Calderdale Local Plan hearing – Stage 2 Consultation
This consultation may sound dull and not relevant to everyday lives, but this process will shape how Calderdale looks and functions in the future. We would love to see Calderdale leading the way in sustainable growth, in ambitious targets for better standards of working, living and travel. We feel that Calderdale deserves better than the vision this plan sets out.
For Calderdale, this stage of the local plan process falls in the middle of the most seismic shift in how we live our lives that we have seen in generations. This rapid change, along with growing emergency on mitigating the climate emergency have meant that the objectives of this Local Plan have evolved at pace. The Plan needs to reflect our new reality.
I write this on the day when a new Government White Paper has been published on a proposed ‘shake up’ of the planning system. This would cut local democratic scrutiny in the planning system, among many other concerns. That, however, is a discussion for another day. Right now, we continue to engage with the process as it exists, to champion outcomes that are good for the economy, the environment and the well-being of the people who live in Calderdale. The way we do this is to challenge some of the presumptions and assumptions made in the preparation of the draft Local Plan.
The plan process asks for consultation on different sections, known as ‘matters’. These cover the main areas in which the Local Plan Inspector will need to feel confident that the Local Plan is ‘sound’.
We have responded to some of these, and there are links to our submissions at the end of this news post.
We know however, that formal consultation responses can be a bit of a dry read, so below is a quick summary of some of the points we have made.
The additional housing growth proposed is unsound. Housing figures are calculated alongside the economic growth figures. The figures proposed for economic growth in the region are wildly unrealistic. We provide a breakdown of these figures in our Matter 7 response. The current Objectively Assessed Housing Need (OAN) is 840 per year (9,015 over the ‘plan period’). The targets put forward by the council are for a housing increase of 14,950 (997 per year).
In fact, far from increasing, the 2016 and 2018 household projections indicate that housing need may be falling. That is, falling below the figure of 840, so releasing Green Belt now when there is evidence that it may not be needed is premature.
The Council’s starting position when preparing the current Plan was to aim to minimise Green Belt impact. This makes it even more startling that a quarter of the entire 2018 proposed allocation is directed towards two very large Green Belt sites, and that the additional 2020 allocations are also directed to Green Belt. We have looked at the evidence submitted, and cannot see that an urban capacity study has been carried out, to assess whether any of this housing could be accommodated in other ways.
Climate Action and Emissions:
The pattern of proposed Green Belt releases, and their contingency upon road upgrades, puts them directly at odds with the need for climate action and road traffic reduction. Calderdale declared a climate emergency at the start of 2019, we want to see the right actions being taken to make this declaration meaningful. A recent report called The West Yorkshire Emissions Reduction Pathways (July 2020) report for the West Yorkshire Combined Authority shows that we have to plan now to achieve our climate goals. We need to shape places that embrace active travel and accessible services.
A recent study by Transport for New Homes has highlighted the failure of many ‘garden’ towns and suburbs to achieve any of their sustainable transport options.
We believe that for this plan to work, it must have a strategy to reduce road use, and our dependency on roads and make a policy provision to ensure any new housing meets zero carbon standards. This plan does not achieve these standards. The plan presented fails on the councils own criteria to shift transport towards sustainable options.
We need to make sure that we make the most of our opportunities. The density of housing developments is critically important. If the density is too low, things like bus services or local shops are less viable. More compact development brings the benefit of sustainability. If designed well, it can also be brilliant in terms of open space provision and community infrastructure. The plan proposes a minimum density of 30dpha, which is low. Average density of housing in Calderdale in 45dpha. The plan should not support low density developments. It is contrary to the National Planning Policy Framework (NPPF) 2019.
We need to be smarter, and think in more creative ways to achieve great outcomes. The Green Belt is providing a vital function for the people of Calderdale by keeping open countryside permanently within reach. If the population grows, then the need for Green Belt to provide that function also grows. Green Belt should be enhanced, to develop the ecosystem services it supplies as well as accessibility and enjoyment. We need to look after our environment, and make sure that it is right for our needs, and right for the needs of future generations. We need easy access to services that does not rely on private car use. We need to be part of strong communities and neighbourhoods. We need to be bold in striving to meet targets on emissions and zero carbon homes. These are the best outcomes for our society, and CPRE believes that Calderdale deserves the best. The quality of our future depends on it.
The provisional Stage 2 Hearing date has been set for mid-September. The final date and form (due to Covid-19 restrictions) have yet to be confirmed, but all updates are made available on the Calderdale Council website. We will be making representations at the hearing.
CPRE West Yorkshire Consultation Response Submissions:
- Matter 7 – Housing Need
- Matter 8 – Growth delivery, Infrastructure and Viability
- Matter 9 – Spatial Development Strategy
- Matter 12 – Site assessment process and the Green Belt
- Matter 13 – Employment Allocations and Policies
- Matter 15 – Garden Suburbs
- Matter 16-21 – Housing Allocation Sites
- Matter 24 – Addressing Climate Change