Utkinton and Cotebrook Objection to 16/01492/OUT
Formal Objection Notes for a residential development proposal for 22 houses.
Utkinton and Cotebrook Parish Council recently discussed Planning Application 16/01492/OUT – residential development of up to 22 dwellings with access at Northgate, Utkinton and at an Extra-ordinary Parish Council Meeting on 26th July 2016 it was resolved, unanimously, to place on record an Objection to the Application on the following grounds. This decision was taken in the light of discussions prior to the Parish Council meeting proper with 19 residents in attendance.
Utkinton and Cotebrook Parish Council asks Cheshire West and Chester Council to refuse the application based on the following based on the following key factors:
- No proven need for Affordable Housing substantially above the current level of supply in the Parish
- The lack of sustainability of the village – as evidenced in previous planning applications declined by CWaC
- Impact on traffic and highways
- Impact on the village and rural environment
- Issues related to communication
Each of these is discussed below. Utkinton and Cotebrook Parish Council wishes to state that its research shows that the Parish, as a whole, is not against development per se, just developments that are seen as inappropriate for a village of its size and rural location.
Were a development of the scale any type of the one proposed to be permitted in Utkinton it would increase the numbers of households by 10.6% (i.e. from 208 to 230) and add 64% to the stock of affordable or social rented properties (making this latter sector some 16% of the total housing stock).
This objection is a synopsis of discussions with advisors to the Parish Council who have submitted a separate, full and very detailed objection to Cheshire West and Chester Council Planning Team.
On behalf of the Parish Council
F Tunney – Chair
3rd August 2016
Housing Need Surveys
- The Parish Council questions the veracity of the forecast housing need within the application – it is based on an extrapolation of data relating to an unsubstantiated future need through ‘newly formed’ family units rather than verifiable need. It also questions the economic grounds as being based on Census and ONS data rather than detailed questioning of the whole village.
- An Advisor to the Parish Council contacted a consultant statistician to review the methodology and conclusions from the arc4 Housing Needs Survey commissioned by the developer and he found it lacking in substance and credibility. These findings are contained in an Objection to the Development submitted separately by Mrs A Pownall and summarised in the Appendix A.
- The key issue is that a highly qualified and eminent statistician has looked at the arc4 survey in detail and has concluded that it does not represent statistically credible evidence of any significant affordable housing need in the village. Furthermore, he concluded that the Parish Council’s most recent survey WAS credible evidence. This fact alone may mean the application should proceed no further as SOC2 clearly states that for affordable housing to be allowed on a rural exception site the developer must prove a need for affordable housing for local need, but they haven’t proved this at all.
- Two previous developers (Muir Housing and Plus Dane) consulted with residents prior to submitting planning applications for this parcel of land and both withdrew their interest.
- Muir Housing didn’t conduct a Housing Needs Survey and withdrew before formally applying.
- However, Plus Dane did and received NO responses at all then withdrew again before applying.
- Utkinton and Cotebrook Parish Council have undertaken Housing Needs Surveys on three occasions (2006, 2012 and 2016) and the results show a degree of consistency in terms of the immediate needs
- 2006(86 responses = 36% return)
- 2012(156 responses = 48.1% return)
- 2016(68 responses = 22.8% return +1 received after the deadline)
- The responses in the 2016 survey indicated that 3 people (1 individual and 1 couple i.e. two households) would require affordable housing over the next 3 years.
- The Parish Council surveys conducted in 2012 and 2016 were distributed by hand to every household in the parish (c.308 households) and anonymity was an option for all respondents.
- There are already social rented houses (22) in the village and the average ‘churn’ of tenants averages 1.75 a year so most of the immediate need identified in the surveys may be met through Weaver Vale Housing Trust.
- In addition to the lack of credibility surrounding the data from arc4’s survey, there were issues with it being attributed to a developer in Cotebrook and it wasn’t until the survey was published on the CWaC website that it became known it was commissioned by the applicants.
- It should be noted that in each of the three Housing Surveys conducted by the Parish Council there was an acceptance by villagers that some development of affordable housing might be required (but it should be noted that such expression of acceptance does not infer that villagers have a need for affordable housing), but in none of the surveys was it to the levels indicated by this Planning Application, or indeed any of the three previous proposals.
- The applicant proposes that this would be a rural exception site. In fact it is not adjacent to the existing Village Settlement Boundary (CWaC Local Plan 1) and it is, therefore, the Parish Council’s opinion that it is not a rural exception site as defined in SOC2. The plot of land is within an ASCV (Area of Special County Value).
- The mix of houses proposed falls outside of SOC2 Policy of 30% for market housing (8 / 22 = 36.4%).
