Ryedale Dev elpment Framework - Representations : 5 July 2006



1.1. My name is Paul Andrews. I am a former local government officer with over twenty three years experience of working for public authorities. I have lived in country districts during most of my working life. From September 1988 to April 1996, I was Ryedale’s Council Solicitor. As such I provided legal support to all Ryedale’s planning enquiries during that time, and also provided legal advice to the Council’s three planning committees. So I am familiar with the planning process, although I hold no planning qualifications.

1.2. In about 2001 I became a parish councillor for the Habton Parish, and in May 2003, I was elected as a district councillor to RDC for the Malton ward.

1.3. My submissions have two purposes:

1.4. To support the amendments I have proposed to the LDF

1.5. To advance the Habton Parish Council’s views in support of Mr. Alec Bulmer’s case for the designation of a site at Manor Farm Great Habton for 16 houses (8 of them to be affordable houses). See Exhibit 1 – Letter from our local MP.

2. Question 2 – Spatial Strategy - Is the role and balance of development between main towns, market towns and other settlements appropriate and fully justified?

2.1. I would submit that it is not, for the following reasons:

2.2. This is a policy which has not worked in the past. The present policy requires new housing development to be concentrated within the market towns, and, for that reason, village development limits were tightened and restricted. In spite of this, more new development has been built in the countryside than in the towns.

2.3. There is more demand for new houses in the countryside than in the market towns. This is one of the factors that results in making houses in the countryside inordinately expensive and overvalued.

2.4. Ryedale is a large district with a high proportion of agricultural and equestrian businesses. Ryedale is known as the “Newmarket of the North”. These businesses not only include farms and racing stables, but also the businesses which support farms and racing stables. There is therefore a need for local accommodation for people who live and work in these businesses.

2.5. Ryedale’s traditional businesses, being largely based on agriculture and equestrian activities, are widely dispersed and are not concentrated in the market towns. For example, my own village of Great Habton has several farms, a racing stables and a haulage yard. Within a radius of three miles there is Westlers, a large food processing business, BATA (which provides services to agriculture), and the nationally renowned Flamingoland theme park and zoo.(Exhibit 2 – map showing businesses dispersed over the Habton area)

2.6. There is also a large tourism sector, including hotels, guesthouses, stately homes ( Castle Howard is one of the best known in the country and organises open air concerts which are attended by thousands), a famous preserved railway, rural and other museums, pubs and businesses which support country recreational activities such as hiking, fishing, shooting, hunting, horse riding etc.

2.7. With so many employment opportunities dispersed outside of the market towns, it can hardly be appropriate to restrict new housing development for those who work in them to the market towns and a limited number of “service villages”. It makes no sense, in environmental terms, for workers to travel from towns like Malton to work at places like Flamingoland, or to any of the racing stables.

2.8. There is a real sense of local community in the villages of Ryedale. Unfortunately, house prices have risen to such an extent that it is no longer possible for ordinary working people to buy houses in the villages where their families live and work. Local working people cannot afford these prices. The result is that young local people who are first time buyers have no chance of buying a house near their families or place of work. Exhibit 3 shows a comparison of house prices between the years 2000 and 2005 in the Malton and Leeds areas in regard to terraced and semi-detached houses. It will be seen that houses in both areas have risen dramatically, but that prices in Malton are higher than in Leeds, and that the difference between prices in Malton and Leeds has increased considerably during the last five years. Unfortunately, the same internet site does not seem to be able to provide separate figures for house sales within villages, but I can say that the four bed roomed house we bought in 2000 at Great Habton is one of four houses on a development where one house is currently on the market for more than double the price paid for ours.

2.9. Many people believe country people are better off than people who live in towns. This is not so. Country incomes, particularly in the agricultural sector are very low compared with those of people who live in cities. As income in other businesses have risen, incomes from agriculture have continued to decline, so that few farm workers are paid more than the National Minimum Wage, and this low wage culture extends beyond agriculture to most other businesses. The result is that, as house prices rise, ordinary country working people find themselves at a serious disadvantage, when compared with outsiders who look for a pleasant home in attractive surroundings from which they can commute to work in either York or Leeds – or even London. So, instead of staying within the community they move to places like Leeds, where houses are cheaper and wages are greater. The result is that local communities are becoming less and less sustainable.

