Our response to Roch Gate planning application

Following our post alerting you that the privately owned land (formerly Roch Gate Motel) was being considered for planning permission to house 18, 2 bed properties, we were asked to submit a response as a Community Land Trust to the planning application.

Our formal response submitted on 4th May 2020 read as follows:

Attn Matthew Griffiths
National Park Offices
Llanion Park
Pembroke Dock
SA72 6DY

Dear Mr Griffiths

Ref: Planning Application NP/20/0155/FUL

Before responding to the specifics of this planning application we would like to introduce our organisation and explain its principles, in order for you to understand the basis for our comments.

Nolton and Roch Community Land Trust (CLT) has recently been formed to help create affordable homes for people with strong local connections. Our first step has been to conduct an extensive local housing survey to understand exactly what is needed. Next we plan to engage with local landowners to identify potential sites that could be developed to meet those needs.

To minimise costs we expect to obtain land at below commercial market rate and, to ensure that local people always have priority, the freehold of the property will remain with Nolton and Roch CLT. If houses are intended for purchase then a suitable covenant will be obtained to ensure local priority and affordability when the house is subsequently sold on. Importantly, we wish to create housing developments that contain a mix of house sizes and designs, are properly integrated into our community, incorporate a proportionate degree of amenity space and comprise energy-efficient homes built to a high, eco-friendly standard.

A person’s home is the single most important factor contributing to their well-being. By making a strong contribution to the design, layout, density and surroundings of the buildings and by defining the criteria against which houses are allocated, our CLT will ensure that the costs and complications of maintenance will be minimised and that the property will be reserved for local people in perpetuity. Crucially, the homes we build will be enjoyed and valued by their occupants for generations.

The housing development proposed in this Planning Application, whilst appealing to the affordability element of our objectives, falls short in several other respects.

1. There is no evidence presented that Nolton and Roch Community requires 18 No. 2-bedroomed houses for purchase. The CLT housing survey, conducted over the last 5 weeks, reveals that most respondents require 3 or more bedrooms. Of 40 respondents wanting affordable housing, only 10 people seek 2-bedroom homes. And there are more, as the survey uncovers the ‘hidden’ housing needs of locally-connected families living away. Such homes present difficulties for growing families especially those having children of different sex. The biggest demand is for self-build (or self-finish) houses. The Planning Policy for Wales1 recommends that “New Housing developments … should incorporate … house types, tenures and sizes to cater for the range of identified housing needs and contribute to the development of sustainable and cohesive communities”.

2. It is noted that the Pre-planning Public responses include a statement that:
“a policy can be provided (albeit with some flexibility included) to ensure that there is some prioritisation to address local needs.”
This is hardly a strong measure of engagement with the community and gives little confidence that local needs will be seriously addressed. There has been no opportunity for the CLT to participate in the design or specification of the properties proposed.

3. No provision is made to incorporate eco-friendly design principles e.g. using local, renewable materials and Modern Methods of Construction (MMC) as proposed in the Welsh Government Strategy for Affordable Housing2.

4. No provision is made to incorporate renewable energy to help minimise running costs, reduce carbon emissions and embrace government green energy objectives3.

5. No provision has been made for any community/amenity space.

6. Environmental Sustainability is mentioned:
“… energy and water efficient technologies and segregated recyclable waste will be explored throughout the detail design stage”, but this is vague and needs to be more specific. The CLT wishes to see affordable housing developed that is eco-friendly and embraces modern, energy efficient technologies.

7. The developer claims the houses will be affordable i.e. a price 30% below market rate and suggests £130k per house. Can this price can be guaranteed? What happens if the price escalates to beyond local affordability? Will there be restrictions in place to prevent the houses being sold to non-local residents and/or at inflated prices? If so, who writes them and how will they be policed?

8. One of the requirements for Exception site status when permitting the construction of affordable housing is that the land will be acquired at below market rate – to assist in reducing the overall cost of the completed property, i.e. enabling good quality housing to be “affordable” without having to compromise on space or design standards. The site in question was not purchased under such a scheme and doesn’t benefit from the purchase cost constraints that go with it. This might explain why the proposed houses in this development are designed to a minimal space standard with little consideration to the factors addressed in 3, 4, 5, and 6 above.
The smallest plot (No. 8) has a garden area of just 30 sqm. Though claiming to be comparable with housing elsewhere in Roch, the gardens are half the size of those in St Brides view. Also, a mere glance at the site plan (provided in this application) suggests that plot sizes in the recent affordable housing development of Ocean Drive, are very much larger than those being proposed for the motel site.

Virtually all other housing in Roch occupies considerably larger plots.

9. It is proposed that onward sale of the properties will be constrained by a covenant. It is important to know exactly what those constraints will be.

10. The same developers previously obtained planning permission for a motel to be built on the same site. Having obtained planning permission they then sought to sell on the site for others to construct the buildings. This strategy failed and the ghastly, decaying eyesore was left to deteriorate even further for another five years. Is there any guarantee that the same fate would not occur to this planning proposal, should it be granted?

11. The motel site sits at the entrance to Pembrokeshire Coast National Park. Any development here needs to set a good example of quality building design that looks good, enhances community spirit and promotes its occupants’ well-being. The last thing we want is for local people to feel there is no other choice but to settle for uninspiring, cramped and inefficient houses that incur high running costs. We want to create a sustainable and cohesive community.

12. There is no provision for a pedestrian crossing over the Nolton road and the drawings don’t show the new pavement that is mentioned in the consultation response.

In conclusion, The CLT objectives for affordable housing in Nolton and Roch are:

1. to ensure that any houses built are designed to modern, high standards and will meet all current and advisory affordable housing requirements, and

2. the houses are designed and built to meet actual, local housing needs, and future occupancy will always give priority to local people, and

3. any new development should be properly integrated in and embraced by the local community, and it should enhance the well-being of its residents.

This proposal fails on all counts. It appears to be a commercial development dressed up to look like affordable housing and cannot be supported by Nolton and Roch CLT in its present form.

Kind regards…

Tony Pasternak,
Nolton and Roch CLT Secretary