Part 2 in Sarah Waite-Gleave’s series of articles on the Local Plan
In Part 2 we look at our top concerns about Dover district housing plans, in particular the exclusion of Dover town from the requirement for minimum percentage of affordable housing and the inadequacy of policies to make new homes properly energy efficient, to end fuel poverty, as indicated in the title of our formal submission, ‘Less Fuel Poverty, More Honesty, More Action for Nature and Climate’.
The 15 strategic policies (SPs) covered by DDC Local Plan, and typical of most plans, are:
- SP1 Planning for climate change
- SP2 Planning for healthy and inclusive communities
- SP3 Housing growth (10998 new homes between 2023 – 2040, many to be built around Whitfield which will become a new town 4 times the size)
- SP4 Residential windfall development,
- SP5 Affordable housing
- SP6 Economic growth
- SP7 Retail and town centres
- SP8 Dover Town Centre
- SP9 Deal Town Centre
- SP10 Sandwich Town Centre
- SP11 Infrastructure & developer contribution
- SP12 Strategic transport infrastructure
- SP13 Protecting hierarchy of designated environmental sites & biodiversity assets
- SP14 enhancing green infrastructure and biodiversity
- SP15 Protecting historical environment.
There are development management policies (DMs) behind these SPs. As explained in my previous article all these have to conform to the national government policy on development. A link to the text of the DDC local plan is here.
Key concern 1: The fight for genuinely affordable housing in Dover town
The public want to see new affordable homes in Dover town itself, not just among the new builds in surrounding areas. At the first consultation (Reg 18 under lockdown January – March 2021) and at second consultation (Reg 19 October – December 2022) the public were told by planning officers, this was out of the question due to being ‘unviable’, ‘failing a viability test’. The meaning of this language is unclear to many members of the public, and justifiably, people feel planning officers are hiding their decisions from public view using obscure language.
Viability means profitability. In locations where the cost of building is thought to be higher, (because brownfield) and where the ability to pay more for a two or three-bedroom house is reduced (due to lower local average income levels) then the algorithms used by the agencies paid by local government planning authorities (LPAs) to do viability assessments, indicate that property developers are less likely to clear the 30% profit margins they like to achieve. At the public hearings, affordability was on the agenda on 9 December 2023. I heard Simon Drummond-Hay of HDH Planning & Development Ltd, defend the viability study he had done for DDC. This company appears to cover about a third of the viability studies done for local planning authorities across England.
I needed to correct Drummond-Hay who said (in justification of no affordable housing requirement for developments within Dover Urban area) that much of Dover town was an ex-mining community. I pointed out that, while Deal’s Mill Hill, and Aylesham and Elvington and Betteshanger were ex-mining communities, Dover town was not, and its economy was based both on port-related logistics companies, light industry and retail, and tourism and other services; and thus there was a strong case for DDC to amend its policy and follow the Thanet District Council example (Local Plan adopted 2020) and make all of the district subject to a requirement to build 30% affordable housing or social housing without any exclusion of Dover town. We said DDC department of planning was wrong to say “for Dover urban area it is not viable to require affordable housing including the minimum requirement in the NPPF 2021 for 10% affordable home-ownership”.
Obviously, it would be of grave concern for communities to be trapped in poor housing because of ‘off-the-peg’ inadequate assessment of local economic circumstances.
The high-profit development of executive homes has pulled developers to greenfield sites around the edges of Walmer / Deal urban area since 2015. This has resulted in 30% over-development around Deal / Walmer between 2013 and 2023 and, in 2023, severe traffic congestion bordering on gridlock. Most of the greenfield developments have been ‘windfall’, i.e. not on sites included in the previous local plan. So, we suggested a policy pushing developers to do the right thing in Dover town, while also discouraging them from doing the wrong thing in Deal / Walmer. Our amendment was as follows:
In the case of planning applications on developments of over eight dwellings on windfall development sites, within three miles of the outer boundaries of Deal / Walmer, permission will only be given if the developer applicant has previously undertaken a development of a similar scale within Dover Urban area which provides a minimum of 30% affordable housing.Dover District Green Party
Key concern 2: Building in a climate-friendly manner – homes that will genuinely protect residents in climate crisis
I spoke to Lord Deben – who has recently stepped down as chair of the UK Climate Change committee – on 31 October 2023 in Canterbury, at a Canterbury Climate Action Partnership event. He said again then, as he has done consistently, that:
” … the scrapping of plans to ensure all new homes were built to zero-carbon standards in 2015 was ‘stupid’, that it was a ‘scandal’ that one million homes have been built since then without such high environmental standards, and that there should be an end to building homes that would need retrofitting in future.“John Gummer, Lord Deben
He agreed with me that Kent’s 13 local planning authorities should be putting zero-carbon standards into their local plans. At the DDC public hearing in December 2023, I read out Lord Deben’s view from the article in Construction News. We put before the planning inspectors, Mr Birkenshaw and Mr Coyne, the example of Reading Borough Council and other LPAs who included a requirement for zero carbon homes in their recent local plans.
Again, DDC Local Plan includes fine words:
“The council will seek to ensure that all new build development contributes to the mitigation of, and adaptation to, climate change, through a) including low carbon design approaches to reduce energy consumption in buildings.”
Many of us see the need to specify quantified regulations on how low carbon design should be; on how much to reduce energy consumption in buildings.
We say the DDC local plan is weak on this issue and will not be compliant with legality (legally binding net zero strategy, Climate Emergency Declaration 2019 and Climate Change Act 2008), unless DDC adopts zero-carbon homes standard.
The list of councils building zero carbon homes included in 2021: Exeter City Council, (200 finished, 1000 on the way), Leeds (1000 nearing completion), Norwich (100 finished), York, Wales (1400), Oxford (40), Enfield, Meridian Water development (10,000 homes). (see article in references).
We recommend this amendment (closely based on Reading Borough Council Local Plan adopted 2019 and Oxford City Council Local Plan adopted 2016).
“Given the scale of residential development in Dover up to 2040, achieving the aims of the Climate Change Strategy will not be possible without that development having a minimal impact on carbon emissions. Therefore, the requirement will be that major new housing is built to zero-carbon homes standard. In general, where homes are not designed to be carbon neutral, this will mean as a minimum a 40% improvement in the dwelling emission rate over the 2013 Building Regulations plus a contribution of £1,800 per tonne towards carbon offsetting within Dover (calculated as £60 per tonne over a 30 year period). The requirement will increase from 31 March 2028 to at least a 50% reduction in carbon emissions.“
In our view, developers who build affordable homes which are then expensive to heat, trap residents in fuel poverty. Low income residents then have to bear the cost of heating badly insulated homes. The developers take the profit, and there is no improvement in dwelling emission rate in the district.
Coming soon, in part 3: the protection of nature and local travel and a call to arms!