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Response Details

Response Details
From Whiteley Homes Trust (Chandra…
Date Started: 13 Mar 2017 09:16. Last modified: 13 Mar 2017 09:16
Status Complete
Response ID #528062

1

Agree that the challenges set out in section 2 of the consultation document are the key challenges facing Elmbridge?

 

  • Yes, I agree
  • No, I disagree
  • I don't Know

Please explain your answer
The Whiteley Homes Trust is grateful for the opportunity to respond to the Elmbridge Local Plan: Strategic Options Consultation.

Our response focuses exclusively on matters affecting older people, including those of limited financial means who are the Trust’s charitable beneficiaries. However, most of the issues we address apply to all people as they age, irrespective of their financial circumstances.

The Strategic Housing Market Assessment highlights the substantial expected increase in the number of older people and the proportion of the population that will be over age 65.

We accept that the challenges in section 2 are the key challenges facing Elmbridge, but feel that the central importance of housing in older people’s lives warrants greater emphasis. For older people, housing is about a lot more than just bricks and mortar; it is about every aspect of their health, happiness and longevity. The Council should actively encourage developers to build adaptable homes in suitable places, and remove barriers wherever possible.

Most retired people spend a lot of time at, or near, their homes, especially when their mobility declines. Older people want to be able to shop locally and engage in social activities locally, with friends and families. Many of them need access to public transport. They often worry about their safety, and anyone who does not own their home craves security of tenure.

Accommodation for older people should be both suitable for their current circumstances and adaptable for their future needs, which often include dementia. When they need care and support, they would generally prefer to receive it in their own homes rather than in a care home or nursing home. This enables them to live as independently as they can, and avoids institutionalising people unnecessarily. The hospice at home movement shows that high levels of care can be provided in people’s own homes. There is some evidence that doing so for older people can be cheaper for the NHS and social services, as well as very much better for the individuals concerned.

Public policy often considers housing in categories that reflect needs at different times in people’s lives: general needs housing, supported housing, extra care housing, care homes. This approach is reflected in paragraphs 4.20-4.23 of the consultation document. Relying on needs-related housing means that many older people have to move, sometimes more than once, despite being at a time of life when they are least able to adapt to new surroundings.

It is much better if people continue to live in their own homes and have them adapted to their changing needs. Housing for older people should be located and designed to support independent living. It needs to be flexible and adaptable, especially as mobility declines and technology offers increasing possibilities. This would be a people-centred approach, rather than a building-centric approach.

Suitable housing would bring other, strategic benefits to Elmbridge as well as the NHS and social services. If older people are attracted by the housing available to them, they are more likely to move at an earlier stage in life. They are more likely to settle down well, bringing social and health benefits. And they are more likely to vacate larger properties that are suitable for growing families.

This is the philosophy adopted by the Whiteley Homes Trust. Research by the Cass Business School shows that people who have moved to Whiteley Village in the last 100 years have lived longer on average than they would have done outside. We now have two planning applications awaiting decision that will enable us to provide high levels of care to people in their own homes by harnessing the power of the community and exploiting technology to the full.

We would also identify one further challenge, acknowledging the charity’s specific interests. By its nature, a local authority’s planning function tends to adopt a regulatory approach rather than an enabling approach. This need not always be the case.

Elmbridge should adopt a proactive and joined-up approach to significant planning applications that will help it meet its challenging housing targets. This means encouraging developers of housing for older people to follow the strategic approach described above, and actively helping them to achieve it. Doing so would require a culture change and be a major challenge for the planning processes.

The Whiteley Homes Trust is a charity established over 100 years ago. We provide nearly a quarter of sheltered housing in Elmbridge and are keen to use our assets to help more, poor older people.

We have a Conservation Area Appraisal and Management Plan agreed with the Council, which identifies areas suitable for infill development. We have worked with the Prince’s Foundation for Building Community to ensure we preserve the unique heritage of our Village. We paid for the platinum pre-application service.

Yet it remains very difficult, and very expensive, even for an organisation such as ours to navigate its way through the planning process. We would hope that our efforts would be strongly supported and encouraged by Elmbridge, and we would greatly welcome the chance to work more collaboratively with the Council to pursue our mutually-beneficial agenda.

