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

Comment ID pol/505
Document Section Spelthorne Local Plan Preferred Options: policies Housing Policy H1: Homes for All View all on this section
Respondent Nexus Planning (Mr Steven Doel) View all by this respondent
Response Date 21 Jan 2020

Housing Need

Croudace Homes welcomes the fact that the provision of 603 homes per annum is expressed as a minimum, but we provide further detail on this matter in our response to Policy ST2.

Housing Mix and Standards

The Council makes it clear that development proposals will be expected to provide a mix of housing as set out in the Strategic Housing Market Assessment, or similar evidence for market and affordable units. Croudace Homes clearly supports the requirement for new residential developments to deliver a mix of housing types and sizes to meet current and future housing needs, having regard to the most up to date evidence. However, reference to ‘’Development Proposals’’ in that context implies that all new schemes should provide a SHMA compliant mix of units including smaller schemes below, for example, 10 units. This surely would not be realistic or desirable.

In any event, even on larger sites Croudace Homes considers that blanket compliance with the SHMA mix is overly specific and restrictive. In particular, the policy as worded does not allow for sufficient variation in mix across greenfield and urban sites or between settlements where a different mix may be required in response to local market demands. The characteristics and constraints of each site will also have a direct bearing on the most appropriate mix. For example a steeply sloping site might better lend itself to flatted development, at the expense of larger family homes.

If the desired mix of units is to be delivered across the Borough as a whole, there must be acknowledgement that the most appropriate mix will vary from site to site in response to local market conditions and the individual characteristics of each site. Some sites will deliver a higher proportion of smaller units, some a higher proportion of family dwellings.

Croudace Homes therefore believes that greater flexibility must be built into Policy H1 to reflect this reality by making it clear that the final mix will be agreed on a site by site basis having regard to the most up to date evidence on housing need and any evidence regarding local market conditions.

Space Standards

Criterion 5 Outlines that all new development across all tenures will be expected to meet the minimum space standards set out by MHCLG. However, it is important to note that the Government’s internal space standards are optional i.e. it is at the discretion of the local authority as to whether to set these additional technical requirements. In that regard, PPG (ID 56-002-20160519) is clear that before doing so: ‘’local planning authorities will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans’’.

There is no evidence available which demonstrates that the provision of new homes in the borough has fallen below the Government’s minimum space standards and that there is therefore a genuine need for the policy as set out.

Croudace Home has no objection to the proposal that studio developments which fall below the minimum space standards will be acceptable where they offer ‘’purpose built, innovative and unique accommodation to address a specific need in the community’’. However, it is unclear why this caveat has been applied to studio accommodation only. It is demonstrably the case that other types of accommodation can perform precisely the same role, in many instances more effectively than studio accommodation and should also be considered on their merits even where they fall below the prescribed national space standards.

Accessible Homes

Croudace Homes notes the requirement that all new build dwellings should comply with Building Regulations Part M4 (2) and that for larger schemes, at least 10% of dwellings should be built to Building Regulations Part M4 (3) ‘’unless it is unfeasible to do so’’. 

PPG (ID 56-007-20150327) is clear that local planning authorities should demonstrate a need for such policies but should take into account factors such as the likely future need for such housing, the size, location, type and quality of the dwellings needed, the accessibility of the existing housing stock, how needs vary across different housing tenures and the overall impact on viability.

Firstly, the necessary evidence for all new dwellings to meet Building Regulations Part M4 (2) has not yet been provided. Secondly, Croudace Homes considers that reference to development being ‘feasible’ is somewhat vague. The policy should make it clear that the stipulated percentage to meet Category M4 (3) will be required subject to overall viability.

Specialist Accommodation 

We note the requirement that all developments of 100 homes or more must provide an element of specialist accommodation ‘’unless it can be demonstrated that it is unfeasible to do so’’. Croudace Homes acknowledges that an element of flexibility is therefore provided so that provision can be considered on a site by site basis having regard to local provision and market conditions. However, as with accessible homes, we consider that reference to ‘’feasibility’’ is a vague term. The policy should be amended to make it clear that provision is subject to viability.

Self-Build and Custom House Building

We note that in addition to the requirements set out above, draft Policy H1 also expects schemes of 100 dwellings or more to provide 5% of the total homes as serviced plots for sale to custom builders ‘’whilst there is an identified need’’. It goes on to suggest that ‘’Higher density residential sites for development of flats are unsuitable for self-build and custom housebuilding plots’’ and they are therefore exempted from the requirement.

In the first instance neither the policy nor the supporting text provides a definition of ‘’higher density residential sites’’ or the proportion of flats that might render a site exempt from the self-build requirement. It could be assumed that only 100% flatted developments would meet that definition but the policy as worded is unclear.

More generally, PPG (ID 57-025-201760728) states that relevant authorities should consider how they can best support self-build and custom housebuilding in their area. This could include:  developing policies in their Local Plan for self-build and custom housebuilding;  using their own land if available and suitable for self-build and custom housebuilding and marketing it to those on the register;  engaging with landowners who own sites that are suitable for housing and encouraging them to consider self-build and custom housebuilding and facilitating access to those on the register where the landowner is interested; and  working with custom build developers to maximise opportunities for self-build and custom housebuilding. 

The Council’s Annual Monitoring Report 2018 outlines it has 47 individuals on the Self Build Register. The demand for serviced plots is therefore not particularly high and the Council should, in accordance with PPG, fully explore all other options for meeting this need before requiring a proportion of serviced plots on larger development sites. This should include the use of the Council’s own land as well as engaging with landowners as set out above.



Proposed Change