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Waverley Borough Council Committee System - Committee Document

Meeting of the Environment and Leisure Overview and Scrutiny Committee held on 15/09/2003
ANNEXE 2 - THE FOLLOWING INDIVIDUALS AND ORGANISATIONS RESPONDED WITH COMMENTS TO THE DRAFT SPG ON POLICY H4 PUBLISHED OCTOBER 2002



ANNEXE 2



The following individuals and organisations responded with comments to the Draft SPG on Policy H4 published October 2002:


1. I R Ings Resident
2. Mr T G Rider Resident
3. Val Hibberd Highways Agency (writing as an individual)
4. Michael Barnes Haslemere Town Councillor
5. Mrs C Stalfhide Resident
6. K Bywater Resident

7. The Haslemere Society
8. Guildford Diocesan Board of Finance

9. Ann Mugford Former Waverley Borough Councillor
10. JCS Mackie Waverley Borough Councillor
11. Anthony Newton Former Waverley Borough Councillor
12. David Harmer Waverley Borough Councillor

13. Bramley Parish Council
14. Godalming Town Council
15. Wonersh Parish Council
16. Hambledon Parish Council
17. Haslemere Town Council
18. Witley Parish Council

19. Government Office for the South East
20. Surrey County Council
21. Chichester District Council
22. Runnymede Borough Council
23. West Sussex County Council
24. Leah Mathias, Surrey Urban Biodiversity Project Officer
25. Environment Agency
26. Campaign to Protect Rural England (CPRE)

27. The House Builders Federation (HBF)
28. The D&M Planning Partnership
29. Howard Hutton and Associates
30. Robert Shaw & Partners
31. Chancellors, Chartered Town Planning Consultants

Schedule of comments on the Draft SPG on Policy H4, and the Council’s response

(The number in the first column is the respondent number from the list above)


