From Cornwall a Developers Paradise.
Enough is enough. Tell the Council you object to 52,500 houses
Cornwall Council is conducting a ‘consultation’ on changes to its Local Plan. One change is to increase the housing target from 47,500, already above the historic rate, to 52,500 houses, mainly to meet demand for second homes. Join me and let the Government’s Planning Inspector know you do not want this level of extra housing.
The consultation runs until March 7th so there isn’t much time.
And here’s a longer objection which you’re welcome to cut and paste, or take extracts from.
I object to Policy 2a – a housing target of 52,500.
The addition of 5,000 houses, equivalent to building a town the size of Helston or Liskeard, to an already excessive target of 47,500 houses is unwarranted. This level of housing growth will have significant adverse impacts on future Cornish communities.
It is unnecessary because
1) The ‘Full Objectively Assessed Need’ calculation is neither full nor objective. Planning guidance (ID: 2a-016-20150227) expects that ONS and DCLG projections of population and household change are ‘tested against local data and understanding’. The Council has not done this. Indeed, it has wilfully ignored the considerable body of evidence that shows how official projections have been grossly out of line with actual outcomes of population and household change for at least a decade. ONS projections for example have consistently and chronically overstated net-migration to Cornwall by 1,000 a year. Estimates of housing demand and calculations of affordability needs based on these flawed datasets are unfit for purpose and require downwards adjustment. For some detailed evidence see https://cornwalldevelopersparadise.wordpress.com/cornwall-council-fails-to-defend-cornwall/objectively-assessed-need-or-subjectively-guessed-greed-the-foan/
2) The 3,221 house uplift to meet demand for second homes is not based on robust data and its rationale is opaque. Moreover, it fails to take into account changing government policy on second homes, namely the new stamp duty rate due to come into force in April.
The Government defines sustainable in the NPPF as ‘ensuring that better lives for ourselves don’t mean worse lives for future generations’ (p.i). It also says that ‘Local Plans are the key to delivering sustainable development’ (p.37). Continuing and expanding a growth rate in Cornwall that has been almost three times higher than that of England since the 1960s (57% compared with 21% 1961-2011) is manifestly NOT sustainable and will bring significant adverse impacts.
a) It is unsustainable environmentally, as ‘the housing policy will have a significant impact on the natural environment’ (Cornwall Council Local Plan sustainability appraisal, p.591). Unaccountably, the Council ignores the conclusion of its own sustainability appraisal that a high population growth policy will have a negative long-term impact on soil and food production, water, biodiversity and the marine environment. Furthermore, no coherent consideration is given in the Local Plan to the NPPF’s aim of ‘moving to a low carbon economy’ (NPPF, p.2). It is unclear how adding to housing and population growth rates will achieve this increasingly urgent aim, one reinforced by the Paris climate agreement of December 2015.
b) It is unsustainable culturally, as it fails to assess the impact on its policies of the Government’s recognition of the Cornish people as a national minority under the Framework Convention for the Protection of National Minorities. The Council admits that ‘the nature of Cornwall as a housing market’ means housing growth is ‘dependent upon significant increases in past rates of net migration’ (Appendix 2 Cornwall’s Full Objectively Assessed Need, Cornwall Council PAC, 17 Nov 2015, p.24). Policy 2a clearly therefore contravenes the spirit and intention of Article 16 of the FCPNM by wittingly or unwittingly encouraging an alteration in the ethnic proportions of the population of Cornwall.
c) It is unsustainable economically as the Council provides no evidence that the balance between net-inmigration of job-seekers and job-generators will be positive. Neither does it provide any evidence to suggest that structural conditions have radically altered, to the extent that the prevailing correlation of high housing and population growth experienced from the 1960s to the 2010s with relative economic disadvantage (as measured by household income and GVA per capita) has now disappeared.
For more and how to download the form: