FAO: Jameson Bridgwater PGDIPL MRTPI
The Planning Inspectorate
3/12 Kite Wing
Temple Quay House
2 The Square
Bristol, BS1 6PN                                                                                                                     21 May 2015


Dear Inspector,

Ref: PINS/C1435/429/6 – Wealden District Council

We (Utopia Tristar Partners or UTP) write with respect to the Public Hearing held yesterday at the Sussex National Golf Club near Uckfield and to thank you for allowing our representative, Mr Kay, to speak on our behalf.

UTP should like to follow up on the points raised yesterday and to explain that we are a not-for-profit concern. We are not therefore developers in the conventional sense, but a think tank with the knowledge base of members who have practical (in some cases hands on) experience of designing and building houses, within an administrative framework that it appears is unable (insufficiently flexible) to provide houses for the ordinary man in the street at sensible prices in relation to his wage packet.

Our other function is to design homes conceptually and advise on strategy, whether mobile units or permanent houses, that could be described as sustainable in a broader context, so that they are also affordable.

Sustainability is a National Planning Policy matter that we feel is not addressed by the proposed Affordable Housing Delivery Local Plan (AHDLP) – especially in the context of “Building a strong competitive economy.” Where planning applications must be determined in accordance with the proposed Local Development Plan (LDP), save for exceptions. It follows that if the DP is not sufficiently forward looking, that short sightedness will stall the move to a sustainable society – such as to halt climate change – one of the major issues that planet earth is facing right now with reference to Resolution 42/187 of the United Nations General Assembly.

There is a requirement for the council to be “Proactive” (Paras 94 & 97 NPPF) in this regard and ensure that new developments should include decentralized energy supply with local energy generation. Yet we see little about this in the proposed Delivery Local Plan, nor in the accompanying Sustainability Appraisal. In our view this is a major failing of the AHDLP, with regard to Paras 151 – 152 of the NPPF.

In connection with our main functions we are able to apply for planning permission for genuinely social housing, to include application negotiations with councils and if necessary, the provision of advocacy for appeals to the Secretary of State. We do this on a pro-bono basis, provided that we feel an application ticks all of the sustainability boxes, thus is deserving of our limited resources.

NARROW VIEW – It was confirmed to you yesterday that the council had not considered some of the options that we raised in brief as may be seen on our website: where the lead page gives a breakdown of costs in relation to a sample sustainable unit.

We consider that there are reasonable alternatives to the means employed by Wealden to deliver affordable housing and that alternatives derived from a social housing model could be tailored to meet the challenge from central government as to more people becoming homeowners. This is important for the man and woman on the street looking for accommodation at the best value. Clearly, that would be a mortgage on a home that is not only affordable in money terms, but also in terms of energy usage and other service bills.

It appears to us that in order to mitigate not considering viable alternatives, that the council’s remit had been narrowed to the delivery of housing for affordable renting only, where that is not delivering affordable housing, but affordable housing for rent; two completely different things. In addition, the rental scheme is not truly affordable, but only a 20% reduction on open market property.

Where the council gave evidence that the rents of these houses was below market rents, such rent is still far more expensive than a mortgage on a house that is built for between £50,000 - £90,000. The point here was well made by Councillor Keeley, that the population should not be made to pay rents for the rest of their lives that are higher than it would be if housing was made available at sensible prices for purchase.

This is a strain on council budgets, where rents to private landlords are high enough to imbalance the aim of a sustainable Circular Economy. This could lead to civil unrest and the collapse of lending institutions that are trading on mist, on mist – so pumping up a bubble that will eventually burst. Such bubbles (Black Monday) are inevitable in a society based on Growth – where continuous Growth is impossible because we only have one planet. Early housekeeping is thus essential.

HEALTH OF THE NATION - The long term effect from mental health issues associated with the high cost of living is a burden on the NHS, for example, with more people dropping out of employment and more claiming disability, when by lowering the cost of living, such build up of the hidden cost of a superheated economy could be significantly relieved as a step towards a Circular Economy.

AFFORDABLE – The definition of what is truly affordable is therefore the point at issue. What Ms Brigginshaw meant when she advised that her council has provided housing for lower rentals, was that they had gone some way to lowering the cost of living for some workers, and that is commendable. We were told that as affordable housing was provided, that more registrants came out of the woodwork presupposing that there are many more applicants who are not signing up because of the waiting lists. One can imagine how many people would sign up to a home @ 40-50% below market rents. That would be the litmus test, suggesting caution and tight rules for a roll out.

As was stated, we consider the council’s proposal to be a bold step in the right direction, but it is a small step compared to what it is possible to achieve by using a formula for genuinely affordable houses – whether for rent or for sale.

UTP’s intentions in attending this examination were to be helpful where we can. We do not wish to be seen as a potential fly in the ointment, and we recognize that by introducing alternative technology, that there will be resistance to change. For example, if standard units were to be deployed, applications for building regulations approval would not need so many council staff to process. Policy making positions may also reduce.

PICKING OVER THE CARCASS – The 35-65 split is an effort to shift the burden of development using what amounts to bribes on the one hand and blackmail on the other, as the statutory tool to try and extort affordable homes from developers who would not normally give two hoots about non profit schemes.