Respondent commentCouncil response
1Policy H4 is being implemented in a way that overrides other policies that protect areas from inappropriate developmentThe key purpose of the guidance is to address the implementation of Policy H4 in conjunction with other policies so that inappropriate development is avoided.
    1
Government does not intend PPG3 to be applied in a blanket way creating problems similar to those in the 1960s with MacMillan’s dash to build 300,000 homes per year.The Government takes a firm line regarding the minimum density of 30 per hectare, but also promotes good design to achieve this density without harm to local distinctiveness. The Council considers that exceptions can be made where justified. The purpose of the SPG is to set out the Council’s approach with character and distinctiveness as the priority.
    1
H4 should not be used to justify outline applications without calling for the applicant to meet all other basic requirements.Agreed. The revised SPG addresses outline planning applications.
    1
Not only BE6 areas that should be excluded from applying H4, e.g. BE4 (Haslemere Hillsides) but more importantly other areas as well.The guidance needs to address how not only the BE6 Low Density Areas will be treated with regard to Policy H4, but also the Frith Hill Area of Special Environmental Quality (Policy BE2), The South Farnham Area of Special Environmental Quality (Policy BE3), The Haslemere Hillsides (Policy BE4), the Godalming Hillsides(Policy BE5) and other areas of low density character that are not specifically designated. H4 will still be a consideration, but the overriding priority will be protection of local character and distinctiveness.
    2
Timing of the draft SPG unacceptable in relation to the high-density residential dwellings planned as part of East Street redevelopment.The draft SPG is written to assist with all residential applications. Its timing is borne out of an apparent need for further guidance as the Policy gathered more weight through the local plan process.
2Re. Para 2.3: Object to a density above 50 dwellings per hectare within Farnham town centre as over development which will damage environs of attractive and historic town and place an intolerable burden on already over-stretched road system.Encouraging densities over 50 per hectare is established national, county and local policy. Development is not necessarily damaging by virtue of being over 50 dwellings per hectare. Much depends on the design and size and type of dwellings. The point about traffic is noted, but as a general principle, higher densities in town centres reduce the need for development in more remote areas where people are more dependent on the car.
3Its an excellent idea to concentrate on smaller flats and houses. The single person and small family units have been overlooked by most town planners in the past and I am glad to note you feel you should redress the balance. Building large, executive housing causes resentment from those who are struggling to either rent or buy a modest property.Support for the policy approach noted.
    4
Should be special consideration for Haslemere as it’s a historic market town in a rural area, and with consideration, areas of conservation. The purpose of the guidance is to address the protection of local character in a context where Government policy is tough on meeting density requirements. This goes for Haslemere as well as everywhere else.
    4
Key areas for interpretation are development policies D1 (Environmental Implications of Development) and D4 (Design and Layout) in consultation with local community, in particular Haslemere Town Council, The Haslemere Initiative, The Haslemere Society and Chamber of Trade.The intention is that with the help of the SPG, developers will know how the Council will interpret government policy on density against local concerns about character and distinctiveness. This is a complex matter but the essence is that Policies D1, D4 and H4 are all relevant, and that good design must address all the issues that are raised to meet the requirements of H4 as far as possible, without compromising Policies D1 and D4.
    4
Any increase in development needs to be quality constructed and designed in keeping and complimentary to the historic an environmentally friendly market town of Haslemere.Agreed. The draft guidance already refers to development and environmental policies in the Local Plan (D1 and D4) and “Surrey Design” because of its objective to protect the character and quality of attractive environments.
    4
Need to identify areas where H4 applies to avoid developers applying to build on as many houses/flats on every available piece of land. This will be the deathnell of our rural area. The Local Plan guides development to the settlements where infill and redevelopment of acceptable sites is the means by which the Borough’s housing requirement will be met. This avoids unnecessary development in the countryside. Policy H4 reflects Government guidance in making best use of land where development is regarded as appropriate. It is the purpose of the guidance to help explain how and when H4 will be applied in different circumstances to balance new development with protection of settlements.
    4
Semi-derelict areas need to be identified for implementation of this policy.It is not necessary to identify semi-derelict areas up front for implementation of this policy. The development industry seeks out semi-derelict areas as well as other under-used properties and sites. Policy H2 of the Local Plan prevents garden land over 0.4 hectares being developed if there is enough housing being built to meet requirements. This means small-scale infill and redevelopment of derelict and semi derelict sites takes preference.
4Until public transport is provided at an acceptable level to meet local and visitor demand, private mobility, primarily by motor vehicle, will continue to need accessibility and satisfactory parking whilst avoiding the creation of unacceptable congestion.PPG3 makes it clear that 1.5 spaces per dwelling is a maximum average to be achieved with new development. Waverley is currently working up a car parking management plan that will contain revised parking standards in accordance with national policy in PPG3 and PPG13, and Surrey County Council’s recently published “Parking Strategy for Surrey”. The revised guidance will make reference to concerns over parking for higher density development away from town centres.
4Choosing areas for relatively high density needs to have provision for amenity and parking (D1 and D4 can implement these aspects)Agree that amenity space and parking must be considered for all residential development. Separate policies in the Local Plan cover these aspects so they will not be overlooked when assessing development proposals.
    4
Social and cultural aspects need full consideration in order to provide an acceptable mix of larger and smaller properties. Price range in this area needs to be considered as smaller properties need to be affordable.The fundamental basis for Policy H4 requiring smaller “market” units is not up for debate in the preparation of this guidance. The Local Plan Inspector reasoned that the policy objectives are sound. Affordable housing at sub-market prices for rent and shared-ownership is a different matter, dealt with under a different Local Plan policy (H5).
    4
Rising standards involving more new and aspiring ‘wealthy’ classes does not relate to concentration of housing in relatively small area (30 dwellings per hectare).The fundamental basis for Policy H4 requiring smaller “market” units is not up for debate in the preparation of this guidance. The Local Plan Inspector reasoned that the policy objectives are sound.
5Concern of overcrowding and ruination of the environmentPolicy H4 is but one policy in the Local Plan, and is not a justification to developers to overcrowd and ruin the Borough with inappropriate development. The Policy itself has a sound basis, and the supplementary guidance will emphasise the importance of policies that protect the environment and amenity of residents and local character.
5More traffic on already over congested roadsFor higher density proposals away from public transport and facilities developers will need to demonstrate they are compatible with the local highway network. The alternative to making best use of land within settlements is to expand settlements outward. People living in those places would be more remote from facilities and more car-dependent. This would not solve the problem of traffic congestion and would result in loss of countryside.
    5
Increased demand on existing services/infrastructureThe concern is noted. It is beyond the scope of this guidance to address infrastructure requirements resulting from new development. Surrey County Council has produced guidance on this matter, and Waverley’s Local Plan contains policies on infrastructure. Work is ongoing on this important issue.
    6
If replacing a family home with flats, the number of parking spaces per flat should be equal to the number of parking places per family home in the immediate area.PPG3 makes it clear that 1.5 spaces per dwelling is a maximum average to be achieved with new development. Waverley is currently working up a car parking management plan that will contain revised parking standards in accordance with national policy in PPG3 and PPG13, and Surrey County Council’s recently published “Parking Strategy for Surrey”. The revised guidance will make reference to concerns over parking for higher density development away from town centres.
6If replacing a family home with flats, the area of garden per building should not be less than the area of garden in other residences in the immediate area.It would be over prescriptive and indefensible to say that the amount of garden land should not be less that of surrounding residences. New development should respect the local character from the point of view of public amenity. Developments that appear out of keeping with the local character are unacceptable under other policy of the Plan (D1, D4).
7The need to provide more housing generally and even more ‘affordable’ housing specifically, should not be allowed to provide the justification for permitting development which alters the character of settlements.Protecting character is a key objective of the Local Plan, to be reconciled with the necessity to accommodate further development. This is a key difficulty that the guidance seeks to address.
    7
Para 2.4 Refers to car parking standards suggesting a ratio of less than 1.5 per dwelling can be applied to help achieve a greater density. It is evident that this is unrealistic and results in more in more on street parking. National statistics reveal that more households have two cars than have one. In Surrey the problem is even more acute. Given that the police seem powerless to take action against vehicles causing obstruction, simply allowing cars to block the already inadequate road network is irresponsible.PPG3 makes it clear that 1.5 spaces per dwelling is a maximum average to be achieved with new development. Waverley is currently working up a car parking management plan that will contain revised parking standards in accordance with national policy in PPG3 and PPG13, and Surrey County Council’s recently published “Parking Strategy for Surrey”. The revised guidance will make reference to concerns over parking for higher density development away from town centres.
    7
Re. Para 3.5: The policy threshold of ‘more than three units’ is sufficiently elastic to allow wholesale redevelopment of large tracts of large tracts of the entire Borough even though there is the qualification of “compatibility in terms of visual appearance” (delete “visual”?). There needs to be more certainty about the areas/types of property that will be irreversibly altered by the application of this policy.The Local Plan Inspector introduced the “more than three units threshold” with reasons clearly expressed in his report. The Policy wording cannot be changed through this SPG, but it does intend to provide greater clarity on how this threshold will be applied. It is also the aim of the guidance to reinforce the importance attached to protection of local character, in the context of a broader strategy that accepts new development can take place within settlements provided it is done in a way that pays heed to local character and other constraints.
    7
Para 4.1 makes reference to areas excluded from H4 through the application of Policy BE6 (Low Density Residential Areas) but the success rate of appellants overturning this policy is high, particularly in Derby Rd/Weydown Rd, Haslemere. There are other areas which are no less worthy of protection and proper consideration should be given to them, either by naming them or including areas specifically. This guidance cannot designate more “low density areas”. The Council is concerned about over-development within low-density residential areas. The revised SPG places H4 as a secondary consideration after protecting local character.
7The character of a town is derived in no small measure from the amount of tree cover and greater development, of necessity, gives rise to removal of such trees. The fact that individually they may not be specimens of great significance is irrelevant; it is their contribution to the overall scene that should be the determinant.Agree. The importance of landscaping and natural features is made clear in the revised SPG. The wider townscape and landscape should be assessed as part of a “Design Statement” which the guidance refers to.
