Spelthorne Local Plan - Preferred Options Consultation: Policies and Site Allocations

Comment ID pol/489
Document Section Spelthorne Local Plan Preferred Options: policies Housing Policy H1: Homes for All View all on this section
Respondent Iceni Projects (Maddi Simpson) View all by this respondent
Response Date 21 Jan 2020

Housing Mix and Standards states that development proposals will be expected to contribute to meeting identified housing needs by providing a housing mix as set out in the Strategic Housing Market Assessment or any similar evidence for market and affordable units.

The Council wants to deliver a wide variety of high quality homes that provide all tenures, types and sizes of housing to meet the needs of the community. This approach is welcomed; although will not be achieved by imposing a Borough wide requirement on housing mix. It is crucial for the Council to incorporate more flexibility into this policy to allow the right types of housing to be delivered in suitable locations.

For example, there is a large requirement in the SHMA (2018) for flats which are appropriate in urban areas, but less so in suburban locations such as the Land East of Upper Halliford. Green Belt sites are often better suited to deliver family homes which is further reinforced by the character of the surrounding area of the site. Any subsequent policy will need to reflect this.

Specialist Accommodation section states that the provision of well-designed specialist forms of accommodation, including sheltered housing, care homes and other appropriate forms of accommodation for the elderly and those with particular needs, will be permitted provided that the development:

• Meets demonstrable established local community need;

• Is in a sustainable location, with access to appropriate services and facilities where these are not provided on site. This includes public transport, shops, local services, community facilities and social networks.

Whilst we support the principle of specialist and supported housing policy, we do not consider it goes far enough as currently drafted. The Council need to understand the level of need on a quantitative and qualitative basis for additional care home bed spaces. We urge the Council to assess both elements in their own SHMA to understand whether the existing standard of accommodation is fit for use going forward.

Furthermore, we consider it unnecessary to request that older person housing schemes should have to demonstrate need, whereas general market housing schemes do not. There is clear under delivery supply in the District and requiring this form of development to clear an additional hurdle will not help meet need.

We consider that allocating additional sites in the Local Plan should be considered. Traditional older person housing schemes struggle to compete with market housing for sites due to the longer-term nature of returns through an element of care and the additional common areas that this type of development seeks to deliver.

Duty to Cooperate & Statement of Common Ground

The Sustainability Appraisal Alternative Option 3 for Policy H1 was to make an upward adjustment to meet over and above Spelthorne’s housing need, as well as the need of neighbouring authorities by considering land not subject to an absolute constraint. The Council rejected this alternative as it is expected to have significant negative impacts on the environment and may result in unsustainable development.

Paragraph 26 of the NPPF (2019) states that local planning authorities are under a duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries. Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy.

Paragraph 60 states that any housing needs that cannot be met in neighbouring areas should also be taken into account in establishing the number of homes planned for. The Council have openly rejected this process and at present there is no evidence as to whether the Council has contemplated the unmet needs of neighbouring areas which will face scrutiny at examination.

As an example, Planning inspector Karen Baker wrote to Sevenoaks District Council last month, following the first stage of local plan examination hearings, concluding that the council had failed to carry out its duty to cooperate with neighbouring councils to find sites for new homes and flagging “significant concerns” about its soundness. She wrote:

“I am not satisfied, therefore, that the council has addressed this key strategic matter through effective joint working, but has rather deferred it to subsequent plan updates”

“a significant failure is the council’s duty to co-operate. Any failure of the duty to co-operate cannot be rectified during the examination and therefore the only option is for the report recommending nonadoption to be issued or for the plan to be withdrawn from examination”

In order to accord with national policy and avoid the Local Plan being found unsound at examination, we urge the Council to ensure it has carried out its duty to cooperate with neighbouring councils, preparing a Statement of Common Ground with neighbouring areas to establish what their level of unmet need is and how a proportion of the homes will be delivered in Spelthorne.

Proposed Change