|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.