7Re para 5.3 The perceived imbalance of the housing stock should not be allowed to influence thinking too greatly. The fact that Waverley has ‘only’ 31% flats, maisonettes and terraced houses against a national 46% is almost certainly irrelevant. Were you to apply the same rationale to, say, Tyneside, you would find that 87% of the housing was terraced. Would you then suggest that against a national figure of 46% they should build more large houses? There is certainly a need for one and two bed flats as the recent survey shows but the haphazard distribution of such accommodation should be guarded against just as much as an excessive number of such units. Easy access to railway stations and bus routes is obviously a requirement of such proposals.The fundamental basis for Policy H4 requiring smaller “market” units is not up for debate in the preparation of this guidance. The Local Plan Inspector reasoned that the policy objectives are sound. The policy responds to the Council’s Housing Needs Survey. Agree that ease of access to public transport is a factor to influence the density of new development. The provision of smaller units lends itself to higher density. Disagree that flatted developments are necessarily unsuited to locations away from public transport. Planning policies promote mixed communities with a range of dwellings types and sizes, though where higher densities are proposed away from town centres, the Council will need to be satisfied the development is compatible with the local highway network.
    7
The draft guidance does not make any reference to making more use of flats over shops. Surely this should be encouraged (as was contemplated by an earlier PPG)Living Over the Shop (LOTS) is a separate and worthwhile initiative to make use of properties over shops. However, Policy H4 does not apply to proposals for LOTS and this guidance is not the place to promote matters unrelated to policy H4.
    7
Para 5.6: Reveals a worrying lack of practicality. Limited size of a dwelling unit should not be allowed to influence the size of rooms. Far too many spec built houses have bedrooms that are too small to constitute habitable rooms as defined in earlier housing legislation (and too small to fit a standard bed in incidentally). While para. 5.11 provides some reassurance, the greater number of material possessions that people have today provides a justification for having more storage space, not less. Developers will have a field day at the expense of those who have to try and live in the cramped boxes that would result from this policy.Agree. The means of controlling dwelling size needs to be simplified. Reference to indicative floor space areas is a simpler and clearer method.
    7
Re para 6.0: While there is a clearly defined need for ‘affordable’ housing, it is a fact that the number of wealthy people has never been greater and it is large, individually designed houses that are sold most quickly because there is little choice and an under-supply. This fact should not be lost site of in an endeavour to meet housing targets.The fundamental basis for Policy H4 requiring two and three bedroom properties dwellings is not up for debate in the preparation of this guidance. The Local Plan Inspector reasoned that the policy objectives are sound. The policy responds to the Council’s own Housing Needs Survey. It does not preclude large housing completely, but ensures that small and medium sized dwellings are provided for.
    7
Traffic generation is probably the greatest influence on ‘amenity’ and quality of life. The road network in and around Haslemere is so inadequate that the provision of more housing should be avoided. For an area of such high landscape value there should be a presumption against development and over-intensification of use. The Local Plan identifies Haslemere as a settlement where development can take place subject to the policies of the Plan. The Highways Authority is consulted regarding issues such as road capacity and safety, and the Borough Council considers the impact on amenity of traffic generation to local people.
    8
Support the aims of the policy and the recognition of the Council of the need to address the shortage of smaller dwellings for one and two person households within this Borough.Support noted.
9There is a finite space within towns and then one will be forced to move to the fringes. But by that time one will have ruined Waverley’s towns. If it is our generation that changes them by crowding in and destroying green lungs then we have left a terrible and lasting testimony. We are but temporary custodians of a splendid and precious heritage.‘Green lungs’ and important open spaces are protected from development. The objective of the policy is not to “fill every space” but to make efficient use of land that is suitable for development in accordance with the objectives of meeting housing need and making effective use of land. Redevelopment of garden land is often the most sensitive to issues of local character, and the revised SPG prioritises character over density.
    9
It is said that small units need not equate to bad planning in design terms. In my experience 90% of the time it does and is likely to continue so. It is unreal to dream otherwise. Space is money in development terms. If all architects were brilliant this problem would not exist, but that is unrealistic.The need for small units and minimum densities does not imply that the Council will permit poor designs. On the contrary design generally has come much higher up the planning agenda in recent years.
9Section 5.3 should not be quoted. Certainly it is a recognised problem for local authority housing, but a small part of total housing in the borough and therefore should not be used as a means of changing policy applicable to all. Social engineering should form no part of town planning policy. For a very long time our sons and daughters have recognised that living in much of Waverley was not an option. They have known that they must go to cheaper areas and move back when they have gone up the ladder if they wish to. Even small units are beyond them at the start of their careers. Small units do not necessarily equate to feasible purchases.The policy applies to market housing in particular in response to the Councils Housing Needs Survey and changing demographic profile. The fundamental basis for Policy H4 requiring smaller “market” units is not up for debate in the preparation of this guidance. The Local Plan Inspector reasoned that the policy objectives are sound.
    9
As regards efficient use of land, I would loath to see every house that is not listed and has a good garden demolished and several units built instead. Maybe there are locations and locations – we must somehow find the words to define where it might be possible and acceptable to build at a higher density. At all costs we must preserve the character of an area. But how is that to be defined in words? Maybe we have to define more streets under Policy BE6, but what a lottery that becomes. In Haslemere Inspectors have undermined that policy by their decisions in several instances. Agree that there are different locations and different types of sites and that protection of local character is the priority. This difficulty is the main reason for preparing the guidance. The supplementary guidance cannot be used to designate new BE6 areas. The revised guidance tries to address local character and place it as the priority factor in designing new developments.
    9
I object strongly to the oft repeated statement that there is no perceived need for large houses. That is nonsense and can be disproved with ease. Neither the policy itself nor the guidance state there is no need for large dwellings. The policy is based on the greater need for two and three bed accommodation than for more executive housing. The policy does not prevent large houses being built. It merely reduces the percentage of them that can be built out of all new dwellings.
    9
I depart from all lip service paid to Planning as a tool to reduce dependence on the motor car by talking about riding bicycles or walking to indifferent public transport. That is unrealistic.This problem is recognised in Waverley, but there remains a logic to having higher density where there is better public transport and more facilities, than where there is worse public transport and fewer facilities. The H4 guidance has to comply with national policy on this.
    10
Need to maintain green fingers or spaces (see Policy BE1)Agreed. The guidance does not suggest that Important Open Spaces be built on.
    10
May be need to designate more BE6 areasThe supplementary guidance cannot be used to designate new BE6 areas. The revised guidance tries to address local character and place it as the priority factor in designing new developments.
    10
BE6 has been overturned by Inspectors and infilling been allowed.The concern is noted but an Inspector’s decision on applying Policy BE6 cannot be dealt with in supplementary guidance for Policy H4.
    10
Small houses are not always affordableIt is not the purpose of Policy H4 to provide affordable housing in the sense of sub-market priced or subsidised accommodation.
    10
Concentrating on small houses we could be building up social problems for the future. People need space in their homes – young couples likely to end up having children, the elderly need space as they spend more time at home.The policy seeks homes at the smaller end of the range suitable for small households. It does not advocate cramped living conditions. The basis for the policy itself is not open to debate in the guidance.
    10
1.5 spaces per household is unrealistic. Public transport not always available. There is a need for more off-street parking.PPG3 makes it clear that 1.5 spaces per dwelling is a maximum average to be achieved with new development. Waverley is currently working up a car parking management plan that will contain revised parking standards in accordance with national policy in PPG3 and PPG13, and Surrey County Council’s recently published “Parking Strategy for Surrey”. The revised guidance will make reference to concerns over parking for higher density development away from town centres.
    11
People who live in the towns still need car parking. Not all facilities are within easy reach by public transport or other non-car means. Making cars difficult to park will not make people want to own them less. PPG3 makes it clear that 1.5 spaces per dwelling is a maximum average to be achieved with new development. Waverley is currently working up a car parking management plan that will contain revised parking standards in accordance with national policy in PPG3 and PPG13, and Surrey County Council’s recently published “Parking Strategy for Surrey”. The revised guidance will make reference to concerns over parking for higher density development away from town centres.
11Need for smaller homes is recognised but the condensed character of building is to the detriment of the modest sized towns. These measures might be ok in metropolitan areas where people will choose to live because of the attraction of the city.The need to protect local character and environmental quality whilst accommodating new development is recognised, and is the purpose of other policies in the local plan, and is the main reason for preparing this guidance.
11Paras 5.4– 5.10: Too cumbersome and prescriptive. Looks like a nightmare except for planning agents and lawyersAgree. Indicative floor space areas are a simpler means of adding further guidance on this matter.
    11
Para 2.6: Outrageous that in towns, amenity and play space can be compromised.Policy H10 of the local plan covers amenity space. The revised guidance will not suggest that sub standard provision of amenity will be acceptable.
    11
Re para 5.3 The shortage of smaller houses is recognised, but how relevant is it to cite Waverley’s 31% of stock in the form of flats against a national average of 46%? Of course its lower, Waverley is a mixed small town rural area so its bound to have a smaller proportion of flats than a national average heavily influenced by the conurbations.The fundamental basis for Policy H4 requiring smaller “market” units is not up for debate in the preparation of this guidance. The Local Plan Inspector reasoned that the policy objectives are sound. The policy responds to the Council’s own Housing Needs Survey.
    12
Attempting to address H4 on its own is likely to result in creating new problems. A more holistic view needs to be taken which is partially recognised in the commentary on the interplay between H4 and H5. However there are a number of other important policies with H4 is in apparent conflict or interfaces in significant ways. There are indeed interfaces with other housing and environmental polices which are referred to throughout the document, but an entirely holistic policy review is better left for the Local development Framework that will replace the Local Plan. The current Local Plan is relatively new (adopted April 2002) and is intended to read holistically. The purpose of the SPG is to deal with some specific problems that have occurred in the interpretation and application of Policy H4.
    12
Starting point is that the Regional Planning Strategy which calls for Waverley to generate, as its share of Surrey’s total, around 210 new homes per annum from 2001 to 2016. Waverley is well ahead of this requirement, but falls short of the Regional Strategy’s requirement for 160 new affordable homes per annum as part of the 210. This is not a sensible proportion, but we lack a coherent definition of affordable housing and we ought to be taking this opportunity to redefine what we mean by it. We should write into the H4/H5 guidance new, higher requirements of affordable housing, around the 40% level, of which say, 10-15% should be specified for Shared Ownership Schemes.This is not an attempt to write supplementary planning guidance on Policy H5 of the Local Plan (affordable housing). In any event supplementary planning guidance cannot be used to change policy. A policy review on affordable housing is best left until the current review of national planning policy for affordable housing is complete, and we know the outcome of changes to funding for affordable housing.
    12
H4 as it stands / as it is proposed creates conflict with the need to contain the growth of traffic, parking requirements and the protection of the ambience of our towns and villages. Constructing (for a semi-rural area) high density housing irrespective of the availability or otherwise of appropriate infrastructure is a recipe for future problems of some severity. That is not the function of planning policies.

