NPPF Changes Consultation 2015
Increasing Residential Density Around Hubs
Do you agree with the Government’s definition of commuter hub? If not, what changes do you consider are required?
There is no size threshold set for a ‘commuter hub’ in the consultation document in terms of population size or number of dwellings. Our experience in Guildford borough is that planners will attempt to set local development criteria that force small communities to become large communities simply because they have frequent presence of inter-urban bus services passing through them and/or they contain a small rural station. These routes might be there due to public subsidy or historical accident.
We are concerned that rural ‘commuter hubs’ in the Green Belt surrounded by small rural communities based in the Green Belt encourage inward journeys by car to reach the transport interchange. This leads to rural congestion, inappropriate speeding on D class and unclassified roads and a reduction of safety for cyclists and pedestrians on such routes. Levels of automotive pollutants rise and threaten health of children and older adults in rural communities. If there is such a thing as ‘sustainable development’, this is not it.
Rail and bus service frequency in dispersed rural areas is not fixed as many depend on local authority subsidy. Train and bus operators can have their operations subsidised by local authorities to provide more frequent services at peak times. This should not be an opportunity for LPAs to manipulate the number and service frequency in order to claim a rural village with a number of rail and bus services qualifies as a ‘commuter hub’. Our experience in Guildford borough is that this was done in the creation of a now-debunked Settlement Hierarchy evidence document submitted at the commencement of the Local Plan process. Subsequent actions by Surrey County Council to reduce their budget is seeing bus route subsidies withdrawn and low use rural routes being withdrawn from rural settlements in the Green Belt that previously had the route presence and frequency used to inflate their suitability for development.
Railway stations in Green Belt villages used by local commuters do not make the village a ‘commuter hub’, made ripe for housing development by revision of Green Belt boundaries during the Local Plan process.
- We propose a viability test for rural rail and bus services emanating from a rural settlement that might be proposed by an LPA as a potential ‘commuter hub’. The viability test shall evaluate solely the routes of train and bus operators that operate without public subsidy. The evaluation shall be based on the number of passenger miles of those routes with a threshold set at an average of 50 passenger miles per user. Such routes, where average passenger miles per user fall below this threshold, shall be regarded as not contributing to a ‘commuter hub’ status.
- We propose the exclusion of routes that are sustained by public subsidy as they are effectively a social service and should not be considered in the evaluation of what forms a ‘commuter hub’.
- We propose the removal of any frequency of service test as this is easily manipulated through public subsidy of operators.
- We propose a test for rural settlements that might be proposed as ‘commuter hubs’ by LPAs based on either the number of residential dwellings or local population. We propose a starter threshold of 1,500 residential dwellings or a starter threshold of a population of 2,500 residents.
Do you have any further suggestions for proposals to support higher density development around commuter hubs through the planning system?
Higher densities are appropriate in large residential communities with sizeable commercial centres and frequent train services to a number of destinations. We are concerned that these hubs should not become just dormitory residential settlements. It may be appropriate to ensure the provision of retail and other services where none exist.
The fact that developers will pay no CIL towards infrastructure costs could lead to a low standard of amenities. It is essential to create not just housing but attractive, well balanced communities with a sense of place.
Do you agree that the Government should not introduce a minimum level of residential densities in national policy for areas around commuter hubs? If not, why not?
- We agree that it is not for the government to introduce density levels. We consider that it should be up to the local planning authority take account of special designations such as conservation areas. In Guildford, some rural stations abut or are located in the Green Belt and AONB and these designations will need to be taken into account when determining where growth is permitted.