- It should, also, be noted that the level of consultation between the applicant’s architect / agent (Vivio / RAMD) was deemed less than adequate with it being, initially, by internet invitation only and then with 12 ‘slots / appointments’ of 10 minutes each having to be booked only 4 households attended (7 individuals).
Other significant factors within the application
- The revised layout shows a total of 22 dwellings – an increase of almost 40% on the previous application.
- The landscape value of the site and its context within an ASCV and proximity to the Cheshire Sandstone Ridge.
- The highways statement is out of date and contains wrong information, particularly with regard to the ingress and egress from the site, boundary walls and raised table.
- The developer characterises the development as infill when, in fact, it is a stand-alone development.
Unsustainability of the village
- It sits approximately 1.6 miles by road to its nearest Key Service Centre – Tarporley.
- The village does not enjoy a regular bus service, only ‘dial-a-ride’ services provided by ‘Tarporley Shuttle’ (bookable between 09:30 and 14:30 Monday to Friday) and ‘Rural Rider’ Bookable for services between Utkinton and Northwich (Wednesday and Friday mornings and Winsford Wednesday and Friday Afternoons). These services are not suitable for any resident wishing to connect with full and regular bus services from Tarporley to Chester and Crewe for the purpose of employment or for visiting a hospital or other appointments. This lack of connectivity therefore creates a demand for an increased use of private cars or taxis.
- Utkinton residents have no access to Health Services (Doctors, Dentists or Pharmacies) except by private car.
- There is no safe footway or cycle way between Utkinton and Tarporley, it’s Key Service Centre, putting further pressure on the use of private cars.
- The only employment opportunities in the village are located at Rose Farm Shop and anyone seeking employment in the immediate area would require their own transport or taxi.
- Conversations with the employees at the shop suggest a degree of unease with the siting of such a large development so close to the facility and its future as a village hub.
- The village has few amenities:
- A village hall with parking for 4 vehicles and a tennis court
- A shop
- A Church of England Primary School.
- The applicant has suggested factors that are either misleading or simply wrong;
- The village is NOT a Local Service Centre within the CWaC Local Plan 2
- The village does NOT have a church (the C of E church was converted to a school many years ago and the Methodist Chapel converted to a private dwelling in or around 2009).
Impact on the village and its rural environment
- If each ‘affordable unit’ had access to a single car and the ‘market accommodation’ an average of two cars, that would mean 30 more private cars in the village and Part 1 and the NPPF actively discourage development which necessitate an increase in car usage, preferring development to be located in more sustainable places where there is public transport – which there is plainly not in Utkinton.
- Similarly the proposed development would sit significantly more elevated than its closest ‘neighbours’ including the farm shop complex – which was restricted to single storey in its planning applications. That the proposed and revised development is at two storeys and will sit immediately abutting to Rose Farm Shop and its businesses (Café, Garden Centre and Shop) may deter customers from visiting and causing economic hardship and this could have an impact on the future of the focal point for village life – the shop and post office.
- There have been a number of environmental and ecological studies done to support this application but the real impact will be on the overall environment of the village by depriving a number of species of habitat that is vital to their well being – bats, owls, birds and other animals.
- The proposed development sits outside the ‘Village Settlement Boundary’ set by CWaC who have already refused applications for two single residential properties that fell outside the Village Settlement Boundary – In one of these cases (Rowley Hill Farm) Utkinton was described as a ‘hamlet’ and ‘unsustainable’ by the CWaC Planning Committee.
- Recent planning applications for just single houses in/ adjacent to the village have been turned down on the basis that the village is unsustainable, so if single houses have been refused on this basis, how could 22 houses be allowed as they would result in so many more people living in an unsustainable place which goes directly against the sustainability policies of both the NPPF and Part 1 of the Local Plan.
- However, this site is being considered (by CWaC) as a Rural Exception Site for affordable housing which is different, but there is the question of whether the site can be considered to be adjacent to the village or not … its’ boundary touches the Village Settlement Boundary along a very small percentage of its perimeter adjacent to the garden of No 16 Northgate (see plan below):
Extract from Part 1 Local Plan – Development Plan Proposals Map of the proposal site – village boundary shown in black running down the west side of John Street and the north side of Northgate. The site boundary shown in red is consequently NOT adjacent to the village settlement for the vast majority of its length.
- Many villagers have said that they would like to see the field as an amenity for all to enjoy – Northgate field is the only remaining green space in the village and some have asked why it could not be used for community purposes.