We should discriminate between differing parts of the built environment, on the basis of available infrastructure. In particular, we should limit the existing H4 to those parts of the built environment where there is available within, say, 1200 metres a public transport service which operates at frequencies of 30 minutes or less from 0730 to 2000 Monday to Friday. We should then develop an alternative policy to apply to other parts of the built environment, with appropriate adjustments to the parking guidelines in those other locations.
Agree that accessibility to public transport and infrastructure is a factor that influences the appropriate density for a given site. This is reflected in “Surrey Design” and the H4 revised SPG adopts this concept. The revised guidance requires applicants to justify high density proposals away from town centres.
    12
In order to give more clarity, we should review BE6 and paragraph 4.15 of the Local Plan to give clearer guidance as to exactly what is Waverley’s policy. The interface between H4 and D2, D4, aspects of the Surrey Structure Plan and other infrastructure strategies of SEERA, Surrey and Waverley might be helped by such a review. Alternatively it might be prudent to state clearly exactly how these various policies are supposed to be treated when they appear to impact on H4. At the moment Members could easily derive any conclusion in some cases, and that is surely undesirable. The H4 guidance is not a vehicle where Policy BE6 can be legitimately reviewed, but the revised guidance explains that local character takes precedence in areas designated under policies BE2 – BE6, and also in non-designated low-density areas.
    13
This policy makes sense at a time when smaller dwellings are getting scarcer and large houses are getting largerNoted.
14The document does not take into account the cumulative effect of a number of small or minor developments upon a particular areaThe objective to meet housing requirements through infilling and redeveloping brownfield land is a policy choice taken in preference to the outward “sprawl” of settlements. It is beyond the scope of this supplementary guidance to change that position, except to reinforce the need to protect local distinctiveness and amenity. The provision of infrastructure to meet the needs of development is also beyond the scope of this supplementary guidance but is an issue that is being looked at. Surrey County Council has produced separate planning guidance on this.
15Existing smaller dwellings within settlement boundaries should be protected from being extended into large homes. Also bungalows attractive to the elderly are being converted into 2 storey homes. Policy H4 deals only with new residential development, not extensions. The Council has prepared design guidance for house extensions, but has no policy for restricting extensions within settlements other than if they fail on design considerations. It is not for this guidance on H4 to deal with that matter.
16In most rural areas in Waverley 30-50 dwellings per hectare is likely to be excessive without essential character being compromised. Country lanes unsuited to traffic increase.In rural areas development is normally restricted to sites within the settlement boundaries of villages (Policy RD1 of the Local Plan). Densities of 30-50 per hectare have successfully been achieved in village locations. The guidance will emphasis the priority consideration to protect local character and the compatibility with the local highway network.
16In rural areas 30-50 dwellings per hectare is excessive where local transport, roads and accesses are already inadequate. One or more parking space has to be provided for each average dwelling. The over-riding objective for rural areas should be to permit new housing on a sustainable basis and having regard to all available supporting infrastructure.In rural areas the Council is aware that public transport is less available and will look critically at the parking requirements of new development. The revised guidance makes this clear.
17In paragraph 3.1 it is admitted that the implementation of H4 cannot always be met without harming the character of the area. To avoid this allow density and size in proportion to that which already exists in an area, only allowing higher density or bulk if a sound planning argument can be made. Redevelopment within housing areas inevitably results in a higher density than previously. The revised guidance points to quality designs to ensure that buildings are layouts are appropriate in terms of the scale of buildings and other characteristics. New developments that propose overly bulky buildings to the detriment of the area will fail Policies D1 and D4 of the Local Plan.
17H4 needs clear identification of areas to be developed. For example Low Density Residential Areas Policy BE6 can be greatly expanded to include roads such as Tower Rd and Wood Rd in Hindhead, and Courts Hill Rd, Courts Mount Rd and Beech Rd in Haslemere etc. etc.The H4 guidance is not a vehicle where Policy BE6 can be legitimately reviewed, but the revised version makes it clear that in designated and undesignated areas of low density, protecting the local character takes priority.
    17
Sites of one hectare, rather than sites for three dwellings should be considered for higher densities, as many gardens in Haslemere and Hindhead fit this description and hence whole streets could rapidly change in character.The Local Plan Inspector introduced the “more than three units threshold” with reasons clearly expressed in his report. The Policy wording cannot be changed through this SPG, but it does intend to provide greater clarity on how this threshold will be applied. It is also the aim of the guidance to reinforce the importance attached to protection of local character, in the context of a broader strategy that accepts new development can take place within settlements provided it is done in a way that pays heed to local character and other constraints.
    17
With reference to H4 “encouraging higher densities in places with good public transport" the planning policy should require express consideration of the availability and accessibility of bus, coach and train transport in the immediate vicinity of a proposed development.Agree that a link needs to be made between density and availability of public transport.
    17
To seek to limit the use of cars by restricting car parking spaces to 1.5 dwellings per household is unrealistic. There are many places in this area which are not well served by public transport, hence the need for 2/3 cars per household is common.PPG3 makes it clear that 1.5 spaces per dwelling is a maximum average to be achieved with new development. Waverley is currently working up a car parking management plan that will contain revised parking standards in accordance with national policy in PPG3 and PPG13, and Surrey County Council’s recently published “Parking Strategy for Surrey”. The revised guidance will make reference to concerns over parking for higher density development away from town centres.
    17
Encouragement should be given to conversion or construction of managed one or two room flats (or hostel types), privately owned, around town centres and convenient nodes.Policy H7 in the Local Plan encourages “Special Needs Housing” to meet the needs of specific groups. It does not need to be addressed in the guidance on Policy H4.
    17
Notwithstanding the need for low-cost housing, there remains the need for good quality larger houses, as evidenced by house prices. Rising standards involving more new and aspiring “wealthy” residents does not relate to high-density housing.The fundamental basis for Policy H4 requiring two and three bedroom properties dwellings is not up for debate in the preparation of this guidance. The Local Plan Inspector reasoned that the policy objectives are sound. The policy responds to the Council’s own Housing Needs Survey. It does not preclude large housing completely, but ensures that small and medium sized dwellings are provided for.
    17
Special consideration should be given to Haslemere/Hindhead in view of it being a rural area containing a historic market town and conservation areas, interspersed with Green Belt, Areas of Outstanding Natural Beauty and areas of National Trust Land. More emphasis should be given to identifying and redeveloping semi-derelict areas within the Borough and encouraging upper floors within shopping areas for residential use.The guidance needs to adequately address the protection of character and environmental quality of settlements regardless of whether in Haslemere or in other locations. Semi-derelict land need not be identified up-front in this SPG, though this work will form part of an Urban Capacity Study to be carried out at a future date. Living over the shop (LOTS) is a separate and worthwhile initiative, but Policy H4 is not a relevant consideration to those proposals.
    17
Difficult to agree with a policy that encourages further development in areas that are already suffering traffic congestion and other problems.This is a comment on the wider issue that the Local Plan (and national and County policies) seek to accommodate development within settlements, and is beyond the scope of the H4 guidance to change. The alternative to making best use of land within settlements is to expand settlements outward. People living in those places would be more remote from facilities and more car -dependent, which does not solve the problem of traffic congestion and would result in loss of countryside.
    17
Amenity space should be provided as well as parking on higher density schemes.Agree. These are covered by other policies in the Plan.
    18
Support smaller dwellings to meet local needs rather than continuing with luxury dwellingsNoted.
18“Efficient use of land” should be interpreted differently in rural and town locations. In rural locations it may be more appropriate to have more of a site undeveloped as an amenity area surrounding high-density small units rather than having every last square metre incorporated into the built scheme. Thus the built density may achieve the 30 per hectare threshold, but over the site area as a whole the density is less more in keeping with the surrounding area. The amount of building and open space appropriate for a site will vary depending on local character, regardless of whether in a village or town. The revised guidance addresses net density in more detail than the draft, and if areas of the site should remain undeveloped there might be a case to exclude them from the net site area.
18The infrastructure and facilities (schools, surgeries etc.) cannot support ongoing development at these high density levelsIt beyond the scope of this guidance to address infrastructure requirements resulting from new development. Surrey County Council has produced guidance on this matter, and Waverley’s Local Plan contains policies on infrastructure. The concern is valid and is noted, and work is ongoing to look at this problem.
    18
Until there are frequent (at least every 10 minutes) public/community transport links from villages to towns, the car will remain the only viable transport option. It is pointless to limit car parking to less than a realistic amount.PPG3 makes it clear that 1.5 spaces per dwelling is a maximum average to be achieved with new development. Waverley is currently working up a car parking management plan that will contain revised parking standards in accordance with national policy in PPG3 and PPG13, and Surrey County Council’s recently published “Parking Strategy for Surrey”. The revised guidance will make reference to concerns over parking for higher density development away from town centres.
    18