What has happened nationally as a result of the failure of councils to take control of their patch is that there is a Klondike style land rush, due to the fact that sites not normally open to development proposals are now being given consideration despite locations outside of the development framework. In other words, Greenfield sites are now open for business provided that a/the developer is prepared to be both blackmailed and bribed at the same time.

VIABILITY – The question then arose as to how much a developer could be blackmailed, before they turned to defend profits by way of a legal challenge in terms of viability – and this in turn frightened the council, in that housing targets might then not be deliverable. Obviously, within the constraints of a “narrow” view, councils can be forgiven for taking that position – because a mix of high cost housing and lower cost housing is better than no housing at all.

TOO MANY CHIEFS - The problem here is that the ratio is all wrong in terms of sustainability. It cannot be that 35 workers support 65 managers – and that is what the present split says. It is the other way around, 65 workers to 35 managers – and probably there are many more workers to managers in a Circular Economy. Hence, the proposed 35/65 ratio, unless boosted by proactive affordable developments, is sure to lead to problems. Once the population wakes up to what is happening, the marches like that in London recently, could become a regular feature.

DELIVERABILITY – That brings us on to the ability to deliver with the high cost of land, application fees, and other professional charges. Using the blackmail system to force wealthy developers to do their dirty work is not the surest way of delivering sustainable houses for a Circular Economy. It might seem to many councils that that is their only option, but in fact where they are once again developing their own sites and should be proactive, they have the ability to put in housing at greatly reduced cost. More importantly, such designs tackle climate change – and addressing climate change reduction is part of the requirement of the NPPF from 2012 as cited above.

EXPERIENCE – We were asked how many homes we have delivered. Despite our best efforts (as a not for profit) to interest council’s in low cost homes, the replies tell us that we are wasting our limited resources trying to persuade councils that say they do not commission developments. These are the replies received to date.

We would suggest that councils put out to tender, if they wish to reduce housing costs, but in doing so, to ask for alternative construction methods with the same longevity as bricks and mortar. This would enable affordable housing delivery at a 100% rate with no bribes or blackmail. It is all down to strategy.

EXAMPLE – By accident, one of our partners took on a case, advising a local developer about a flatpack cabin that this council was arguing was a house – hence could demolish – where he only had permission for a mobile home.

Indeed it was a house by definition. But by virtue of some small changes to the design it was very easy to make the unit compatible with the Caravans Act and fully mobile. It is also possible to do the reverse, turning a similar unit into a house (by design).

What was so interesting about this home, was how cheap it was. A flatpack was delivered from a local sawmill for around £15,000. It only cost another £10,000 all in to fit the unit out with heating and electrics, and the client had a home for £25,000. Today that would be £35,000.

The point is that in assisting this client to meet with regulations, we effectively delivered an affordable home that Wealden were looking to demolish. And that is another issue that is not helping councils to deliver affordable housing, where they frequently seek to bulldoze houses that could be made to meet their requirements and so reduce the need for fresh developments. Demolition is itself wasteful of energy invested.

Taxpayers are thus fronting the costs of administrative practices that go against the need for a Circular Economy, in that systems should be sustainable – even administrative systems. One potential cure to cut administrative costs is to assist irregular developers to conform to policies.

Taking £35,000 as the base line from the above example (inflation adjusted), we would need to add around £16,500 for energy and heat capture equipment, taking the cost of a sustainable unit to £51,500 for this particular real-life example. Other designs could be £10,000 cheaper as per example designs seen at:

The remaining issue is the cost of the land and planning consent.

FREE PLANNING CONSENTS – Avoids the need for a council to use their powers to purchase land compulsorily. Though this may be an alien concept to any council department who derives their income from fees, applications on land that is not owned by a council is another step closer to the ideal, where landowners give up their land on a voluntary basis. This could be seen as proactive.

The alternative to free consents is the provision of identifiable areas of land for development, but only for genuinely affordable housing.

The suggestion was that if a landowner knows that a field in his ownership has planning permission for 10 affordable homes, that he is likely to want to build those homes or allow an association to build those homes in return for a reasonable ground rent, or sensible land valuation in the event of sale.

It was then suggested that negotiation with landowners up front would be preferable and that is agreed, provided that they don’t see themselves on a diamond encrusted stairway to millionaires row, simply because that is what other landowners are achieving at the moment.

CIRCULAR ECONOMY – This is not something that councils can ignore, in proposing schemes that “get around” their duty to provide low cost housing in their administrative area. Housing based on high quality (mostly) pre-fabricated units as per the example above, should include energy generating and storage as part of the design. That is all part of being affordable, in that affordability in the sustainable sense not only includes the cost of finance, but also the cost of services to a home. 

We would thus urge the Secretary of State to correct any defect in this proposed AHDLP by directing that in addition to asking local developers to contribute to affordable house builds in the ratio of 35/65% that such developments should encompass the tenets of the NPPF in respect of sustainable energy, hence climate control. 

We would also urge the Secretary of State to direct the council to be proactive in the identification of land for affordable housing and/or to pursue their own social and low cost housing developments, taking into account the latest developments.

Thank you again for allowing our observations to be taken into consideration.

Yours faithfully,

Leslie Grant
for Utopia Tristar Partners



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