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Waverley Borough Council Committee System - Committee Document

Meeting of the Executive held on 30/09/2003

Summary & Purpose
Surrey County Council is preparing a new County Structure Plan. In November 2003 the Structure Plan will be subject to an “Examination-in-Public” (EiP). The County Council has published “Pre-EiP Changes” to the Plan, which includes an increase in the number of dwellings allocated to each District and Borough in Surrey. This report summarises the key changes and recommends a response at paragraph 13 of the report.

Quality of Life Implications
Natural Resource Use
Pollution Prevention and Control
Biodiversity and Nature
Local Environment
Social Inclusion
Safe Communities
Local Economy
Resource Use
Prevention and Control
and Nature
Safe, Healthy
and Active

The Structure Plan is a strategic ‘land-use’ plan based upon ‘sustainable development’.

E-Government implications:

The Structure Plan and supporting technical documents are available on the Surrey County Council website at www.surreycc.gov.uk.

Resource and legal implications:

There are no resource or legal implications arising from this report.


This report was considered by the Executive at its meeting on 1st September 2003. The Executive agreed to refer the report to the Environment and Leisure Overview and Scrutiny Committee to consider the Council’s draft response to the Surrey Structure Plan “Pre-EiP” Changes.


1. The Surrey Structure Plan sets the strategic planning framework for the County. Structure Plans are being phased out under Government reforms to the planning system. They will eventually be replaced with “Regional Spatial Strategies”. Until that happens, the Structure Plan will remain valid. When Waverley prepares a Local Development Framework (to replace the Local Plan) it will need to comply with the new Structure Plan, as well as regional and national policies.
2. The adopted Structure Plan has been in place since 1994. The process for the new Structure Plan is set out below:

January 2001Structure Plan First Deposit Draft published
December 2002Structure Plan Second Deposit Draft published
11th July to 22 August 2003Pre-Examination-in-Public Changes ‘on deposit’
18th Nov to 19th Dec 2003 Examination-in-Public takes place
February 2004EIP Panel report
June 2004Surrey County Council adopts the Structure Plan

3. The Executive previously considered a report on the Structure Plan on 4th February 2003 when it agreed comments on the “Second Deposit Draft”. Annexe 1 sets out the County Council’s responses to those comments. The County Council disagrees with this Council’s comments, which related to sustainability, the Green Belt and the Countryside, and Dunsfold Aerodrome. Policies on the Green Belt and the Countryside will be discussed at the EiP, with Waverley invited to participate. Officers have made further requests of the County Council to reconsider the Plan’s wording with regard to Dunsfold Aerodrome (see letter at Annexe 2).

Pre-EiP Changes

4. The key issues in the Plan will be discussed at an “Examination-in-Public” (EiP), before an independent panel. The County Council placed “Pre-EiP Changes” to the Plan ‘on deposit’ from 11th July to 22nd August 2003. The purpose of this report is to recommend the response at paragraph 12. The opportunity to comment on matters not addressed in the Pre-EiP Changes has passed.

5. The key areas of change over the Second Deposit Draft Plan are:
The distribution of new housing
The deletion of a proposed new community north-west of Guildford
Affordable housing

The distribution of new housing (Policy LO7)

6. Regional Planning Guidance (RPG9) allocates 35,400 dwellings to Surrey, to be built between 2001 and 2016. The “Second Deposit Draft” failed to identify sufficient land to meet this figure, with a shortfall of 7,500 dwellings. The Pre-EiP Changes address the shortfall as shown in the table below:

Housing distribution in
“Second Deposit Draft” Plan
(published December 2002)
Housing distribution in
“Pre-EiP” Changes
Capacity Allocation
Strategic allocationTotalCapacity AllocationStrategic AllocationTotal
Epsom & Ewell
Mole Valley
Reigate & Banstead
Surrey Heath

7. The “capacity allocations” are derived from the “Surrey Housing Capacity Study”. This provides an assessment of the likely supply of housing in the County in the period 2001–2016, before any strategic allocations are added. The study was carried out jointly, and agreed as a technical assessment of capacity by Surrey County Council and officers of the 11 district and borough planning authorities in Surrey. The methodology was revisited and made more robust for the final version of the study, which resulted in the revised estimates of “capacity” that informed the Pre-EiP Changes.

8. The Structure Plan strategy directs new development to sites within settlements, in preference to green field sites. This accords with Government policy. To maintain and enhance the quality of urban life, planning authorities will be required to prepare “Comprehensive Urban Strategies” (CUS). These will link new development to an overall vision for an urban area and the longer-term community needs. CUSs will address infrastructure, design excellence and other aspects that contribute to urban quality of life. More detail is provided in “Managing Urban Areas” – a supporting document to the Structure Plan, also prepared jointly by the Surrey Authorities.

9. To put Waverley’s allocation into context, 2,810 dwellings over 15 years equates to 187 dwellings per annum. Over the last five years the Borough has seen, on average, 190 new dwellings per annum. The allocation of 2,810 dwellings anticipates no need for green field land releases in the Borough.

