expected, reflecting
half-a-million fewer births and almost 400,000 more deaths. In consequence it
has been estimated that Household formation will reduce by some 30% (from
218,000 to 151,000) by 2031.This will have a direct downward impact on the
Council's housings needs assessment. For supporting evidence please refer to
recent research published by Ian Mulheirn, Director of Consulting at Oxford
Economics, former HMG Think-Tank Member and HM Treasury economist at 

The combination of the revised assumptions for the Windfall
Allowance, the number of dwellings to be built in the 8 Group 1 villages and in
Gilston, together with a revised housing need projection, could easily mean an
over-supply in excess of 2,000 dwellings

Comment 2

The Council should review and update its 'Windfall', Group 2
village and Gilston housing supply assumptions, in the light of the research
done and referred to above and in The consequent
housing supply calculations should, as a result, be modified where needed. It
should also review the housing need data, in the light of the revised ONS data

Based on this research and revised calculations, the Council
should re-examine whether it can justify using the East of Stevenage (Gresley
Park) site, which was very late to be added to the District Plan (possibly the
latest), specifically to meet the 5 year land supply (and is now not needed to
meet this target). In addition it is sited on green belt assessed to be of
“paramount importance”.

At the very least development on this site should be delayed
until it is demonstrated conclusively that the site is really needed. Sites
should not be developed against unnecessarily cautious assumptions. Once built
on, this precious land is lost for ever.


MM/12/01 East Of Stevenage

The comments made by Aston Parish Council under MM/3/13 have
identified the pressing need for EHDC to review both the housing supply and
demand data to ensure that the inclusion of East of Stevenage is justified by
the housing need and supply data.

Certainly it is known that EoS 1 is not needed to meet the 5
year housing supply, which we understand was the main reason for including it
very late in the planning process

APC also believe that the inclusion of EoS1 is unsound, not
just because the need for the 600 houses is not justified by the housing demand
and supply data, but also for the following reasons:

Contrary to NPPF Guidance, no “exceptional
circumstances” have been advanced for the specific removal of the EOS1 location
from the Green Belt. Similarly, the Council has failed to evidence that all
other reasonable options for meeting housing need have been ‘examined fully’ .This
latter point is particularly relevant as the Council has repeatedly failed
under examination to explain how and why it allocated this site of
‘"paramount importance" to the Green Belt over others of lesser

We understand that the “exceptional
circumstances” has been defined by a “catch all” argument covering the whole of
East Herts. We are not aware that such a blanket argument is demonstrated to be

No firm provision for Secondary Education
students living in Gresley Park has been determined.

The Council has not identified, or financially
addressed, necessary highway modifications required to provide safe access to
the Show people’s site.

The Council has not acknowledged the need for
further traffic studies, required by HCC (Highways) into the impact of EOS1 on
junctions south of Lanterns Lane to the A602.

In addition the traffic modelling of Gresley Way
and environs done to date was based on generic input data (not data relevant to
the East of Stevenage) and the modelling does not examine the likely increase
in “rat running” through adjacent villages, such as Walkern, Aston End, Aston
and Benington. It therefore has not costed mitigation measures required to
minimise the consequential traffic impact on the Villages of Aston and Walkern.

The viability of the Pigeon proposal has rightly
been challenged by an independent panel of Architects. The proposal needs to be
thoroughly reviewed and subjected to a risk assessment prior to inclusion in
the Adopted Plan. 

Comment 2

EHC should review the housing demand and supply data as recommended
under MM/3/14, and should withdraw EoS from the District Plan if there is
demonstrated to be no need for it.

At the very least EoS1 should be delayed until it is
demonstrated conclusively that it is needed to meet the modified housing demand
and supply data

This delay should be used to address the uncertainties
contained in the EoS current proposal which are listed in 3 – 7 above 



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 Key points summary_Wk1.pdf

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