In summer 2020, the Government released two papers for consultation. The first paper, dealing with the determination of housing targets, received widespread critical comment. In particular, it promoted use of a conceptually-flawed algorithm that would load substantial housing targets into areas around London. This would result in significant increases in housing density (with the need for high rise flats and ugly infill development) and pose a threat to the Green Belt. FEDORA’s response was circulated to supporters in early October.
The second paper proposes a new approach to planning with the intention of making a complex system speedier and more responsive. FEDORA has submitted a detailed nine-page response, a copy of which can be read by clicking here.
While many of the Government’s proposals are sensible, there are a number of areas where there would be serious adverse implications for local residents.
1. Land Categorisation
The paper proposes dividing land into three types: Growth, Renewal and Protected. This is far too crude and would probably result in much of Oxshott being defined as Growth. FEDORA’s view is that a fourth category is required: Enhance. This category would apply to those established non-urban or semi-rural residential areas that require measured gentle densification to respect the existing sustainable character.
2. Standard method of determining housing requirements
The Government has a hypothesis that comparatively high local house prices are a sign of unmet demand and that prices should then be reduced by increasing supply. FEDORA has already pointed out the flaws in this hypothesis and believes that a far more sensible basis for assessing local housing need is to use ONS statistics.
3. Infrastructure
FEDORA continues to point out that the Government pays lip-service to the need to provide enhanced infrastructure prior to major development. As a consequence, developing sites in semi-rural areas without adequate public transport, safe pedestrian pathways and proper cycle lanes enshrines car dependency. That creates congestion and pollution that runs contrary to the declared policy of enhanced sustainability.
4. Developer contributions
The present basis for assessing developer contributions is inadequate and developers are able to manipulate assessments to their financial advantage. A significantly improved system is needed in order to ensure that local authorities such as Elmbridge can collect funding to help cover infrastructure improvement and the construction of affordable housing.
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