Housing distribution in
“Second Deposit Draft” Plan
(published December 2002)
Housing distribution in
Strategic allocationTotalCapacity AllocationStrategic AllocationTotal
|Epsom & Ewell|
|Reigate & Banstead|
|Policy||Waverley Borough Council’s comments on the Structure Plan Second Deposit Draft||Changes suggested by Waverley BC||Surrey County Council’s response to Waverley’s comments|
|LO1 - The Location of Development||There is no clear link between the sustainability objectives set out in the introductory chapter and the policies themselves. It would be beneficial if a ‘keynote’ sustainability were introduced establishing a firm sustainable foundation.||Add an additional paragraph at the beginning of LO1: “Planning authorities will seek to maintain and improve the quality of life within Surrey without compromising the ability of future generations to meet their own needs and to provide for homes, jobs, infrastructure and services without undermining the value of the built and natural environment.”||Disagree. The suggested change is unnecessary. The introductory chapter and diagram on page 11 refers to the way in which the Structure Plan relates, as a whole, to the objectives of sustainable development.|
No change to Plan.
|LO1||There is no clear indication in the document that policies themselves have been subject to an Environmental Appraisal.||Undertake an Environmental Appraisal of the Plan to assess its environmental impact.||A Sustainability Appraisal has been carried out and was published alongside the draft Structure Plan. The Sustainability Appraisal included environmental objectives as well as economic and social objectives.|
No change to Plan.
|LO4 – The Metropolitan Green Belt and |
LO5 – The Countryside
|These policies remain confusing and are likely to create serious problems in implementation.||a) Include 2 distinct policies in the Structure Plan, one for Green Belt with its genesis in PPG2 (with specific reference to Major Developed Sites) and one for countryside beyond the Green Belt with its genesis in PPG7|
b) The policies should ensure that reference to re-use and adaptation of buildings both in the Green Belt and in the Countryside Beyond the GB should require that the building to be retained is capable of retention/re-use without substantial reconstruction or enlargement.
|Disagree. This implies that the Metropolitan Green Belt is not countryside whereas PPG7 advice should relate to all countryside with additional measures applicable if that countryside is also designated as Green Belt.|
Reference to the nature of existing buildings is a detailed matter covered in Local Plan policies.
No change to Plan.
|DN9 – General Aviation||a) Supplementary Planning Guidance to be prepared by Waverley Borough Council will deal with the question of the future of Dunsfold Aerodrome, including flying activity. |
b) Paragraph 4.28 of Policy DN9 of the Structure Plan implies that flying activities of the aerodrome are a discreet use, whereas they are ancillary to the use of the aerodrome for the “assembly, repair and flight testing of aircraft”.
|As the Structure Plan gives an inaccurate indication of the true position regarding activities at Dunsfold Aerodrome and as the future of the aerodrome, including any potential flying activities will be fully covered in the SPG, it is felt that the specific and positive references to re-using the site for light aviation should be omitted from both Policy DN9 and the accompanying text.||Disagree. The policy reflects the County Council’s view on what is considered to be the most suitable use for the site.|
Accept that the granting of planning permission for light aviation would require a change of use from the current sui generis use applicable to the site, which is for the assembly, repair and flight testing of aircraft, as granted in April 2002.
Although some impact on local populations is likely to be inevitable, the aerodrome is one of the remotest large sites in Surrey. Therefore the numbers of people affected would be relatively small. In addition, planning conditions to control the nature and type of flying would limit the impact on surrounding areas.
The use of Dunsfold for light aviation would comply with Govt. guidance in PPG13. This advises that local authorities should, where appropriate, protect disused sites which could help to enhance aviation infrastructure serving the regional and local area.
The Govt. has stated that business aviation may become squeezed out of major airports, as capacity constraints cause these airports to focus on more valuable commercial traffic. As business traffic is forced to relocate to general aviation fields, this in turn is likely to have a knock-on effect for light aviation, which may be squeezed out of general aviation airfields. Dunsfold aerodrome could therefore provide a vital role in providing for the light aviation community in future.
No change to Plan.
|Policy and Reference||Waverley Borough Council comments on Pre-EIP Changes||Suggested changes|
|LO8 (3) Managing Housing Provision||In Surrey a strong housing market means that historically development has exceeded planned provision. The Structure Plan contains a mechanism to withhold large sites from development until such time as they are needed to meet strategic housing requirements. This has for many years applied to sites over 0.4 hectares. |
The Pre-EiP changes now state that this approach applies not only to “large” sites over 0.4 hectares, but also to “medium” sites for “10 or more dwellings” on sites of less than 0.4 hectares.
Introducing the “medium” sites category into this policy will create practical problems with its implementation. The criteria for deciding when a site should be withheld from development should be based on site size, rather than the number of dwellings a developer proposes for a site.
Contrary to a key objective of the Plan to make the best use of land, this policy could discourage developers from making the best use of medium sites. For example, a site of 0.3 ha could be capable of accommodating more than 9 dwellings without harming local character. A proposal for 9 dwellings on that site would comply with PPG3 at 30 dpha, yet ‘ducks’ the threshold in Policy LO8 and would be brought forward early.
Nowhere does it specify whether the 10 dwelling threshold is net or gross, or for that matter, whether the 0.4 ha threshold is net or gross site area. As suggested the 10 dwelling threshold should be removed, and since there is less scope for disagreement over the gross site area, it is suggested that ‘gross’ site area is used.
|That reference to “medium” sites in Policy LO8 is deleted, and that paragraph 2.43 reads as follows: “The local planning authorities will monitor the rate at which |medium and large housing sites are coming forward for development and manage the release of these sites through the identification of phasing periods within local plans. For the purposes of the policy, medium sites are those of 10 or more dwellings but less than 0.4 hectares in area and large sites are those of 0.4 hectares or more in area (gross).
|Additional comments on Policy LO8 – Managing Housing Provision:|
|Size should not be the only determinant as to whether a site should be withheld from development. The policy should only apply to sites of an open nature (such as garden land and undeveloped open spaces) to avoid the situation where positive benefits from redeveloping a derelict site are delayed. This is the approach introduced by the Inspector at the Waverley Local Plan Public Inquiry regarding Policy H2 of the Waverley Local Plan.||Add the following to paragraph 2.43:
It is not considered desirable to delay the redevelopment of currently developed sites where this could result in their becoming derelict and unsightly. Policy LO8 therefore applies only to large previously undeveloped sites and other land of a predominantly open nature including garden land.|
|Whilst the Structure Plan benefits from a mechanism to ‘manage’ housing provision, there is a negative effect which is that the site size threshold can discourage land assembly in order to create a larger site, which would enable a higher quality, comprehensive development with better use of land. The Structure Plan should recognise this effect, and deal with it with reference to how piecemeal development within settlements will not be permitted. ||Add text to the final bullet point under “How policies LO7 and LO8 will be implemented” to read as follows:|
Surrey Design will contribute toward the achievement of high quality residential and mixed-use environments by promoting best practice both in the development process and the use of key urban design principles. Piecemeal development will not be permitted where it would prejudice a more comprehensive and efficient redevelopment appropriate to the area’s location and character.