2.10. In former times, the village communities were kept together by the allocation of council houses to local people: – rural housing policies always have served a different purpose than urban ones - as farm cottages were sold off, the former tenants and their families moved into council houses which had been built in their villages. This was achieved by awarding waiting list points in favour of applicants who had a local connection.

2.11. In 1991 Ryedale sold its Council house stock to Ryedale Housing Association, which has since merged into a larger body (Yorkshire Housing Association) which serves a much larger area than Ryedale, including York and Leeds. Since 1991, as far as I am aware very few (if any) new Housing Association houses have been built in the villages – most have been built in the market towns. Since then, many have been sold to tenants under the preserved right to buy. So there is a shortage of rented accommodation for local people.

2.12. This situation has been made worse by government policy. I personally handled the legal work for the housing transfer of 1991. The transfer agreement contained a clause that restricted the use of Ryedale’s housing stock to people who were in housing need in Ryedale. In 1999, this restriction was taken out of the agreement so as to allow Ryedale’s old housing stock to be made available to applicants who had no local connection. At about the same time, the government required the Housing Corporation – the body which regulates housing associations and funds new developments – to require all housing associations to stop awarding waiting list points to applicants for having a local connection. So Ryedale Housing Association no longer awards waiting list points on this basis.

2.13. This is an issue which the Council is aware of. Unfortunately, the Council’s way of dealing with the issue is far from practicable. The Council recognises the need for affordable housing in the villages, but wants to concentrate all new development within the market towns. So, what the Council proposes is to prevent any new housing in the villages or the open countryside – not even allowing such development within the existing village development limits. However, the Council will make an exception in favour of exclusively affordable housing developments which may still be built within village development limits. In making this concession, the Council have produced NO evidence to show that there is any housing association which is at all likely to build any new affordable houses in the villages in the near (or even the foreseeable) future.

2.14. There is also an assumption that private developers might be prepared to build affordable houses. Whilst it is not unreasonable to expect private developers to build such houses as part of larger developments, it is quite unrealistic to expect them to build many developments which are exclusively affordable. Developers say such developments just would not be viable, and, so far, none has been built to date, as far as I am aware: so why should any be built in the future plan period?

2.15. The situation has been made even worse by Regional and National policies. As we all know, Whitehall and the Regional Office hand down to local planning authorities figures which determine the requirements for new housing, and local planning authorities are expected to produce plans or development frameworks which implement these figures. So government has always expected a slow growth in housing in rural North Yorkshire, and the housing requirement figures for Ryedale have always reflected this. The effect has been a policy of restricting new housing, by concentrating it in the towns, and, to this end, the village development limits of the present plan were drawn more tightly than they had been before, and many sites which had been allocated within the village development limits before were excluded from them (for example the Manor Farm development at Great Habton). This current LDF tightens the policy even more by prohibiting any development in non-service villages even in the development limits – except affordable housing.

2.16. The figures handed down from Whitehall worked perfectly well, while the demand for housing in Ryedale was limited. However, in the last few years, there has been a complete change of circumstances. Commuters are willing to travel greater distances to work, and many retired people have moved into Ryedale. This has put pressure on house prices, and the policies which restrict the number of new houses have pushed prices up even more. Before 2000, house prices in the rural areas used to be well below the price of houses near York. Now that differential is disappearing, but rural wages and incomes have not significantly increased, and country people find themselves priced out of the market.

2.17. This leads to the rather dubious distinction between holiday lets and permanent dwellings. Both types of accommodation are either houses or flats, and both have the same appearance as, and have to have the amenities of, a permanent dwelling: the distinction is in the time you are allowed to remain in occupation. So, a holiday let is classed as an employment use of land, but not as a residential use. Because holiday lets are classed as an employment use, they do not contravene the government’s housing requirement figures. Further, as farming is in difficulty generally, permission for holiday lets falls neatly into the policy of farm diversification, and traditional farm buildings in traditional farm yards all over Ryedale are being converted into holiday lets, when they could be used to ease the shortage of new housing.

2.18. In many villages, particularly those in or near the National Park or other areas of high amenity value, there are large numbers of holiday lets: in some villages there are so many holiday lets that the village is dead in the winter.