Para 2.4: Flexible approach to amenity space not supported. Small high-density units require public space or they will appear cramped. Children need social space that is overlooked rather than making trips to other recreational areas.Agree that children need overlooked play areas, which is dealt with under Policy H10 of the Local Plan. Spaces between buildings that serve an aesthetic purpose are a design consideration. The revised version makes no reference to having a ‘flexible’ approach to amenity space.
    18
Waverley encouraged to set stringent design and sustainability criteria, especially on infill sites. Land assembly and retro-fitting modular system housing suitable to the area are preferable to ad-hoc infill which can destroy the character of an area. Protecting character is a key message to emerge from the consultation. Land assembly as means of avoiding ad-hoc infill is promoted in the draft guidance and the revised version.
    18
No mention in SPG of a presumption of building on brownfield land. WBC should be encouraged to seek small parcels of land for assembly in preference to back gardens.Back gardens are classified as brownfield land under PPG3. However, a different policy in the Local Plan (H2) protects garden land over 0.4 hectares if the Borough does not need the housing to meet its housing requirement at the time.
    18
Basements should be considered where water table allows. These provide useful parking, utility and storage areas without increasing the built footprint, thus releasing the ground and upper floor space for living and working.Agree that basements provide useful space without increasing the development footprint. If used for storage the floor space will not count toward the habitable floor space guidelines. The revised SPG takes this point on board.
    18
Concern over lack of control over small dwellings within settlements being extended to become larger dwellings. Small dwellings being lost this way and there is no room to build new small dwellings.This guidance on H4 cannot change extensions policy on small dwellings within settlements.
    18
Rooms intended as bedrooms should allow sufficient storage space as well as bed making space. Studies may be rooms too small to function even as a bedroom for a child with the accompanying clutter. Don’t be too prescriptive and judgmental on room usage, but take the opportunity to be imaginative and encourage live/work by insisting that broadband connections and outlets in rooms are as standard as power points.Agree. Live/work units and flexible internal layouts are encouraged in national and county design guides. Reference to indicative floor space areas is a simpler means of adding further guidance on this matter.
    18
With over-riding need for affordable housing it is illogical to reduce the quota on schemes where densities exceed 40 per hectare. WBC should increase the affordable housing requirement from 30% to 50% in line with some other BoroughsThis guidance supplements policy H4 and is not a vehicle to change affordable housing policy.
    19
The weight to be afforded to the SPG will increase if the advice on preparing and making available a statement of consultation in paragraph 3.16 of PPG12 is followed.Agree. The final document will contain a statement of consultation.
    19
The SPG is clearly cross-referenced to Local Plan Policy H4 and is generally consistent with national and regional planning guidance.Noted.
    20
The SPG seeks to interpret PPG3 and Structure Plan Review Policies DN10 and DN12 at the local level in relation to the most appropriate mix of dwelling sizes and densities at an increased level, commensurate with accessibility and local character. This approach seeks to ensure the most efficient use of urban land. We therefore have no overall objections to the draft, but have comments concerning specific matters.Noted.
20Consideration of the most appropriate mix and density of dwellings should be closely related to design, layout and sustainability matters. These matters are referred to in para. 3.6 – 3.7 concerning small sites. Welcome references to “Surrey Design”, but it was adopted subsequent to the Local Plan and is not mentioned under Policy D4: Design and Layout. Design issues and the principles of Surrey Design would therefore benefit from being given more prominence in the SPG by being included under a separate heading on design criteria.The revised guidance relates mix and density to design, layout and sustainability considerations and refers to Surrey Design.
20In view of the importance of achieving affordable housing targets it would be beneficial to include a section that deals with affordable housing within individual residential schemes. It should indicate how the inclusion of affordable housing influences density and dwelling mix, as well as design and layout. In addition to Surrey Design, reference to the documents “Housing to Underpin Economic Success” and “Making Affordable Housing Happen in Surrey” would be beneficial in terms of best practice.The draft guidance includes a section that seeks to address the interface between Policy H4 and affordable housing provision. This has been amended to take on board the points made.
21Chichester DC will consider including a similar policy in the next review of their Local Plan / LDF.Noted.
    22
This appears to be a pragmatic approach to interpreting PPG3Noted.
    23
It would be helpful if the Borough Council would define what they mean by ‘larger sites’ in order to avoid ambiguity by developers when encouraging efficient use of land and affordable housing.Agree. With regard to Policy H4 the site size threshold is clarified further in the revised SPG. “Larger” sites were referred to in the draft SPG in the context of sites that provide affordable housing. This wording is avoided in the revised guidance.
    23
Welcome the use of SPG to clarify the Council’s position regarding PPG3. Use of housing needs survey is particularly helpful. Use of Surrey Design Guide welcomed.Noted.
    24
Amenity space for flats is often unused and unsuccessful in providing useable amenity space. Green/brown roofs offer an interesting alternative with environmental benefits and spaces more attractive for use by residents.Agree. This is the type of information that is useful in preparing design guidance and guidance on provision of amenity space. Further work needs to be done on this, for example in respect of privacy and amenity for neighbours, but in principle green roofs offer an interesting approach.
    25
Welcome inclusion of Policies D1(a) and (e) and D4(d) in the guidance, and suggests additional criteria to those policies.This is useful advice for when those policies are reviewed, but this guidance relates to Policy H4 and is not the place to introduce the suggested criteria.
    26
Supports PPG3 and H4 to protect Green Belt and countryside. Welcomes an SPG on the policy, and recognises need for sympathetic development in Waverley’s settlements.Noted.
    26
Welcomes the continued emphasis on small dwellings and affordable housing.Noted.
    26
Para 2.5 Goes beyond PPG3 anticipating densities over 50 dwellings per hectare in out of town locations. The paragraph should acknowledge specifically the need also to take account of the impact of the development on local and wider-area traffic and on local services and infrastructure.The point made here reflects the fact that depending on the size of dwellings proposed (e.g. a development of entirely 1 and 2 bed flats) densities above the 30-50 per hectare range could sometimes be achieved perfectly acceptably. The same goes for sheltered accommodation. The intention of the wording is to clarify that the 30-50 range in the policy is indicative, and that higher densities can be approved provided the proposal is acceptable in all other regards, such as amenity space and parking provision and other planning matters such as local character. The revised guidance takes a tougher stance however, to ensure that such proposals are justified.
    26
Important that small homes do not lose their character by being extended and that affordable housing remains affordable through legally watertight arrangementsThe Council has produced separate guidance on extensions to deal with the issue of retaining the character of dwellings. Legal arrangements are made with affordable housing, which is the remit of Local Plan policies H5 and H6.
    26
Good consultation with local amenity groups, residents and parish councils on individual planning applications is crucial to the successful implementation of Policy H4.Agree. This consultation exercise is the first step to increase understanding and get feedback from residents and interest groups.
    27
It would be legitimate for the Council to encourage a proportion of the overall development as flats to help alleviate problems identified in the Housing Needs Survey, but promotion of this tenure type should not be subject to all development. Encouragement of repetitive dwelling types reduces housing mix, the opportunity to create mixed communities and the opportunity of greater choice in housing, all of which are contrary to PPG3. As such the HBF believe that prescribing tenure types will force developers to produce proposals that will reinforce social distinctions and further diverge from PPG3. It is not the intention of the policy or the supplementary guidance to promote any particular form of tenure or to encourage “repetitive dwelling types”. The policy lists various dwelling sizes and the minimum proportion of each type that can be provided. The guidance does promote flatted development as a means of providing small units on sites where a pavilion building is preferable to a several houses. This is a suggested design solution that may be appropriate to overcome concerns with character and over development on certain sites.
    27
Para 5.5: Many homes are still sold in terms of number of bedrooms, reception rooms and bathrooms, but modern construction methods can provide larger, multi-purpose spaces or space which residents can then sub divide to meet their own requirements. Encouraging such developments provides adaptability. Use of study rooms and modern layout types improves “robustness” and “sustainability”Agree. The means of controlling dwelling size to ensure the “two and three bedroom dwellings” rule is not abused needs to be simplified. Reference to indicative floor space areas is a simpler means of adding further guidance on this matter.
    28
In addition to Policy BE6, reference should also be made to Policy areas BE2, BE3, BE4 and BE5. These areas also represent low-density areas of special character within which proposals for development are controlled by strict criteria which cannot comply with Government Guidance relating to densities or Policy H4. Para. 4.2 should also include specific reference to Policies BE2, BE3, BE4 and BE5.Agree that the guidance needs to address how not only the BE6 Low Density Areas will be treated with regard to Policy H4, but also the Frith Hill Area of Special Environmental Quality (Policy BE2), The South Farnham Area of Special Environmental Quality (Policy BE3), The Haslemere Hillsides (Policy BE4), the Godalming Hillsides (Policy BE5) and other areas of low density character that are not specifically designated. The revised guidance places priority on local character in these designated areas, rather than Policy H4.
29Objective of Policy H4 is sound, but concern about the effect on the borough as a whole if H4 were applied uniformly. Whilst the Govt. intended to maximise the density on new development so that any new land take was minimised and not wasted, it never intended that all redevelopment at to be at the same high densities. It certainly wants better use to be made of under developed urban land, subject to the character issue. One way forward is to distinguish between new development and redevelopment opportunities.

