Wakefield Local Plan: a failure to meet local, affordable housing needs
Consultation on the Wakefield Local Plan ran from Thursday 18 May until Wednesday 28 June 2023. Read my response below. And thank you to the many constituents who responded to my short survey.
To whom it may concern,
I am writing as the Member of Parliament for Hemsworth Constituency on behalf of hundreds of constituents who have raised concerns with me over a number of proposals within the Local Plan.
I would like this opportunity to remind the inspector that my area is one of the most deprived and least socially mobile constituencies. It also has lower rates of educational attainment, fewer top jobs (as defined by the ONS) and has an average wage almost £15,000 less than London.
Let me be clear, this is not our fault, it is the fault of being totally held back by successive governments which have failed to invest, have sucked out resources and cut our public services to the bone. In short, it is about money. Please take into account this backdrop when considering the potential impact of the Local Plan.
As you know, I have already made written and oral submissions to the Planning Inspector on three specific proposals:
The land behind Springvale Rise and on Vale Head Park for the building of 266 houses to be developed on the site, Reference Number LP21;
The land at Highfield Road, Hemsworth, Reference Number LP1511;
And land South of Featherstone alongside proposed South Featherstone Link Road Local Road Network Scheme, Reference Number LP11 and LP1335
I do not wish to repeat the specific objections already submitted, but I would like to raise the issues my constituents and I have with the overall soundness of the Local Plan. As the National Planning Policy Framework (NPPF) sets out the four legal and procedural requirements for a Local Plan to be deemed “sound”, I will take each in turn.
NPPF section 35 (a)
35 (a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development
Under this part, I will focus on the urgent need for affordable housing.
Firstly, I do not believe the Local Plan, as it stands, meets local needs, especially in regard to the three proposals referred to above.
Our area is in desperate need of affordable, well-built and sustainable housing which does not put additional pressure on already overloaded public services. However, in some cases there is no provision in these proposals for affordable housing, with the focus instead being on building executive housing which only really benefits property developers, not local people.
In our district there are over 20,000 people on the waiting list for a council house. I have had constituents come into my office with appalling stories where tenants have been at the mercy of landlords. For example, I have seen an increase in the number of people asking for my help after being handed a “no fault eviction” notice. In one such example recently, of a section 21 notice, a family of three were in effect left homeless. The local council will now need to act to help them, despite having fewer resources as a result of budget cuts (about 40% since 2010). With the cost of living crisis getting worse, these issues are being compounded.
According to the House of Commons Library nearly 80% of new housing built in Wakefield District since 2012 is ‘unaffordable’. Indeed, only 3,130 affordable homes since 2012 have been built in the entire district; the figures include affordable homeownership, affordable rent and social rents.
Let me be clear, this is not the local council’s fault. The fact is, central government has driven policy in the last 40 years towards selling off the council housing stock, reducing the power of local authorities and, more recently, in the Localism Act, only aiming for 10% affordable housing in new builds.
As an example, the proposals under Reference Number LP1511 explicitly say there will be no provision for affordable housing.
Some people raised the issue of the lack of social housing stipulated in the proposal at the consultation meeting on Monday 9th May 2022, but no adequate answer was given. There was no clarification provided as to the allocation of social housing, only that it may be “mixed”. This is simply not good enough.
I also object to the fact that many of the proposals indicate that there will be building on the green belt. My constituency, made up of a number of former mining villages, is over 80% green belt. However, there are plenty of brownfield sites which could be built on.
NPPF Section 35 (b)
35 (b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence
As you will be aware, my constituency covers a number of towns and villages in the heart of the West Yorkshire countryside. I am determined to ensure that green belt land in our area is protected and not built upon. Our local history, culture and environment are not only a part of our heritage, but also a part of our identity and sense of cohesion as a community.
I am of the strong opinion that, with the urgency of the climate crisis and the health of the nation after covid, we should not, as a country, be causing more destruction to our green belt.
However, many of the proposals in the Plan wish to eat into our green belt. As an example, proposals under Reference Number LP21 states that there will be a demotion of green belt land to “greenfield” land. To quote the Local Plan directly “it is proposed that this site will be removed from the green belt.”