2.19. In other words, the way local policies and national policies interact at present actually reduces the supply of homes, without in any way discouraging the demand. All these factors combine to force house prices out of the range of the local people who need them.

2.20. There is also an environmental issue. Holiday lets, by their very nature, must generate more car journeys than permanent dwellings, if the dwellings are occupied by people who work locally

2.21. The concept of “service villages” does not fit Ryedale. There are certainly some villages which are larger than others and have more infrastructure and services, but this is not the way Ryedale works. As mentioned before, Ryedale’s businesses, particularly its agricultural, leisure, tourist and equestrian businesses are dispersed throughout the countryside and not concentrated around specific “service” villages.

2.22. It is more realistic to look at groups of villages – rather than individual service villages. For example, my village, Great Habton, is in a group of villages which includes Amotherby, Swinton, Rhyton, Kirby Misperton and others. Within a range of three miles, there are the following employment opportunities and local infrastructure:

2.22.1. Easterby’s racing stables – employs about 50. The gallops go around the back of the village, and one block of stables is half a mile down the road. Easterby’s own houses within the village, which they let to their employees.

2.22.2. Bulmer’s’ haulage – this is a business which has grown out of farm diversification – believed to employ more than thirty people and situate opposite the Easterby stables;

2.22.3. Flamingo land zoo and leisure theme park;

2.22.4. BATA in Amotherby – a large business which supports farming;

2.22.5. Westler’s foods – believed to employ over a hundred workers – one of the district’s largest employers;

2.22.6. A butcher’s shop, which also sells general groceries;

2.22.7. Several village post offices;

2.22.8. Several churches;

2.22.9. A popular Chinese restaurant, (the Queen’s Head);

2.22.10. A cordon bleu restaurant and pub (The Grapes, Great Habton)

2.22.11. Other pubs which also serve food in Great Barugh and Kirby Misperton,

2.22.12. Several village halls (including one particularly big one at Kirby Misperton), a sports centre at Swinton, several village cricket grounds etc.

2.22.13. A local primary school in Amotherby

2.23. Indeed, there are more facilities within this group of villages and within a 3 miles radius of any of them than there is within three miles of Sheriff Hutton, which is to be designated as a service village.

2.24. Paragraph 3 of PPS7 states:

2.25. “Away from larger urban areas, planning authorities should focus most new development in or near local service centres where employment, housing (including affordable housing), services and other facilities can be provided close together. This should help to ensure these facilities are served by public transport and provide improved opportunities for access by walking or cycling. These centres (which might be a country town, a single large village or a group of villages) should be identified in the Development Plan………………….”

2.26. I cannot recall the group of villages option ever having been given any serious consideration during the preparation of this local development framework.

2.27. In these circumstances, it would seem both illogical and contrary to the policies of PPS7 to restrict development within the Habton/ Amotherby group of villages to affordable housing only, as proposed in the draft LDF.

2.28. It is in this context that I would particularly like to support the Parish Council’s case for the site at Manor Farm Great Habton. In this respect, I submit as Exhibit 4, the statement I wrote for the hearing that took place into Mr. Bulmer’s recent planning appeal on that site, and would refer again to the copy letter from our local MP to the Council’s Chief Executive (Exhibit 1).

2.29. I know my local area well, and can discuss it at length. However, I would be surprised if the Great Habton group of villages is unique within Ryedale, and would expect there are many other groups of villages which are in a similar position.

3. So, to answer the questions under Section 2:

Is the role and balance of development between main towns, market towns appropriate and fully justified?

3.1. The answer has to be “NO” for the reasons set out above. The Council has failed to consider the “Groups of Villages” option. It is considered that this will unduly restrict and prevent any new development outside towns and service villages. This will be completely inflexible, and will prevent villages and groups of villages from growing, and force more and more of the low paid working population who work in or near the villages to move into the towns or out of the district. It is not in accordance with paras.2-4 and 7 of PPS 7

3.2. Is the strategy for development in smaller villages appropriate?

The answer is “NO, because no account has been taken of the service groups of villages option.. There is no strategy for development in non-service villages – only a plain refusal. The plan not only in effect prohibits all new residential development except affordable housing, but fails to revise the village development limits – something it leaves for later. The Council knows perfectly well that, with such a policy in place, there will be no need to revise the village development limits, because no-one will want to build in the villages in these circumstances. They have not thought out the impact this might have on sustainability.