Potential impact on communications
- Whilst not covered as part of ‘sustainability’ the level of remote working in the village was evidenced in the 2012 research for the Parish Plan. Broadband was installed in the village two years later. However, the existing BT Green Box and the one for BT Fibre Broadband were designed to accommodate the number of premises when the ‘Phase 1 roll-out was planned – approx. 2011’ (From ‘Connecting Cheshire’).
- This may have a significant impact on the ability for remote / home workers.
APPENDIX A – EMAIL BETWEEN A POWNALL AND DR D WARNE
From: David W. WARNE (BW)]
Sent: Thursday, July 28, 2016 1:44 PM
To: ‘Ann Pownall’
Subject: RE: Statistical Credibility of Housing Needs Surveys
Dear Mrs. Pownall,
Attached please find my comments.
David W. WARNE, BSc, MSc, PhD, CStat
From: Ann Pownall
Sent: 28 July 2016 09:55
To: ‘David W. WARNE (BW)’
Subject: Statistical Credibility of Housing Needs Surveys
Dear Dr. Warne,
I write further to our recent discussion, and I would be obliged if you could give me your professional opinion in your capacity as a professional statistician about the following matter.
As discussed, a housing developer has recently submitted a planning application to build 22 houses on a field near to the village where I live. The local planning regulations stipulate that where development is proposed on such as site that is outside a settlement boundary, only “affordable “ houses will be permitted (i.e. ones which will be owned and let by a “social landlord” at a rent less than open market rents), and that the developer must provide evidence that there is a real need for the proposed affordable houses, through a housing needs survey to be submitted with their planning application.
This being the case the prospective developer commissioned a housing needs survey from a company (ARC4) who compile and provide housing data.
Having read ARC4’s survey report I am concerned that the methodology which ARC4 used to compile their data is not necessarily correct, and that some of the assumptions that ARC4 made when calculating their housing needs figures are not appropriate. If the resulting housing needs figures are accepted it will have a strong influence on whether the planning application is approved or not, and if the houses are built or not, so it is obviously essential that the data which the developers are using to support their application is correct and statistically credible. At present I am concerned that the ARC4 figures may not be right, as the scenario which they indicate is the case in the village (i.e. lots of young people on low incomes, all wanting to stay in the village and therefore in need of affordable housing) is very different from the pattern of what we know actually happens in the village regarding people moving in and out, housing needs etc., as witnessed during the 24 years that we have lived here.
I would therefore be grateful if you could give me your opinion regarding whether you think the figures that ARC4 are now quoting to justify the developers statement that affordable houses are needed in the village are statistical credible, and I would be grateful if you could answer the questions shown below, with explanation/ justification for your answers where necessary.
Explanation and discussion about how ARC4 survey was conducted and how the data in their report was compiled
- ARC4 obtained the telephone numbers for 173 of the 296 households in the village.
- Out of those 173 households that ARC4 contacted via telephone ARC4, got 69 households to answer their survey.
This indicates that the remaining 104 households out of the 176 that ARC 4 contacted refused to answer the survey, and I am assuming that this was because they weren’t interested in affordable housing.
Question 1: Would you agree that this is a reasonable assumption to make on my part?
Answer 1: Yes. Also nothing is known about the other 123 households without a phone number, so they can’t be used in the calculations.
- From the 69 cold-call telephone surveys that ARC4 did complete, only 5 households expressed an interest in the possibility of needing an affordable house in the village within the next 3 years.
- From this “raw data” of 5 interested households, ARC4 then multiplied up this number (to use their expression “weight” the figures” ) as follows:
This appears to be something of a large assumption, particularly since 104 of the 176 households that they even contacted didn’t want to answer their survey, and, as noted above, therefore probably weren’t interested at all.
Question 2:Do you consider that this is an appropriate way to calculate the possible number of houses that would be required for the whole village?
Answer 2: No.
- Arc4 then went on to say that by comparing the financial data collected from the 5 households that showed an interest against recent data about open market freehold and private rental house prices in the area, it was apparent that none of the 22 assumed households would be able to afford market value housing in the village (either freehold or rented) and would all therefore need affordable housing.
I was concerned that if the financial data obtained from the 5 households that expressed an interest was incomplete or lacking in any way that the average income figure used to make the above analysis of the 5 households, and which was then used for the assumed 22 houses might be artificially low, and therefore not reliable.
Obviously if all 5 households had given their details, the average income calculated for this group of 5 households would be accurate, but if only 1 or 2 of the 5 households had submitted their financial data the average calculated may well not be representative of even the 5 households, and would be even less likely to be accurate for the assumed 22 houses i.e. an error would have been made about the assumed income for the 5 houses, and this error would then have been compounded by assuming that all 22 of the assumed houses would have the same low income .