Policy H4 should apply to all greenfield sites in accordance with Govt policy and SoS call-in threats for greenfield sites. H4 should also apply to existing commercial sites moving to residential use. Development of commercial land/buildings usually needs to take place at the highest densities possible to make it economic.
    The SPG should explain that there is a general requirement to redevelop existing residential sites at the highest density consistent with the character of the area so as to make better (note not ‘best’) use of urban land.
    The key difference is to remove the requirement to develop all sites at 30 per hectare and require an H4 development on any site that produces more than three dwellings. In practice this means any site over 0.1ha of which there are many throughout the Borough.
      The redevelopment of an existing house in large grounds which is in a low-density area, for say 4 dwellings, makes ‘better’ use of urban land and thus could be said to accord with govt. policy. It provides three additional houses.

      New occupiers will have traditionally traded up which means that smaller housing may well have been released at the bottom end of the chain. Such a solution would be more in keeping with the character of an area since the type of units would be similar. It would also avoid a sharp change in density.
      Policy H4 is a consideration for residential development on all sites being a policy in the local plan. Agree that it should not mean its identical application in all circumstances, and that residential sites should be redeveloped “at the highest density consistent with the character of the area”.

      The revised guidance takes a different approach to the draft SPG in listing the key factors to be considered in determining an appropriate design solution for a given site. This effectively means that whilst H4 is a consideration on all sites, the Council is seeking development at densities as high as possible consistent with the character of the area.