3.2.1. The strategy does not take into account existing and future services, as demonstrated in the Great Habton group of villages. It is appreciated that Amotherby may be included as a service village, but it is considered that Amotherby/ Swinton should be not be taken in isolation, but be considered as part of a wider group. As regards transport, due account should be taken of the private motor car. Most people have one, and use them to travel to work. Bearing in mind the absence of public transport and the fact that businesses in Ryedale are dispersed and not concentrated in the towns, it is important that people should be able to live near to where they work, instead of having to travel from places like Malton, for example, to work at places like racing stables, Westlers Food or Flamingoland, which are located way out in the countryside.

3.3. Is the strategy limiting development in the open countryside appropriate?

3.3.1. The answer is “No”, in so far as non-service villages are concerned – again for the reasons stated above. It does not accord with PPS7, for reasons stated before. Further, one of the purposes of PPS7 would seem to be to include policies “to sustain, enhance, and where appropriate, revitalise country towns and villages”. The impact of the strategy of, in effect, restricting new housing development to affordable housing only will be to sterilise all villages which are not classed as service villages.

3.4. Does the strategy enable provision of housing to meet local housing needs in appropriate locations?

3.4.1. The answer is “NO”. As far as non-service villages are concerned, there is no provision for any balance between affordable housing and other housing, because only affordable housing will be permitted. Further, as stated before, few (if any) private developers are likely to want to build developments which comprise exclusively affordable houses in villages which are not service villages. I am not aware of any that have been built so far, and there is little evidence to suggest there will be any change in the future. Further, I am not aware of any recent development by housing associations in non-service villages, and the council has no housing stock of its own, and therefore has no control over where publicly funded rented or shared-equity housing is going to be built.

3.4.2. As far as redundant farm buildings are concerned, there should be a presumption in favour of residential conversion, and the policy of prohibiting all reuse except for employment or holiday lets should be rescinded.

4. Question 3 Levels of Housing and Employment Provision

4.1. Housing Provision

4.1.1. This has been dealt with above, and I will not repeat earlier comments except to stress: I do not think 3,500 new dwellings over a 15 year period is anything like enough. Further, it is quite clear that policies CP2 and CP4 will not create sustainable or mixed communities in non-service villages. The overall impact of all these restrictive policies will be to force house prices further upwards, and to continue the trend of driving local people out of the villages and out of the district, and of making villages less sustainable.

4.1.2. An additional point needs to be made on affordability.

4.1.3. The present policy in villages is to insist that, if a developer wishes to build more than a certain number of houses (I believe 5 in villages), one of them must be affordable. This means that, if the developer applies for permission to build less than that number, he can get away with not building any affordable houses. In most villages, few developers will want to build affordable houses, and so they can simply apply for the minimum number and no affordable houses will be built. The answer is to make the numbers for each settlement cumulative, so that, e.g. if one developer builds 4 ordinary houses in a village, and another developer then applies for permission to build more houses, the first house the second developer builds must be an affordable one, and so on. It is suggested that a policy of this kind is more likely to achieve significant numbers of new affordable homes in no-service villages than the one advocated in the LDF.

4.2. Employment Provision

4.2.1. The points I would wish to address are mainly (iii) and (iv)

4.2.2. As regards (iii):

4.2.3. I have already dealt with the issue relating to holiday lets. These are classed as an employment use of land, but their form is, in general, residential, and, in environmental terms, they generate more traffic movement than residential development. In my view, farmers should be allowed to convert redundant farm buildings – particularly the old historic type – into residential units.