2

Do you consider there are other challenges that we should be addressing?

 

  • Yes
  • No
  • Don’t know

Please explain your answer
«No response»

3

Do you consider any particular challenge or challenges that are more important than the others?

  • Yes
  • No
  • Don’t know

Please explain your answer
Older people’s housing needs are particularly challenging. For detail, please see response to question 1.

4

Agree that Option 2 is the most appropriate option?

  • Yes, I agree
  • No, I disagree
  • I don’t know

If you disagree, please explain why and what other option would you support and why?
We fully understand the pressures on the Council and the conflicts it must reconcile. We accept that strategic option 2 is the most appropriate option. In doing so we have two significant comments:

1. Planning for housing for older people should take a strategic, people-centred approach to their changing needs. Homes should be located to encourage residents and communities to be active, enable the NHS and care providers to operate efficiently, and designed to be inherently adaptable.

2. The Council rightly notes that not all green belt is of the same quality. This can equally apply to small tracts of land within the green belt which would be appropriate for development. It would be helpful to set out criteria by which these could be assessed. For example, Whiteley Village is in green belt land assessed as being moderately performing, yet much of it is poor quality land that is not used by the public. In the summer, dry fern on scrub land can even be a fire hazard. Such land should be re-designated because it could be developed without contravening the spirit of the national green belt policy.

5

Do you consider the suggested exceptional circumstances are sufficient to support the amendment of the Green Belt boundary?

 

  • Yes
  • No
  • Don’t know

Please explain your answer
Please see answer to Question 4.

Areas which are currently ‘moderately’ performing in Green Belt terms may also offer exceptional circumstances that would support an amendment to their Green Belt boundary, particularly where this would meet the identified needs of the Borough.

6

Agree that, given the appropriate exceptional circumstances, these three key strategic areas are appropriate for removal from the Green Belt?

 

  • Yes, I agree
  • No, I disagree
  • I don’t know

Please explain your answer
«No response»

7

Do you know of any sites within any of the three key strategic areas that could be considered for future development?

 

  • Yes
  • No

Please explain your answer
«No response»

8

Do you consider that other areas of land should be removed from the Green Belt including those that are moderately or strongly performing?

 

  • Yes
  • No
  • Don’t know

Please explain your answer
See answer to Question 4.

We consider that the approach to the Green Belt (Option 2) should be amended to support development in the Borough within carefully selected areas that are ’moderately’ performing where exceptional circumstances exist.

The requirements for demonstrating exceptional circumstances are not defined in national policy, but are unique to each locality. The draft Local Plan is not specific in what would be considered exceptional circumstances. Given the overwhelming evidence of the need to providing housing for the ageing population, we consider this should be attributed significant weight as a specific reason for flexibility under Option 2.

We would welcome the proposed review of core strategies, especially policy CS6 Whiteley Village. Through planning policy, the Council has supported the ethos of the village and the evolving needs of its residents, older people of limited means.

Land surrounding Whiteley Village (area 39) is currently identified as ‘moderately’ performing within the Green Belt. Current plans seek to use previously agreed infill sites. We feel that there is scope to identify more sites that are poorly performing in green belt terms that could be used to meet future housing priorities. This would help to provide flexibility and strategic direction for long term management of development at Whiteley Village.

9

Do you agree that we should seek to provide more of a balance in terms of the size of new homes being built?  

 

  • Yes, I agree
  • No, I disagree
  • Don’t know

Please explain your answer
We suggest that the challenge of providing homes for the older people is specifically reflected in the Council’s policy. Most homes built for older people are 1 or 2 bed units and should be differentiated from the general market homes requirement.

10

Given the over delivery of homes with 4 or more bedrooms should we try to limit their delivery in future?

  • Yes
  • No
  • Don’t know

Please explain your answer
«No response»

11

Should we seek to increase minimum densities at sustainable locations in the urban areas, such as in town centres and at train stations, above 40 dwellings per hectare, where this would not impact on local character?

