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Response Details

Response Details
From Deleted User
Agent Deleted User
Date Started: 21 Mar 2017 09:42. Last modified: 21 Mar 2017 09:42
Status Complete
Response ID #529691

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 National Planning Policy Framework (NPPF) provides the Government's guidance on Local Plans and details that they must be prepared with the objective of contributing to the achievement of sustainable development. To this end, they should be consistent with the principles and policies set out in the Framework, including the delivery of a wide choice of high quality homes, to create sustainable/ inclusive and mixed communities. To help achieve this, the NPPF (para 50) requires LPAs to, inter alia:

• Plan for a mix of housing based upon current and future demographic trends, market trends and the needs of different groups in the community (such as, but limited to, families with children, older people, people with disabilities/ ...
(Underlining my emphasis)

LPAs should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development and net gains across all three. Early and meaningful engagement and collaboration with neighbourhoods/ local organisations and businesses is essential. A wide section of the community should be proactively engaged so that Local Plans 1 as far as possible, reflect a collective vision and set of agreed priorities for the sustainable development of the area.

Crucially Local Plans should plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of the Framework. This should be undertaken using robust and up-to-date evidence about the economic, social and environmental characteristics and prospects of the area.

Para 182 of the Framework requires that at a stage whereby the Local Plan will be examined by an independent Inspector, the submitted Plan ought to be considered 'sound' namely that it is:

• Positively prepared- the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

• Justified- the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

• Effective- the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

• Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

Our following comments have been prepared with regard the above tests of soundness.

2. Regulation 18 - Local Plan

The production of the ELP comprising policies aimed at meeting the identified needs for the Borough is supported in principle, however there are objections to certain areas of the Plan and these are addressed as follows.

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
«No response»

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?
«No response»

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
«No response»

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
«No response»

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
«No response»

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
«No response»

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
«No response»

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
«No response»

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
«No response»

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
Para 021 of the National Planning Practice Guidance (NPPG) confirms that the need to provide housing for older people is critical given the projected increase in the number of households aged 65 and over and which accounts for over half of new households. The ELP sets out the objectively assessed housing needs (OAN) for the Borough as being 9,480 units during the period 2015 - 2035; i.e. 474 dwellings per annum (dpa) and which amounts to an uplift of in the region of 250dpa on the target set out in the 2011 Core Strategy.

The Strategic Housing Market Assessment (SHMA - 2016) confirms the population of older people
{65+) in the Borough as being approximately 26,000 in 2014, and this is expected to increase by
13,600 (52%) by 2032. The need for accommodation for older people is stated as being 1,336
dwellings (2015 - 2035, pp. 38 ELP), however this is not considered sufficient to meet the likely addition 10,000 new households over the age of 65, forming in the next 20 years, as indicated in the SHMA. The ELP needs to address this need.

It is clear that the Council faces great challenges going forward in terms of meeting its needs and in particular for older persons housing. In this context, the ELP will have to positively plan for housing and older persons housing to ensure an "effective" strategy based on appropriate evidence is delivered in accordance with the NPPF (para 182).

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
«No response»

17

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

«No response»

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
«No response»

19

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

«No response»

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
«No response»

21a

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

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

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
«No response»

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
From experience, Pegasuslife often finds that development sites within town centres are most appropriate for older persons housing in allowing for nearby access to shops and other services. Accordingly, redevelopment of employment and commercial land can often make a valuable contribution towards older person's housing.

The Council's Authority Monitoring Report (November 2016) sets out the recent position regarding employment land in the Borough and this confirms as of 01 June 2016, there was a total of 98,555 sq. m of vacant commercial floorspace, of which 37,133 sq. m comprises vacant office (B1a) floorspace. The table below demonstrates the extent of vacant commercial floorspace in the Borough:

Table 1: Vacant floorspace as of 01 June 2016
Vacant floorspace sq.m: B1a = 37,133; B2 = 22,2552; B8 = 19,623; A1 = 12,889
% of total floorspace: B1a = 38%; B2 = 23%; B8 = 20%; A1 = 13%
Source: 2015/16 AMR

The ELP confirms that there is demand to fill an additional 30,000 - 40,000 sq. m of office floorspace and 20,000 - 30,000 sq. m of warehousing, assumed to be up to 2035. The Council's Land Availability Assessment (LAA - 2016) indicates that there is scope to develop much of this as new build amounting to 20,000 sq. m for offices and warehousing (10,000 sq. m each) proposed to be carried out through redevelopment and intensification of existing Strategic Employment Land (SEL). The LAA (Section 4) indicates the following SEL as having potential to accommodate this:

a) The Heights, Weybridge;
b) Hersham Technology Park; and c) Molesey Industrial Estate.