I note that the government’s own National Planning Policy Framework (NPPF) sets out in Chapter 13 how green belt land should be protected. On altering established green belt boundaries, the NPPF says that established boundaries should only be altered in “exceptional circumstances”, where fully evidenced and justified, and refers to “permanence in the long term”. The NPPF also says that inappropriate development is harmful to the green belt and should be approved only in “very special circumstances”.
In addition, under section 138 of the NPPF, green belt land serves the purpose of preventing the merging of towns, safeguarding the countryside from encroachment and preserving the special character of historic towns. As we know, Hemsworth is mentioned in the Domesday Book.
My constituents and I are of the view that there are no justifiable grounds to redesignate the site as greenfield land and that, in line with the government's own legislative framework, there are no “exceptional circumstances” for building on land that is currently green belt.
Linked to the protection of the green belt is the need to preserve our precious flora and fauna. As an example, I would like to turn to the proposals under Reference Number LP11 and LP1335. My office commissioned a wide ranging ecology report of the areas in question, an overview of which you can read here. It found there were 16 protected species of birds, 10 protected species of mammal and a number of protected designated sites, including one protected internationally as a Site of Special Scientific Interest.
Why should our green areas have to be built upon like this? There are alternatives. As of 2017, when Wakefield’s Brownfield Register was last updated, over 247 hectares of brownfield land was identified. I would ask the inspector whether due consideration has been given to potentially viable brownfield sites and what assessment has been made.
NPPF Section 35 (c)
35 (c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground
I do not believe that the proposals under Reference Number LP11 and LP1335 will be deliverable. This is because of the size and nature of the project outlined in the local plan. Some 1,500 homes were initially proposed to be built but this has been reduced to 1,000, which is still a staggering amount of houses for the available resources in the area.
The impact on local services and infrastructure is going to be sizable. There is no provision for public services in the proposals put forward. No plans for education even though local schools are over-capacity. There is no mention of additional health services – this is particularly problematic when a significant number of the proposed new builds are aimed at older people, who are more likely to need healthcare.
At the 2021 census, there were nearly 13,000 residents in Featherstone. The plan to build 1,000 to 1,500 homes will have a significant impact on the population, and thus local services.
Featherstone is in the top 10% of most deprived areas in the country (HoC data) and clearly more needs to be done to improve services, traffic, housing and the high street in the area. As I have stated above, locally we have nearly 20,000 people on the waiting list for a council house, but with only a 100 or so houses designated as affordable under these proposals, this development will not help boost Featherstone’s local economy, nor address our housing shortage.
There is also a huge problem with traffic congestion; the roads are already full. There will be significant additional traffic, congestion and subsequent pollution of the air as a result of thousands of extra residents, resulting in significant traffic disruption. Capacity on the roads will be at breaking point.
Alignment has changed a number of times, and there is no justification for the current alignment, nor has there been a proper justification from the council’s planning department.
I have already received numerous letters and emails objecting to the proposals, particularly the link road which will go from South Featherstone through Hessle to Ackworth. I urge the inspector to review the long-term effectiveness of these proposals and in particular to re-consider the building of a link road.
Consistent with national policy
The government’s policy to “level up” the country is more of a soundbite than a realistic goal. However, the NPPF judges the soundness of the plan partially on national policy aims. As such, it has become clear that there is no consistency with the plan and levelling up our area.
As stated above, there is little provision for affordable housing, meaning local people are priced out of the area they are from. Not only that, the focus on executive housing often results in people from outside the area buying properties in order to commute to the larger cities such as Leeds or Sheffield. They are likely to go shopping outside of the area in their cars rather than using local shops and helping to boost our dying high streets. In 2021 the government launched its “strategy to regenerate high streets” and “to breathe new life into town centres”; this cannot be achieved if local people cannot afford to live close enough to these areas, or do not have enough disposable income to contribute to the local economy.
One of the cornerstones to levelling up should be access to high quality public services. Under each of the three proposals I have not seen any viable strategy for ensuring services will be equipped to deal with the increase in demand, especially in Featherstone where an extra 1,000 houses are to be built. At present our GP surgeries are in crisis and many people cannot get an appointment. I myself had to ring my surgery over 200 times one morning just to get a repeat prescription. Dentists are over capacity, schools are full and public transport has been cut; the road network is simply incapable of handling the extra traffic.