4.2.4. Current policies have little regard to the appropriateness of employment development to the settlement in which they are to be located. In rural Ryedale, the traditional employment use of land is generally connected with agriculture or equestrian businesses. So, people who live in villages would expect to put up with the smells and noise generated by local farms, but would not expect to have to put up with the kind of noise and smell and other adverse aspects which are generated by a business which has no connection with agriculture or horses. So, for example, in my own village of Great Habton, there is the Manor Farm site. This used to be within the village development limits, but was taken out of the village development limits by the current plan (as explained above). It is a site which is described by the current local plan as being “in the centre of the settlement”. The fact that it is now located outside the village development limits does not prevent its use for employment purposes. So, when the agricultural barn on the site became redundant, the owner applied for and obtained planning permission for B1 and B8 uses. The B8 use includes warehousing and storage, and this could include a haulage business – like the one just up the road, but well outside the village. A use such as this is totally inappropriate in a village like Great Habton which is, in essence, primarily residential, where there are a lot of young children. This is one of the reasons the Parish Council is determined that site should be allocated for residential development. Another example is the Manor Farm site in Old Malton. This is a site in a Conservation Area directly opposite the historic priory church. The farmyard, including all the farm buildings, has become redundant, but only part of the said farmyard is within the village development limits. The same principles have come into operation as apply to the Manor Farm site at Great Habton: the site cannot be developed in its entirety for residential purposes. So the developer has applied and obtained planning consent for offices and light industry. Again, the permission obtained is for development which is not appropriate for what is essentially a residential area within a Conservation Area.

4.3. It is therefore suggested that the LDF should make clear that employment uses within rural villages should be restricted to businesses which are either agricultural or equestrian or which support such businesses. It is suggested further that land for non-agricultural and non-equestrian businesses should be allocated either on existing or expanded industrial estates, or at appropriate locations at or near easy access to main roads.

4.4. It is appreciated that there are many tourist businesses in the countryside, and I take the view that these should be encouraged – particularly pubs and hotels in villages.

4.5. As regards village pubs, post offices, shops, churches, halls etc., it should be recognised that these cannot survive unless there is a core of local customers who will continue to support them outside the holiday seasons. Local pubs, in particular, tend to be the hub of the local community in villages, and it is important that they should be sustained by local customers. This is another reason why the “service villages” approach on its own is wrong for Ryedale. Village communities should be looked at within the context of the surrounding countryside and neighbouring villages to see if they can be treated as part of a group of villages. I believe this view is acknowledged by the emphasis placed by PPS7 on sustainability

4.6. Some villages within the group which are big (like Swinton) cannot accommodate very much more residential development (perhaps for highways or other reasons). In such circumstances it might be appropriate to look at some of the smaller villages within the same group to see if there is room for development there, which might contribute to the overall sustainability of all the village communities within the group.

4.7. So, for example, many village communities are concerned about keeping their local primary school. The local primary school will usually serve many more villages than just the village where it is situated. In such circumstances, it does not seem appropriate to say that the village with the school is to be classified exclusively as the “service village”, without also having regard to the other villages which are also served by the school. The same applies to all the local businesses which rely on the same group of villages.

4.8. Equestrian businesses.

4.8.1. The main equestrian business within the district is the numerous racing stables. Malton is known nationally as the “Newmarket of the North” and the racing industry here is very important for the local economy. It is a traditional industry, and, in so far as it concerns the breeding, nurture and training of animals, has much in common with agriculture. The racing industry provides considerable local employment, and horses trained in Ryedale are raced all over the country. So, it is a mistake to treat the racing business in Ryedale like just another leisure business, which is the impression one receives from reading the plan.

4.8.2. The racing industry is very close to agriculture in other respects. Race horses have to be continually exercised, and this is usually done on “gallops”, which are tracks (often surfaced with wood shavings or other material) that go round the outside of farm fields. The land inside the tracks is quite often owned by the racing stables and let out to local farmers.

4.8.3. In other words, there is very little to distinguish the traditional racing industry from farming in regards to the part it plays in conserving and managing the countryside. This should be recognised in the local plan, and the industry should be encouraged by giving consideration to extending to the racing community some of the benefits which national policy confers on agriculture.

4.8.4. This applies particularly to the provision of on-site accommodation in remote locations, where this is necessary not only for the accommodation of staff for security and management purposes, but also for the reception of visitors, clients and potential new clients, provided that this is done in a way which does not detract from the visual amenity of the general landscape, and is secured by suitable occupancy conditions.

4.8.5. Paragraph 32 of PPS 7 acknowledges that, “in some parts of the country, horse training and breeding businesses play an important economic role. Local planning authorities should set out in their LDDs their policies for supporting equine enterprises that maintain environmental quality and countryside character.” It would seem to me that there is insufficient detail in the LDF to satisfy this requirement, particularly bearing in mind the importance of the traditional racing industry to this “Newmarket of the North”.

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