This position regarding employment floorspace in the Borough is therefore summarised below:

Table 2: Employment floorspace position up to 2035
a. Total Additional Demand: Office 30 - 40,000 sqm. Warehousing 20 - 30,000 sqm.
b. Delivered as New Build at The Heights, Hersham and Molesey: Office 10,000 sqm and Warehousing 10,000 sqm
c. Remaining Demand (a-b): Office 20 - 30,000 sqm and Warehousing 10 - 20,000 sqm.
d. Existing vacancy (table 1): Office 37,133 Warehousing 42,175 sqm (B2 + B8).
e. Spare Capacity: (d-c): Office 7,133 - 17,133 sqm Warehousing 22,175 - 32,175 sqm

The table above demonstrates surpluses of employment land going forward of 7,133- 17,133 sqm of office floorspace, and 22,175 - 32,175 sqm for warehousing. It is considered that future planning policies should afford flexibility for employment land to come forward for alternative uses in view of the surplus demonstrated above and also in light of the uplift in housing needs prevailing in the Borough.

Contrary to this, the ELP (Para 4.28) suggests the importance and retention of SEL designations where the policy is for uses to be restricted to offices, warehousing and industrial and that alternative uses including residential and retail will be resisted. The ELP goes on to refer that the principle of Policy CS23 (Employment Land Provision) of the Core Strategy will be retained and that specific areas to be designated as SEL will be considered as part of the next stage of the Local Plan. These steps are not considered to be justified with appropriate evidence and particularly having regard to the surplus of employment land identified above.

In terms of SEL, it is unclear as to why such areas form this designation and what the importance of this is, i.e. what makes SEL unique from other employment land? SEL were introduced under Policy ELE9 of the Replacement Elmbridge Borough Local Plan (2000) and this planning "designation" appears to be based solely on the size of such employment areas being over 1 hectare as referred to in the supporting text to the policy.

The SEL designation was subsequently carried over into the Core Strategy (as referenced at Policy CS23), notwithstanding the note at Appendix 4 which refers to the replacement of Policy ELE9 with CS23. The current Development Plan does not contain any narrative as to status of SEL or reason justifying the allocation. The only references to SEL are the annotated areas on the Council's policy map and at Policy CS23 (Core Strategy), which seeks their retention without expressing their current status or reason for being.

In view of the above, it is considered that the Council should review both the function and purpose of SEL (through an Employment Land Review) and weigh this against the current surplus of employment land and the uplift in need for housing. Such an exercise should occur in order to justify policies concerning employment land and in this context, the Council's current stance is considered to be premature, ineffective and unjustified in the light of the NPPF.

The Council's proposed policy is not considered to enable flexibility in terms of the relative need for different land uses on employment sites as advocated by the NPPF (para 22). Such policy is also considered to go against the spirit of the Government's agenda of seeking to solve the housing shortage in the UK, and one such measure was the introduction in 2013 of temporary Permitted Development Rights for change of use from office to residential - made permanent in 2016.

Moreover, the ELP contains three broad options for growth and two of which, including the Council's "preferred option", comprise development in the Green Belt. The NPPF states that Green Belt boundaries should only be altered in exceptional circumstances (para 83). Unmet housing need on its own would not constitute exceptional circumstances, as acknowledged in the ELP (page 19). The Council has therefore put forward 3No. exceptional circumstances for seeking to alter the Green Belt boundary as the following (para 3.15):

• One of the worst levels of affordability in the country coupled with an under supply of affordable homes;
• Need to deliver a better mix of new housing away from current delivery focussed on houses of
four or more bedrooms; and
• The land that is being kept open for the purposes of Green Belt is no longer meeting those purposes.

Development within the Green Belt may be required to provide a growth strategy capable of delivering the Council's full identified housing need; however such options could potentially be resisted in terms of the functions of the Green Belt as set out in paragraph 82 of the NPPF. SEL and previously developed land offers the opportunity to provide new residential development to meet the local need as identified within points 1 and 2 of paragraph 3.15 of the ELP and therefore should also be considered an appropriate location for such development. Furthermore, development sites within town centres can be more appropriate for older persons housing as they allow for easy access to nearby services and facilities without the need to rely on the private car. As such, land released from the Green Belt may be a less suitable and sustainable location for older persons housing.

Therefore, it is considered prudent that flexibility is afforded in terms of developing sites within the built up area of settlements including previously developed and employment sites so that the plan can deliver an effective strategy in accordance with the NPPF (Para 182) and minimising the land required for Green Belt release.

It is considered that the Council needs to demonstrate that the Local Plan is being "positively" prepared and is "justified" and "accords with National policy". It is considered that the next stage of the Local Plan should specifically seek to address the need for housing for older people, plus enabling the flexibility for town centre and other sites to come forward to meet such needs.

The Local Plan also needs to be "justified" against the most up-to-date evidence base and it is advised that further work is undertaken in order to seek to establish the purpose and function of existing employment sites. This will then provide justification by which housing and employment policies going forward can be based on.

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
«No response»

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
«No response»

25

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

«No response»

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?

«No response»

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
«No response»

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
«No response»

30

Are there other approaches we should consider?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

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?

«No response»

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?

«No response»

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.

 

These representations have been prepared on behalf of our Client, Pegasuslife, in respect of the Elmbridge Local Plan (ELP). Pegasuslife provides high quality housing for older people throughout the UK, and often develop sites that are principally situated in town centres and served by good transport links. Pegasuslife has development interests across the UK, including the South East and the Borough area. By way of a few examples, sites in the south-east currently being developed by our Client include inter alia, Purley, Hampstead Heath, Seaford and Harpenden.

34. Files

«No files»