      Applications should be supported with a Design Statement demonstrating a thorough understanding of the site, its opportunities, and constraints, so that exceptions to policy H4 can be fully justified in light of PPG3.

      The revised guidance provides greater clarity over the site size threshold.
      29The SPG should be able to identify the type of area where H4 will not normally be applied. This could be described as low density established residential areas where there is some consistency in the locality e.g. all detached houses in reasonably sized grounds.

      Where the area is mixed, with no consistent dwelling type, redevelopment would be expected to be at H4 densities and mix i.e. minimum 30 per hectare and mainly 2/3 bedroom units if more than three units (net of demolition) result. In the case of existing residential areas, character rather than the number of units should be the key criteria when deciding whether H4 should be applied
      H4 is a consideration for any residential development in the Borough, but the guidance clarifies the priority attached to ‘character’ in the policy’s implementation. Regarding low-density residential areas special mention is made in the revised guidance, along with designated areas of low density and special environmental character.

      The revised guidance also clarifies that the “more than three dwelling” threshold applies to the gross number of units, not the number of units net of demolition.
        29
      Proposed change to paragraph 1.1: Policy H4 of the Waverley Borough Local Plan 2002 is set out below. The two objectives of Policy H4 are to ensure that residential development makes efficient use of land, and increases the supply of smaller dwellings (add “on appropriate sites”).This paragraph does not appear in the revised version.
        29
      Proposed change to paragraph 1.3: Revised Planning Policy Guidance Note 3 (Housing) and a Borough Housing Needs Survey in 1997 led to more specific policy in the Local Plan. In addition its scope was increased. Policy H4 applies not only to large sites, but also to (delete fairly small) sites of ‘more than three dwellings’. This paragraph does not appear in the revised version.
        29
      Insert new paragraph after 2.3 that reads “Redevelopment of existing residential sites should be at the highest density consistent with the character of the area so as to make better use of such sites”.Agree that this principle should be reflected in the guidance.
        29
      Bring the section on “Low density residential areas” forward making it the third section of the SPG and add the following paragraph to the end of the section: “Policy H4 will not normally be applied where redevelopment is envisaged within established low density areas which are characterised by large housing in individual plots. In such cases redevelopment should be at the highest density consistent with the character of the area.” Agree that this principle should be reflected in the guidance.
        29
      The section titled “Small sites and low density areas” be renamed “Higher density schemes”, to become section 4 of the SPG, and that the paragraph numbered 3.1 in the draft be deleted. The revised version has a different structure.
        29
      The third “test” within paragraph 3.4 of the draft SPG be amended to read: “ Even if the site is unsuitable for a density of at least 30 dwellings per hectare, could development nevertheless provide more than three small units that proposed in such a way that is compatible with its context in terms of visual appearance, amenity considerations and intensity of use?”This section does not appear in the revised guidance.
        29
      Rewrite paragraph 3.5 as follows:
      The policy threshold of ‘more than three units’ applies if the Council regard the site as being capable of accommodating more than three small units in such a way that is compatible with its context in terms if visual appearance, amenity considerations and intensity of use. In these circumstances a proposal for fewer larger dwellings on that site If the site is not in an established low density residential area and, after applying the above tests, it is felt that the site could be developed with a higher number of units than proposed the proposal will be deemed contrary to Policy H4 on the grounds that it makes inefficient use of land by not providing the types of dwellings for which there is an identified need. This approach will be taken even if the Council accepts a site is unsuitable for a density of 30 dwellings per hectare or more.
      This paragraph does not appear in the revised version.
        29
      Amend paragraph 3.6 as follows: If it is marginal as to whether the site is suitable for a higher number of units the application more than three small units, an application for a fewer number of larger units must be fully justified to help inform a planning decision. Every site has a unique set of constraints and each application is treated on its merits, but it is for the developer to make the best use of a site through innovation and good design. Good design is a requirement of Replacement Local Plan Policy D4 (Design and Layout) for all development. “Surrey Design” provides useful design guidance1.This paragraph does not appear in the revised version.
      30Principle concern is the application of Policy H4 to all sites including those of 3 dwellings or less. You seek to address this issue in your guidance note at paragraph 3.1, where it states “the Council recognises on certain sites, particularly small sites, in low-density areas, the requirements of Policy H4 cannot always be met without harming the character of the area”.
        Whilst acknowledging that this may be a difficulty the guidance does not place significant emphasis on the protection of the character of the area, and instead at paragraph 3.6 places the onus upon the applicant to justify the proposals. It must however be accepted that there are numerous housing plots within the Borough which could withstand subdivision or redevelopment, which if Policy H4 were applied, would result in a form of development which is completely out of keeping with the character of the area. A typical example is where a house lies within a larger than typical plot, the subdivision of which would result in two or three dwellings which are in keeping with the size and character of dwellings in the area. In such cases, in order to comply with H4 it would be necessary to provide a significantly larger number of units which would be alien to the character of the area, result in unacceptable traffic generation and likely to receive considerable opposition from local residents. This was clearly recognised by Mr. Harmston (the Local Plan Inspector) in his reasoning and recommendation but it appears to have been overlooked by your Council in not following his recommendation.
          There is a conflict between the opening of the policy which states that it applies to sites where it is proposed to erect more than 3 dwellings and the last paragraph of the policy. The Inspector’s recommendation is quite clear at pages 163 and 164 where a fourth criterion (criterion (d)) refers to density. The density element of the policy was clearly intended to refer only to sites for more than 3 dwellings. Your authority has repeated only criteria (a) to (c), but instead of applying the fourth criteria you have added it as a separate part of the policy, and it is not clear whether the “more than three dwelling” threshold applies to the density aspect of the policy.