  • Yes (If yes, what density do you think would be appropriate?)
  • No
  • Don’t know

Please explain your answer
N/A

12a

Within the three key strategic areas we will be exploring opportunities for accommodating our development needs taking into account site constraints, land ownership, compliance with other planning policies and the need to support sustainable development.  If potential housing sites are identified within these areas, do you consider it appropriate to

a. deliver at higher densities i.e. above 40 dwellings per hectare, in order to maximise delivery?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

12b

Within the three key strategic areas we will be exploring opportunities for accommodating our development needs taking into account site constraints, land ownership, compliance with other planning policies and the need to support sustainable development.  If potential housing sites are identified within these areas, do you consider it appropriate to:

b. Support lower density developments that maintain the open character of an area and reflects the surrounding character

 

 

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

13

Agree with our approach to continue to apply Policy CS21 of the Core Strategy e.g. consider on a case by case basis whether local circumstances are sufficient to warrant the requirement of affordable housing contributions on all sites where there is a net increase in housing and where it is viable?

 

  • Yes, I agree
  • No, I disagree
  • I don't know

Please explain your answer
«No response»

14

Are there any other aspects of Government policy which you think we should consider with regard to meeting the accommodation needs of non-travelling Travellers?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

15

Do you consider there to be any other specific housing needs that are an issue within Elmbridge and that we should seek to address as part of the new Local Plan?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
See answer to Question 1.

Providing suitable housing for older people should be a major focus for housing policy and included as one of the Borough’s key challenges for the next plan period. Planning Practice Guidance (PPG) describes the need to provide housing for older people as ‘critical’.
The predicted population growth of persons aged 65 and older living in Elmbridge will be over 13,600 between 2015 and 2032.

In light of the above, we welcome the specific focus on older people in paragraphs 4.20-4.22 of the consultation paper. However, we caution against the inherent assumption that people should move when they need higher levels of care, which is likely to be the case for many residents of sheltered housing. Similarly, all homes for older people should be accessible by design (paragraph 4.23). A segmented approach will feel increasingly dated as technology develops, for example introducing robotics into care. It is better to build accommodation which can be easily adapted to individuals’ needs and where care can be brought to them economically.

Whiteley Village is already adopting a philosophy of designing adaptable, technically advanced homes and taking care to people, rather than people to care homes. In the right circumstances, it could play a critical role in assisting Elmbridge Borough to meet its identified need for suitable accommodation for older people.

16

Do you agree that the Council should seek to protect our most important and strategic employment areas from redevelopment to uses other than offices, warehousing and factories?

 

  • Yes, I agree
  • No, I disagree
  • I don't know

Please explain your answer
N/A

17

If not, what degree of flexibility do you consider would be appropriate with regard to alternative uses in such areas?

N/A

18

Do you think that there are any exceptional circumstances that would support the amendment of the Green Belt boundary at Brooklands to support the further development of employment uses at this site?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

19

Other than Green Belt what other barriers do you consider could prevent further development at Brooklands?

N/A

20

We will seek to maintain our broad support for tourism related development as set out in the Core Strategy. However, to recognise the importance of Sandown Park Racecourse as both a sporting and exhibition venue should we:

Encourage the redevelopment of Sandown Racecourse to provide improved and extended conference and hotel facilities?

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

21a

Maintain our policy of focussing new retail development to town and village centres?

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

21b

Continue to protect primary shopping areas from other uses as set out in the current Core Strategy?

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

21c

Consider allowing other important uses in primary high street shopping frontages such as doctor’s surgeries, dentists and libraries?

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

22

Should the Council continue to give a high level of protection to all open spaces and designate those spaces that meet the criteria for Local Green Spaces?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

23

Do you agree with our approach to biodiversity and mitigating the impact of new development on the Thames Basin Heaths habitat?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
While we support the protection of the SPA, we consider that the approach to providing SANGs and assessing the impact on the SPA within the 5km buffer zone should be carefully considered. The current SANG guidance is centred on the provision for residential development. We would suggest that this guidance is assessed against an appropriate evidence base to consider different types of development, particularly those within C2 use classes. The current guidance should not be applied generically to all development as it does not reflect the specific circumstances of proposed sites.

An example of this is the recent development proposals at Whiteley Village, where new residents are extremely unlikely to cause recreational pressures on the SPA due to the extensive services and facilities on offer and fact that residents will be of lower average mobility than the general population. Applying assessments generically can unreasonably deter organisations that would otherwise contribute to the Council achieving its targets.