All this is due to cuts by central government, not because of any failings of staff or local authorities, but we do have to consider the impact after 13 years of austerity and the covid pandemic.
Although I am the MP and I have made my case above, I feel it is always much better to amplify the voices of local people. As such, I ran a short online survey to ensure everyone had their chance to submit their view to me.
I had over one hundred responses which unanimously expressed deep concerns about the local plan’s soundness.
Firstly, there were worries about the impact on green spaces in our area. One constituent commented that “they want to take away our green areas”, and another said: “I think it's disgusting it's all about money, money, we are no longer protecting our green belt and our wildlife, there are plenty of Brownfield sites to build these houses on”.
Indeed, many expressed dismay at the plans which could have easily avoided the green belt. For example:
“Completely lacks any assessment of the current situations on housing, roads and infrastructure. Idiotic ploughing on despite exceeding their housing requirement for the last 10 years. They fail to see the assets around them which could be converted into housing stock, instead they allow building on green spaces, and facilitate house builders to omit social housing via the loophole by which they state social housing would be detrimental to the new development”.
“These plans are removing what brought me to the area: green open spaces. The site on Highfield Road is regularly used by children for football games and the local community for dog walking, exercise etc. Again the site at Vale Head Park is also an outstanding area of natural beauty which needs to be preserved. Better use for these sites would be benches, wildflower areas, and development of run down properties and empty shops over the development of new housing. I do not think these plans have been considered with any thought or consideration to those who already reside here or the number of vacant/for sale properties in the area which need investment first.”
As we already know, public services are stretched to almost breaking point. This was raised by the majority of respondents; here are some examples:
“I believe that the four criteria will not be met, due to the fact that the influx of families will put extreme pressures on facilities such as doctors, schools and the environment. Facilities which are overstretched currently.”
“Where is the additional plan for schools to accommodate the children from these additional houses? Ackworth children already have to travel to other villages as all local schools have no availability.”
There aren't enough school places to accommodate all the new homes. Doctors’ and dentists’ extra appointments are impossible to access now so again where are all the extra residents going to go. The land at the top of highfield road is well used by local football teams, if this field is built upon where will the teams go? We need more for the children to do not less…. health services and schools, there is nowhere to build any more facilities to accommodate the extra residents either, so what exactly is going to happen if they get the go ahead? Also even if they build alternative routes into the new estates people will still use the existing roads if this is a more direct route into the estates. Highfield Road is used now to short cut and avoid the traffic lights on Crosshills so this will only get worse. Hemsworth simply cannot accommodate this amount of new housing.”
Another point that was raised a number of times was the traffic problems and the fact that our current highway infrastructure simply cannot take any further traffic.
“This is not what is needed in Hemsworth. The infrastructure is not there. Highfield Road is dangerous now, it's a very narrow road with residents parking on the road making it nigh on impossible to see oncoming traffic now. Imagine a higher volume of traffic.”
“I live in Featherstone and there are already too many houses. I am affected by the traffic on the A645 daily as my house is Pontefract Road. Featherstone does not have the infrastructure to support more housing.”
“Traffic in and around all areas is horrendous with many accidents occurring and bringing further housing will increase this, cause congestion and hamper services.”
There is also anger at the fact that national policy objectives will be undermined by the local plan, particularly its impact on the local environment:
“Any movement towards a carbon neutral area will be severely affected by the extra pollution from more cars and homes. The peace and mindfulness of existing residents will be adversely affected by all the developments.”
“The local plan has not considered the impact it will have on our town and villages, it has not considered the infrastructure and it’s not considered the pollution this will have an effect on, it's not considered our rare wildlife and not considered the environmental issues that will already suffer greatly from these developments that are a bad choice for Hemsworth, Fitzwilliam and Kinsley.”
I hope you will consider the points above in detail and also read them alongside my previous submissions and oral statements at the evidence sessions. As a courtesy I would like to inform you that I intend to make this submission available publicly so my constituents can read it.
Jon Trickett MP