10. If the Committee supports the recommendation, and does not object to the revised allocation of 2,810, then Waverley’s ‘housing land supply’ position changes. Currently the Council is refusing housing developments on large, open sites, on the grounds of prematurity, under Policy H2 (Monitoring and Phasing of Housing Provision) in the Local Plan. In other words, certain large sites, that are acceptable in principle for development, can be ‘withheld’ until such time as they are needed to help meet the Council’s strategic housing requirements. It acts as a ‘brake’ to development when planned housing provision is being exceeded. The increase in housing numbers in the Pre-EiP Changes means the Council would no longer be in a position to apply Policy H2. There are currently two planning appeals pending where Policy H2 was a reason for refusal. The Council would need to withdraw that reason for refusal in those cases.

Deletion of proposed new community northwest of Guildford (Policy LO7)

11. A proposal for a new community northwest of Guildford has been deleted. A new community to the northeast of Guildford remains in the Plan if Guildford Borough Council cannot find sufficient housing supply from previously developed land.

Affordable Housing (Policy DN11)

12. There are no significant changes to policy, but the target in the Second Deposit Draft Plan that 40% of all new housing should be “affordable” is being looked at again. The revised strategy for locating development (discussed above) means more reliance on small, previously developed sites, where there is less scope to secure affordable housing. The abolition of Local Authority Social Housing Grant could also jeopardise the delivery of affordable housing. Work is currently underway to assess how affordable housing delivery can be maximised within the revised planning strategy and current financial constraints. The results will inform the debate at the EiP.

Officer comments on the “Pre-EiP Changes”

13. The following officer comments are suggested:
Executive – 1st September 2003

14. The following two issues arose at the meeting on 1st September, which the Executive has requested the Environment and Leisure Overview and Scrutiny Committee to give particular consideration.
The housing distributions set out in paragraphs 6-10; and
Whether Farnham should be included within the Blackwater Valley sub area.

Officer Comment

15. RPG9 allocates 35,400 dwellings to Surrey to be built between 2001 and 2016. The 2002 Deposit Draft failed to identify sufficient land to meet this figure. The Pre-EiP changes have sought to address this shortfall based on capacity allocations derived from the Housing Capacity Study that has been carried out jointly by the County and the 11 Boroughs/Districts.

16. The allocations have been made having regard to Government policy which directs new development onto “brownfield” sites. Policy LO2 of the Deposit Draft Structure Plan indicates that the management of development within urban areas and the enhancement of the quality of the built environment will be achieved through Comprehensive Urban Strategies. These strategies will complement the Surrey Design Guide and the Development Policies (particularly Polices D1 and D4) in the Waverley Borough Local Plan 2002.

17. Waverley allocation of 2,810 dwellings equates to some 187 dwellings annually. This figure is consistent with current trends which show that over the last five years the Borough has seen, on average, some 190 dwellings being built each year. The Capacity Study referred to above indicates that this figure is achievable within the existing policy framework and will not necessitate the allocation of Greenfield sites.

18. Members have debated the question as to whether Farnham should be included in the Blackwater Valley Sub-Area on a number of occasions, the most recent being in August 2002. At that time Members “welcomed the identification of the Blackwater Valley as a separate sub-area, where the priority is to ensure that the area is to be planned in a co-ordinated way, as it is consistent with RPG9 and should help to protect the interests of the people living in Farnham”.

19. The changes proposed in SS32 and SS33 highlight the special environmental qualities and distinctiveness of Farnham and recognise the need to deal with transport infrastructure. The changes also recognise the work that the Blackwater Valley Network is undertaking to address the problems of the area in a co-ordinated and comprehensive way.

20. Farnham Town Council’s comments on the Housing matters are attached for Members’ information at Annexe 5.

Environment and Leisure Overview and Scrutiny

This report was considered by the Environment and Leisure Overview and Scrutiny Committee at its meeting on 15th September 2003. Having considered the comments, the Committee agreed that it had nothing further to add.


It is recommended that the Executive conveys the comments set out at paragraph 13 and Annexe 4 of the agenda report to Surrey County Council as Waverley’s draft response to the Surrey Structure Plan “Pre-EiP” Changes.
Background Papers

Surrey Structure Plan Deposit Draft, December 2002
Pre-Examination-in-Public Changes, July 2003
Surrey Housing Capacity Study, June 2003
Managing Urban Areas, June 2003


Name: Daniel Hawes Telephone: 01483 523295

E-mail: dhawes@waverley.gov.uk


Annexe 1
Summary of Waverley Borough Council’s representations to the Surrey Structure Plan and the County Council’s response

PolicyWaverley Borough Council’s comments on the Structure Plan Second Deposit DraftChanges suggested by Waverley BCSurrey County Council’s response to Waverley’s comments
LO1 - The Location of DevelopmentThere 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.
LO1There 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 Aviationa) 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.

Comms/exec/03-04/257Annexe 4
Comments on the “Pre-EiP Changes” to the Surrey Structure Plan

Policy and ReferenceWaverley Borough Council comments on Pre-EIP ChangesSuggested changes
LO8 (3) Managing Housing ProvisionIn 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.