24

Do you agree that our strategic and pro-active approach to supporting our heritage assets is appropriate?

  • Yes, I agree
  • No, I disagree
  • I don't know

Please explain your answer
We support a proactive approach towards the Borough’s heritage assets. In particular, we note that there is often potential to allow re-development to support the long-term protection of the asset and its key features. This potential should be emphasised in the emerging plan; development proposals can enhance historic assets and can provide wider material benefits.

At the same time, it should be recognised that protecting heritage assets comes at a substantial cost. In 2015 Whiteley completed a ten-year refurbishment project for over 250 listed cottages at a cost of £33 million. Its current development proposals will cost about £50 million. Both figures are substantially higher than they could have been because of our strong wish to preserve the Village’s heritage and ambience.

However, money spent on heritage cannot be spent on the charity’s beneficiaries. This is another reason why a collaborative approach to planning between the Council and developers is in everyone’s interests, to ensure that the costs of preserving our heritage are kept to a reasonable level.

25

If not, what approach do you think we should take?

As above.

26

Do you agree that the Council’s current approach to considering design and character is appropriate?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

27

If not what approach do you think we should take?

While we agree with the Council’s general approach to design and character, we consider that reference should be made to the need to ensure good design inside the home, particularly when designing for older people.

Please see answer to Question 1 for an explanation of older people’s needs and priorities.

We consider these issues to be particularly relevant given the ever-increasing need for accommodation for older people. This should be recognised in design related policy and allowance made for flexibility in house type design which, for older persons’ housing, needs to be able to adapt over time to meet changing needs

28

Should we look at including a policy providing more detailed advice on what is required to limit the cumulative impact of small scale development on flood risk?

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

29

Do you consider the existing policies seeking to reduce the impacts of new development with regard to delivering more sustainable travel patterns outlined above are still appropriate?

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

30

Are there other approaches we should consider?

  • Yes
  • No
  • Don't Know

Please explain your answer
N/A

31

What do you consider to be the essential infrastructure items required to support new communities e.g. the potential development of the 3 key strategic areas?

N/A

32

What smaller infrastructure improvements do you think could be made within your local area to address some of the negative impacts arising from new development?

N/A

33

We recognise that there may be other issues or options we have not considered that you would like to raise. If there are we would like to hear these and consider them as part for this consultation. Please use this space to write anything else you would like us to consider.

 

The consultation document suggests that a number of existing Core Strategy policies will be reviewed through the next stage (Regulation 18) of consultation in the Council’s ‘Preferred Strategic Approach and Policies’. We welcome the opportunity to engage at that stage but offer the following comments on the specific policies to be reviewed:
CS6
For individual settlement area policies, such as CS6 (Whiteley Village), it is suggested that the Council is minded to continue with this approach within the new Local Plan setting out a vision for each settlement area. It suggests that these policies will be locally distinctive, identifying the strengths, weaknesses, opportunities and threats to the areas. Their accompanying maps will be updated to identify the broad location of any new development opportunities and any improvement schemes that are set to take place.
Policy CS6 currently supports the development of the village and, specifically, the provision of housing for the elderly, especially those of limited means. The policy recognises the unique circumstances of the Village and the role of supporting the needs of older people within the wider community, as well as the concept and wishes of the Founder, William Whiteley.
We support retaining an individual settlement policy for delivering accommodation to meet the changing needs of the village and demographic of the population. We also support updating maps which identify the broad location of any new development opportunities.
We welcome the opportunity to meet with Council officers to assist in the formulation of a new settlement area policy for Whiteley Village. This would need to take account of the increasing funding pressures faced by the Whiteley Homes Trust, a registered charity. Any new policy should recognise that flexibility will be needed to create funding streams for new development for its beneficiaries (poor, older people). The Trust must develop innovatively to ensure that modern and fit-for-purpose homes and facilitates can be provided while still respecting the prime purpose and heritage of the village.



CS20
Policy CS20 (Older People), supports the development of specialist accommodation for older people. It also says the Council will support Whiteley Village.
We consider that this policy should be brought up to date to reflect the changing philosophy for older people’s housing explained in our answers to Question 1 and 27.

34. Files

«No files»