Consequently I asked the author of the report how many of the 5 households had divulged their financial status during the ARC4 telephone surveys, upon which ARC4 then made the assumption that all 22 households would have a low income. However the author steadfastly refused to tell me how many of the 5 households supplied this data, claiming that to do so would be in breach of the Data Protection Act, which is not correct as I was not asking for the names, addresses or financial details of the households concerned, just the number of households. If the author had given me this figure I would of course have been no wiser than I was before about the identity of any of the parties involved
[Reviewer’s comment: This point is well made, but there’s also the question whether the data from 5 households can be extrapolated to the other 291, and it probably can’t be as it’s a very biased sample]
- From this I was concerned that only a very few, or even none of the 5 households provided ARC4 with any financial data, and that the author had based his analysis of average income and house prices on financial data from either only a very few of the 5 households, or even none.
- The above assumption doesn’t appear to make sense if you know what the people in the village are like, as there is a huge variation in the income levels of people in the village, from people living in social housing to several millionaires, and the young people forming what ARC4 refer to as “newly-forming” households (i.e. young people leaving the parental home and needing a home of their own) would obviously come from this wide range of backgrounds, and will have a diverse range of incomes i.e. some will have low incomes and no financial support from their parents, and might need affordable housing, while other young people will have good jobs and incomes, and financial support from their wealthy parents, and would not need affordable housing in the village.
If this were not the case, it would mean that all young people in the village growing up and leaving their parental homes would need affordable housing, which would have already produced a backlog of people needing affordable housing, but there isn’t a backlog, as has been proved by several other recent housing needs surveys conducted in by both the Parish Council, and a different developer, Dane Housing, (who obviously had a vested interest in trying to prove that there was a need for houses to be built) ; all these surveys have shown a very low number of people in need of affordable housing, and this number has not increased significantly over several years i.e. there is no growing backlog. See section 11 below regarding Parish Council housing needs surveys, and Dane Housing housing needs survey.
Furthermore if there was a backlog of people in newly-forming households needing affordable housing it would result in them having to either stay in their parental homes, which could lead to overcrowding, or even becoming homeless, but the ARC4 survey itself says that there are no households in the village that are considered to be overcrowded (and from where people would consequently want to move), and there are no homeless households in the village.
Question 3: Do you think that the author should be prepared to disclose how many households’ financial data was used to calculate the average income in order to make his assumptions credible?
Answer 3: Yes, that would seem sensible
Question 4: Do you think it is justifiable for the author to assume that all 5 households would have the same level of income based on the financial data obtained from what might be only a small proportion of these households?
Answer 4: No, the confidence interval from even all 5 would be very large, and also it is probably not representative of any households other than these few
Question 5: Do you think the author’s assumption that, from the data given by some of the 5 households, all 22 of the assumed households would be on similarly low incomes and would all consequently need affordable housing is correct and credible?
Answer 5: No, that is making further unjustified assumptions
- Whilst the report itself says that only 4 of the assumed 22 households anticipated staying in the village during the next 3 years (which would amount to only 1 of the 5 households that were actually surveyed, reversing the previous sum), it then assumes that if more affordable housing were available in the village that all 22 households would want to stay in the village. However there is already affordable housing in the village, owned and let by a social housing landlord, who have said that over the past 4 years an average of 1.75 houses have become available each year, and again, because there is no backlog in the number of people needing affordable housing, this would indicate that the current level of affordable rented housing in the village is sufficient to meet the needs of those who need such housing.
Question 6: Do you think that the author’s assumption that all of the assumed 22 households would want to stay in the village if more affordable accommodation was available, and would , based on the previously assumed income levels, need affordable housing is a credible assumption to make, taking into account
(a) The ARC4 survey itself only found one household (raw data) that actually said they anticipated wanting to stay in the village,
(b) There is already social housing available in the village, and
(c)Given that the annual vacancy rate and the number of people who have been shown to be in need of affordable housing (from a number of recent housing surveys), correlate well, to prove that the existing social housing provision caters well for the existing need, which is proved by the fact that there is no significant backlog.
Answer 6: The existing available accommodation seems to have been ignored and the assumption that if 22 houses were available then more people would want them doesn’t seem to be justified
- The main reason that there is not a backlog of households needing affordable housing in the village, or any overcrowded houses or homelessness (and therefore no proof that there would be any significant increase in the size of the backlog in the future) is that the young people who form the “newly-forming” households, do not stay in the village, as, being as unsustainable as it is , there is nothing on offer for young people in the village and they move away to bigger towns or cities. I.e. there are no jobs, education facilities, medical facilities, public transport, shops, pubs, or sports facilities etc. in the village, all of which are obviously necessary for newly forming households.