          The SPG should make it clear that this policy only applies as a whole to proposals for more than 3 dwelling units. The way the guidance is worded implies that this policy applies to all sites. This is clearly contrary to the Inspector’s recommendation. In paragraph 6.76 the Inspector states “that once about 4 new dwellings is reached, such developments are most likely to occur on larger sites where there is scope to increase densities and provide for more units where the terms of the policy apply.”
          Agree that for the sake of clarity the entire policy (the density element as well as the dwelling size requirements) should be subject to the site size threshold.

          The fourth criteria (d) of the policy as worded by the Inspector became a separate element of the policy to avoid very low-density proposals for three or fewer executive homes being permitted on sites well capable of providing the smaller dwellings being sought by the policy.

          The revised guidance clarifies that the Council could consider a site suitable for a higher density than that proposed, even if the applicants propose three or fewer dwellings. This approach is consistent with the Inspector’s interpretation because he states that the site size threshold should be handled flexibly. The important factor is whether or not a site has scope for different designs that make better use of the site whilst respecting local form and character.
          30Para 5.1: The statement “In addition to density requirements, Policy H4 requires new residential development to include smaller dwellings” is incorrect. The mix of dwelling sizes only applies to sites of more than 3 net new dwellings. This form of interpretation goes beyond what would be acceptable as supplementary guidance as it changes the meaning of the policy. Specific reference should be made to sites of more than three dwellings in the text.Agree that the threshold of the entire policy is “more than three dwellings” and that this should be clarified. Policy applies to proposals for more than 3 dwellings total (gross, not net).
            30
          I am concerned about the criteria against which it is proposed to assess the number of bedrooms that a dwelling will have. Paragraph 5.5(a) implies that a dwelling can only have 2 reception rooms on the ground floor, and that any more reception rooms will be considered as bedrooms. Part (b) of this paragraph goes on to state that a dining room must be on the same floor as the kitchen to ‘avoid carrying food up and down stairs’. I believe that both of these assertions go beyond the responsibilities of the local planning authority and unnecessarily inhibit personal choice and lifestyles.Agree. Use of indicative floor space areas is a more useful approach to overcoming the problem of ensuring dwellings proposed are those to which the policy is aimed.
            30
          Welcome the advice at paragraph 3.7 that the development of back land and garden land can be acceptable in principle. There are a large number of sites within the developed areas and settlements of the Borough that could be developed without harm to the amenities or character of the area, but where the Council has historically taken a negative view. Such sites could form a significant element of the windfall contribution and reduce the need for the development of greenfield sites.Noted, though care will be taken to emphasise avoidance of piecemeal development.
          31Re. Para 3.2: It is noted that the provision of flats is seen as a way of optimising the number of units, but minimising the amount of built form. Within this context it will often be the case that flatted development needs to be both higher than standard two storey houses, and larger in terms of footprint. This point should be acknowledged in the guidance, albeit that individual proposals will be assessed with respect to impact on character and amenities.Agreed. This point needs to be made and may be a reason why a site may be unsuited to flats even if the developer attempts to make it look like a large house.
            31
          Confirmation that there are consequences resulting from increased densities is welcomed. Inevitably such development will result in changes to the character of particularly large houses set in substantial grounds. The acknowledgement that on smaller sites provision of higher density development may not always be possible is acknowledged. However, PPG3 compliant development will change existing character, whether the sites concerned are small or large. Indeed, the larger the site the more impact higher density will be likely to have. High quality imaginative design can make higher density schemes acceptable on both small and large sites. There is a danger that the Supplementary Guidance is therefore too prescriptive.The revised guidance attempts to make clear that primary consideration is given to local character from the public amenity point of view rather than the private amenity point of view, and that density can be increased, up to a point, without detriment to the visual character and quality of an area. This approach goes for sites large enough to produce a variety of design, density and dwelling mix options.
          31Re para 3.7 The Government requires better use of ‘previously developed land’ for new housing. In settlements a large proportion of this will be residential gardens, often involving back land sites. Use of the phrase ‘development of back land and garden land can be appropriate’ suggests that all garden land is to be considered in the same way as back land. Although development of back land needs to be undertaken carefully, it is wrong to bracket back land with garden land in this way. Non back land ‘garden’ sites will make up the vast majority of ‘previously developed land’. The issue here is about avoiding “piecemeal” development. Regardless of any distinction between back land and garden land, comprehensive redevelopment is sought where it would otherwise fragment the urban form and create a less coherent street pattern, for example with numerous accesses off existing streets and lots of cul-de-sacs.
            31
          Re para 4.2 Through innovative design, it might be possible to provide higher density development, but low building to land ratios (such as flats) which could maintain the character. Consideration should be given to more flexibility in this respect.

          There is a danger that objectors to the introduction of higher density development will argue that the site and surroundings concerned is an area with ‘low density characteristics’. The likely result therefore is that the objectives of Policy H4 will not be realised.
          The revised guidance already promotes this approach as a means of increasing densities but minimising built form.



          The aim of the guidance is to ensure that densities are optimised whilst respecting local character, which is the priority consideration. A distinction is drawn in the guidance between character from the private perspective and character from the public perspective.
            31
          The acknowledged need for 1 and 2 bedroom flats reaffirms the point made earlier in this guidance, or elsewhere, it is necessary to accept that such development will often mean buildings of larger footprints and higher than standard two storey housing.Agree. If the guidance promotes flats within a building designed to look like a large house, it should acknowledge this issue. It will not always be appropriate to use this design approach if it means the building will clearly appear oversized for its context.
          31Paras 5.4-5.11: Exerting control over the internal layout of dwellings and bedroom sizes in this way is too prescriptive. These are matters between developers and their customers. Once houses have been completed and occupied, how is it proposed to control subsequent applications for residential extensions in this context? In this general context, there should be recognition in the guidance that using roof spaces (as a second floor) is a sustainable way of providing larger houses (which will also be needed, particularly with increasing second marriages and consequent extended families) whilst at the same time minimising building footprints.Indicative floor space areas are a simpler means of adding further guidance to control dwelling size. Agree that use of roof space is a sustainable means of increasing the size of a house.

          The use of roof space as habitable accommodation is encouraged provided it has no detrimental impact on privacy. Where habitable accommodation is proposed in the roof space, it will count towards the overall floor space figure used as guideline to determine whether or not the size of the dwellings proposed genuinely meet the objectives of the policy.


          Comms/Executive/2003-04/159