If this were not the case, again there would already be a large backlog of newly forming households needing housing in the village – but there isn’t.
Question 7: Do you agree that the fact that there is no backlog of newly forming households wanting affordable housing in the village is proof that most newly forming households move away from the village to seek employment opportunities and the facilities that they need in larger settlements, and that consequently ARC4s assertion that all of the assumed 22 households would want to stay in the village is not justifiable?
Answer 7: Yes
10.In summary, this indicates to me that,
(a) the social housing provision (i.e. affordable housing) that already exists in the village is sufficient to meet the needs of most of those who can’t afford market housing, hence no backlog for this reason, and
(b) newly forming households move away from the village, hence no backlog for this reason, and
(c) the young people who form the newly-forming households cannot all be assumed to have the low levels of income (as has been assumed by ARC4) and consequently some at least would be able to buy houses on the open market , hence no backlog for this reason.
Question 8: Do you agree with the above summary?
Answer8 : Yes
11.The local Parish Council recently conducted their own housing needs survey, which was conducted in writing with all 296 households in the village receiving a hand-delivered survey. Residents then had 4 weeks to weigh and consider whether they would be interested in an affordable house or not before replying to the Parish Council on a confidential basis. This would seem to be a much more reliable way of conducting a survey and gathering accurate data on an issue as financially important as whether someone would want to take on a house or not, than, as ARC4 did, cold-calling people and expecting them to make such a decision during a 10-15 minute phone call.
The results from this survey showed that only 3 people (in 2 households) in the village expressed an interest in taking on an affordable house in the village within the next 3 years. 68 out of 299 households returned their survey forms to the Parish Council, which was a 23% return rate, (i.e. extremely similar to the ARC4 survey’s return rate of 69 out of 296 households), but since every household in the village had been surveyed, it has to be assumed that those who did not reply were not interested in affordable housing, or they would have returned their survey forms.
Furthermore other Parish Council Housing Needs Surveys carried out in recent years have returned similar figures as follows:
2006 Survey: 86 replies received from 270 households that were surveyed (=32% response rate) which showed a need over the next 5 years of 5 households (NB not 3 years as the current ARC4 and Parish Council surveys have been).
2012 Survey : 156 replied received from 296 households (=52% response rate) which showed a need for the next 3 years of 4 households.
The above information therefore shows that the level of people expressing a need for affordable houses has been at a consistently low level over the past 10 years, and remains so now.
As mentioned above, a development company, Dane Housing, (who were interested in building affordable houses on the same site, and therefore had a vested interest in wanting to prove that there was a need for such houses) conducted a written housing needs survey in November 2013, which was posted to every household in the village, but they received no replies whatsoever.
Question 9: Would you agree that the recent Parish Council survey would appear to be more statistically credible than the ARC4 survey, and that the results thereof are more statistically significant than the results/ assumed figures from the ARC4 survey?
Answer 9: Yes
- Since the author of the ARC4 survey said he could not give his client, the developer, a list of the names and addresses of the 5 would-be tenants to present to the planning authority, as to do so would breach the Data Protection Act, it would seem to me that the developer has no credible evidence from the survey to support his assertion that there is a need for affordable housing in the village, even from the 5 households that expressed an interest. Obviously there will not be any evidence from the other 17 households, as they are only theoretical at this stage.
Since the Planning Authority needs to see proof that there is a real need for the proposed houses to be built before granting planning consent, it seems to me that they would need a full list of the names and addresses of all the prospective tenants who they could then check were genuinely interested, and financially able, to take on something as financially binding as a house. However, the ARC4 report doesn’t deliver this information, and quotes figures which have been calculated on unsubstantiated assumptions, and which are based on data that they are not prepared to disclose (with no good reason why they can’t do so), and consequently I cannot see how their survey data could be deemed to be sufficiently statistically credible for the Planning Authority to accept it as evidence of a housing need, and to grant planning consent accordingly.
The recent Parish Council Survey, however, contains all the necessary data of specific real households, which the Parish Council could pass on to the Planning Authority (obviously in confidence and with the householders’ consent) if the planning Authority wanted to investigate the how genuine the would-be tenants’ interest was.
Question 10: In summary, do you think the ARC4 survey is compiled from accurate and complete data,and presents enough statistically credible evidence, to enable the planning authority to accept that there is a need for 22 houses to be built?
Answer 10: No
Thank you for your assistance in this matter. I look forward to hearing from you in due course.